Company
Manjeet Kumar and Company
(Chartered Accountants)
Version
1.1
Effective Date
1 September 2023
1. Objective
Manjeet Kumar and Company ("the Firm") is committed to providing a safe, respectful, and dignified work environment free from sexual harassment. This Policy is framed in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("POSH Act") and rules made thereunder.
2. Scope & Applicability
This Policy applies to:
- All employees (permanent, temporary, contractual)
- Articles, trainees, interns, and consultants
- Visitors, clients, and any person interacting at the workplace
It covers sexual harassment occurring at:
- Office premises
- Client locations
- Training programs, meetings, official travel
- Any place arising out of or in the course of employment
3. Definition of Sexual Harassment
Sexual harassment includes any unwelcome act or behavior, whether directly or indirectly, such as:
- Physical contact and advances
- Demand or request for sexual favors
- Sexually colored remarks
- Showing pornography
- Any other unwelcome physical, verbal, or non-verbal conduct of sexual nature
4. Prohibition of Sexual Harassment
Sexual harassment at the workplace is strictly prohibited. Any act of sexual harassment shall invite disciplinary action, irrespective of the position or designation of the person involved.
5. Internal Complaints Committee (ICC)
The Firm shall constitute an Internal Complaints Committee (ICC) as required under the POSH Act.
Composition:
- Presiding Officer (Woman employee)
- At least one other senior employee member
- Proprietor of the firm.
Details of the ICC members shall be displayed at the workplace and communicated to employees.
6. Complaint Redressal Mechanism
6.1 Filing of Complaint
- Any aggrieved woman may file a written complaint with the ICC within 3 months from the date of incident
- Complaints may be extended for another 3 months for valid reasons
- Assistance shall be provided if the complainant is unable to write
6.2 Inquiry Process
- The ICC shall conduct a fair, confidential, and impartial inquiry
- Both parties shall be given an opportunity to be heard
- Inquiry shall be completed within 90 days
6.3 Action & Recommendations
Based on findings, the ICC may recommend:
- Written apology
- Warning or reprimand
- Deduction of salary
- Termination or other disciplinary action
7. Confidentiality
All information relating to complaints, inquiry proceedings, and actions taken shall be strictly confidential, as mandated under the POSH Act.
8. Protection Against Retaliation
The Firm strictly prohibits:
- Victimization
- Intimidation
- Retaliation against the complainant, witnesses, or ICC members
Any such act shall invite disciplinary action.
9. False or Malicious Complaints
While genuine complaints are encouraged, malicious or knowingly false complaints may attract action as per law, after due inquiry by the ICC.
10. Awareness & Training
The Firm shall:
- Conduct awareness sessions on POSH
- Display this policy prominently
- Sensitize employees regarding professional conduct and workplace dignity
11. Responsibility of Employees
All employees shall:
- Maintain professional behavior
- Respect dignity and privacy of colleagues
- Report any incident of sexual harassment promptly
12. Management Commitment
The Firm's management is committed to:
- Zero tolerance towards sexual harassment
- Timely redressal of complaints
- Continuous monitoring and compliance with POSH laws
13. Effective Date & Amendments
This Policy is effective from 1 September 2023 and may be amended from time to time to align with legal or organizational requirements.
Frequently Asked Questions
Common questions about the POSH policy, complaint process, confidentiality, and workplace responsibilities.
Who does this POSH policy apply to? expand_more
This policy applies to employees, articles, trainees, interns, consultants, visitors, clients, and any person interacting at the workplace, including office premises, client locations, official travel, and related work environments.
What kinds of behavior are treated as sexual harassment under this policy? expand_more
The policy covers unwelcome physical contact and advances, requests for sexual favors, sexually colored remarks, showing pornography, and any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature.
How can a complaint be filed and how long does the inquiry take? expand_more
An aggrieved woman may file a written complaint with the Internal Complaints Committee within 3 months of the incident, with possible extension for valid reasons, and the inquiry process is to be completed within 90 days.
Is the complaint process confidential and is retaliation prohibited? expand_more
Yes. The policy requires strict confidentiality around complaints and inquiry proceedings, and it clearly prohibits victimization, intimidation, or retaliation against the complainant, witnesses, or ICC members.
What responsibilities do employees and management have under this policy? expand_more
Employees are expected to maintain professional behavior, respect dignity and privacy, and report incidents promptly, while management commits to zero tolerance, timely redressal, awareness efforts, and ongoing POSH compliance.
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