POSH (Prevention of Sexual Harassment) policy

POSH (Prevention of Sexual Harassment) policy

A POSH Policy is a document used to make awareness among the employees and other personnel of an organization about the POSH Act, 2013 (The Sexual Harassment of Woman at Workplace (Prevention, Prohibition, and Redressal) Act, 2013). The purpose of this Policy is to provide a safe, secure and enabling environment, free from sexual harassment to every woman.

Having a POSH policy for a business is essential in making sure the employees are adhering to the POSH rules and to ensure that the employees are treated with dignity and respect by other employees of the organization.

The POSH Policy is applicable to all employees of the organization. Further, the Policy endeavours to protect its women employees at any place visited by her which arises out of or during the course of her employment with the organization including transportation provided by the organization.

This policy has been framed in accordance with the provisions of “The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013” and rules framed thereunder (hereinafter “the Act”). ZEEL Rainwear Policy intends to provide protection against sexual harassment of women at workplace and the prevention and redressal of complaints of sexual harassment and matters related to it.

This policy extends to all the employees of the company including permanent management and workmen, temporaries, trainees and employees on contract at its workplace or at client site. The Company will not tolerate sexual harassment, if engaged in by clients or by suppliers or any other business associates.

Sexual Harassment

Sexual Harassment includes such unwelcome sexually determined behaviour, as physical contacts and advances, sexually coloured remarks, showing pornography and sexual demands whether by words, gestures or actions.

Such conduct can be humiliating and may constitute a health and safety problem

It is discriminatory when the complainant has reasonable grounds to believe that his or her objection would disadvantage them in connection with employment, including recruiting or promotion or when it creates a hostile working environment.

Sexual harassment includes such unwelcome sexually determined behavior (whether directly or by implication) as: (a) Physical contact and advances;

  1. A demand or request for sexual favors;
  2. A demand or request for sexual favors;
  3. Showing pornography;
  4. Unwelcome sexual advances involving verbal, non-verbal, or physical conduct such as sexually coloured remarks, jokes, letters, phone calls, e-mail, gestures, showing of pornography, lurid stares, physical contact or molestation, stalking, sounds, display of pictures, signs, verbal or non-verbal communication which offends the individuals sensibilities and affect her/his performance.
  5. Eve teasing, innuendos and taunts, physical confinement against one’s will and likely to intrude upon one’s privacy;
  6. Act or conduct by a person in authority which creates the environment at workplace hostile or intimidating to a person belonging to the other sex;
  7. Conduct of such an act at work place or outside in relation to an employee of ZEEL or vice versa during the course of employment; and
  8. any unwelcome gesture by an employee having sexual overtones.

Sexual harassment is emotionally abusive and creates an unhealthy, unproductive atmosphere at the workplace.

However, an employee who is sexually harassed can complain about the same even if there is no adverse job consequence.


Whether or not such conduct constitutes an offence under law and a breach of the employment rules, an appropriate complaint mechanism in the form of “Complaints Committee” has been created in the company for time-bound redressal of the complaint made by the complainant.

Company will ensure that any Complainant will not suffer adverse job consequences as a result of any complaint being made.

Internal Complaint Committee (“ICC”)

The Company has formed a Internal Complaints Committee for redressal of harassment complaints and for ensuring time bound treatment and resolution of such complaints.

The Committee comprises of:
  1. Amita Mone- Chairman & Member
  2. Ashwini Singasane- Employee & Member
  3. Laxman Pawar- Employee & Member
  4. Dhananjay Bhalerao- Employee & Member
  5. Manoj Singh- Employee & Member

(To be appointed by the person nominated by the Board for the purpose)

The Internal Complaints Committee is responsible for:

- Investigating every formal written complaint of harassment.
- Taking appropriate remedial measures to respond to any substantiated allegations of harassment.
- Discouraging and preventing any harassment at work place.


The Company is committed to providing a supportive environment in which to resolve concerns of harassment as under:

Informal Resolution Options

When an incident of harassment occurs, the victim of such conduct can communicate her/his disapproval and objections immediately to the harasser and request the harasser to desist from such conduct in the future.
If the harassment does not stop or if the victim is not comfortable with addressing the harasser directly, she/ he can bring the concern to the attention of the Complaints Committee for redressal ofgrievances. The Complaints Committee will thereafter provide advice or extend support as requested and will do the needful to resolve the matter.

It is advisable that the victim keeps a record of incident i.e. date, place, possible witness and file a complaint as soon as possible.

Procedure for complaints in occurrence of sexual harassment:

  1. Any employee with a harassment concern, who is not comfortable with the informal resolution option or has exhausted such option, may make a formal complaint to the Chairperson or any member of the Internal Complaints Committee. The victim should make a complaint within three months from the date of occurrence of the event or in a case of series of incidents, within a period of three months from the date of the last occurrence.
  2. The complaint should be submitted in writing for it to be considered as formal and for the committee to probe and take the necessary actions. The victim may submit the complaint in the form of a written letter, duly signed by the victim and submitted in a sealed envelope to the Chairperson/Member of Internal Complaints Committee. Alternatively, the victim may also send in a written communication through email to the Chairperson/Member of Internal Complaints Committee. The victim should disclose their name, department, date of occurrence, place of occurrence in the complaint letter.
  3. If any complaints are received by any of the Members of the Internal Complaints Committee, the member is obliged to bring it to the notice of the Chairperson within three working days from the receipt of the complaint.
  4. If any complaints are received by any of the Members of the Internal Complaints Committee, the member is obliged to bring it to the notice of the Chairperson within three working days from the receipt of the complaint.
  5. If any complaints are received by any of the Members of the Internal Complaints Committee, the member is obliged to bring it to the notice of the Chairperson within three working days from the receipt of the complaint.

    Disciplinary action may include any of the following:

    • Formal written apology
    • Suspension form services
    • Transfer
    • Withholding promotion
    • Termination
    • Police Complaint
  6. In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for appropriate disciplinary action by the Internal Complaints Committee and the Management.

    The Company understands that it is difficult for the victim to come forward with a complaint of sexual harassment and recognizes the victim’s interest in keeping the matter confidential. To protect the interests of the victim, the accused person and others who may report incidents of sexual harassment, confidentiality will be maintained throughout any investigatory process to the extent practicable and appropriate under the circumstances.
  7. All records of complaints, including contents of meetings, results of investigations and other relevant material will be kept confidential by the Company except where disclosure is required under disciplinary or other remedial processes.
  8. The Company is committed to ensuring that no employee who brings forward a harassment concern is subject to any form of reprisal. Any reprisal will be subject to disciplinary action.
  9. This policy has been evolved as a tool to ensure that in the interest of justice and fair play, our employees have a forum to approach in the event of instances of sexual harassment. However, if on investigation it is revealed that the complaint was made with a malicious intent and with the motive of maligning the concerned individual / tarnishing his/her image in the company and to settle personal/professional scores, strict action will be taken against the complainant.

    The Committee may also take suo-moto action, if any incident of harassment is brought to its attention, without any formal complaint being made in this regard.
  10. All employees of the Company have a personal responsibility to ensure that their behavior is not contrary to this policy. This policy is deemed to be a part of the terms of employment.

    All employees are encouraged to reinforce the maintenance of a work environment free from sexual harassment.
  11. A copy of this Policy shall be given to all employees and to all new recruits and they shall sign a statement acknowledging that they have received, read, understood and will abide by the Policy.