BASIS OF THE POLICY:
Sexual harassment at the workplace results in violation of the fundamental rights
of a woman
- to equality under Articles 14 and 15 of the Constitution of India
- to life and to live with dignity under article 21 of the Constitution
- to practice any profession or to carry on any occupation, trade or business which includes a
right to a safe environment free from sexual harassment.
Protection against sexual harassment and the right to work with dignity are universally recognized
human rights by international conventions and instruments such as Convention on the Elimination of all
Forms of Discrimination against Women, which has been ratified on 25 June 1993 by the Government of
India.
Euclidee Software Solutions Private Limited, is an equal employment opportunity company and is
committed to creating a healthy working environment that enables employees to work without fear of
prejudice, gender bias and in a harassment free workplace to all employees without regard to race,
caste, religion, colour, ancestry, marital status, gender, age, nationality, ethnic origin or disability. The
Company also believes that all employees of the Company have the right to be treated with dignity.
Sexual harassment at the work place or other than work place if involving an employee or employees is
a grave offence and is therefore, punishable
This Policy extends to all employees of Euclidee Software Solutions Private Limited and any other
company which may be incorporated in future with applicability of Euclidee Software Solutions Private
Limited, HR policies - hereinafter referred to as 'Company' / 'Organization' in this policy. It is deemed to
be incorporated in the service conditions of all employees of the Company in India. Local country laws
will take precedence over this policy, in other geographies, if applicable.
This version of the policy is effective from 1st January 2026 and supersedes all prior policies and
communication on this matter.
PART - A
1. INTRODUCTION :
At Euclidee Software Solutions Private Limited, all employees are expected to
uphold the highest standards of ethical conduct at the workplace and in all their interactions
with business stakeholders. This means that employees have a responsibility to
a. Treat each other with dignity and respect
b. Follow the letter and spirit of law
c. Refrain from any unwelcome behavior that has sexual connotation (of sexual nature)
d. Refrain from creating hostile atmosphere at workplace via sexual harassment
e. Report sexual harassment experienced and/or witnessed to appropriate authorities and abide
by the complaint handling procedure of the company.
This policy has been framed in accordance with the provisions of “The Sexual Harassment of Women at
Workplace (Prevention, Prohibition and Redressal) Act, 2013” and rules framed there under (hereinafter
“the Act”). Accordingly, while the policy covers all the key aspects of the Act, for any further clarification
reference shall always be made to the Act and the provisions of the Act shall prevail.
If any aspect relating to sexual harassment not explicitly covered in this policy is provided for by the law,
then the law will be applicable. In case of any conflict between the policy and the law, the law will
prevail.
This policy provides protection against sexual harassment of women at workplace and the prevention
and redressal of complaints of sexual harassment and matters related to it.
2. SCOPE :
This Policy extends to all employees of the Company and is deemed to be incorporated
in the service conditions of all employees of the Company in India. Local country laws will take
precedence over this policy, in other geographies, if applicable.
3. DEFINITIONS :
Sexual harassment may occur not only where a person uses sexual behavior to
control, influence or affect the career, salary or job of another person, but also between co-workers. It
may also occur between an employee and someone that employee deals with in the course of his/her work
who is not employed by the Company.
A. “Sexual Harassment” includes any one or more of the following unwelcome acts or behavior
(whether directly or by implication), but not limited to:
Any unwelcome sexually determined behavior, or pattern of conduct, that would cause
discomfort and/or humiliate a person at whom the behavior or conduct was directed
namely:
i. Unwelcome sexual advances involving verbal, non-verbal, or physical conduct,
implicit or explicit
ii. Physical contact and advances including (but not limited to) touching, stalking,
sounds which have explicit and /or implicit sexual connotation/overtones,
molestation
iii. Teasing, Voyeurism, innuendos and taunts with implicit sexual connotation, physical
confinement and /or touching against one’s will
iv. Demand or request for sexual favors
v. Sexually colored remarks or remarks of a sexual nature about a person's clothing or
body
vi. Display of pictures, signs etc. with sexual nature/ connotation/ overtones in the
work area and work-related areas
vii. Showing pornography, making or posting vulgar / indecent / sexual pranks, teasing,
jokes, demeaning or offensive pictures, cartoons or other materials through email,
SMS, MMS, gestures etc.
