Solv Platforms Private Limited
(formerly Standard Chartered Research And Technology India Private Limited)

Prevention of Sexual Harassment Policy

1. Introduction

Solv (hereinafter referred to as “Company”) is committed to creating a safe environment for all employees. The Company has zero tolerance for any uncomfortable behavior that falls under the purview of sexual harassment. This Policy is separate from and in addition to policies relating to anti-harassment or any such other policy.

In furtherance of this commitment, the Company has implemented the Prevention of Sexual Harassment Policy in line with the requirements of the Sexual Harassment of Women at the Workplace (Prevention. Prohibition and Redressal Act, 2013 (hereinafter referred to as “PoSH Act 2013” or“the Act”)

To ensure a safe workplace for all, this Policy is gender neutral and covers persons of all genders as well as includes all categories of employees, whether permanent or on contract, and at their workplace or client sites

Ignorance of this policy will not be considered an excuse during an incident.

The existing policy has been revised by incorporating the rules and procedures as mandated in the Act.

2. Definitions

2.1 Workplace: The ‘workplace’ is defined to include office premises and any place visited by the employees arising out of or during the ordinary course of employment. It shall explicitly cover virtual work environments, social media interactions, and AI-generated content that create a hostile work environment or constitute harassment. The policy shall apply to thirdparty harassment, including clients, vendors, customers, and external consultants if the harassment occurs in connection with workplace duties. The workplace includes:

All offices or other premises where the company’s business is conducted;
Any other site away from the company’s premises where company-related activities are performed (For example, off-site or company-organized social events, training sessions conducted);
Any social, business, or other events related to the company’s work where any conduct or comment may have an adverse impact on the workplace or workplace relations;
Transportation provided by the company to undertake a professional journey;
All work-from-home and virtual communications inclusive of telecommunications and online virtual meetings, emails, or communications that are conducted or shared on any virtual platforms;
This definition will also include a hybrid model of workforce in organizations where this policy will still be applicable to the part of the employees working from remote locations, or even from home and if there are any complaints from either an employee working from home to an employee in office or vice-versa, the IC proceedings will accordingly be conducted online as well upon the discretion of the IC itself.

2.2 Complainant: The ‘Complainant’ refers to the individual filing the complaint. This includes anyone associated with the company in a full-time/part-time capacity as a permanent or a temporary employee, contractor, consultant, vendor, intern, volunteer, or visitor to the company. In a situation where the allegations of sexual harassment are made by a third party against an employee of the company, the company will work to ensure a fair and unbiased inquiry process and take action against the employee accordingly.

2.3 Respondent: The ‘Respondent’ refers to the individual against whose actions the complaint has been filed. The term refers to anyone associated with the company in a fulltime/ part-time capacity, as a permanent or temporary employee, contractor, consultant, vendor, intern, volunteer, or visitor.

2.4 Witness:The ‘Witness’ is any individual or individuals who have been called upon by either the complainant, respondent, or the committee to report their statements as a part of the inquiry proceedings.

3. What is the Internal Committee?

The Company has instituted an internal committee (hereinafter referred to as the IC or Committee) for the redressal of sexual harassment complaints and for ensuring unbiased and time-bound resolution of complaints following the regulations laid down by the act.

The Internal Committee is responsible for conducting an inquiry into every formal written complaint of sexual harassment and making recommendations to the Company on the actions to be taken against the responsible person. The IC will also be responsible for the preparation and submission of the Annual Report prepared by the IC for each calendar year to be submitted to the District Officer the employer and maintain a record of such annual reports.

Every IC member shall undergo annual training on the latest legal updates, trauma-informed inquiry methods, and handling e-evidence. IC members must sign a conflict of interest disclosure before taking up any case. Any member with a direct or indirect personal connection to either party must recuse from the proceedings.

Removal of IC :

IC’s role is limited to sexual harassment complaints.
Reason for removal: IC should also handle preventive measures, conduct awareness workshops, and ensure policy enforcement.

The names and contact details of the members of the Internal Committee are displayed on the notice board and in this Policy (Annexure 1). The maximum term of each member of IC will be 3 (Three) years from the date of their nomination.

