Prevention of Sexual Harassment (POSH) Policy

1. Purpose and Commitment

Cognizance IP (LLP) ("the Firm") is committed to providing a safe, respectful and dignified working environment for every employee, partner, consultant, intern, vendor and visitor, irrespective of gender. The Firm has zero tolerance for sexual harassment of any kind and is committed to preventing, prohibiting and redressing sexual harassment at the workplace in accordance with the POSH Act, 2013 and the rules framed thereunder.

2. Applicability

This Policy applies to all employees, including permanent, temporary, probationary and contractual staff, as well as partners, interns, trainees, consultants, freelancers and third-party contractors, at all locations where the Firm operates, including client sites, off-site meetings, work-related travel and virtual/remote work environments. It extends to conduct occurring through digital communication channels used for work purposes.

3. Definition of Sexual Harassment

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

Circumstances such as implied or explicit promises of preferential treatment, threats of detrimental treatment, interference with work, or humiliating treatment likely to affect health or safety may also amount to sexual harassment.

4. Internal Committee (IC)

The Firm has constituted an Internal Committee to receive and inquire into complaints, comprising a Presiding Officer (a woman employed at a senior level), at least two employee members committed to the cause of women or with experience in social work or legal knowledge, and one external member from an NGO or association familiar with issues relating to sexual harassment. At least half the members shall be women. Where a location has fewer than ten employees, or where the complaint is against the employer, the complainant may approach the Local Committee constituted by the District Officer.

5. Complaint Procedure

5.1 Filing a Complaint

A written complaint may be made to the IC within three months of the incident, or of the last incident in a series. The IC may extend this period by a further three months for recorded reasons. Complaints may be submitted to any IC member, or routed via info@cognizanceip.com, marked strictly confidential and addressed to the Internal Committee.

5.2 Conciliation

Before initiating an inquiry, and only at the request of the aggrieved employee, the IC may attempt conciliation, provided no monetary settlement forms the basis of such conciliation.

5.3 Inquiry

Where conciliation is not requested or fails, the IC shall inquire into the complaint, ordinarily completing it within ninety days. Both parties are given a reasonable opportunity to be heard. Interim measures may be recommended during the inquiry.

5.4 Report and Recommendations

The IC shall submit its report within ten days of completing the inquiry. If allegations are proved, it may recommend action including written apology, warning, reprimand, withholding of promotion or increment, termination, or compensation. The employer shall act on the recommendations within sixty days.

5.5 False or Malicious Complaints

Where the IC concludes a complaint was false or malicious, it may recommend appropriate action. A mere inability to substantiate a complaint shall not attract action.

6. Confidentiality

The identity of the complainant, respondent, witnesses and details of proceedings shall not be published or made known to the public, press or media. Breach of confidentiality may attract disciplinary action.

7. Protection Against Retaliation

Retaliation against any individual who, in good faith, reports an incident, participates in an inquiry or supports a complainant is strictly prohibited and treated as serious misconduct.

8. Duties of the Employer

The Firm shall provide a safe working environment, display the composition of the IC, organise regular awareness programmes, provide facilities to the IC, assist in securing attendance of respondents and witnesses, treat sexual harassment as misconduct, and file annual reports as required.

9. Training and Awareness

The Firm conducts periodic sensitisation programmes and training sessions for all employees, including new joiners as part of onboarding.

10. Policy Review

This Policy is reviewed periodically and updated as necessary. Any amendments are communicated to all employees.

Contact the Internal Committee

info@cognizanceip.com · +91-6283268638 · L445, Steel Strips Tower, Derabassi, Mohali (Punjab), India – 140507