Prevention of Sexual Harassment(POSH)
Jubilant Biosys Limited

1st February 2021

Prevention of Sexual Harassment
Table of Contents
No.

DetailsPage

1.

Introduction

3

2.

Objective3

3.

Effective Date

3

4.

Definitions

4

5.

Sexual Harassment

46.

Complaint Mechanism

5

7.

Complaint Process

58.

Conciliation

6

9.

Possible Outcomes

6-7

10.

Punishment for False or Malicious Complaints and Presenting
False Evidence

7

11.

Confidentiality

7

12.

Conclusion

713.

IC Member List & Reporting Options

8* Disclaimer: This policy acts as a guideline for all the employees of Jubilant Biosys Limited and is to be used strictly for internal circulation only.

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PREVENTION OF SEXUAL HARRASSMENT (POSH)
1. INTRODUCTION
Jubilant Biosys Limited (‘Company’) as an employer is committed to creating a work place thatis free from all forms of sexual harassment. This policy is designed to enable employees to workwithout fear of gender bias and sexual harassment. Therefore, in order to deal with sexualharassment at workplace the Company has articulated this Prevention of Sexual Harassment
Policy (‘POSH’ or ‘Policy’).
The Policy aims to prevent/prohibit, redress any alleged incident of sexual harassment and, if
necessary, to enforce disciplinary action in face of any such occurrence. It defines sexualharassment and provides a framework to respond to complaints of sexual harassment at theworkplace.
Any form of sexual harassment at the workplace is unacceptable and is regarded as misconduct
as per this Policy. The Company has adopted Zero Tolerance towards sexual harassment
and will act in accordance with its disciplinary procedures for violations. The Company will also
comply with specific laws and regulations under local jurisdictions relating to sexual harassment.
Sexual harassment can be reported without fear of reprisal or retaliation. The Company will
investigate all allegations of sexual harassment promptly and discreetly. The Company will also
initiate disciplinary action as per the details provided in this Policy.
All employees (whether in full time or part time employment of the Company, in permanent,
probationary, trainee, retainer, temporary or contractual basis), and contractors of the Company
must comply with this Policy.

2. OBJECTIVEa.
b.
c.
d.
e.
f.

Provide a work environment free from fear, reprisal, coercion, discrimination, andharassment of sexual nature.
Express zero tolerance regarding any sexual harassment at the workplace through theprevention, resolution, and deterrence of acts of sexual harassment.
Enable all those working for, associated with, and visiting the Company to raise theirconcerns and make complaints without any fear of retaliation.
Define sexual harassment and provide a clearly stated codified redressal mechanism forany sexual harassment occurring at workplace.
Provide a fair procedure for the resolution, settlement, or prosecution of complaints ofsexual harassment.
Conduct impartial investigations and take appropriate action in a timely manner.

3. EFFECTIVE DATEThis version supersedes all earlier versions and is effective from February 1, 2021.

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4. DEFINITIONSa.

Aggrieved Person: Any individual (employed, associated and / or visiting the Company
workplace) who makes an allegation of sexual harassment.

b.

Workplace: Includes all offices and branches of the Company, and any place visited bythe employee during the course of his/her employment, including transportation provided
by the Company for undertaking such journey, as well as Company related social
events.

c.

Respondent: Any person (employed, associated and visiting the Company) against
whom the aggrieved person has submitted a complaint of sexual harassment.

5. SEXUAL HARRASSMENT
Sexual Harassment can occur directly or indirectly and can involve the following:a. Sexual advances or requests for sexual favors or other physical or verbal conduct of asexual nature, when: (1) submission to such conduct is made an express or implicit conditionof employment; (2) submission to or rejection of such conduct is used as a basis for
employment decisions affecting the individual who submits to or rejects such conduct; or (3)such conduct has the purpose or effect of unreasonably interfering with an employee’s work
performance or creating an intimidating, hostile, humiliating, or offensive working
environment.
b. While it is not possible to list all of the circumstances which would constitute sexual
harassment, the following are some examples: (1) unwelcome sexual advances – whether
they involve physical touching or not; (2) requests for sexual favors in exchange for actualor promised job benefits such as favourable reviews, salary increases, promotions,increased benefits, or continued employment; or (3) coerced sexual acts.
c. Depending on the circumstances, the following conduct may also constitute sexual
harassment: (1) use of sexual epithets, jokes, written or oral references to sexual conduct,gossip regarding one’s sex life; (2) sexually oriented comment on an individual’s body,comment about an individual’s sexual activity, deficiencies, or prowess; (3) displaying
electronically or otherwise, sexually suggestive objects, pictures, cartoons; (4) unwelcome
leering, whistling, deliberate brushing against the body in a suggestive manner; (5) sexual
gestures or sexually suggestive comments; (6) inquiries into one’s sexual experiences; or(7) discussion of one’s sexual activities.
d. While such behaviour, depending on the circumstances, may not be severe or pervasive
enough to create a sexually hostile work environment, it can nonetheless make co-workers
uncomfortable. Accordingly, such behavior is inappropriate and may result in disciplinary
action regardless of whether it is unlawful under local statutes.
e. It is also unlawful and expressly against this Policy to retaliate against an employee for filinga complaint of sexual harassment or for cooperating with an investigation of a complaint ofsexual harassment.

