POSH Policy

1. Policy Statement

Bhavani Shipping Services India Pvt. Ltd. ("Company") is committed to providing a safe, secure, inclusive, and respectful work environment where all individuals are treated with dignity and respect. The Company maintains a zero-tolerance approach toward any form of sexual harassment and is committed to preventing, prohibiting, and redressing such conduct.

This Policy is established in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("POSH Act"), and applicable rules thereunder.

The Company expects all employees, consultants, contractors, vendors, clients, visitors, and any person associated with its operations to uphold the highest standards of professional conduct.

2. Purpose

The objectives of this Policy are to:

• Prevent incidents of sexual harassment at the workplace.
• Provide a clear framework for reporting and addressing complaints.
• Ensure prompt, fair, and confidential investigation of complaints.
• Protect individuals from retaliation for reporting concerns.
• Promote awareness and sensitivity regarding workplace conduct.

3. Scope

This Policy applies to:

• Permanent employees
• Probationary employees
• Contractual employees
• Temporary staff
• Consultants and advisors
• Interns and trainees
• Apprentices
• Volunteers
• Third-party personnel working with the Company

This Policy applies to all workplaces including:

• Company offices and branches
• Client locations
• Business travel
• Conferences and seminars
• Company-sponsored events
• Off-site meetings
• Virtual workplaces
• Remote work environments
• Any location visited in connection with employment

4. Definition of Sexual Harassment

Sexual harassment includes any unwelcome act or behavior of a sexual nature, whether direct or implied, including but not limited to:

Physical Conduct

• Unwelcome touching, patting, hugging, or physical advances
• Physical interference with movement

Verbal Conduct

• Sexually suggestive remarks
• Offensive jokes or comments
• Repeated requests for dates despite refusal
• Comments regarding appearance, body, or personal life

Non-Verbal Conduct

• Staring, gestures, or facial expressions of a sexual nature
• Displaying sexually explicit materials
• Sharing inappropriate images or videos

Digital or Online Conduct

• Sending inappropriate emails, messages, memes, or social media content
• Cyberstalking or online harassment
• Inappropriate conduct during virtual meetings

Sexual harassment may also include:

• Implied or explicit promise of preferential treatment in employment
• Implied or explicit threat of adverse employment consequences
• Interference with work performance
• Creation of an intimidating, hostile, or offensive work environment
• Humiliating treatment likely to affect health or safety

5. Rights and Responsibilities

Employee Responsibilities

All employees shall:

• Maintain professional conduct at all times.
• Treat colleagues, customers, and stakeholders with dignity and respect.
• Refrain from engaging in any form of sexual harassment.
• Cooperate fully during investigations.
• Maintain confidentiality regarding complaints and proceedings.

Manager Responsibilities

Managers and supervisors shall:

• Foster a respectful workplace culture.
• Act promptly upon receiving concerns.
• Report complaints to the Internal Committee.
• Prevent retaliation against complainants and witnesses.

Employer Responsibilities

The Company shall:

• Provide a safe workplace.
• Display POSH awareness notices.
• Conduct regular awareness and training programs.
• Constitute and maintain an Internal Committee.
• Assist complainants in filing complaints where necessary.

6. Internal Committee (IC)

The Company shall constitute an Internal Committee ("IC") in accordance with applicable law.

The IC shall consist of:

• Presiding Officer – Senior woman employee
• Minimum two employee members committed to women's causes or having legal/social knowledge
• One external member from an NGO, legal background, or related field

The details of the current IC members shall be communicated separately and displayed on Company notice boards and internal communication platforms.

7. Complaint Mechanism

Any aggrieved woman who believes she has been subjected to sexual harassment may submit a complaint to the Internal Committee.

Submission of Complaint

The complaint should:

• Be submitted in writing.
• Contain details of the incident(s).
• Include supporting evidence, if available.
• Be submitted within three months from the date of the incident or the last incident in a series.

Where the complainant is unable to submit a written complaint, assistance shall be provided by the Internal Committee.

Complaints may be submitted through:

• Email: [POSH Email Address]
• Internal Committee Members
• HR Department
• Designated reporting portal

8. Conciliation

Prior to initiating an inquiry, the complainant may request conciliation.

However:

• Monetary settlement shall not form the basis of conciliation.
• Conciliation shall only occur at the complainant's request.
• If conciliation succeeds, the matter shall be closed upon implementation of the agreed terms.

9. Inquiry Process

Upon receipt of a complaint:

1. The IC shall acknowledge the complaint.
2. A copy of the complaint shall be provided to the respondent.
3. The respondent shall submit a written response.
4. The IC shall conduct a fair, impartial, and confidential inquiry.
5. Both parties shall have the opportunity to present evidence and witnesses.
6. Principles of natural justice shall be followed throughout the process.

The inquiry shall generally be completed within the timelines prescribed under applicable law.

10. Interim Relief

During the inquiry process, the IC may recommend:

• Transfer of either party
• Change in reporting structure
• Leave for the complainant
• Restriction of contact between parties
• Temporary reassignment of duties
• Any other appropriate measure

The Company shall implement such recommendations where feasible and appropriate.

11. Confidentiality

The Company is committed to maintaining confidentiality regarding:

• Identity of the complainant
• Identity of the respondent
• Witness statements
• Inquiry proceedings
• Recommendations and findings

Unauthorized disclosure of information related to a complaint may result in disciplinary action.

12. Protection Against Retaliation

The Company strictly prohibits retaliation against any person who:

• Files a complaint in good faith
• Participates in an inquiry
• Provides evidence or testimony
• Supports a complainant

Retaliation includes:

• Threats
• Intimidation
• Harassment
• Discrimination
• Adverse employment actions

Any act of retaliation shall be treated as misconduct.

13. False or Malicious Complaints

The Company recognizes that inability to substantiate a complaint does not automatically make it false.

However, where the Internal Committee determines that a complaint was made maliciously or with knowingly false evidence, appropriate disciplinary action may be recommended in accordance with applicable law and Company policies.

14. Disciplinary Action

Where allegations are substantiated, disciplinary action may include:

• Written warning
• Formal apology
• Counseling
• Mandatory training
• Withholding promotion or increment
• Transfer
• Suspension
• Termination of employment
• Any other corrective action deemed appropriate

The severity of disciplinary action shall depend upon the nature and seriousness of the misconduct.

15. Awareness and Training

The Company shall:

• Conduct POSH awareness sessions annually.
• Train all employees on acceptable workplace conduct.
• Provide specialized training to Internal Committee members.
• Include POSH orientation during employee onboarding.

16. Record Keeping

The Internal Committee shall maintain records relating to:

• Complaints received
• Investigations conducted
• Findings and recommendations
• Corrective actions implemented
• Annual reporting requirements

All records shall be maintained securely and confidentially.

17. Policy Review

This Policy shall be reviewed periodically and amended whenever required due to:

• Changes in applicable laws
• Regulatory requirements
• Organizational needs
• Recommendations from management or the Internal Committee

18. Contact Details

For reporting concerns or seeking guidance regarding this Policy:

Email: [email protected]

Human Resources Department: Ms Rajalakshmi Alate

Policy Approval

Version Review