The Government of India has promulgated the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“the Act”) along with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 (“the Rules”).
In order to implement the provisions of the Act and to ensure protection against sexual harassment at the workplace, Externix Informatics Pvt. Ltd. (“the Company”) has formulated this policy known as the Externix Informatics Pvt. Ltd. Prevention of Sexual Harassment Policy (“the Policy”).
Externix Informatics Pvt. Ltd. is committed to the principles of equal opportunity and equality of treatment. Every employee is entitled to dignity, respect, and a safe working environment.
The Company maintains competitive employment policies, practices, and benefits, reflecting its commitment to attract, develop, and retain talent.
As an equal opportunity employer, the Company strives to provide a workplace free from sexual harassment—physical, verbal, or psychological—and free from gender-based discrimination.
The Code of Conduct and Living Our Values Policy strictly prohibit sexual harassment and discrimination based on color, religion, gender, age, ethnicity, national origin, disability, or any other protected characteristic.
Every employee has the right to work in an environment free from harassment, intimidation, or offensive behavior, without fear of retaliation.
Sexual harassment is a violation of fundamental human rights and an infringement of the right to life, liberty, and security as guaranteed by the Constitution of India.
The Hon’ble Supreme Court of India, in Vishaka & Ors. vs. State of Rajasthan & Ors. (AIR 1997 SC 3011), recognized sexual harassment at the workplace as a violation of Articles 14, 15, 19(1)(g), and 21 of the Constitution of India.
In compliance with these guidelines, Externix Informatics Pvt. Ltd. has constituted Internal Complaints Committees and established appropriate grievance redressal mechanisms.
The objectives of this Policy are to:
Provide protection against sexual harassment at the workplace
Prevent incidents of sexual harassment
Ensure effective redressal of complaints
All individuals associated with Externix Informatics Pvt. Ltd. are required to exercise their authority and responsibility to promote a safe, secure, and inclusive work environment for employees of all genders.
The Company strictly prohibits retaliation against any individual who raises or reports concerns in good faith. Any form of retaliation will invite disciplinary action, including termination, in accordance with applicable labor laws.
This Policy applies to all individuals associated with Externix Informatics Pvt. Ltd., including but not limited to:
Permanent, temporary, ad-hoc, and contractual employees
Probationers, trainees, apprentices, and interns
Consultants, retainers, and individuals on deputation
Contract labor, daily wage workers, and agency staff
Visitors, vendors, and any other person associated with the Company
The Policy applies across all Company locations in Uttarakhand, Haryana, Karnataka, and any other operational locations in India.
The scope of this Policy extends beyond the physical workplace and includes:
Client locations
Travel undertaken for official work
Virtual and remote work environments
Online meetings, video calls, chats, emails, and social media interactions related to work
Employees working remotely are expected to maintain the same standards of behavior, etiquette, and professional conduct as required at the physical workplace.
“Sexual Harassment” includes any unwelcome sexually determined behavior, whether directly or by implication, including but not limited to:
Unwelcome physical contact or advances
Demand or request for sexual favors
Sexually colored remarks or jokes
Displaying pornography or sexually explicit material
Sending inappropriate or offensive messages, emails, or digital content
Inappropriate comments or conduct on social media
Any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature
Such acts are covered under this Policy regardless of whether they occur physically or through virtual or remote working modes.
The following, among other behaviors, may amount to sexual harassment when connected with any act of sexual nature:
Implied or explicit promise of preferential treatment in employment
Implied or explicit threat of detrimental treatment in employment
Threats regarding present or future employment status
Interference with work or creation of a hostile, intimidating, or offensive work environment
Humiliating conduct affecting health or safety
This list is illustrative and not exhaustive. Any behavior perceived as sexual harassment by the aggrieved individual may be considered so if determined by the Internal Complaints Committee (ICC).
Any aggrieved person may submit a written complaint to the Internal Complaints Committee (ICC) within three (3) months from the date of the incident, or in the case of a series of incidents, within three (3) months from the date of the last incident.
Complaints must be submitted in the prescribed format (Annexure-2).
If the complaint cannot be made in writing, the ICC shall provide reasonable assistance.
The ICC may extend the filing period by an additional three (3) months for valid reasons recorded in writing.
In cases where the complaint involves male against male, the matter will be referred to the Employee Relations team and addressed under the applicable disciplinary procedures.
Externix Informatics Pvt. Ltd. shall:
Provide a safe and secure working environment
Display details of penal consequences and ICC constitution at conspicuous locations
Conduct regular awareness and sensitization programs
Provide necessary facilities and support to the ICC
Assist in securing attendance of respondents and witnesses
Provide required information to the ICC
Assist the aggrieved person in filing complaints under the Indian Penal Code, if requested
Initiate appropriate legal or disciplinary action against perpetrators
Treat sexual harassment as misconduct under service rules
Monitor timely submission of ICC reports
Maintain strict confidentiality of proceedings
Include details of complaints and their disposal in the annual report
All new employees shall undergo mandatory POSH e-training during onboarding. Refresher training will be conducted once every two years.
All details of complaints, inquiries, recommendations, and actions taken shall remain strictly confidential. Any breach of confidentiality may attract disciplinary action.
During the pendency of an inquiry, the ICC may recommend interim relief to the aggrieved person to prevent further harassment or retaliation, including any necessary protective measures.
Any person aggrieved by the recommendations of the ICC or by non-implementation of such recommendations may file an appeal before the appropriate authority within ninety (90) days of publication, in accordance with Section 18 of the Act.
For terms not defined in this Policy, the definitions provided under the Act, the Rules, and the Externix Informatics Pvt. Ltd. Code of Conduct shall apply.
This POSH Policy reflects Externix Informatics Pvt. Ltd.’s unwavering commitment to dignity, equality, and a harassment-free workplace.