viii. Repeatedly asking to socialize during off-duty hours or continued expressions of
sexual interest against a person’s wishes
ix. Giving gifts or leaving objects that are sexually suggestive
x. Eve teasing, innuendos and taunts, physical confinement against one’s will or any
such act likely to intrude upon one’s privacy; Persistent watching, following,
contacting of a person; and
xi. Any other unwelcome physical, verbal or non-verbal conduct of sexual nature
B. The following circumstances if it occurs or is present in relation to any sexually determined act
or behavior amount to sexual harassment:
i. Implied or explicit promise of preferential treatment in employment;
ii. Implied or explicit threat of detrimental treatment in employment;
iii. Implied or explicit threat about the present or future employment status;
iv. Interference with the person’s work or creating an intimidating or offensive or
hostile work environment; or
v. Humiliating treatment likely to affect health or safety.
An alleged act of sexual harassment committed during or outside of office hours falls under the purview
of this policy. Further, it is important to note that whether harassment has occurred or not does not
depend on the intention of the people but on the experience of the aggrieved woman.
C. Aggrieved woman:
In relation to a workplace, a woman, of any age, whether employed or not,
who alleges to have been subjected to any act of sexual harassment by the respondent.
D. Complainant:
Any aggrieved woman who makes a complaint alleging sexual harassment under this policy
E. Respondent:
A person against whom a complaint of sexual harassment has been made by the
aggrieved woman under this policy
F. Employee:
A person employed at the workplace, for any work on regular, temporary, ad-hoc or
daily wage basis, either directly or through an agent, including a contractor, with or without the
knowledge of the principal employer, whether for remuneration or not, or working on a
voluntary basis or otherwise, whether the terms of employment are express or implied and
includes a coworker, a contract worker, probationer, trainee, apprentice or called by any other
such name.
G. Special Educator:
A Special Educator means a person trained in communication with people
with special needs in a way that addresses their individual differences and needs.
H. Workplace:
a. Premises, locations, establishments, enterprises, institutions, offices, branches or units
established, subsidiaries which are controlled by the Company.
b. Places visited by the Employee arising out of or during the course of employment including
official events, accommodation and transportation provided by the employer for
undertaking a journey.
I. Employer:
A person responsible for management, supervision and control of the workplace
4. ROLES AND RESPONSIBILITIES :
It is the responsibility of all to respect the rights of others and to
never encourage harassment. It can be done by:
a. Refusing to participate in any activity which constitutes harassment
b. Supporting the person to reject unwelcome behavior
c. Acting as a witness if the person being harassed decides to lodge a complaint
d. Redressal Mechanism – Formal Intervention
In compliance with the Act, any complaint under this policy shall be followed by a formal redressal
mechanism as described in this Policy.
PART - B
1. INTERNAL COMPLAINTS COMMITTEE (HENCEFORTH KNOWN AS ‘COMMITTEE’) AND ITS
CONSTITUTION :
To prevent instances of sexual harassment and to receive and effectively deal
with complaints pertaining to the same, Internal Complaints Committees (IC) have been
appointed for the company. The detail of the committee is notified to all covered persons at the
location (workplace). The committee at each location comprises of:
a. Presiding Officer: A woman employed at a senior level in the organization or workplace
b. At least 2 members from amongst employees, committed to the cause of women or
who have had experience of social work or have legal knowledge
c. One external member from amongst legal fraternity, non-governmental organizations
or associations committed to the cause of women or a person familiar with the issues
relating to sexual harassment
d. At least one half of the total members nominated being women
2. RESPONSIBILITY OF THE COMMITTEE :
a. Receiving complaints of sexual harassment at the workplace
b. Initiating and conducting inquiry as per the established procedure
c. Submitting findings and recommendations of inquiries
d. Coordinating with the employer in implementing appropriate action
e. Maintaining strict confidentiality throughout the process as per established guidelines
f. Submitting annual reports in the prescribed format
3. COMMITTEE MEMBERS :
Internal Complaint Committees have been formulated the details
about the current members of the IC is enclosed in Annexure A.
