POSH Policy (Prevention of Sexual Harassment)

Introduction

At Pink Vision Media Pvt. Ltd., we are committed to providing a safe, respectful, and inclusive workplace for all. We follow a zero-tolerance approach towards sexual harassment and discrimination in any form.

Every employee, contractor, trainee, consultant, or visitor has the right to dignity at work—a right we recognise as fundamental and universal. This policy applies equally to women, men, and transgender persons, ensuring fairness and protection across all identities.

Key Definitions

• Aggrieved Individual – Any person who alleges sexual harassment, including employees (permanent, contractual, trainees), consultants, and visitors.
• Complainant – The aggrieved person or their representative who submits a complaint.
• Respondent – The person against whom a complaint is made.
• Employer – The management of Pink Vision Media, responsible for supervision and control.
• IC (Internal Committee) – Committee formed under the POSH Act to address women’s complaints.
• DC (Disciplinary Committee) – Committee formed to address complaints from men and transgender persons.
• Presiding Officer – Senior employee leading the IC (woman) or DC (male/female).
• Workplace – Includes all offices, studios, shoots, events, travel, and any transport/accommodation provided by Pink Vision Media.

Background

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act) protects women against workplace harassment.

Pink Vision Media extends this protection to all genders, recognising that men and transgender persons may also face harassment. In case of conflict between this policy and the POSH Act, the POSH Act will prevail.

Declaration

We strictly uphold a zero-tolerance policy against sexual harassment. No individual, regardless of gender, will face such misconduct within our premises or in any work-related environment.

Objectives

• Prohibit sexual harassment at the workplace.
• Define scope and coverage.
• Raise awareness and sensitise employees.
• Establish IC (for women) and DC (for men & transgender employees).
• Ensure fair, speedy redressal while maintaining confidentiality.
• Encourage survivors to report without fear.
• Deter malicious or false complaints.
• Ensure full compliance with the POSH Act.

What Constitutes Sexual Harassment?

Examples of Misconduct

• Physical contact or advances.
• Demands or requests for sexual favors.
• Sexually colored remarks.
• Display of pornography.
• Sexual advances via email, WhatsApp, social media, or other digital platforms.

Circumstances that amount to harassment

• Explicit or implied promises of preferential treatment.
• Threats of negative treatment or termination.
• Hostile, intimidating, or offensive work environment.
• Conduct affecting health or safety.

Policy Awareness

Responsibilities of Employees

• Refrain from harassment.
• Report incidents promptly.
• Support co-workers to ensure a safe environment.
• Avoid false complaints.
• Seek clarification when unsure.

Responsibilities of the Employer

• Provide a safe workplace.
• Conduct awareness and training sessions.
• Form IC & DC.
• Provide facilities for inquiry.
• Take disciplinary action against offenders or malicious complainants.

Coverage

Applies to men, women, and transgender individuals.

• Complaints by women → IC
• Complaints by others → DC

Covers employees, contractual staff, consultants, and visitors. Extends to offsite events, travel, and gatherings.

Complaint Process

Filing a Complaint

Must be filed in writing within 3 months of the incident (extendable by 3 more months).

• Women → posh@pinkvisionmedia.com
• Men & Transgender persons → dc@pinkvisionmedia.com

Complaints can be filed by representatives if the aggrieved person cannot.

Procedure

• Conciliation – May be attempted if requested by the complainant.
• If conciliation fails, → Formal inquiry begins.

Interim Measures

• Administrative leave for the Respondent.
• Up to 3 months’ paid leave for the Complainant.
• Suspension of the Respondent during the inquiry.

Criminal Proceedings

If the act amounts to a crime under the IPC, the IC will assist in filing an FIR.

Inquiry Timeline

• Complaint shared with Respondent within 7 working days.
• Respondent to reply within 10 working days.
• Inquiry to be completed within 90 days.
• Report submitted within 10 days of completion.

Findings & Actions

• If harassment is proven → disciplinary action as per law.
• If the complaint is false/malicious → action against the complainant.
• Employer must act on recommendations within 60 days.

Rights of Parties

• Non-retaliation – No victimisation for filing/responding.
• Fair hearing – Both parties will be heard.
• Confidentiality – Identities and proceedings will remain strictly confidential.

Closing Note

Pink Vision Media is committed to building a workplace where dignity, safety, and respect are non-negotiable. This policy ensures compliance with the POSH Act and extends protection to all genders, making our workplace fair, secure, and inclusive.