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Policy on Prevention of Sexual Harassment

1. OBJECTIVE

  1. Addictive Learning Technology Limited (hereinafter referred to as "LawSikho" or the "Company") aims to provide a safe and inclusive workplace for individuals irrespective of their gender, caste, community, race/ethnicity, color, social status, civil status, age, and physical ability.
  2. The Company takes a strong stance against any form of sexual harassment. All efforts shall be made to ensure that all decisions of the Company are free of any discrimination. Prompt and strict disciplinary action will be initiated against any individual or group caught engaging in any form of sexual harassment or discriminatory activities.
  3. Sexual harassment at workplace causes serious psychosocial and physical hardship to victims and also harms organizational performance and reputation. The Company is committed to strictly addressing all such incidents.
  4. This policy is framed in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and applicable rules/notifications, as amended from time to time.

2. APPLICABILITY

  1. This policy applies to co-founders, employees, consultants, trainee associates, interns, external experts, project-based personnel, and students, irrespective of location.
  2. It applies in all work-related settings and activities, inside or outside the workplace, including business trips, social events, and virtual workplaces/classrooms (including messaging groups, virtual meeting platforms, and project management/performance platforms).
  3. This policy is gender neutral and applies to conduct of all covered parties.
  4. Any incident between students, or between students and faculty / institute / university members, will be addressed by the ICC under this policy.
  5. The Company will publicly display this policy and relevant ICC contact information for awareness and access.

3. ACTIONS IDENTIFIED AS SEXUAL HARASSMENT

  1. Sexual harassment includes, but is not limited to, unwelcome acts/behavior such as:
    • Physical contact and advances
    • Demand or request for sexual favors
    • Sexually colored remarks
    • Showing pornography
    • Any unwelcome physical, verbal, or non-verbal conduct of a sexual nature
    • Creating a hostile environment or disadvantage in employment/benefits due to sexual conduct
    • Touching, stalking, sexually suggestive sounds/gestures, molestation
    • Displaying sexual images/signs in work or related spaces
    • Offensive sexual communication affecting dignity or performance
    • Repeated unwanted romantic pursuit
    • Voyeurism, taunts, confinement, or intrusive acts against will/privacy
  2. Sexual harassment is not limited to explicit demands for sexual favors and may also include sexual teasing/jokes, repeated offensive flirtation, sexual verbal abuse, degrading comments, suggestive displays, subtle pressure for sexual activity, and inappropriate physical contact.
  3. All team members must treat each other with respect, uphold law, avoid unwelcome sexual conduct, avoid hostile environments, and report incidents experienced or witnessed.
  4. Connected conduct such as implied promise/threat regarding employment, intimidation, humiliation, or hostile work conditions may also amount to sexual harassment.
  5. These prohibitions apply across all communication modes (in-person, phone, voicemail, paper, email, chat, SMS, and digital platforms).
  6. Occasional socially acceptable compliments and consensual relationships may not constitute sexual harassment by themselves. However, any intimidating, hostile, or offensive behavior remains unacceptable.

4. OBLIGATIONS OF THE COMPANY EMPLOYEES

  1. Each employee is obligated to follow this policy and report incidents observed as a third party to ICC members.
  2. All employees share responsibility to uphold equal opportunity and zero discrimination values.

5. INTERNAL COMPLAINTS COMMITTEE (ICC)

  1. The Company has constituted an Internal Complaints Committee (ICC) for time-bound redressal of complaints under this policy. Complaints may be sent to compliance@lawsikho.in.
  2. Members of the ICC:
    • Ms. Priyanka Karwa, Director of Employability and Placements, Presiding Officer
    • Ms. Sapna Anil Sarda, Member
    • Ms. Sanghita Mukherjee, Member
    • Mr. Siddhant Baid, Member
    • Mr. Ashok Naik, External Member
  3. The ICC tenure shall be 3 years from appointment. ICC receives complaints, investigates formal written complaints, facilitates conciliation where requested, recommends actions, and initiates legal action where required.
  4. If a complaint is against the Presiding Officer or any ICC member, such member shall recuse and an alternate member may be appointed to avoid conflict of interest.

