PoSH Policy
Prevention of Sexual Harassment at Workplace
1. Our Commitment
Consort Digital Private Limited (hereinafter "Consort Digital") is committed to fostering a workplace that upholds dignity, respect, equality, and safety for all. Sexual harassment is a violation of an individual's fundamental rights guaranteed under Articles 14, 15 and 21 of the Constitution of India and constitutes a serious breach of workplace ethics and professional conduct.
In line with the provisions of "The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013" (hereinafter "the Act") and rules framed thereunder, this Policy adopts a zero-tolerance approach towards sexual harassment in any form. It aims not only to prevent, prohibit, and redress incidents of sexual harassment but also to promote a culture of mutual respect and gender equality.
This Policy is applicable to all employees, contractors, interns, and visitors associated with Consort Digital. It extends to all physical, virtual, and remote workplaces where official interactions or duties occur.
For any queries, please contact the Internal Committee at: speakup@consortdigital.com
2. What Constitutes Sexual Harassment
Sexual harassment includes any unwelcome acts or behaviour (whether directly or by implication) of a sexual nature, strictly including but not limited to:
Physical Conduct
- Unwanted physical contact (touching, patting, pinching)
- Deliberately invading personal space
- Hugging, kissing, or stroking
- Physical advances blocking paths or cornering
- Attempted or actual sexual assault
Verbal Conduct
- Sexually coloured remarks, jokes, or comments
- Comments about appearance, body, or private life
- Repeated unwelcome requests for dates
- Unwelcome propositions or sexual innuendos
- Quid pro quo harassment (favours for benefits)
Non-Verbal & Visual
- Sexually suggestive gestures, staring, or leering
- Displaying sexually explicit images or posters
- Sending suggestive memes, emojis, or links
- Offensive body language of a sexual nature
Digital / Online Conduct
- Unwelcome sexually explicit messages via email/text
- Unwanted video calls/conduct during virtual meetings
- Online stalking or monitoring with sexual intent
- Posting sexually offensive content about colleagues
3. Internal Committee (IC)
The Internal Committee (IC) is constituted in accordance with the provisions of the Act to receive and investigate complaints of sexual harassment, ensuring confidentiality and fair treatment. The committee comprises a Presiding Officer, Internal Members, and an External Member familiar with issues relating to sexual harassment.
4. Complaint Process
Any aggrieved woman may make a complaint of sexual harassment at the workplace to the IC in writing within 3 months from the date of the incident.
File Complaint
Submit written complaint to IC within 3 months of incident (extendable by another 3 months if valid reasons exist).
Acknowledgment & Initial Meeting
IC acknowledges complaint within 3 days. Initial meeting with complainant within 7 days.
Notice to Respondent
Respondent receives copy of complaint within 10 days and must respond within 10 working days.
Inquiry
Formal inquiry commences within 15 days and must be completed within 90 days. Proceedings are confidential.
Report & Recommendation
IC submits report to management within 10 days of inquiry completion.
Action
Employer implements recommendations within 60 days of receiving the report.
SHe-Box Portal
Complaints can also be filed via the Government of India's SHe-Box (Single-Window Complaints Portal) at https://shebox.wcd.gov.in.
Note: Use of SHe-Box does not substitute the internal IC inquiry process. The IC remains the primary body for resolution.
5. Confidentiality & Protection
✅ Strict Confidentiality: All information relating to sexual harassment complaints, including the identity of the complainant, respondent, and witnesses, contents of the complaint, and inquiry proceedings, shall be kept strictly confidential. Breach of confidentiality constitutes serious misconduct.
✅ Protection Against Retaliation: Retaliation in any form against a complainant, witness, or IC member is strictly prohibited. This includes adverse employment actions, harassment, social ostracization, or digital retaliation. Any act of retaliation will be treated as gross misconduct attracting immediate disciplinary action.
✅ Malicious Complaints: While the inability to substantiate a complaint does not imply falsity, disciplinary action will be taken if malicious intent or false evidence is conclusively established.
