POSH

Policy on Harassment Free Workplace

Introduction

As a Company, Asirvad Microfinance Limited (AML) is committed to ensuring that the work environment at all its locations is conducive to fair, safe and harmonious relations between employees. Discrimination and harassment of any type/form are strictly prohibited. We place high importance in creating a discrimination-free workplace and any violation of any form is not tolerated as part of our employment practices.

We have also ensured that no employee is at a disadvantage by the way of gender discrimination. This note, therefore, enunciates the Company’s approach to the issue of sexual harassment and its policy for dealing with any incidence of the same.

Scope of this Policy

This policy applies to all individuals who are employed in a permanent or temporary capacity at any business location or deployed/visiting at the customer site by the Company. This policy document will be made available to all Divisions associated with the Company with a clear objective to establish a similar approach in dealing with this issue.

Definition of Issue

A broad definition of sexual harassment consists of any physical or verbal behaviour and any form of communication that has unnecessary, improper or unwelcome sexual connotations. Sexual harassment may vary in form depending on circumstances. It may consist of, but not be limited to, any of the following:

• Unwelcome sexual advances, requests for sexual favours, display of sexual visuals, sexual audios, pornographic or obscene material and any other verbal or physical conduct of a sexual nature
• Transmitting any message, by mail, telephone, e-mail etc. which is obscene, lewd, suggestive or blatantly sexual in nature
• Any explicit or implicit communication wherein a sexual favour or demand, whether by words or actions, is made a condition for an individual’s employment, career progress, promotion etc. thereby creating a hostile environment
• Sexually charged jokes or remarks and behaviour which have sexually oriented innuendoes
• Consistent pattern of unnecessary physical contact, staring or targeting unreasonable attention at an individual in day to day dealings
• Any pervasive pattern of behaviour which makes employees uncomfortable, insecure or feel humiliated or disadvantaged based on gender differentiation
• Physical & sexual assault

As mentioned above, this is an indicative but not an exhaustive list of possible forms of sexual harassment.

AML’S Policy on Sexual Harassment

The Company’s policy is to totally prohibit any form of sexual harassment in the way employees behave with each other. This would also include complaints relating to instances outside of the workplace during working hours. This applies equally to all employees of AML. Any incident of sexual harassment will be taken extremely serious and complaint of this nature will be immediately investigated and appropriate action will be taken against the offending employee/s. Such action will depend on the nature and seriousness of the offence and will include strict disciplinary action including and up to termination of services.

Complaints Handling Process

The Company has established the following process to ensure that any incidence of sexual harassment is dealt with appropriately, sensitively and expeditiously.

Process for dealing with incidents of sexual harassment

• Any employee who experiences sexual harassment can get in touch with any member of the Internal Complaint Committee (ICC) / Local Complaint Committee (LCC) whose contact details are provided in this document for convenience and confidential access. Alternatively, the affected employee may approach State Head / DM/ HOD or HR team member and such person will inform a member of the ICC immediately.
• On receipt of such a complaint, the Committee will immediately arrange to fully investigate all relevant details of the matter and ensure confidentiality of the legal proceedings. The complainant cannot choose to remain anonymous. It will do so with all possible care, sensitivity and discretion in protecting the sensibilities of the affected employee.
• The employee/s, who has allegedly committed the offence, would be given all reasonable opportunities to be heard by the Committee. Principle of natural justice will be followed irrespective of gender bias. The result of this investigation will be formally recorded and communicated to the AML Management along with a recommendation from ICC for appropriate action.
• The Committee will normally complete this process within 30 days after receiving the complaint and make its formal recommendation within 10 days after completing the enquiry process, unless there are exceptional circumstances.
• In the case of a multi locational context, one of the committee members will travel to the location in question as is required to ascertain the facts based on which the committee would discuss and assess the complaint in question.
• Necessary action will then be initiated by management based on the recommendation of the investigating committee/ICC based on the circumstances and seriousness of the offence
• Where the Company is legally advised that any such incident constitutes a criminal offence, the Company will inform the relevant authorities, provide full details and request appropriate action
• The Company will ensure that the career interests of the complainant are not adversely affected by virtue of the individual having drawn attention to such an offence
• In order to ensure that this important matter is not trivialized, any complaint, which, in the opinion of the Committee, is blatantly false or has been motivated by reasons that are clearly unconnected with gender issues, would be viewed very seriously by the Company and appropriate action taken against such malicious complainant/s
• HOD and State Head at all locations will also be expected to be sensitive to any circumstances or behaviours among their colleagues which appear to go against the Company policy on this matter. In case they become aware of any such incidence, they will immediately inform the head of the Committee and take appropriate action as advised
• We believe in No Retaliation against those employees who have raised concerns of this nature in Good Faith and the issues raised will be investigated with full conviction

