Prevention of Sexual Harassment (PoSH) Policy

A. Policy Statement

Chryselys Services Private Limited (“Chryselys India”) is committed to providing a safe and respectful workplace for all employees. The company strictly prohibits sexual harassment in any form and will  take necessary actions to address any violations of this policy. The prevention, prohibition, and redressal of sexual harassment is a priority, in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013 (the “SHW Act”). This policy amounts to the service rules of Chryselys India for all concerns of sexual harassment at the workplace concerning women and shall prevail over anything contrary and supersede any prior policies on this subject.

B. Scope

This policy applies to all employees of Chryselys India, including permanent, temporary, contractual, and third-party personnel. It also covers harassment by clients, vendors, and visitors. The policy extends to the “Chryselys India workplace” which includes but is not limited to workplace premises, company transportation, any place visited by employees arising out of or during the course of work and any work-related activities or activities that have work-related consequences, whether within or outside company premises or on modes of communication (virtual or otherwise).

C. Definition of Sexual Harassment

Sexual Harassment includes any unwelcome sexually determined behavior (whether directly or by implication) such as:

1. Physical contact and advances
2. A demand or request for sexual favors
3. Making sexually colored remarks
4. Showing pornography
5. Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.

The following circumstances, if present, may also amount to sexual harassment:

1. Implied or explicit promise of preferential treatment in her employment.
2. Implied or explicit threat of detrimental treatment in her employment.
3. Implied or explicit threat about her present or future employment status.
4. Interference with her work or creating an intimidating or offensive work environment.
5. Humiliating treatment is likely to affect her health or safety.

Acts of sexual harassment at the workplace, where substantiated in accordance with the processes laid down under this Policy, will be treated as act(s) of misconduct with consequences, disciplinary or otherwise.

D. Other Definitions

1. 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.
2. Employer: Any person responsible for the management, supervision and control of the Company’s workplace and Employees of the Company.
3. Employee: A person employed at a Company 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 co-worker, a contract worker, probationer, trainee, apprentice or called by any other such name.
4. Interim Relief: The reliefs provided to the Aggrieved Woman upon her written request, by the Employer, upon recommendation of the Internal Committee of the Company in accordance with the SHW Act. These may include but not be limited to transfers, grant of paid leave, and change of reporting or any other means to prevent retaliation and/or further contact with the Respondent for the pendency of the Inquiry.If the Respondent is a direct supervisor of the Aggrieved Woman or any witnesses named by her, or is a person influencing the career growth of the Aggrieved Woman or any witnesses named by her, the reporting structure will be changed till the time the inquiry is concluded. In an effort to ensure an unbiased inquiry, involved parties may also be placed on leave during the course on an inquiry as per the discretion of the Internal Committee.
5. Respondent: Person against whom the Aggrieved Woman has made a complaint.

E. Responsibility

It is the responsibility of every employee to maintain a workplace free from sexual harassment. Employees at all levels are required to comply with this policy and report any behavior they believe constitutes sexual harassment. In case a manager or  supervisor is informed or witnesses an incident of sexual harassment, it is their duty to mandatorily report the same confidentially.

F. Internal Committee

Internal Committees (ICs) have been established at all locations of Chryselys India to handle complaints regarding sexual harassment. The ICs will consist of a Presiding Officer, who is a senior female employee, along with other members including an external member with experience in handling such cases. All cases of sexual harassment will be dealt with by the ICs. The current list of IC members is in the Annexure to this policy and may be updated from time to time.

G. Redressal Procedure

Any Aggrieved Woman at the Chryselys India Workplace may make a complaint of SexualHarassment against a Respondent to the Internal Committee. A Respondent can be a male, female or person of the third sex.

1. A complaint may be made in writing to the concerned IC or any member of the IC (as per the list in Annexure) within three months of the incident. The email id for reporting any concerns of sexual harassment is POSH.Complaint@chryselys.com.
2. Anonymous complaints are discouraged. However, all complaints are dealt with confidentially. In case a verbal complaint is made, reasonable assistance will be provided to help the Aggrieved Woman make her complaint in writing.
3. The Aggrieved woman can opt for either conciliation or inquiry. In case of conciliation, she will need to request the same to the IC.
4. In case of inquiry, the aggrieved woman can provide witness names/evidence to support her allegations.
5. Within a reasonable period of receipt of request for inquiry, the IC will ensure that the Respondent is aware of the allegations raised against him and able to provide their explanation to the same. Both parties will be given an opportunity to present their case and evidence. Meetings of the IC may be in person or conducted virtually.
6. During the proceedings, the IC may take steps to ensure the comfort of the Aggrieved Woman by granting leave, work from home or transfer to either party. Steps will be taken to reduce conflict amongst employees and the potential for retaliation. Cross examination, where exercised will be through written questions submitted to the IC in advance. The Aggrieved Woman may in writing request for any Interim Relief.
7. Inquiries should be completed within 90 days of initiation of inquiry. A final report will be submitted by the IC within 10 days of completing the inquiry.
8. All proceedings of the IC will be confidential and in accordance with rules of natural justice. The IC(s) has the powers of a civil court as provided in the SHW Act. In the event that a person not identifying as a woman wishes to make a complaint of sexual harassment against a colleague, the same can be made to Santosh Srivastav Gogulapati, Head of Human Resources (+91 9160602000).