4. LODGING A COMPLAINT:
An aggrieved woman may make, in writing, a complaint of sexual
harassment at workplace to the Internal Committee within a period of 3 months from the date
of incident/ last incident. The Internal Committee can extend the timeline by another 3 months
for reasons recorded in writing, if satisfied that these reasons prevented the lodging of the
complaint within the period.
Provided that where such a complaint cannot be made in writing, the Presiding Officer or any
Member of the Internal Complaint Committee shall render all reasonable assistance to the
women for making the complaint in writing.
i. If the Aggrieved Woman is unable to make a complaint on account of her physical
incapacity, a complaint may be filed by:
a. her relative or friend; or
b. her co-worker; or
c. an officer of the National Commission for Women or State Women’s Commission; or
d. any person who has knowledge of the incident, with the written consent of the
Aggrieved Woman
ii. If the Aggrieved Woman is unable to make a complaint on account of her mental
incapacity, a complaint may be filed by:
e. a. her relative or friend; or
f. b. a special educator; or
g. c. a qualified psychiatrist or psychologist; or
h. d. the guardian or authority under whose care she is receiving treatment or care;
or any person who has knowledge of the incident jointly with the Aggrieved
Woman’s relative or friend or a special educator or qualified psychiatrist or
psychologist, or guardian or authority under whose care she is receiving treatment
or care
iii. If the Aggrieved Woman for any other reason is unable to make a complaint, a
complaint may be filed by any person who has knowledge of the incident, with her
written consent.
iv. If the Aggrieved Woman is deceased, a complaint may be filed by any person who has
knowledge of the incident, with the written consent of her legal heir.
The complaint shall be submitted by the complainant to the IC in writing or shall be submitted to
the IC electronically at [email protected], The complaint can also be physically
submitted to any IC member.
5. RECEIVING A COMPLAINT (GUIDELINES):
Dealing with incidents of harassment is not like any other type of dispute. Complainants may be
embarrassed and distressed and it requires tact and discretion while receiving the complaint.
The following points are to be kept in mind by the receiver of the complaint:
i. Complaints are listened to and the complainant informed that the Company takes the
concerns seriously. Complainant is informed that these concerns will be reported to the
appropriate committee and follow up will be done speedily.
ii. Situations are not to be pre-judged. Written notes are to be taken while listening to the
person. When taking notes, complainants own words, where possible, are to be used
accurately. Clear description of the incident in simple and direct terms is prepared and
details are confirmed with the complainant.
iii. All notes are kept strictly confidential. Complainant’s agreement is taken to allow
proceeding with the matter, which involves a formal investigation.
iv. The complainant is advised that although the process is confidential, the respondent
needs to be informed and any witnesses and persons directly involved in the complaint
process will also learn of the complainant’s identity
v. Care is taken to prevent any disadvantage to or victimization of either the complainant
or the respondent.
6. RESOLUTION PROCEDURE THROUGH CONCILIATION
i. Once the complaint is received, before initiating the inquiry, the committee may
take steps to conciliate the complaint between the complainant and the
respondent. This is only if requested by the aggrieved woman.
ii. No monetary settlement can be made as a basis of conciliation.
iii. In case a settlement is arrived at, the committee records & reports the same to the
employer for taking appropriate action. Resolution through conciliation is to happen
within 2 weeks of receipt of complaint.
iv. The committee shall provide copies of the settlement to complainant & respondent.
v. Where a settlement is arrived at, no further inquiry is to be conducted by the
committee.
