Policy on Prevention of Sexual Harassment of Women at Workplace

Objective

To create a work environment where safety and dignity of women employees is ensured and they are protected from Sexual Harassment as envisaged by the Supreme Court of India Guidelines on Sexual Harassment (August 1997), the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the corresponding Rules, 2013.

Scope

This Policy applies to all employees of Synokem Pharmaceuticals Limited and Synokem Lifesciences and their fraternity—whether permanent or temporary, probationary or part‑time, or working as a consultant, on a voluntary basis, or engaged through a contractor or agent.

Where Sexual Harassment occurs against any female employee as a result of an act by a third party or outsider while on official duty, SYNOKEM will take all steps necessary and reasonable, as per applicable rules and regulations, including initiating action at the workplace of the third party or outsider.

This Policy is applicable to any allegation of Sexual Harassment at SYNOKEM premises including any place visited by an employee arising out of or during the course of employment and/or transportation provided by SYNOKEM ("Workplace").

Definitions

• Act: The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and any amendments thereto.
• Aggrieved Woman: Any female employee of SYNOKEM or any woman who alleges to have been subjected to any act of Sexual Harassment at the Workplace.
• Internal Complaints Committee (ICC): The committee constituted as per the provisions of the Act.
• Respondent: The person against whom the allegation of Sexual Harassment has been made by the Aggrieved Woman.
• Sexual Harassment means and includes, among other things:
  1. Unwelcome behaviour of a male employee towards a female employee (whether directly or by implication) such as:
  2. Physical contact and advances;
  3. A demand or request for sexual favours;
  4. Sexually coloured remarks;
  5. Showing pornography;
  6. Any other unwelcome physical, verbal or non‑verbal conduct of sexual nature.
  7. Implied or explicit promise of preferential treatment to a woman employee in her employment; or
  8. Implied or explicit threat of detrimental treatment to a woman employee in her employment; or
  9. Implied or explicit threat to a woman employee about her present or future employment status; or
  10. Interference with her work or creating an intimidating, offensive or hostile work environment; or
  11. Humiliating treatment likely to affect her health or safety.

Functioning of Committee

Lodging a Complaint

• The Aggrieved Woman may make a complaint directly to the Presiding Officer of the ICC. The Presiding Officer should attempt to try and resolve the grievance informally before escalating the matter to the formal Committee, within three months from the date of incident.
• If the Aggrieved Woman is unable to make a complaint due to physical incapacity, a complaint may be filed by (a) her relative or friend, (b) her co‑worker, (c) an officer of the National or State Commission for Women, or (d) any person who has knowledge of the incident, with the written consent of the Aggrieved Woman.
• If the Aggrieved Woman is unable to make a complaint due to mental incapacity, a complaint may be filed by (a) her relative or friend, (b) a special educator, (c) a qualified psychiatrist or psychologist, (d) her guardian, or (e) any person who has knowledge of the incident jointly with any of the persons mentioned above, with written consent.
• Where the Aggrieved Woman is, for any other reason, unable to make a complaint, a complaint may be filed by any person who has knowledge of the incident, with the written consent of the Aggrieved Woman.
• The ICC may, for reasons to be recorded in writing, extend the time limit if unavoidable circumstances prevented filing within the said period.
• Complaints shall contain all material and relevant details concerning the alleged Sexual Harassment, including the name of the contravener. Information disclosed shall be treated as confidential by ICC members.
• If the Aggrieved Woman wishes to initiate action under the Indian Penal Code, 1860 ("IPC"), she may inform SYNOKEM management; the Company will provide necessary assistance to file the complaint.

Conciliation

• Before initiating an inquiry, and only at the request of the complainant, the ICC may take steps to settle the matter through conciliation.
• No monetary settlement shall be the basis of conciliation.
• Where a settlement is arrived at, the ICC shall record the settlement and forward it to SYNOKEM management for action as per the recommendation and provide copies to the complainant and the respondent.

Inquiry into Complaint

• The ICC shall inquire into the complaint in accordance with the provisions of the Act and applicable rules. Any such inquiry (with due conciliation as appropriate) shall be completed within three months.
• Confidentiality of the complaint procedure will be maintained.
• The ICC shall conduct the inquiry in accordance with the principles of natural justice and provide an opportunity of being heard to the complainant and the respondent as well as the relevant witnesses.

Inquiry Report

• Upon completion of the inquiry, the ICC shall provide its findings to the Director within 10 days from the date of completion of the inquiry and make the report available to the concerned parties.
• The Director shall act upon the recommendation within 60 days of receipt.
• If the ICC concludes that there is no case for Sexual Harassment, the complaint may be dropped and SYNOKEM management notified.

Penalties to Respondent

If the complaint is proved prima facie by the ICC (based on the material and/or witnesses verified), the Committee may recommend to the Director appropriate punishment to the Respondent, including:

• Warning in writing;
• Immediate suspension from the services;
• Immediate termination; and/or
• Referral of the case to the local police/judiciary based on the gravity and merits of the case.

Punishment for False Complaints

Where the ICC concludes during or after inquiry that the allegation against the Respondent is malicious or false, appropriate punitive action may be taken by the Director against the person who made the complaint, as per service rules, on the ICC’s recommendation.

Confidentiality

Notwithstanding anything contained in the Right to Information Act, 2005, the contents of the complaint, the identity and addresses of the Aggrieved Woman, Respondent and witnesses, any information relating to conciliation and inquiry proceedings, recommendations of the ICC and the action taken by SYNOKEM shall not be published, communicated or made known to the public, press or media in any manner.

The Management Assurance

• Express prohibition of sexual harassment will be notified and circulated.
• Prohibition of sexual harassment is included in the Service and Conduct rules of the Company.
• Complainants or witnesses will not be victimised or discriminated against while dealing with complaints.