Governance

Prevention of Sexual Harassment

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1. Policy Statement

Cornwill Realty Corp. ("the Company") is committed to providing a workplace free from sexual harassment and ensuring that every employee is treated with dignity and respect.

This policy is framed in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the Rules framed thereunder (collectively, "the POSH Act").

2. Scope and Applicability

This policy extends to all employees — permanent, temporary, contractual, trainees, probationers, apprentices, and those engaged through third-party agents. It also extends to visitors, clients, customers, and any other person present at the workplace.

"Workplace" includes all offices, project sites, off-site locations visited during work-related travel, transportation provided by the Company, and any place visited by an employee arising out of or during the course of employment.

3. Definition of Sexual Harassment

Sexual harassment includes any one or more of the following unwelcome acts or behaviour, whether directly or by implication:

  • Physical contact and advances
  • A demand or request for sexual favours
  • Making sexually coloured remarks
  • Showing pornography
  • Any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature

4. Internal Complaints Committee (ICC)

The Company has constituted an Internal Complaints Committee in compliance with Section 4 of the POSH Act. The ICC includes:

  • A Presiding Officer who is a senior woman employee
  • Not less than two members from among employees committed to the cause of women
  • One external member from an NGO or association committed to the cause of women, or a person familiar with issues relating to sexual harassment

At least one half of the total ICC members shall be women.

5. Complaint Mechanism

Any aggrieved woman may make a written complaint to the ICC within 3 months of the incident. Where the incidents are of a continuing nature, within 3 months of the last incident. The ICC may extend this period by a further 3 months if it is satisfied that circumstances were such as to prevent the person from filing within the initial period.

Complaints may be sent to: posh@cornwill.com

Or by sealed letter addressed to "Presiding Officer, Internal Complaints Committee" at 229/230 Arun Chambers, Tardeo Road, Mumbai 400034.

6. Inquiry Process

The ICC shall complete the inquiry within 90 days of receipt of the complaint. The ICC shall:

  • Give both parties an opportunity to be heard
  • Permit examination of witnesses
  • Recommend interim relief measures if necessary (such as leave for the complainant or transfer of either party)
  • Prepare an inquiry report with findings and recommendations within 10 days of completing the inquiry

The report shall be submitted to the employer, who must act on the recommendations within 60 days.

7. Confidentiality

The identity, address, and details of the aggrieved person, the respondent, and any witnesses shall not be disclosed to the public, media, or any other person, except as required by law. Breach of confidentiality shall attract penalty as per the POSH Act.

8. Consequences

If the allegation is proven, the ICC may recommend action ranging from written warning to termination of employment, along with counselling, community service, withholding of promotion or increment, or any other action as it deems appropriate.

Malicious or false complaints may lead to action against the complainant under this policy — though mere inability to substantiate a complaint shall not attract such action.

9. No Retaliation

The Company strictly prohibits retaliation against any person who files a complaint, participates in an inquiry, or cooperates with the ICC. Any act of retaliation shall be treated as a separate act of misconduct.

10. Annual Reporting

The ICC shall submit an annual report to the Company and to the District Officer in the format prescribed under the POSH Act.

This policy is constituted under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.