Internal Complaints Committee (ICC)

AML has established an Internal Complaints Committee (ICC) for Sexual Harassment consisting of four internal members and one external member. The names of the members of this Committee and their contact details are given below.

Name	Role	Contact Details	Location
Ms. Suryapraba	Presiding Officer	9847239398 gmlegalcorporate@manappuram.com	Kerala
Mr. Bikram Mishra	Member	9384698860 bikram.mishra@asirvad.in	Chennai
Ms. Gowri	Member	9344913544 Gowri.s@asirvad.in	Chennai
Mr. Ramachandran S	Member	s.ramachandran@asirvad.in	Chennai
Ms. Sujitha Rabeca	Member	6379902792 sujitha.rabeca@asirvad.in	Chennai

External Representative: – Ms. Suryapraba

Email id: gmlegalcorporate@manappuram.com

Contact no: +91 – 9847239398

Mr. S V Raja Vaidyanathan, Managing Director, Asirvad Microfinance Limited (AML), will provide all necessary support to the work of this Committee.

Local Investigation Committee

AML has established a Local Complaints Committee (LCC) for Sexual Harassment consisting of five internal members and one external member. The names of the members of this Committee and their contact details are given below

Name	Role	Contact Details	Location
Ms. Suryapraba	Presiding Officer	9847239398 gmlegalcorporate@manappuram.com	Kerala
Mr. Bikram Mishra	Member	9384698860 bikram.mishra@asirvad.in	Chennai
Mr. Ramachandran S	Member	s.ramachandran@asirvad.in	Chennai
Ms. Gowri	Member	9344913544 Gowri.s@asirvad.in	Chennai
Mrs. Sujitha Rabeca	Member	6379902792 sujitha.rabeca@asirvad.in	Chennai
Head of the Respective State for States other than TN	Member	As per list given
HR of the Respective State	Member	As per list given

Head of States other than TN

State	POSH-State Representatives	Mail ID	Contact number
Kerala	Arun Kumar R	arun@asirvad.in	9526832233
Karnataka	Madhava Rao M	madhava.rao@asirvad.in	7755933336
Gujarat	Dinesh Kumar S	dinesh.k@asirvad.in	7000015835
Madhya Pradesh	Ajit Kumar Sabat	ajitkumarsabat@asirvad.in	9589076688
Chhattisgarh	Dharmendra Malviya	dharmendra.malviya@asirvad.in	9644099909
Punjab	Lalit Bisht	lalit.bisht@asirvad.in	9915902000
Chandigarh	Lalit Bisht	lalit.bisht@asirvad.in	9915902000
Haryana	Lalit Bisht	lalit.bisht@asirvad.in	9915902000
Uttar Pradesh	Paras Kumar Wasnik	paras.wasnik@asirvad.in	8572937777
Jharkhand	Mukul Verma N	mukulverma@asirvad.in	7766904040
West Bengal	Santanu Nandi	santanu.nandi@asirvad.in	7363045557
Bihar	Soumitra Chakraborty	soumitra.chakraborty@asirvad.in	7369941901
Rajasthan	Rahul Dixit	rahul.dixit@asirvad.in	7230002400
Uttarakhand	Paras Kumar Wasnik	paras.wasnik@asirvad.in	8572937777
Maharashtra	Madhava Rao M	madhava.rao@asirvad.in	7755933336
Odisha	Sudhir Ranjan Pattanaik	sudhir@asirvad.in	7328842931
Tripura	Mukul Verma N	mukulverma@asirvad.in	7766904040
Assam	Mukul Verma N	mukulverma@asirvad.in	7766904040
Goa	Madhava Rao M	madhava.rao@asirvad.in	7755933336