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6. COMPLAINT MECHANISM
An ‘Internal Committee’ (the ‘IC’) has been created by the Company to address complaints
made by the Aggrieved Person. Any Aggrieved Person, who is the recipient of any unwelcome
sexual behavior as described by this Policy or knows of the occurrence of such harassment tothe aggrieved person (provided it has obtained the written consent of the Aggrieved Person),may report the same. Complaints must be made in writing.
a.

The IC will be comprised of the following three or four employees/persons
designated/nominated for this role by the Company:
(i)
(ii)

iii)
b.

Presiding Officer - who shall be a senior level manager of the Company.
Two members - each of whom shall be from amongst the Senior employees of
the Company (or in absence of senior employees within the Company, thenit may nominate from its parent or affiliated companies). At least one ofwhom will be a female.
An independent person/NGO, where required under local laws, to provide special
assistance to the IC in dealing with such issues.

The IC is responsible for:• Investigating every formal written complaint of sexual harassment, consistent withlocal laws and in a prompt and fair manner.
• Taking appropriate remedial measures to respond to any substantiated allegationsof sexual harassment.
• Discouraging and preventing employment-related sexual harassment.
• Writing reports relating to the sexual harassment complaints received by it.
• Maintaining confidentiality of the process.

7. COMPLAINT PROCESS
A. INFORMALa) The Aggrieved Person may opt to communicate his / her concerns immediately to theRespondent and request the Respondent to cease and desist.
b) If the harassment does not stop or if the Aggrieved Person is not comfortable withaddressing the Respondent directly, he/ she can bring his / her concerns to the attentionof the IC. The IC will undertake a prompt and thorough investigation as stated above.

B. FORMAL COMPLAINT INQUIRY PROCESS:a) Any Aggrieved Person with a sexual harassment concern, who is not comfortable withinitiating the informal process may make a formal written complaint to the IC.
b) The IC shall conduct an investigation and submit a written report containing the findings
and recommendations to the Ombudsperson, on behalf of the Company, who shallforward the same to the Company with his/her final recommendations.
c) The Company shall consider the final recommendations and take required actions toimplement the same as deemed appropriate, within 60 days.

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Human Resources58. CONCILIATIONa) The purpose of the IC is to resolve/redress the complaint of the aggrieved person.
Hence, the first step by the IC will be to make an attempt to resolve the raised issue
through mutual discussion between the Aggrieved Person and the Respondent. The
mutual discussion will be considered based on the gravity of misconduct as construed
by the Aggrieved Person and her/his request to adopt conciliation process.
b) On the request of the Aggrieved Person, within 30 working days after the first meetingor any time prior to the commencement of the inquiry proceedings, the IC after making
sure that the Aggrieved Person is not opting for conciliation under any force / threat willtake steps towards settling the matter between the aggrieved person and theRespondent. This will be done through the process of separate and joint meetings
between the concerned parties. Conciliation will be completed within 50 days of initiationof the conciliation process, which may be conducted in a shorter timeline subject to thediscretion of the IC, or as may be requested by the Aggrieved Person.
c) During the process of conciliation, the IC will endeavour to resolve the matter and reachan amicable resolution by means of meetings and discussions. No monetary settlement
shall be made basis of the conciliation.
d) The IC will record the terms of settlement acceptable to the Aggrieved Person and theRespondent and file a closure report with the Company to take further action, if any, asrecorded in the settlement. Copies of the settlement shall be provided to the Aggrieved
Person and the Respondent. All persons involved in the conciliation will maintain thedignity and confidentiality of the persons involved. The Aggrieved Person will have theright to withdraw from the conciliation process by stating the reasons for withdrawal tothe IC.
e) Post the conciliation process, after the settlement is arrived, the IC will not conduct any
further enquiry of the complaint. Reasonable follow up communication may be
maintained with the Aggrieved Person by the IC.