6. DUTIES AND FUNCTIONING OF ICC

  1. ICC members shall remain accessible to employees and stakeholders covered under this policy.
  2. ICC shall maintain records of observed and reported incidents for proceedings and compliance.
  3. ICC shall ensure fair disclosure, natural justice, and unbiased inquiry while handling complaints.
  4. ICC shall maintain confidentiality of identities, incident details, and proceedings, subject to lawful/necessary disclosure.
  5. Proceedings may be conducted through video conferencing for remote participants.
  6. ICC may appoint a secretary to coordinate and record proceedings/minutes where required.

7. PROCEDURE FOR FILING AND DEALING WITH COMPLAINTS

The ICC shall follow applicable procedure and timelines under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013.

  1. Complaints should be made in writing as soon as possible after the incident. Assistance may be provided for recording written complaints.
  2. Complaints can be filed with ICC/ICC members via email at compliance@lawsikho.in, with identifying details. Anonymous complaints shall not be acted upon.
  3. Complainants may file police complaints in serious cases; the Company will extend support.
  4. If needed, complainant and respondent may be separated during inquiry through transfer/leave arrangements.
  5. Both parties will be heard and provided fair opportunity to present documents, witnesses, and responses.
  6. If complaint does not disclose sexual harassment on its face, ICC may close it by recording reasons.
  7. If complaint is found false and malicious, appropriate disciplinary action may be recommended.
  8. If complaint is against an ICC member, such member will not participate in enquiry.

Informal Complaints Procedure: With complainant consent, ICC may first attempt conciliation and amicable resolution. On settlement, ICC records terms and shares with both parties and employer. If settlement terms are breached, ICC may proceed with inquiry or refer matter as appropriate.

Formal Complaints Procedure: A complainant need not exhaust informal options before formal complaint. ICC inquiry will follow principles of natural justice, confidentiality, impartiality, and equal opportunity to be heard.

Timelines: Complaints should ordinarily be filed within 90 days of incident; ICC should initiate proceedings within 10 days, complete investigation within 90 days, submit report within 10 days thereafter, and management should implement recommendations within 60 days (subject to justified written extensions where applicable).

8. GUIDELINES ON RECOMMENDATIONS BY ICC

Recommendations may vary based on severity and impact (mental, emotional, physical, and professional). Recommendations may include:

  • Formal apology (public/private)
  • Counselling
  • Written warning
  • Change of work assignment / transfer
  • Suspension or termination
  • Demotion
  • Monetary compensation as per law/policy

9. CONFIDENTIALITY OF PROCEEDINGS

All complaints and related proceedings shall be handled with strict confidentiality by all involved parties, including ICC members. Breach of confidentiality may lead to financial/legal consequences and disciplinary action as determined under applicable policy and law.

10. ASSURANCE AGAINST RETALIATION

  1. The Company will ensure that complainants and witnesses are not victimized or discriminated against for reporting incidents or participating in proceedings.
  2. Any retaliation, coercion, obstruction, or reprisal is prohibited and will attract disciplinary action.

11. OBLIGATIONS OF THE EMPLOYER

  1. Provide required facilities to ICC for handling complaints and conducting enquiry.
  2. Assist attendance of respondent and witnesses before ICC/local committee.
  3. Provide relevant information/documents required by ICC.
  4. Initiate action under applicable law where required (including against non-employees where incident occurs at workplace).
  5. Treat sexual harassment as misconduct and initiate appropriate action.
  6. Monitor timely report submission by ICC and support annual reporting obligations.

12. INTERPRETATION OF POLICY AND QUESTIONS

Questions regarding interpretation and application of this policy may be sent to compliance@lawsikho.in.

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