POLICIES

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013

BSML as an employer is committed to creating a healthy and safe work environment that enables employees to work free from unwelcome, offensive and discriminatory behavior. The aim is to enable them to deliver their best at work without fear of prejudice, gender bias and sexual harassment. The Company recognizes consequences of sexual harassment and that sexual harassment can subject individuals to fear, stress and anxiety. It acknowledges the strains that such harassment places on work and family life of an individual.

Sexual harassment at the workplace is a form of discrimination. Protection against sexual harassment and right to work with dignity are universally recognized human rights by international conventions and instruments. Therefore in order to deal with sexual harassment at workplace the Company has set out Prevention and Redress of Sexual Harassment Policy.

The Policy aims to prevent/prohibit, redress any incident of sexual harassment and to enforce strong disciplinary action in face of any such occurrence. It defines sexual harassment and provides a framework to deal with complaints of sexual harassment at the workplace or related to the workplace.

Any form of sexual harassment whether overt or covert is therefore unacceptable and regarded as misconduct as per this Policy. It explicitly prohibits sexual harassment at work place or off site, either during or in connection with activities related to work. The Company will take action consistent with its disciplinary and grievance procedures against any employee found to have breached this Policy. The Company will also take steps to comply with any specific domestic laws relating to this issue.

The Policy applies to all those employed and associated with the Company. They can be regular, temporary, ad hoc or daily wage basis employees. They include contract workers, consultants, retainers, probationers, trainees, and apprentices or called by any other such name engaged by the Company. They could be appointed either directly or through an agent including a contractor. It could be with or without knowledge of the Company. The terms of employment could be expressed or implied. This Policy also applies to all vendors, contractors, customers, agents, retainers and suppliers who do business with the Company and/ or visit the employees of Company.

Policy will be incorporated in the service conditions of all employees explicitly or by inferences and will come into effect immediately. All parties connected with the Company are mandated to follow this Policy and to work collaboratively to prevent sexual harassment

a) Sexual harassment can happen both in direct and / or indirect manner. It could be asking something in exchange (Quid Pro Quo) and / or difficult, intimidating and offensive work environment (Hostile Work Environment) that interferes with the work and performance at work. It could be either before and / or after incident of sexual harassment. The behavior may be a single incident or continuous unwelcome behavior.

b) Unwelcome denotes unwanted, undesirable and uninvited behavior that makes a person feel uncomfortable. A behavior or a gesture while may be acceptable to one person, need not be acceptable and comfortable for another person. Intention of the person and/or motive behind the behavior will not be taken into account when it comes to classifying/naming behavior as sexual harassment. Sexual harassment cannot be justified and defended from this point of view. If the person was offended, humiliated or intimidated by the behavior of the person or even felt so, it will fall within the purview of this Policy. It is important how the person perceives/understands /interprets the behavior. Impact and effect of the sexual harassment on the person is important.

c) The behavior will be definitely held as unwelcome, if the person has made it clear that the behavior is offensive and unwelcome. This will be pronounced where the person of the behavior is junior and indicating that the behavior is unwelcome to a senior would be difficult.

Examples: granting or denying recruitment, granting or denying promotion, threat of demotion, threat of termination or suspension, achieving or denying a privileged position such as a board member / special committee member, positive or negative performance appraisal result / career advancement, threats to spoil career, increased or decreased remuneration / bonus / allowances, issuing or denying any other form of benefit or enhancement such as travel overseas, or training, or conference attendance or such related activities.

(i) Physical contact or advances (e.g. pushing, grabbing, jostling, touching the body and / or attempts to do so)

(ii) Demands and requests for sexual favors (e.g. unwanted sexual attention, forcing to spend time together).

(iii) Sexually colored remarks (e.g. verbal sexual innuendos such as jokes, suggestions, or hints about sexual behavior, comments about physical appearance, offensive comments abusive language).

(iv) Showing pornography (e.g. Display, giving or sending of pornography in the form of pictures, books, magazines, postcards, photos, animation, sound recording, film, video, and video games done personally and/ or via documents, or by telephone, cell-phone messages, web site communication, or emails)

(v) Any other physical, verbal and non-verbal behavior of sexual in nature (e.g. Non-verbal communication such as staring, gestures of sexual nature, following the person, stalking, persistent visiting, telephoning, sending of cell-phone messages, or other invasions of personal privacy, spreading rumors about sexuality, gender and / or character of a person).

Hostile Work Environment will include the following:

a) Direct and / or indirect promise of preferential (special) treatment in employment.

b) Direct and / or indirect threat of detrimental (harmful / damaging) treatment in employment.

c) Direct and /or direct threat about present or future employment status.

d) Creation of conditions and situations that interfere with work or creation of an intimidating or offensive or work environment.

e) Humiliating treatment likely to affect health and / or safety of the aggrieved person.

Complaint Mechanism

There is an Internal Complaints Committee (ICC) constituted by an order in writing at all the four zones i.e. North, East, South & West each across the country, wherever employee headcount is more than ten employees.

Simmi Karna

Presiding Officer

9833523131 | Extension No.: 4035

Persis Hodiwalla

Member

9136669774 | Extension No.: 4014

Mushira Mohammed

Member

7977592350 | Extension No.: 4013

Gyani Lal

Member

9867012121 | Extension No.: 4006

Sakshi Sirari

External Consultant

9930285055

Complaints Process:

The aggrieved person should give a written complaint to any of the member of Committee at the earliest point of time and in any case within 15 days from the date of occurrence of the alleged incident.

The complaint should contain all the relevant details concerning the alleged sexual harassment including the name of the contravener.

The Committee member will maintain confidentiality of the identity of the involved parties to the extent possible.

The matter will be investigated within 2 days or necessary enquiry will be held if necessary. It would be entitled to elicit all forms of evidence in this regard and the concerned parties would co-operate. The entire process will be completed within 30 days from date of submission of the complaint.

Both parties will be given an opportunity to present their views to the member investigating the complaint. After examination of the complaint, the Committee member shall decide on the appropriate punishment and in consultation with HR shall initiate the disciplinary action, including a verbal warning, suspension, or termination of employment. If the action amounts to an offence under Indian Penal Code, then the company will initiate criminal proceedings.

Individuals who are guilty & found to have committed sexual harassment will be subject to appropriate disciplinary action, including immediate termination depending upon the circumstances.

Additionally, concerned individuals shall also be liable for such actions taken by BSML, as per applicable Criminal/ Civil laws.

All managers are responsible for creating an atmosphere free of discrimination and harassment, sexual or otherwise. All employees are responsible for respecting their co-workers’ rights.

The company absolutely prohibits acts of retaliation against any employee for filling a good faith complaint for assessing in good faith in a complaint investigation.