Prevention of Sexual Harassment (POSH)

1. Scope

This policy applies to:

• all employees — permanent, probationary, temporary, contractual and on secondment;
• interns, trainees, apprentices and consultants;
• clients, vendors and visitors interacting with our people; and
• any workplace — our offices, client sites, off-sites, work travel, and digital spaces such as email, chat, video calls and internal tools, including remote work.

2. What counts as sexual harassment

Sexual harassment includes any one or more of the following unwelcome acts or behaviour, whether direct or by implication:

• physical contact and advances;
• a demand or request for sexual favours;
• making sexually coloured remarks;
• showing pornography; or
• any other unwelcome physical, verbal or non-verbal conduct of a sexual nature.

The following circumstances also amount to sexual harassment:

• implied or explicit promise of preferential treatment in employment;
• implied or explicit threat of detrimental treatment in employment;
• implied or explicit threat about present or future employment status;
• interference with work, or creating an intimidating, offensive or hostile environment;
• humiliating treatment likely to affect health or safety.

The test is whether the behaviour was unwelcome to the person receiving it — not whether the person doing it intended harm.

3. Internal Committee (IC)

Tecosys has constituted an Internal Committee to receive and inquire into complaints. As required by the Act, it is headed by a senior woman employee, at least half its members are women, and it includes an external member familiar with issues relating to sexual harassment.

Committee members and their contact details are also displayed at our registered office in Bhatpara, West Bengal and circulated internally.

4. How to raise a complaint

1. Submit a written complaint to the Internal Committee at hr@tecosys.in, or to any IC member directly.
2. File it within three months of the incident (or of the last incident in a series). The IC may extend this by a further three months for good reason.
3. If the complainant cannot file in writing, any IC member will provide reasonable assistance to put the complaint in writing.
4. Where the complainant is unable to complain because of physical or mental incapacity or death, a legal heir or authorised person may file on their behalf.

5. Inquiry process and timelines

• Conciliation — at the request of the complainant, the IC may attempt settlement before inquiry. No monetary settlement will be the basis of conciliation.
• Notice to respondent — within 7 working days of receiving the complaint.
• Inquiry completion — within 90 days of the complaint.
• IC report — submitted to the employer within 10 days of completing the inquiry, and made available to both parties.
• Action on recommendations — implemented within 60 days of the report.
• Appeal — either party may appeal to the appropriate authority within 90 days of the recommendations.

During the pendency of an inquiry, the IC may recommend interim relief such as transfer, leave of up to three months, or restraining the respondent from reporting on the work of the complainant.

6. Confidentiality

The identity of the complainant, respondent, witnesses, the contents of the complaint, the inquiry proceedings and the recommendations are strictly confidential and will not be published or disclosed to the public, press or media. Breach of confidentiality attracts a penalty under Sections 16 and 17 of the Act, and disciplinary action at Tecosys.

7. Protection against retaliation

Any form of retaliation, victimisation or adverse action against a complainant, witness or IC member — including exclusion, demotion, negative appraisal or termination — is a serious violation of this policy and will invite disciplinary action independent of the outcome of the complaint.

8. Consequences of a proven complaint

Where an allegation is proved, the IC may recommend one or more of the following:

• written apology, warning, reprimand or censure;
• withholding of promotion, increment or pay rise;
• counselling or community service;
• suspension or termination of employment or contract;
• deduction from salary or wages as compensation to the aggrieved person.

9. Malicious complaints

A complaint found to be malicious, knowingly false, or supported by forged or misleading documents may attract action against the complainant. Inability to prove a complaint does not, by itself, make it malicious — a separate inquiry is required before any such finding.

10. Awareness and reporting

• All employees complete POSH orientation at induction and a refresher annually.
• IC members receive periodic training on conducting inquiries.
• Tecosys files an annual report with the District Officer and includes the number of cases filed and disposed of in its annual report, as required by law.

11. Contact

Internal Committee: hr@tecosys.in
People team: avishek@nutaan.com