4. What is Sexual Harassment?

In addition to the above, the following unwelcome acts or behaviors either occurring individually, as a combination of individual acts, or collectively may constitute sexual harassment at the workplace (whether directly or by implication) namely:-

Any other unwelcome physical, verbal or non-verbal conduct of sexual nature;
Implied or explicit promise of preferential or detrimental treatment in the employment, occurring or present in relation to or connected with any act or behavior of sexual harassment
- Implied or explicit threat about the present or future employment status, occurring or present in relation to or connected with any act or behavior of sexual harassment

Sexual harassment includes digital harassment, such as:

Sharing of inappropriate content via workplace communication tools (e.g., Slack, MS Teams, WhatsApp).
Unsolicited virtual meeting invites for non-professional discussions of a sexual nature.
Repeated friend requests, social media stalking, or digital monitoring of a colleague’s online activity.

During the inquiry into an incident, it is the impact or effect of the behavior on the Complainant and not the intent of the Respondent that is critical in the IC taking up the case.

Unwelcome Sexual Conduct: This includes any unwelcome acts of sexual nature that include advances, harassment, or unwelcome textual or graphical representations to any individual or in the presence of an individual regardless of whether those actions concern that individual. This also includes sharing these representations about a person with a mala fide intent.

Victimisation: Any action taken in form of retaliation by an individual or a group of individuals, or the organization against the individual who has reported incidents of sexual harassment in good faith to maintain a safe work environment for all employees. This is not limited to the complainants but also anyone who has participated in the proceedings to redress an alleged incident of sexual harassment as a witness.

5. Redressal of Complaints of Sexual Harassment

The Complainant can communicate disapproval and objections immediately to the Respondent and request the Respondent to behave appropriately. If the harassment does not stop or if the Complainant is not comfortable with addressing the Respondent directly, the Complainant may request the Committee to speak with the Respondent so as to address the matter through the informal process, failing which formal resolution inquiry proceedings will begin.

Informal Resolution	Formal Resolution
In the informal resolution process, before initiating an inquiry under Section 11 of the Posh Act and at the request of the Complainant, take steps to settle the matter between the Complainant and the Respondent through conciliation.	If the Complainant is not comfortable with the informal resolution, a formal resolution or inquiry into the complaint will be conducted. The committee will provide a reasonable opportunity of being heard by both the Complainant and the Respondent.
Under the informal process, compensation or monetary settlement cannot be granted to the Complainant.	Under the formal process, compensation or monetary settlement can be granted to the Complainant.
The possible corrective action in an Informal Redressal includes: a verbal/written warning, counseling, or a gender workshop	Where the Committee arrives at the conclusion that the allegation against the Respondent has been proved, it will recommend to the employer to take action which may include one or more of the following: Undergoing a counseling session; A written warning to the Respondent and a copy of it maintained in the employee’s file; Change of work assignment/transfer for either the Respondent or the Complainant; Written apology to the Complainant; Verbal warning; Reprimand or Censure; Withholding of Promotion; Withholding of pay rise or increments; Termination of services of the employee found guilty of the offense

The table below explains the features of the formal resolution process:

a. Quorum	Three (3) members of the Internal Committee including the Presiding Officer.
b. Attendance at an inquiry hearing	The committee will provide a reasonable opportunity to be heard to both the Complainant and the Respondent. If either party fails to attend three consecutive hearings without sufficient cause, the IC may terminate the inquiry or pass an exparte order with fifteen days’ notice to the concerned party.
c. Summoning Witnesses	While conducting the inquiry, the IC will call upon such Witnesses as it may deem appropriate. The Complainant and the Respondent will have the right to submit a list of Witnesses.
d. Completion of inquiry report	The Committee will complete the inquiry within ninety days of receiving the complaint and submit a written report containing the findings and recommendations to one of the Founders or Board of Directors (as decided by the company).
e. Action taken by the Company	The Company will ensure corrective action on the recommendations of the Committee within sixty days of receiving the inquiry report. The IC will keep the Complainant and the Respondent informed of the same.
f. No Legal representation	Neither the Complainant nor the Respondent will have the right to be represented by legal counsel at any stage of inquiry by the Committee.
g. Assistance during criminal proceedings	If the Complainant desires to take criminal action against the Respondent, there will be no objection by the Internal Committee and the Company. In such an event, the Company will attempt to provide all reasonable assistance to the Complainant. The Company may also choose to initiate criminal proceedings against the Respondent.