7. RESOLUTION PROCEDURE THROUGH FORMAL INQUIRY:
The committee will initiate inquiry in the following cases:
i. No conciliation is requested by aggrieved woman
ii. Conciliation has not resulted in any settlement
iii. Complainant informs the committee that any term or condition of the settlement
arrived through conciliation, has not been complied with by respondent
8. MANNER AND PROCEDURE OF INQUIRY INTO COMPLAINT:
i. Complainant should submit the complaint along with supporting documents and the
names of the witnesses, if any.
ii. The Committee will hold a meeting with the Complainant within seven days of
receipt of the complaint, but no later than a week in any case.
iii. At the first meeting, the Committee members shall hear the Complainant and
record her allegations. The Complainant can also submit any corroborative material
with a documentary proof, oral or written material, etc., to substantiate her
complaint.
iv. The Committee shall proceed with the enquiry and communicate the same to the
Complainant and Respondent.
v. Upon receipt of the complaint, the committee will send 1 copy of the complaint to
Respondent within 7 working days of receiving the complaint.
vi. Respondent shall reply with all supporting documents within 10 working days of
receiving the copy of the complaint.
vii. Thereafter, the Respondent may be called for a deposition before the Committee
and an opportunity will be given to him to give an explanation, where after, an
inquiry shall be conducted and concluded.
viii. The Complainant shall be provided with a copy of the written explanation submitted
by the Respondent.
ix. If the Complainant or the respondent desires any witness/es to be called, they shall
communicate in writing to the Committee the names of witness/es that they
propose to call.
x. The Committee shall call upon all witnesses mentioned by both the parties.
xi. The Committee shall provide every reasonable opportunity to the Complainant and
the Respondent for putting forward and defending their respective case.
xii. If either party desires to tender any documents by way of evidence before the
Committee, the same is to be supplied as original copies of such documents.
Signatures should be affixed on the respective documents to certify these to be
original copies.
xiii. No legal practitioner can represent any party at any stage of the inquiry procedure
xiv. The Complaints Committee is to make inquiry into the complaint in accordance with
the principles of natural justice
xv. In conducting the inquiry, a minimum of three committee members including the
Presiding Officer are to be present
xvi. The employer shall provide all necessary assistance for the purpose of ensuring full,
effective and speedy implementation of this policy
xvii. Where sexual harassment occurs as a result of an act or omission by any third party
or outsider, the company shall take all steps necessary and reasonable to assist the
affected person in terms of support and preventive action.
xviii. In the event, the complaint does not fall under the purview of Sexual Harassment or
the complaint does not mean an offence of Sexual Harassment, the same would be
dropped after recording the reasons thereof.
xix. If the complainant or respondent desires to cross examine any witnesses, the
Committee facilitates the same and records the statements. In case complainant or
respondent seeks to ask questions to the other party, they may give them to the
Committee which asks them and records the statement of the other party.
xx. Any such inquiry is completed, including the submission of the Inquiry Report,
within 90 days from the date on which the inquiry is commenced. The inquiry
procedure should ensure absolute fairness to all parties.
9. INTERIM RELIEF:
During pendency of the inquiry, on a written request made by the
complainant, the committee may recommend to the employer to:
i. Transfer the complainant or the respondent to any other workplace
ii. Grant leave to the aggrieved woman of maximum 3 months, in addition to the leave
she would be otherwise entitled
iii. Prevent the respondent from assessing complainant’s work performance
iv. Grant such other relief as may be appropriate
v. Once the recommendations of interim relief are implemented, the same is informed
to the committee.
10. TERMINATION OF INQUIRY:
Committee may terminate the inquiry or give ex-parte decision, if
complainant or respondent respectively is absent for 3 consecutive hearings, without sufficient
reason. 15 day written notice is to be given to the party, before termination of enquiry or ex-
parte order.
11. ACTION TO BE TAKEN AFTER INQUIRY:
Post the inquiry, the committee submits its report containing the findings and recommendations to the
employer, within 10 days of completion of the inquiry.
