SEAGULL POSH POLICY

( Prevention of Sexual Harassment )

1. Purpose :
The purpose of this policy is to create a safe and respectful workplace environment free from sexual harassment for all employees. This policy outlines the measures and procedures for the prevention, prohibition, and redressal of sexual harassment at the workplace.
2. Scope :
This policy applies to all employees, including permanent, temporary, trainees, and any other individuals engaged by the Seagull, regardless of their position or designation.
3. Definition of Sexual Harassment :
Sexual harassment includes any unwelcome sexually determined behaviour, whether directly or by implication, such as:
• Physical contact and advances
• Demand or request for sexual favours
• Sexually coloured remarks
• Showing pornography
• Any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature.
4. Policy Statement :
Seagull is committed to providing a work environment that ensures every employee is treated with dignity and respect and afforded equitable treatment. Seagull will not tolerate sexual harassment and will take appropriate action against any individual who violates this policy.
5. Internal Complaints Committee (ICC) :
Seagull has established an Internal Complaints Committee (ICC) to address complaints of sexual harassment. The ICC is consist of:
• Ms. Divyanka Parulekar – Senior Manager HR & Admin – Seagull International LLP
• Ms. Suja Baiju – Senior Manager – Operations – Seagull International LLP
• Mr. Prakash Kadam – Manager – Mobilization – Seagull International LLP
• Mr. Reji Philip – Founder & MD – Cosmos Agencies LLP
6. Complaint Mechanism
• Filing a Complaint: Any employee who experiences or witnesses sexual harassment should report it to the ICC in writing within three months of the incident.
• Inquiry Process: The ICC will conduct a prompt and thorough investigation, maintaining confidentiality to the extent possible.
• Decision and Action: Based on the findings, appropriate action will be taken, which may include disciplinary action against the perpetrator.
7. Disciplinary Action :
Disciplinary actions may include, but are not limited to:
• Written apology
• Warning
• Withholding of promotion
• Termination from service
• Legal action
8. Protection Against Retaliation:
Seagull prohibits any form of retaliation against employees who report sexual harassment or participate in the investigation process. Any act of retaliation will be subject to disciplinary action.
9. Awareness and Training :
Seagull will conduct regular training and awareness programs for all employees to sensitize them about the prevention of sexual harassment and the provisions of this policy.
10. Review and Monitoring :
The policy will be reviewed periodically by the ICC and management to ensure its effectiveness and compliance with legal requirements.
11. Conclusion :
The company is committed to creating a safe and respectful work environment. All employees are encouraged to uphold the principles of dignity, respect, and equality in the workplace.

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