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    1. preamble
  • this policy is Derivium Tradition Securities (India) Private Limited & Genev Capital Private Limited(company) policy against sexual harassment. company affirms its objective of maintaining a work environment that is free from sexual harassment.
  • 2. prohibition of sexual harassment
  • (a) company strictly prohibits sexual harassment in its work environment.
  • (b) “sexual harassment” means:
    (i) any conduct that is unwelcome and sexual in nature; examples of such conduct are:
    a. physical contact and advances;
    b. a demand or request for sexual favour;
    c. making sexually coloured remarks;
    d. showing pornography.
    (ii) any conduct/circumstance that is harassing in nature but only if it supports one’s own or another person’s unwelcome conduct of a sexual nature. examples of such conduct/circumstances are:
    a. retaliation in any manner, for complaining against sexual harassment or giving evidence in support of such a complaint;
    b. implied or explicit promise of preferential treatment in the harassed person’s employment;
    c. implied or explicit threat of detrimental treatment in the harassed person’s employment;
    d. implied or explicit threat about the harassed person’s present or future employment status;
  • (c) “work environment” means:
    a. interactions amongst the company’s employees*, irrespective of location and timing;
    b. interactions between the company’s employee and a third party during the course of employment or third party’s business relationship with the company;
    c. interactions between an employee of the company/third party having a business relationship with the company and a visitor to the company’s premises/events.
    * the term “employee” includes permanent as well as temporary employees, individual consultants and trainees (paid as well as unpaid
  • 3. prevention of sexual harassment
  • a. the company believes that sexual harassment can be eliminated through awareness.
  • b. the company will spread awareness within its organization through communication about sexual harassment and its consequences for the organization and the individuals involved.
  • c. the company will also take other appropriate steps as may be required to prevent and eliminate sexual harassment from its work environment
  • 4. redressal of complaints
  • a. company has constituted internal complaints committee (icc) to investigate & decide complaints of sexual harassment covered in this policy.
  • b. the names and contact details of the icc members are listed in appendix a to this policy.
  • c. anyone who faces or is affected by sexual harassment in the company’s work environment may make a complaint to the icc.
  • d. the procedures and time frames for filing, investigating and deciding complaints; and rights and obligations of the parties involved in the complaint are detailed in appendix b to this policy.
  • 5. punishment for sexual harassment
  • A. the Company shall take suitable action as recommended by the ICC against any employee who is found guilty of Sexual Harassment after due investigation. Such action may include one or more of the following:
    a. a warning,
    b. a written apology,
    c. mandatory counseling sessions or community service,
    d. fines,
    e. withholding of promotions or increments,
    f. suspension from service,
    g. termination of service.
  • B. any person who is found guilty of sexual harassment of a woman after due investigation by the icc shall be liable to pay compensation for any losses suffered by the harassed woman due to such sexual harassment.
  • C. The following acts of Sexual Harassment by a man against a woman are also criminal offences under the Indian Penal Code and are punishable as described below:
    a. physical contact and advances involving unwelcome and explicit sexual overtures;
    b. a demand or request for sexual favors;
    c. showing pornography against the will of a woman;
    d. making sexually coloured remarks.
    * the offences under (a), (b) and (c) are punishable with fine and/or rigorous imprisonment of up to 3 years. The offence under (d) is punishable with fine and/or simple or rigorous imprisonment of up to 1 year.
  • 6. consequences of making false or malicious complaints
  • if the icc concludes that a complaint is intentionally false or malicious or that any person has intentionally provided false or misleading evidence of any kind, the person who knowingly made such a false or malicious complaint or knowingly provided such false or misleading evidence may be punished in the same manner as described in para 5 (a) and (b) above. a complaint will not be automatically treated as false or malicious just because of failure to prove that sexual harassment occurred.
