Prevention of Sexual Harassment (POSH) Policy
Policy Statement
Leads Baton is committed to providing a safe, secure, respectful, and inclusive work environment free from sexual harassment, discrimination, intimidation, and retaliation.
The company follows a zero-tolerance approach towards any form of sexual harassment at the workplace and is committed to complying with the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and related rules.
All employees, interns, consultants, vendors, clients, visitors, and stakeholders are expected to maintain professional conduct and uphold dignity and respect in the workplace
Purpose of the Policy
The objectives of this policy are to:
- Prevent sexual harassment at the workplace.
- Promote a respectful and inclusive work culture.
- Provide a safe mechanism for reporting complaints.
- Ensure timely and fair investigation of complaints.
- Protect employees against retaliation or victimization.
- Spread awareness regarding acceptable workplace behaviour.
- Comply with legal obligations under applicable laws.
Scope of the Policy
This policy applies to all individuals associated with the organization, including but not limited to:
- Permanent Employees
- Probationary Employees
- Contract Employees
- Consultants
- Interns and Trainees
- Apprentices
- Freelancers
- Temporary Staff
- Volunteers
- Directors and Management
- Clients, Vendors, Suppliers, and Visitors interacting with employees
This policy is applicable across all work-related environments, including:
- Office Premises
- Branch Offices
- Client Locations
- Work-from-Home (WFH) Environments
- Business Travel
- Offsite Meetings and Events
- Company-Sponsored Programs and Gatherings
- Virtual Meetings and Online Communication Platforms
- Company-Provided Transportation
Definition of Sexual Harassment
Sexual harassment refers to any unwelcome act, behavior, or conduct—whether direct or implied—that is physical, verbal, written, visual, digital, or psychological in nature.
This includes, but is not limited to, the following:
Physical Conduct
- Unwanted touching
- Physical advances
- Inappropriate contact
- Blocking movement
- Assault or coercion
Verbal Conduct
- Sexually colored remarks
- Offensive jokes
- Comments about appearance/body
- Repeated requests for dates despite refusal
- Lewd comments or innuendos
Non-Verbal Conduct
- Staring or inappropriate gestures
- Displaying offensive images or videos
- Sending inappropriate emojis or expressions
- Suggestive looks or signals
Digital or Online Harassment
- Sending inappropriate messages or emails
- Sharing explicit or offensive content
- Online stalking
- Offensive comments on chats or social media
- Repeated unsolicited communication
- Quid Pro Quo Harassment
Demanding sexual favors in exchange for:
- Promotions
- Salary increases
- Job security
- Better appraisals
- Employment opportunities
- Hostile Work Environment
Behavior that creates:
- Fear
- Humiliation
- Intimidation
- Emotional distress
- Unsafe working conditions
What Does Not Constitute Sexual Harassment
The following generally do not constitute harassment when
- done respectfully and professionally:
- Constructive feedback
- Work-related supervision
- Performance management
- Disciplinary action
- Consensual personal interactions outside professional influence.
However, context, impact, and intent may still be considered.
Rights of Employees
Every employee has the right to:
Responsibilities of Employees
Employees are expected to:
- Maintain professional behavior
- Respect personal boundaries
- Avoid inappropriate conduct
- Report incidents promptly
- Cooperate during investigations
- Attend POSH awareness programs
- Avoid spreading rumors or confidential information
Employer Responsibilities
Leads Baton shall:
- Provide a safe workplace
- Display POSH awareness notices
- Conduct regular training and workshops
- Constitute an Internal Committee (IC)
- Assist complainants during the complaint process
- Ensure confidentiality
- Take corrective actions when necessary
- Prevent victimization or retaliation
- Maintain records and reports as required by law
Internal Committee (IC)
The company shall establish an Internal Committee to address complaints related to sexual harassment.
Composition of IC
Presiding Officer
Aditya Shankar (Founder & Managing Director)
Internal Committee Members
Shefali Saraf
Aditya Shankar
Taruna Khaneja
External Member
Ruchi Saraf
Legal Head
Kavita (High Court Advocate, Bangalore)
At least 50% of the committee members shall be women, and the committee shall function impartially, confidentially, and in accordance with applicable legal provisions.
