Policy on Prevention of Sexual Harassment – IPRS

Policy on Prevention of Sexual Harassment


Applicability of the Policy

This Policy applies to all persons employed or retained at Indian Performing Right Society Ltd (hereinafter collectively referred to as the “IPRS”) for any work on regular, temporary, ad hoc or daily wages, enter directly or through an agent, including a contractor, with or without the knowledge of the IPRS, whether for remuneration or not whether the terms of employment or retention are express or implied and includes co-workers, a contract worker, probationer, trainee, apprentice, intern or any other person called by any other such name (“Employee”). Every female Employee deserves, and has the right to be protected against sexual harassment, regardless of whether the Respondent (person against whom sexual harassment is alleged) consider their behavior to be normal or acceptable and whether or not the aggrieved woman had the opportunity to “avoid” the sexual harassment. In accordance with the law as well as the ethics of this organization there shall be zero tolerance of sexual harassment of women at the workplace. No person shall indulge, or cause to be indulged under instructions from superior or otherwise, in sexual harassment of women at the workplace.
Scope of ‘Sexual Harassment at workplace’
Sexual Harassment means and includes any one or more of the following unwelcome
– physical contact and/or advances; For e.g., unwelcome grabbing or deliberate touching or brushing against any part of the body of another person and the like, staring intently, whistling, winking, stroking private parts;
– soliciting sexual favors; For e.g., forcing a subordinate to provide sexual favors by promising promotion, pay increases or an easier work life, or threatening demotion unless, i.e. implied/ explicit threat of present or future employment status
– making sexually colored remarks; For e.g., making enquiries about anyone’s sex life, making sexual innuendos or gender-based sexist remarks or jokes which are sexually colored, lewd statements about one’s appearance/ body/ clothing;
– showing or dissemination of pornography;
– any other unwelcome physical, verbal or non verbal conduct of sexual nature; For e.g., forcing a woman to drink or dance or hug against her wishes at a corporate event, sharing or emailing/ SMS-ing/ MMS-ing/ Whatsapp-ing sexist jokes or making sexist remarks, pursuing a woman Employee with “romantic” intentions and forcing reciprocation, clicking pictures of a woman Employee without their consent;
– humiliating treatment based on sexual remarks likely to affect health and safety;
– Interfering with work, creating a hostile or offensive work environment directly or indirectly based on sexual remarks or sexual advances. It is the impact and effect the conduct has on the female Employee that will define the behavior as sexual harassment. Workplace includes the IPRS premises and/or any other place visited by the Employee arising out of or during the course of employment. This includes IPRS offsite, office meetings held outside the office premises whether in a hotel, restaurant or at an Employee’s residence or any other place. A restaurant where an Employee stops by for a meal during the course of visiting or returning from a business meeting outside the office would be deemed to be a Workplace.

Internal Complaints Committee

In keeping with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“Act”) and the Rules under the Act, IPRS has constituted an Internal Complaints Committee to receive and enquire into any complaints made by female Employees of IPRS and follow due procedure as laid down by the law.

Should you wish to report any incident that is in violation of this policy, you may approach any member of the Internal Complaints Committee listed below. All complaints and proceedings before the Internal Complaints Committee shall be completely confidential.

Internal Complaints Committee

Name Designation Contact Details
Ms Sheetal D Madnani Sr Manager – Legal, Data Distribution sheetal@iprsltd.com
Ms Vibha Oza Sr Manager – Accounts Finance accounts@iprsltd.com
Mr Ravinder Pathak Dy Gen Manager Head– Broadcasting Licensing ravinderpathak@iprsltd.com
Ms Ujwala Masdekar External Member ujwalabijay@yahoo.co.in

The Internal Committee, may, before initiating an enquiry, at the request of the aggrieved woman take steps to settle the matter between her and the respondent through conciliation provided that no monetary settlement shall be made as a basis of conciliation.

Upon the receipt of complaint and completion of an enquiry, if the Internal Complaints Committee establishes that the allegation against the Respondent has been proved, it is empowered to, and shall recommend to the Employer to take any of the following, one or combined actions including but not limited to:

1. Written apology,
2. Warning, Reprimand, or censure
3. Withholding of promotion
4. Withholding of pay rise or increments
5. Terminating the Respondent from service
6. Undergoing a counseling session or carrying out community service

The law also provides that where the Internal Complaints Committee arrives at the conclusion that the allegation against the Respondent is malicious or the complainant has made the complaint knowing it to be false or the complainant or any other person has produced any forged or misleading document, it may recommend to the employer to take action.

Please carefully read, understand and abide by this Policy and refrain from indulging in any actions contrary thereto.

IPRS’ Prevention of Sexual Harassment Policy for women at the workplace is formulated pursuant to the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“Act”) and the Rules there under. IPRS shall follow the rules and procedure enumerated in the said Act. For any person desiring to further read and understand the detailed procedure under the Act, a copy of the same is available with the Internal Complaints Committee.