State HR representatives

State	HR Name	Contact Number	Mail ID
Kerala	Indu Kannan	9526752233	indukannan@asirvad.in
Karnataka	Vijay Pundalik Kumbar	6362966867	vijay.pundalik@asirvad.in
Punjab	Harish Kumar	9053058224	kumar.harish@asirvad.in
Chandigarh	Anmol Sharma	9368070280	anmol.sharma@asirvad.in
Uttar Pradesh	Abhishek Yadav	7084159538	abhishek.yadav@asirvad.in
Bihar	Sumit Kumar	7369941804	sumit.kumar@asirvad.in
Uttarkhand	Anubhav Prakash Tiwari	7084159222	anubhav.tiwari@asirvad.in
Jharkand	Sumit Kumar Lal	7283007535	lal.sumitkumar@asirvad.in
West Bengal	Trisha Roy A	7479002578	trisha.roy@asirvad.in
Tripura	Bippan Nath B	7085061346	bippan.nath@asirvad.in
Assam	Gitanjali Khanikar	6900184141	gitanjali.khanikar@asirvad.in
Madhya Pradesh	Dipali Jain	9285505380	Dpali.jain@asirvad.in
Chhattisgarh	Madhumita S	6262001521	madhumita@asirvad.in
Rajasthan	Priya Saini	7229812222	priya.saini@asirvad.in
Maharashtra	Shital Krishna Kundekar	7410028363	shital.krishna@asirvad.in
Odisha	Laxmipriya Behera	7328842941	laxmipriya.behera@asirvad.in

Safety Guidelines for Women Employees at Work Place

• At Asirvad, we believe that the safety of our women employees is very important, and we ensure that all arrangements are made to create a safe, unbiased and women-friendly environment. Some of the rules that are followed in our offices currently, with respect to the safety of all our employees and women.
• No women employee is allowed to work beyond 7.30 pm in the Company exceptions would be an extension by 1 hour.
• If there is an extension to working hours, the employee needs to get approval from the HOD stating the time she would like to extend and reason with an intimation to the Admin.
• Admin- in-charge to be informed about it 1 day in advance in normal cases and 2 hours in advance to office hours in case of emergency
• Admin-in-charge to intimate the Security in the office about the stay of a particular employee in the office
• Admin-in-charge to book a cab for the drop of women employees from an official travel agent
• Details of the cab, driver to be registered in the register along with a photocopy of the driver’s ID and a signature need to be obtained from the driver in the register
• In case of women and men employees are getting dropped in the same cab, women employee to be dropped first and men employees last, to see women employees reach home safe
• Women employees shall inform administration in-charge of the Corporate Office / Divisional Office Branch Office/post reaching home
• Women employees are advised to save the mobile numbers of admin in-charges, local police station, women protection cell of police in fast dial mode in mobile phones so that they can quickly access them in case of emergency (numbers are given below)
• In case of women employees travelling out of station early in the morning/ late evenings, women employees to be provided drop to airport and pick up from destination airport by office cab or official cab agency, cab driver’s name and number to be given to them in advance
• Training on self-defence and to face emergencies will be given to women employees once in 6 months and awareness camps on emergencies are given once in 6 months

Cases not covered by or requiring relaxation of these rules or where doubt has arisen regarding the interpretation thereof shall be referred to myhrsupport@asirvad.in  and HR shall consider each case on its merit and submit it to the HOD/COO whose decision in such cases shall be final