K.G. EMBROIDERY MILLS LIMITED
Policy of the Company under the Sexual Harassment of Women at
Workplace
(Prevention, Prohibition and Redressal) Act, 2013
1.0 Objective
K.G. Embroidery Mills Limited (‘the Company’ or ‘KG’) is committed to
providing a work environment free from harassment of any kind and in particular,
a work environment that does not tolerate sexual harassment. We respect dignity
of everyone involved in our work place, whether they are employees, suppliers or
our customers. We require all employees to make sure that they maintain mutual
respect and positive regard towards one another.
2.0 Definition of sexual harassment
a) Sexual harassment is unwanted conduct of a sexual nature. The unwanted
nature of sexual harassment distinguishes it from behavior that is welcome and
mutual. Physical conduct of a sexual nature includes all unwanted physical
contact.
b) Verbal forms of sexual harassment include unwelcome innuendoes,
suggestions and hints, sexual advances, comments with sexual overtones,
objectionable sex-related jokes or insults or unwelcome graphic comments
about a person’s body made in their presence or directed towards them.
c) Any other unwelcome physical, verbal or non-verbal conduct of sexual nature
or inappropriate inquiries, and unwelcome whistling directed at a person or
group of persons.
d) Non-verbal forms of sexual harassment include unwelcome gestures, indecent
exposure, and the unwelcome display of sexually explicit pictures and objects
in any media.
e) The following circumstances, among other circumstances, if it occurs or is
present in relation to or connected with any act or behavior of sexual
harassment, as defined in (a) above, may amount to sexual harassment:—
(i) Implied or explicit promise of preferential treatment at work; or
(ii) Implied or explicit threat of detrimental treatment at work; or
(iii) Implied or explicit threat about present or future employment status; or
(iv) Interference with work or creation of an intimidating or offensive work
environment; or
(v) Humiliating treatment likely to affect health, safety or self-esteem.
3.0 Policy statement
a) All KG employees will maintain high standards of dignity, respect and
positive regard for one another in all their dealings.
b) All KG employees will understand and appreciate the rights of the individual
to be treated with dignity.
c) All KG employees are required to maintain a work environment, which is free
from any kind of harassment.
d) All KG employees will refrain from committing any acts of sexual harassment
at work place.
e) Allegations of sexual harassment will be dealt seriously, expeditiously,
sensitively and with confidentiality.
f) KG employees will be protected against victimization, retaliation for filing or
reporting a complaint on sexual harassment and will also be protected from
false accusations.
4.0 Procedure for dealing with complaints of sexual harassment
a) If the person believes that she has been subjected to sexual harassment, then
the
complaint/grievance should be promptly reported to the Internal Complaints
Committee (ICC) through the respective HR Manager or the
Unit/Location/Department Head.
b) Ideally, the complaint should be lodged immediately or within a reasonable
period 3 months from the date of incident/last incident.
c) All complaints / grievances of sexual harassment will be taken seriously, will
be held in strict confidence and will be investigated promptly in an impartial
manner. There may be a need to nominate a senior person to head the
investigation.
d) An “Internal Complaint Committee” will be set up to deal with the complaint.
An employee will head the committee and not less than half of its members
will be women, further to prevent any undue influence, the committee will
also consist of a third party, either an NGO or any other body familiar with
the issue of sexual harassment.
e) The complaint committee will thoroughly investigate the complaint /
grievance and will take the necessary appropriate course of action.
f) Any victimization of, or retaliation against, the complainant or any KG
employee who gives evidence regarding sexual harassment or bullying will
be subject to disciplinary action up to and including termination of
employment.
g) In case, the complaint lodged is found to be false, malicious or forged and
misleading documents have been produced, the ICC post investigations may recommend
disciplinary action against the complainant.
5.0 Disciplinary Action
In case any such conduct amounts to a specific offence under the Indian Penal
Code or under any other law, the company shall initiate appropriate action in
accordance with the law by lodging a complaint with the appropriate authority.
Sexual harassment will not be tolerated at KG. If the outcome of an investigation
by the Internal Complaints Committee shows that harassing behavior has taken
place, the harasser will be subject to disciplinary action up to and including
termination of employment.
6.0 Internal Complaint Committee (ICC)
The Committee will be chaired by Ms. Lakshita Jain (As Presiding Officer). In
addition, the members would include two more internal members Mr. Gaurav
Gandhi and Mr. Rakesh Lodha and an external member Mrs. Anchal Jain The ICC
would examine each case and take a decision from time to time, for conducting the
enquiry proceedings.
7.0 Confidentiality
The contents of the complaint, the identity and addresses of the aggrieved staff
member,
respondent and witnesses, any information relating to conciliation and inquiry
proceedings, recommendations of the Internal Committee and the action taken by
KG shall not be published, communicated or made known to the public, press and
media in any manner. All complaints/grievances of sexual harassment will be
taken seriously, will be held in strict confidence and will be investigated promptly
in an impartial manner. For the purpose of completing the investigation, key
witnesses or other stakeholders may be required to be taken into confidence at the
strict discretion of the Internal Committee.
8.0 Members of Internal Complaint Committee (ICC)
The Internal Complaint Committee shall comprise of as many members as the
Board of Directors may nominate from time to time, provided that at least one-half
of the total number of Members shall be women. The present Members of the ICC
shall comprise of the following:
(i) One Presiding Officer who shall be a senior level employee of the Company;
(ii) Two employee members preferably committed to the cause of women or who
have experience in social work or have legal knowledge;
(iii) One member from amongst Non-Government Organization or Association
committed to the cause of women or a person familiar with the issues relating
to sexual harassment.
The Board of Directors may re-constitute the ICC as may be required from time to
time, within the stipulated requirements under the Act.
9.0 Applicability
The Policy shall become operational from the date as may be decided by the
Board of Directors of the Company.
For K.G. EMBROIDERY MILLS LIMITED
Sd/- Sd/-
Name: Mr. Sumesh Jain Name: Mr. Sarthak Jain
Designation: Director Designation: Director
DIN: 00363413 DIN: 07059269
Frequently Asked Questions (FAQs)
1) What is sexual harassment?
Sexual harassment is defined as any unwanted physical, verbal or visual sexual
advances, requests for sexual favours, and other sexually oriented conduct,
which is offensive or objectionable to the recipient.
2) When is conduct unwelcome or harassing?
Unwelcome sexual advances (either verbal or physical), requests for favors and
other verbal or physical conduct of a sexual nature constitute sexual harassment
when:
Submission to such conduct is either explicit or implicit act.
The conduct having sexual overtones has the purpose or effect of interfering
with an individual's work performance or creating an intimidating, hostile, or
offensive work environment.
3) What is not sexual harassment?
Sexual harassment does not refer to occasional compliments of a socially
acceptable nature. It only refers to behavior that is not welcome, that is
personally offensive, that debilitates morale, and that, therefore, interferes with
the morals and values at work.
4) What should one do if harassed sexually?
If anyone feels that she has been the recipient of sexually harassing behaviour,
report it immediately to the supervisor and the respective HR Manager. It is
preferable to make a complaint in writing, but one can accompany or follow up
the written complaint with a verbal complaint.
If the supervisor is the source of the harassing conduct, report the behavior to
the next level or as mentioned in the sexual harassment policy.
The identity will be protected and one will not be retaliated against for making a
complaint.
5) What happens after a complaint is made?
The ICC will investigate the complaint. The committee will first speak to the
person who has made the complaint and then will speak to the person named in
the complaint. The anonymity of the involved parties will be maintained.
