Gender-Neutral Prevention of Sexual Harassment and POSH Compliance Policy

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 provides a statutory complaint and redressal mechanism for an “aggrieved woman”. Heyaansh will preserve every protection, right, timeline and remedy available to women under that Act and its Rules.

Heyaansh extends its internal prohibition and complaint-handling protection to all persons. Complaints that do not fall within the statutory POSH jurisdiction will be handled through the Company’s gender-neutral grievance, ethics and disciplinary process and under other applicable law. This additional process does not dilute, replace or delay the statutory rights of an aggrieved woman.

Prohibited conduct includes unwelcome physical contact or advances; a demand or request for sexual favours; sexually coloured remarks; showing pornography or sexual content; stalking; sexual messages; intrusive questions; repeated unwanted invitations; sexual gestures; non-consensual recording or sharing; or any other unwelcome verbal, non-verbal, visual, digital or physical conduct of a sexual nature.

Promises or threats relating to employment or business, interference with work, retaliation, a hostile or offensive environment, humiliating treatment, gender-based hostility, and harassment based on perceived or actual sex, gender identity, gender expression or sexual orientation are also prohibited.

Any person may report a concern to HR/Management or email info@heyaansh.in with the subject “Confidential Workplace Harassment Complaint”. Reports may also be made through the whistleblower channel where appropriate. Reasonable assistance will be provided to record a complaint in writing.

A woman wishing to use the statutory POSH route may submit her complaint directly to the applicable Internal Committee without first confronting the respondent or using a managerial grievance route. The Company will not redirect or delay a statutory complaint merely because another internal channel was contacted first.

Where legally required, Heyaansh will constitute an Internal Committee by written order at each applicable administrative unit or office, with the prescribed Presiding Officer, members, external member, independence and tenure. At least half of the members must be women.

The constitution order, current complaint contacts and penal consequences will be displayed at the applicable workplace. Where an Internal Committee is not constituted because the establishment has fewer than ten workers, or where the complaint is against the employer, an aggrieved woman may approach the competent Local Committee.

An aggrieved woman may submit a written complaint to the Internal Committee within three months of the incident or the last incident in a series. The Committee may extend the period by up to a further three months for recorded reasons where circumstances prevented timely filing.

The Internal Committee will follow the statutory requirements governing assistance, conciliation, inquiry, natural justice, interim relief, report, recommendations, employer action, confidentiality, records, annual reporting and appeal. Applicable law prevails if any summary on this page differs from a mandatory requirement.

For referral to the current Internal Committee applicable to a Heyaansh workplace, email info@heyaansh.in with the subject “Confidential POSH Complaint” or contact HR/Management.

A complaint outside the statutory POSH jurisdiction will be assessed by an impartial person or panel without a material conflict of interest. The complainant and respondent will receive a reasonable opportunity to provide information, identify witnesses and respond to material allegations, subject to safety and confidentiality controls.

The recommended service standard is acknowledgement within three working days and conclusion or a documented status update within thirty days, depending on complexity, evidence, availability of participants and legal requirements. Corrective or disciplinary action will be proportionate to substantiated findings and applicable contracts, standing orders or service rules.

Under the statutory POSH route, conciliation may be considered only at the written request of the aggrieved woman before an inquiry begins, and no monetary settlement may form the basis of conciliation.

For other internal complaints, informal resolution may be considered only when freely requested by the affected person, assessed as safe and appropriate, and permitted by law. No person will be pressured to confront the respondent, mediate, withdraw a complaint or accept a settlement.

Without prejudging the complaint, Heyaansh may consider lawful temporary measures such as transfer of either party, reporting-line or schedule adjustment, paid or statutory leave where applicable, remote work, no-contact direction, access restriction, security support, preservation of evidence or other measures reasonably required for safety and process integrity.

For a statutory POSH complaint, interim relief will be considered and recommended in accordance with the Act and Rules, including the specific protections available to an aggrieved woman.

A report is not proof of misconduct. Findings will be based on available evidence and the applicable standard, after a fair opportunity to respond. An inability to substantiate a complaint does not by itself make the complaint false or malicious.

Action for a knowingly false or malicious complaint, fabricated evidence, retaliation, witness interference or breach of confidentiality requires a separate, reasoned finding and fair process. This provision must never be used to discourage good-faith reporting.

Complaint identity, addresses, evidence, proceedings, recommendations and action will be restricted to persons who reasonably need the information or are legally entitled to it. Statutory POSH confidentiality requirements will be strictly followed.

Retaliation, intimidation, adverse treatment, settlement pressure, ostracism, threats, interference with witnesses or evidence, and misuse of authority against a complainant, respondent, witness or person assisting the process are prohibited.

Heyaansh will conduct periodic awareness, manager training and Internal Committee orientation; provide accessible reporting assistance; maintain required statutory and internal records; and publish only anonymised or aggregated information where lawful.

Complaint files will be stored separately with restricted access. Policy effectiveness, recurring risks, training completion and corrective actions will be reviewed periodically without exposing confidential personal information.