6. Powers of the IC

The Internal Committee is vested with the following powers:

Confidentiality:Confidentiality:
The Company understands that it is difficult to come forward with a complaint of sexual harassment. To protect the interests of the Complainant, Respondent, and Witnesses, confidentiality will be maintained throughout any inquiry process to the extent practicable and appropriate under the circumstances.
The identities of the Complainant, the Respondent, and the Witnesses involved with the process are kept confidential. Anyone (Witness, Committee Member, Respondent, or Complainant) who breaches this clause is liable to be penalized with consequences ranging from a fine of five thousand rupees to additional disciplinary action or both.
Interim Protection:
The Committee is empowered to issue certain interim orders during the pendency of the inquiry on the written request of the Complainant. This is to provide interim protection to the Complainant. These include:
- A transfer of the Complainant or of the Respondent to another workplace;
- Grant of leave to the Complainant for a period up to three months;
- Restraint on the Respondent from reporting on the work performance of the Complainant, or from writing their confidential report, and assigning the said task to another officer;
- Such other relief as may be prescribed in the applicable law;
- This is not limited to the complainant but also includes witnesses involved in the proceedings.
No Retaliation:
The Company is committed to ensuring that no employee or witness who brings forward a harassment concern or testifies is subject to any form of retaliation.
Any employee who retaliates against an employee who has reported in good faith a sexual harassment claim, will be subject to disciplinary action, which may include dismissal. Any reprisal will be considered a separate case of harassment. Anyone who abuses this procedure (for example, by maliciously putting an allegation knowing it to be untrue) would also be subject to disciplinary action including dismissal from service.
In the event that the Complainant or any Witness of the Complainant is being supervised by the Respondent or any of their Witnesses, then such reporting assignments will be changed to the extent possible by the Company.
The Company will not victimize or discriminate against a Complainant or Witnesses while dealing with complaints of sexual harassment.
The Company is committed to providing a supportive environment in which the concerns of sexual harassment will be resolved as follows:

7. Complaint Mechanism

When an incident of sexual harassment occurs, a Complainant shall submit a written complaint to the Presiding Officer or any member of the Committee. The Complainant can file a physical copy of the complaint through a sealed envelope or send it through an email.

The complaint should be in writing and clearly include:

The identity, and designation of the Complainant and the identity of the Respondent against whom the complaint is being lodged;
The dates, time, and location of the incident or incidents, since these are useful for speedy redressal;
The identities, designation, and contact information of any other employee who may have witnessed the incident (if any);
Other relevant documented evidence (if available).
IC will not be able to take up complaints which are anonymous in nature.

The Internal Committee is not empowered to redress anonymous complaints of sexual harassment.

The complaint should be made, preferably no later than three months from the date of the incident. If the incidents are continuous or have occurred more than once, then the complaint should be made within three months since the most recent incident. The time period of three months for filing the written complaint may be extended by the Committee at its discretion for an additional three months if it is satisfied that the circumstances were such which prevented the Complainant from filing the complaint within the period of three months. The reasons for an extension will be recorded in writing by the Committee in its final report.

In the event that the Complainant is not able to file a written complaint, they may be assisted by co-workers, relatives, friends, or any other person who has knowledge of the incident with the written consent of the Complainant.