Tenure
The IC members shall hold office for a period as prescribed by applicable law/company policy.
Roles and Responsibilities of the Internal Committee
The IC shall:
Complaint Mechanism
Filing a Complaint
A complaint may be submitted:
- In writing
- Through email
- Through designated reporting channels
The complaint should preferably include:
- Name of complainant
- Name of respondent
- Description of incident(s)
- Date/time/location
- Supporting evidence/witnesses if available
Timeline for Complaint
Complaints should ideally be submitted within 3 months from the incident
Support for the Complainant
The company may provide:
- Emotional support
- Counseling assistance
- Temporary work adjustments
- Leave support
- Transfer/requested seating changes
- Reporting manager changes if necessary
Conciliation Process
Before initiating inquiry, the complainant may request conciliation.
However:
- Monetary settlement shall not be the basis of conciliation.
- Conciliation is voluntary.
- Formal inquiry may proceed if conciliation fails.
Inquiry Procedure
The Internal Committee shall:
Interim Relief During Inquiry
Pending inquiry, the IC may recommend:
- Transfer of parties
- Work-from-home arrangements
- Leave for complainant
- Restriction of interaction
- Temporary reporting structure changes
Confidentiality
Strict confidentiality shall be maintained regarding:
- Identity of complainant
- Identity of respondent
- Witnesses
- Complaint details
- Inquiry proceedings
- Recommendations/actions taken
Breach of confidentiality may lead to disciplinary action.
Protection Against Retaliation
No employee shall face:
False or Malicious Complaints
If a complaint is proven to be intentionally false or malicious after inquiry, appropriate disciplinary action may be taken.
However:
- Lack of evidence alone does not mean the complaint is false.
- Genuine complaints made in good faith shall not attract action.
Disciplinary Actions
Depending on the severity, disciplinary action may include:
- Verbal warning
- Written warning
- Mandatory counseling/training
- Apology
- Suspension
- Salary deduction
- Transfer
- Demotion
- Termination of employment
- Legal action where applicable
Responsibilities of Managers and Leaders
Managers and leadership must:
- Promote respectful culture
- Address concerns immediately
- Avoid biased conduct
- Encourage reporting
- Support investigations
- Prevent retaliation
- Lead by example
POSH Awareness and Training
The company shall conduct:
- Employee awareness sessions
- Manager sensitization programs
- New employee induction training
- Annual refresher training
- IC member training
Training topics may include:
- Workplace conduct
- Reporting procedures
- Rights and responsibilities
- Digital harassment awareness
- Bystander intervention
Record Maintenance and Reporting
The company shall maintain:
- Complaint records
- Inquiry reports
- Action taken reports
- Training records
Annual reports shall be submitted as required under applicable laws.
Applicability to Remote and Hybrid Workplaces
This policy also applies to:
- Video calls
- Messaging platforms
- Emails
- Virtual collaboration tools
- Remote work interactions
Inappropriate online conduct will be treated seriously.
Third-Party Harassment
If harassment involves:
- Clients
- Vendors
- Consultants
- Visitors
- External stakeholders
the company shall take reasonable steps to:
Non-Compliance
Violation of this policy may result in:
- Internal disciplinary action
- Contract termination
- Legal consequences
Blacklisting of vendors/partners where applicable
Policy Review and Amendments
The company reserves the right to:
- Amend the policy
- Update procedures
- Align with legal changes
- Improve grievance
- mechanisms
Periodic review shall be conducted to ensure effectiveness and compliance.
Contact Details for Reporting Complaints
Escalation Contact
Email: info@leadsbaton.com
Phone: +91 9813291004
Office Address: Leads Baton, Sreevari Complex, 1st Floor, No-7, Kogilu Main Road, Yelahanka 560064
Employee Acknowledgment
All employees are required to acknowledge that they:
- Have read the POSH Policy
- Understand acceptable workplace conduct
- Agree to comply with the policy
- Understand reporting procedures
- Will maintain confidentiality
Declaration by the Company
Leads Baton is committed to maintaining a workplace built on dignity, equality, professionalism, and mutual respect. Sexual harassment in any form shall not be tolerated