9. POSSIBLE OUTCOMES:A. During the course of the inquiry, the IC may, on its own and/or at the written request of
the Aggrieved Person, recommend interim actions as appropriate to the Ombudsperson,
on behalf of the Company.
B. When the IC arrives at a conclusion that the allegation against the Respondent areproved, the IC may recommend appropriate disciplinary action(s) basis theirinvestigations and in consultation with the Ombudsperson, including any or more of thefollowing, to the Company:
a.
b.
c.
d.
e.
f.
g.
h.

Written apology;
Warning;
Reprimand or Censure;
Withholding of Promotion;
Withholding of pay rise or increments;
Suspension;
Termination;Counselling;

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i.

In cases where the alleged harasser is a contractor, such person may be barred fromCompany workplace along with termination of his/her arrangement with theCompany.

10. PUNISHMENT FOR FALSE OR MALICIOUS COMPLAINTS AND PRESENTINGFALSE EVIDENCE:
When the IC arrives at a conclusion that the allegation against the Respondent ismalicious or false, it shall recommend the Company to take appropriate disciplinary
action (including those stated in Clause 9B above) against the Aggrieved Person.

11. CONFIDENTIALITY:
The Company understands that it is difficult for the Aggrieved Person to initiate acomplaint of sexual harassment and recognizes the Aggrieved Person's interest in
keeping the matter confidential. To protect the interests of the Aggrieved Person, andothers who may report incidents of sexual harassment, confidentiality will be maintained
throughout any inquiry process, and as mandated by local law. All records of complaints,
including contents of meetings, results of investigations and other relevant material will
be kept confidential by the Company except where disclosure is required underdisciplinary or other remedial and legal processes in order to protect the parties.

12. CONCLUSION:
In conclusion, the Company reiterates its commitment to providing its employees with aworkplace free from sexual harassment/ discrimination and where every employee istreated with dignity and respect.

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IC Members -Jubilant Biosys Limited - Noida
Name

Function

E-mailContact
No.

Role inCommittee

Regina Cheryl Roberts

HR

regina.roberts@jubl.com

9810453742

Chairperson

Dr Dinesh Kumar
SarwalSr Director & Head IPR

dinesh.kumar@jubl.com

9818001244

MemberPalak Singh

HRpalak.Singh@jubl.com

9873011011

MemberSanjay Gupta

Legalsanjay.gupta1@jubl.com9810122389

MemberSudha Venugopal

Ombudsperson
Officesudha.venugopal@jubl.com

9818790555

Member

Sonal Mattoo

NGO
Representative

sonalmattoo@gmail.com

9810740465

Member(NGO)

IC Members - Jubilant Biosys Limited - Greater Noida
Name

Function

E-mailContact
No.

Role inCommittee

Regina Cheryl
Roberts
Dr Dinesh Kumar
SarwalHR

regina.roberts@jubl.com

9810453742

Chairperson

Sr Director &Head - IPR

dinesh.kumar@jubl.com

9818001244

MemberPalak SinghHR

palak.Singh@jubl.com

9873011011

MemberSanjay Gupta

Legalsanjay.gupta1@jubl.com

9810122389Member

Sudha Venugopal

Ombudsperson
Officesudha.venugopal@jubl.com

9818790555

MemberNeha MainiHRneha.maini@jubilantbiosys.com

8130943456

Member

Neelam SinghSynthesis

neelam.singh@jubilantbiosys.com

MemberSerena Lugli

ProjectManagement
NGO
Representative

serena.lugli@jubilantbiosys.com

Member

Sonal Mattoo

sonalmattoo@gmail.com

9810740465

Member(NGO)

Reporting Options•

Email to : ic.pharmova@jubl.com or Ombudsperson@jubl.com•logging/ accessing the web portal www.cwiportal.com, and clicking on the ‘Lodge
Report’ button;•post, in a sealed envelope, to the following mail box: Post Box No. 4374, Ombudsperson- Jubilant Bhartia Group, New Delhi•Toll Free Number: 18601234525 (Availability: Monday to Friday from 0930 -1730 hrs)**********
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