7.1. Processing the Complaint

On receipt of a complaint, the IC will acknowledge the receipt of the email/written letter by the Complainant within 7 working days. The further process of inquiry to be followed will be explained to the Complainant in their first meeting with the ICC.
It is important for the Complainant to understand that even though the process is confidential, the Respondent will be informed of the Complainant and any Witnesses and persons directly involved in the complaint process will also learn of the Complainant’s identity.
If the IC determines that the complaint received is of sexual harassment at the Workplace and falls within the jurisdiction of the IC, then it will proceed with the inquiry.
If the complaint does not fall within the definition of sexual harassment or within the ICC's jurisdiction, the complaint will be referred by the IC to the relevant Human Resources for appropriate action under the relevant and applicable Company’s policy.
Within seven working days from the initial complaint, the IC will forward a copy of the complaint or a statement of allegations to the Respondent, and give the Respondent an opportunity to submit a written explanation.
The Respondent will have an opportunity to submit a written response, along with a list of witnesses’ dates and events if any, to the Committee or make an oral representation in response to the contents of the complaint within ten days of receipt of the complaint.
IC shall investigate the complaint in detail by giving reasonable opportunities for both the parties.
For the purpose of making an inquiry, under this policy, IC have the power of a civil court, vested in it, in respect of:
- Summoning and enforcing the attendance of any person examining him under oath;
- Requiring discovery and production of documents;
- Any other prescribed matter.
During the enquiry process, the Complainant and the Respondent shall refrain from any form of threat, intimidation or influencing of Witnesses.
The Committee shall ensure confidentiality during the enquiry process and will ensure that sufficient care is taken to avoid any retaliation against the witnesses.

7.2. Conciliation before inquiry

IC may, before initiating an inquiry take steps to settle the matter between the Complainant and the Respondent through a process of conciliation. However, the IC can only proceed with conciliation if the Complainant expressly requests for the same. No monetary settlement shall form the basis of the conciliation and all conciliation activities shall be documented.

7.3. Interim Relief

During such enquiry, upon written request by the Complainant, the committee may at its discretion recommend:

To transfer the Complainant or the respondent to any other workplace
Grant leave to the Complainant, up to three months with salary which is in addition to leave to which he/she is otherwise entitled.

Provided, the Complainant has to tender a justified reason for such transfer or leave, such as threat to work in the workplace.

7.4. Completion of inquiry report

The committee shall on completion of the enquiry provide a report of its findings within 10 days from the date of completion of the enquiry and such report shall be made available to both the Complainant and the Respondent.
If the allegation against the Respondent has not been proved, the Committee may recommend not to take any action in the matter.
If the IC arrives at the conclusion that the allegation against the Respondent has been proved, it shall recommend to the Employer.
Such action shall be taken within 60 days of the receipt of report.

7.5. Implementation of Outcomes of the Inquiry

Once the Internal Committee conducts the inquiry as required by the PoSH Act 2013, the Internal Committee shall take one of the following actions:

A. No action taken

B. False or malicious complaint

C. Proven complaint of sexual harassment

The Internal Committee may conclude, through inquiry, that no action will be taken where the Committee is unable to prove the complaint of sexual harassment.

In case the complaint is found to be intentionally false and malicious, the Complainant is liable for appropriate disciplinary action, as defined under “Corrective Action”.

In cases where there is insufficient evidence to prove that harassment has taken place, it won’t be judged as a false complaint and the Complainant will not be liable.

Where the Committee concludes that the allegation against the Respondent has been proved, it will recommend to the employer to take corrective action.

In addition to corrective action, the Internal Committee may recommend compensation

Complaint Resolution Process

8. Appeal

If a Complainant or Respondent feels that the action taken pursuant to the complaint of sexual harassment does not fully or properly deal with the allegations raised in the complaint, they can bring the same to the notice of the Committee, which would then re-evaluate it accordingly on receipt of such other evidence. An appeal for re-evaluation may be made within a period of seven days of the recommendations.

Additionally, if any party is not satisfied with the recommendation/ decision of the committee, they may appeal to the appellate authority in accordance with the act within 90 days of the recommendation being communicated.

9. Access to reports and documents

All records of complaints, including contents of meetings held, results of the inquiry conducted, and other relevant material will be kept confidential by the Company except where otherwise required by law.

10. Amendment

The Company may make any alteration or amendment or rescind any of the clauses of this Policy as and when it finds it necessary to do so as long as it complies with the Act. Any such alterations or amendments or rescinding will be intimated to the employee.

Conclusion

In conclusion, Solv reiterates its commitment to creating and maintaining a workplace free from sexual harassment for every employee.

Internal Committee Composition

The Internal Committee at Solv is as follows:

Name	Designation	Email Address
Chairperson / Presiding Officer: Khusboo Agarwal	Director - Company Secretary	posh@solvezy.com
Member: Loveleen Malhotra	Associate Vice President – Operations	posh@solvezy.com
Member: Shailendra Narang	VP - Financial Services	posh@solvezy.com
External Consultant: Yamuna (Sasha)	External Consultant	yamuna@sashaindia.com

RESPONSIBILITIES REGARDING SEXUAL HARASSMENT

All employees of the Company have a personal responsibility to ensure that their behavior is not contrary to this Policy. All employees are encouraged to reinforce the maintenance of a work environment free from sexual harassment.