  • 7.confidentiality
  • privacy and dignity of individuals must be respected and matters of sexual harassment must be treated with great sensitivity. therefore, all information pertaining to any complaints of sexual harassment should be treated as private and confidential and should not be disclosed to anyone other than the management, icc or the parties involved in the complaint and, to a limited extent, only to those persons strictly on a “need to know” basis and who are expected to implement the decisions of the icc. anyone breaching this obligation of confidentiality shall be liable to pay the company a fine of rupees five thousand (rs.5000).
  • 8. amendments
  • the company may amend this policy and the related appendices from time to time to reflect any changes in the applicable laws or even otherwise to ensure that its work environment is free from sexual harassment.
  • appendix A
    the names and contact details of the icc members
    Name Number Email ID
    Ms. Jyothi Kumar 98200 62382 jyothi.kumar@varahalegal.com
    Ms. Amita Shah 99677 17555 akshah@deriviumcap.com
    Ms. Salomi Ghiya 99677 20555 sghiya@deriviumcap.com
    Mr. Kaushal Mehta 99677 12666 kmehta@deriviumcap.com
    appendix B
    procedures and time frames for filing, investigating and deciding complaints
  • an employee with a harassment concern, who is not comfortable with the informal resolution options or has exhausted such options, may make a formal complaint to the one or all the internal complaints committee via an email. the email complaint should be sent preferably within 15 days, or at the latest, within 1 month from the date of occurrence of the alleged incident. the employee is required to disclose their name, department, and location they are working in, to enable the presiding officer to contact them and take the matter forward.
    the presiding officer of the complaints committee will proceed to determine whether the allegations (assuming them to be true only for the purpose of this determination) made in the complaint fall under the purview of sexual harassment, preferably within 30 days from receipt of the complaint.
    in the event, the allegation does not fall under the purview of sexual harassment or the allegation does not constitute an offence of sexual harassment, the presiding officer will record this finding with reasons and communicate the same to the complainant.
    if the presiding officer of the complaints committee determines that the allegations constitute an act of sexual harassment, he/ she will proceed to investigate the allegation with the assistance of the complaints committee.
    where such conduct, on the part of the accused, amounts to a specific offence under the law, the company shall initiate appropriate action in accordance with law by making a complaint with the appropriate authority..
    the complaints committee shall conduct such investigations in a timely manner and shall submit a written report containing the findings and recommendations to the chairman & managing director as soon as practically possible and in any case, not later than 90 days from the date of receipt of the complaint. the chairman & managing director will ensure corrective action on the recommendations of the complaints committee and keep the complainant informed of the same.
    1. policy brief & purpose
  • this company policy includes the measures we are actively taking to mitigate the spread of coronavirus. it’s important that we all respond responsibly and transparently to these health precautions. we assure you that we will always treat your private health and personal data with high confidentiality and sensitivity.
  • 2. scope
  • this coronavirus policy applies to all of our employees who physically work in our office(s).
  • 3. policy elements
  • 1. all departments will be given a specific number of people to call for work, such that the overall attendance stays within the govt. limits
  • 2. apart from the above, any wanting to stay at home, will be welcome to.
  • 3. everyone coming to work, have to travel back & forth via taxi (on a fully reimbursed basis) and not use public transport like local trains, buses, etc.
  • 4. there will be no financial parameter related cuts, during this period.
  • 5. the leaves taken in this period, will not be adjusted against leaves.
  • 6. if you have recently returned from areas with a high number of covid-19 cases, we’ll ask you to work from home for 14 calendar days, and return to the office only if you are fully infection free. you will also be asked not to come into physical contact with any colleagues during this time.
  • 4. board meetings of the company
  • considering the need to take precautionary steps to overcome the outbreak of the coronavirus (covid-19), the government has in-principle decided to relax the requirement of holding board meetings with physical presence of directors under section 173 (2) r/w rule 4 of the companies (meetings of board and its powers) rules, 2014, for approval of the annual financial statements, board’s report, etc. such meetings may till 30th june, 2020 be held through video conferencing or other audio visual means by duly ensuring compliance of rule 3 of the said rules.