H. Outcomes and Disciplinary Actions

If the allegations are substantiated (in whole or part), disciplinary action will be taken, which may include:

1. Counseling.
2. Verbal or Written apology
   Warning (First or Final)
3. Reduction in pay or other benefits
4. Demotion of reduction in role
5. Transfer or suspension
6. Termination of employment
7. Any other appropriate action as deemed fit.
8. Compensation may also be recommended in accordance with the law.

Even in cases where allegations are not substantiated, the IC may recommend measures that prevent or prohibit further concerns of sexual harassment at the workplace.

I. Action for Retaliation and False Statements

Any form of retaliation against a person for reporting harassment or acting as witness or intervening to stop an incident of sexual harassment is prohibited and will result in disciplinary action. Additionally, if it is found that a complaint was made with malicious intent or testimony provided by a witness with knowingly false information, the complainant or the witness may be subject to disciplinary action.

J. Annexure: Internal Committee Members (List as on 09.12.2024)

The following persons have been nominated as members to the Internal Committee of Chryselys India for its locations at Hyderabad, Chennai, Bengaluru and Panchkula. Any vacancies shall be filled from time to time and revised list circulated.

1. Hyderabad

Name	Designation	Contact Details
Shikha Agarwal	Presiding Officer	shikha.agarwal@chryselys.com +91 8588990313
Amith KA	Member	amith.ka@chryselys.com +91 9446358978
Keerthi Kolluri	Member	keerthi.kolluri@chryselys.com +91 7382167346
Santhosh Srivatsav Gogulapati	Member	santhosh.gogulapati@chryselys.com +91 9160602000
Jayashree Sharma	Member	jayashree.sharma@chryselys.com +91 8552856932
Paulomi Patel	Member	paulomi.patel@chryselys.com
Dr. Devika Singh Coherent Consultants	External Member	devika.singh@cohereconsultants.com +91 9818960361

2. Chennai

Name	Designation	Contact Details
Shikha Agarwal	Presiding Officer	shikha.agarwal@chryselys.com +91 8588990313
Sudharsan Mohan	Member	sudharsan.mohan@chryselys.com +91 9790891696
Keerthi Kolluri	Member	keerthi.kolluri@chryselys.com +91 7382167346
Sivapriya S	Member	sivapriya.s@chryselys.com +91 8825796283
Praveen S	Member	praveen@chryselys.com +91 9176395919
Paulomi Patel	Member	paulomi.patel@chryselys.com
Dr. Devika Singh Coherent Consultants	External Member	devika.singh@cohereconsultants.com +91 9818960361

3. Bengaluru

Name	Designation	Contact Details
Shikha Agarwal	Presiding Officer	shikha.agarwal@chryselys.com +91 8588990313
Biswarupa Mishra	Member	biswarupa.mishra@chryselys.com +91 9740745166
Sowmya Shivarama Gupta	Member	sowmya.s@chryselys.com +91 9740088297
Santhosh Srivatsav Gogulapati	Member	santhosh.gogulapati@chryselys.com +91 9160602000
Maaz Ahmed	Member	maaz.ahmed@chryselys.com +91 8050824787
Paulomi Patel	Member	paulomi.patel@chryselys.com
Dr. Devika Singh Coherent Consultants	External Member	devika.singh@cohereconsultants.com +91 9818960361

4. Rest of India

Name	Designation	Contact Details
Shikha Agarwal	Presiding Officer	shikha.agarwal@chryselys.com +91 8588990313
Biswarupa Mishra	Member	biswarupa.mishra@chryselys.com +91 9740745166
Anindya Mondal	Member	anindya.mondal@chryselys.com +91 8420191551
Santhosh Srivatsav Gogulapati	Member	santhosh.gogulapati@chryselys.com +91 9160602000
Dilasha Choudhary	Member	dilasha.choudhary@chryselys.com +91 96168178287
Paulomi Patel	Member	paulomi.patel@chryselys.com
Dr. Devika Singh Coherent Consultants	External Member	devika.singh@cohereconsultants.com +91 9818960361