12. COMPLAINT UNSUBSTANTIATED:
Where the committee arrives at the conclusion that the allegation against the respondent has not been
proved, it recommends to the employer that no action is required to be taken in this matter. Further, the
committee ensures that both parties understand that the matter has been fully investigated, that the
matter is now concluded, and neither will be disadvantaged within the Company.
13. COMPLAINT SUBSTANTIATED:
Where the committee arrives at the conclusion that the allegation against the respondent has been
proved, it recommends to the employer to take necessary action for sexual harassment as misconduct, in
accordance with the applicable service rules and policies, and this may include:
i. Counseling
ii. Censure or reprimand
iii. Apology to be tendered by respondent
iv. Written warning
v. Withholding promotion and/or increments
vi. Suspension
vii. Termination
viii. Or any other action that the employer may deem fit.
NOTE: The Company is required to act upon the recommendations within 60 days and confirm
to the committee. Post implementation of the actions, follow up with the complainant should
also occur to ascertain whether the behavior has in fact stopped, the solution is working
satisfactorily and if no victimization of either party is occurring.
14. PENAL CONSEQUENCES OF SEXUAL HARASSMENT:
In case the Committee finds the degree of offence coverable under the Bharatiya Nyaya Sanhita, then
this fact shall be mentioned in its report and appropriate action shall be initiated by the employer, for
making a Police Complaint. Under the Bharatiya Nyaya Sanhita, (BNS), Section 76 deals with Sexual
Harassment has made this a ‘cognizable offense’ i.e. a person charged with Sexual Harassment may be
arrested without a warrant.
15. MALICIOUS ALLEGATIONS:
Where the committee arrives at the conclusion that the allegation against the respondent is malicious or
the aggrieved woman or any other person making the complaint has made the complaint knowing it to be
false or the aggrieved woman or any other person making the complaint has produced any forged or
misleading document, it may recommend to the employer to take action against the woman or the person
making the complaint. While deciding malicious intent, the committee should consider that mere inability
to substantiate a complaint need not mean malicious intent. Malicious intent must be clearly established
through a separate inquiry.
16. CONFIDENTIALITY:
The identity of the complainant, respondent, witnesses, statements and other evidence obtained in the
course of inquiry process, recommendations of the committees, action taken by the employer is
considered as confidential materials, and not published or made known to public or media. Any person
contravening the confidentiality clauses is subject to disciplinary action as prescribed in the act.
17. APPEAL:
Any party not satisfied or further aggrieved by the implementation or non-implementation of
recommendations made, may appeal to the appellate authority in accordance with the Act, within 90 days
of the recommendations being communicated.
18. AWARENESS:
Awareness sessions are to be organized to:
i. Formulate and widely disseminate an internal policy or charter or resolution or
declaration for prohibition, prevention and redressal of sexual harassment at the
workplace intended to promote gender sensitive safe spaces and remove underlying
factors that contribute towards a hostile work environment against women.
ii. Carry out orientation programs and seminars for the Members of the IC.
iii. Conduct capacity building and skill building programs for the Members of the IC.
iv. Declare the names and contact details of all the Members of the IC.
v. Use modules developed by the State Governments to conduct workshops and
awareness programs for sensitizing the employees with the provisions of the Act.
19. LEGAL COMPLIANCE:
The IC shall in each calendar year prepare, is such format as may be prescribed, an annual report and
submit the same to the employer and the District Officer (as defined in the Act). The report shall have the
following details:
i. Number of complaints of Sexual harassment received in the year
ii. Number of complaints disposed of during the year
iii. Number of cases pending for more than 90 days
iv. Number of workshops or awareness program against Sexual Harassment carried out
v. Nature of action taken by the employer or District Officer
ANNEXURE A
A. Constitution of Internal Complaints Committee (IC):
1. Presiding Officer - name, email , phone
3. Member –
4. Member -