Management and Team Manager’s responsibilities

Create and maintain a working environment in which all employees feel safe and respected;
Be alert to observe any inappropriate conduct or comments passed;
Refer to the committee in accordance with this policy, when instances of sexual harassment occur;
Provide assistance to the employees if they wish to file a complaint under the Indian Penal Code;
In the event that any visitor(s) engages in sexual harassment or if the company receives complaints from their employees or consultants, the company will assist in filing complaints with the appropriate authorities under the applicable laws enforced and the company will also assist such employees or consultants in distress,
Sexual harassment will be treated as a major misconduct that is dishonorable, detrimental, and discreditable to the reputation of the company which can lead to very severe consequences and actions that also include the dismissal from service.

Employees' Responsibilities

Read and understand the Policy document;
Take reasonable care not to offend co-workers and associates through one’s actions or behavior;
Take responsibility to discourage unwelcome conduct that is offensive, degrading, or humiliating;
Be informed about who is on the Committee;
Cooperate in the inquiry of complaints when called to do so;
Maintain confidentiality at all times in the event that you are involved in or have access to information related to any complaint that is raised;
Maintain and take up any other activity or responsibility that contributes towards making the work environment safe and respectable for all employees.

Behavioral Best Practices

Our company is committed to the safety and well-being of all those associated with us. To ensure that the workplace is safe we would like to list the behaviors we expect employees and associates to avoid:

Eve teasing;
Unwelcome sexual advances or propositions, whether they involve physical touching or not;
Comments on personal appearance and individual’s body;
Sexual comments, innuendoes, gestures, and suggestive or insulting comments;
Use of lewd, foul, off-color, sexually-oriented language or “dirty” jokes with sexual implications;
Sexual epithets, written or oral references to sexual conduct, gossip regarding one’s sex and personal life;
Comments about an individual’s sexual activity, deficiencies, or prowess;
Leering or staring at another’s body and/or sexually suggestive gesturing;
Whistling, touching, stroking someone’s hair, brushing against another’s body, pinching, patting, rubbing; grabbing, groping, kissing, or fondling another person;
Displaying sexually suggestive or explicit objects, posters, pictures, photographs, calendars, cartoons, screensavers, or one’s own body parts;
Sitting in an obscene manner;
Direct or implied inquiries into one’s sexual experiences;
The transmission of a sexually offensive email, voicemail, or instant or text messages;
Unwelcome repeated requests for dates or outings;
Gender-based insults or sexist remarks;
Unwelcome sexual overtone in any manner such as over the telephone (obnoxious telephone calls) and the like such as prank calls, leaving lewd messages on answering machines, SMS, email, or by any other means;
Forcible physical touch or molestation and physical confinement against one's will;
Other behavior or acts that make the workplace intimidating;
Gender stereotyping (for example, women only come late and leave early, or women don’t do their work properly, etc.)

REPORTING SEXUAL HARASSMENT- BEST PRACTICES

If you have faced sexual harassment in the workplace, we advise you to:

Keep a record of incidents (date, times, locations, possible witnesses, what happened, your response, etc.). While the committee understands if you do not have a record of the same, a record of any details can strengthen your case and help you remember details over time.
Report incidents of workplace harassment as soon as possible after the incident occurs, as it aids in better recall of the incident and helps the Committee better ensure the employee’s safety.

If you observe any inappropriate behaviour, do not participate in or encourage the behaviour. Play the role of an active bystander by reaching out to the Internal Committee regarding the behaviour.

Writing a written complaint:

When writing a written complaint, ensure that you include the following:

The identity, and designation of the Complainant and the identity of the Respondent against whom the complaint is being lodged;
The dates, time, and location of the incident or incidents, since these are useful for speedy redressal;
The identities, designation, and contact information of any other employee who may have witnessed the incident (if any);
Other relevant documented evidence (if available).

Solv Platforms Private Limited (formerly Standard Chartered Research And Technology India Private Limited)