Zorvia Health Care Limited ["Zorvia" or "the Company"] is committed to ensuring that all persons engaged with Zorvia work in an environment that is inclusive and provides an opportunity to bring their best selves at the workplace. Zorvia is an equal opportunity employment company, without regard to race, caste, religion, color, marital status, sex or sexual orientation. The Company also believes that all employees of the Company have the right to be treated with dignity.

At Zorvia, all employees are expected to uphold the highest standards of ethical conduct at the workplace and in all their interactions with business stakeholders. This means that employees have a responsibility to:

• Treat each other with dignity and respect
• Follow the letter and spirit of law
• Refrain from any unwelcome behaviour that has sexual connotation (of sexual nature)
• Refrain from creating hostile atmosphere at workplace via sexual harassment
• Report sexual harassment experienced and/or witnessed to appropriate authorities and abide by the complaint handling procedure of Zorvia.
• Encourage all employees and stakeholder to report incidents of sexual harassment and misconduct.

• This policy has been framed in accordance with the provisions of "The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013" [hereinafter also called "the Act" or "POSH Act"] and rules framed thereunder [hereinafter also called "Rule(s)"]. While the policy covers all the key aspects of the Act, for any further clarification, reference shall always be made to the Act and the provisions of the Act shall prevail.
• This Policy is meant to educate the Employees about what constitutes a Sexual Harassment and has been formulated to prohibit, prevent or deter the commission of acts of Sexual Harassment at workplace, and in the event of such an occurrence, to enable a fair mechanism for dealing with such conduct.
• This policy extends to all employees including individuals coming to the workplace for employment or for any other purpose whatsoever including but not limited to visitors, vendors, contractual resources and applies to any alleged act of sexual harassment against persons at workplace, whether the incident has occurred during or beyond office hours.
• The policy is deemed to be incorporated in the service conditions of all employees.
• This policy does not prevent any aggrieved person from taking recourse to the law of the land.
• This Policy shall be reviewed from time to time or as and when there are any amendments to the Act or Rules. This Policy can be modified in future.

• Sexual harassment is a misconduct under the service rules and a grave offence.
• The Company will respond promptly to the complaints/reports of Sexual Harassment and will take immediate measures to ensure there is no violation of this Policy and in case if required, to facilitate legal action.
• Sexual harassment at the workplace is illegal and will result in disciplinary action including potential termination of employment, exclusion from or denial of access to the Company premise, termination of contract and other measures as per this Policy.
• The Company will not tolerate sexual harassment, by/to any supplier, customer, service providers, contractors and/or any other business associates. Any unwelcome behaviour of a sexual nature mentioned in the policy when such incident has taken place on the Company premises would also be dealt with under the provisions of this policy. The Company shall provide assistance to the woman if she so chooses to file a complaint in relation to the offence under the Indian Penal Code (IPC), 1860 [now the Bharatiya Nyaya Sanhita (BNS), 2023] or any other law for the time being in force.

• Sexual harassment: includes any one or more of the following unwelcome acts or behaviour (whether directly or by implication) namely:— (i) physical contact and advances; or (ii) a demand or request for sexual favours; or (iii) making sexually coloured remarks; or (iv) showing pornography; or (v) any other unwelcome physical, verbal or non-verbal conduct of sexual nature. Following behaviours are objectionable and will come under the preview of Sexual Harassment:

  • Sexually coloured remarks and verbal sexual innuendos, such as: jokes, suggestions, or hints about sexual behaviour, comments about physical appearance.
  • Physical contact such as pushing, grabbing, jostling, touching the body and / or making such advances.
  • Non-verbal communication such as staring, gestures of a sexual nature, removal of clothing to display parts of the body (flashing).
  • Display, giving or sending of pornography in the form of pictures, books, magazines, postcards, photos, sculpture, drawing, painting, animation, sound recording, film, video, and video games or offensive and / or abusive language. Demands and /or offers and / or requests, such as for sexual favours, sexual attention, or to spend time together.
  • Following, stalking, persistent visiting, telephoning, sending of inappropriate/sexual cell-phone messages or emails, chat messages, or other unnecessary invasions of personal privacy.
  • Act or conduct by a person such as spreading rumours about sexuality, gender and / or character of a person which creates the environment at workplace hostile or intimidating to a person.
  • Any other physical, verbal and non-verbal behaviour which is sexual in nature done personally and/ or via documents, or by telephone, cell-phone messages, web site communication, or emails.

  The following circumstance, among other circumstances, if it occurs, or is present in relation to or connected with any act or behaviour of sexual harassment of a woman may amount to sexual harassment:

  • implied or explicit promise of preferential treatment in her employment; or
  • implied or explicit threat of detrimental treatment in her employment; or
  • implied or explicit threat about her present or future employment status; or
  • interference with her work or creating an intimidating or offensive or hostile work environment for her; or
  • humiliating treatment likely to affect her health or safety.

  A conduct may constitute sexual harassment if it is unwelcome to the recipient, regardless of whether it was unintentional, intended as playful, or lacks evidence of specific intent. A single occurrence is sufficient to qualify as harassment. Furthermore, sexual harassment can occur regardless of professional hierarchy, including instances where a subordinate harasses a superior.

• Aggrieved woman: In relation to a workplace, a woman, of any age, whether employed or not, who alleges to have been subjected to any act of sexual harassment by the respondent that includes contractual, temporary, visitors.
• Respondent: A person against whom a complaint of sexual harassment has been made by the aggrieved woman.
• Employee: A person employed at the workplace, for any work on regular, temporary, ad-hoc or daily wage basis, either directly or through an agent, including a contractor, with or without the knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise, whether the terms of employment are express or implied and includes a coworker, a contract worker, probationer, trainee, apprentice or by any other such name.
• Complaint: means information, either oral or written, made by the Aggrieved Woman / Complainant. However, complaint made orally must be produced in writing with the assistance of the Internal Committee members.
• Workplace: Premises, locations, establishments, enterprises, institutions, offices, branches or units established, owned, controlled by Zorvia. Places visited by the Employee arising out of or during the course of employment including transportation provided by the employer for undertaking such journey.

• Each complaint of Sexual Harassment shall be dealt with utmost confidentiality and urgency by an Internal Committee (hereinafter also called as "IC") constituted by the Company.
• IC should consist of at least 4 (four) members and will have representation of men and women with at least one-half of the total members as women.
• A senior level woman employee shall be appointed as the presiding officer of the IC ("Presiding Officer").
• Minimum two members of the IC will be appointed from amongst employees who are preferably committed to the cause of women or who have had experience in social work or have legal knowledge.
• One member of the IC must be from amongst non-governmental organizations or associations committed to the cause of women or a person familiar with the issues relating to Sexual Harassment.
• The Presiding Officer and every member of the IC shall hold office for a period of three years. However, there is no restriction on reappointment of the Presiding Officer or Member or on the reconstitution of IC.
• The Presiding Officer / a member shall automatically vacate her/his office upon ceasing to be employee of Zorvia.
• A member of the IC may resign at any time by tendering his / her resignation in writing to the Company.
• Names of the members of the IC, along with their contact details are provided in the order constituting the IC which has been duly displayed at conspicuous place in at the Workplace.

Where the IC arrives at the conclusion that the allegation against the respondent has been proved, it shall recommend to the employer to take suitable action which may include but shall not be limited to any of the followings:

• Asking the respondent to give a written apology
• Issuing warning, reprimand or censure to the respondent
• Withholding of promotion of the respondent
• Withholding of pay rise or increments of the respondent
• Terminating the respondent from service of the Company
• Denying to the respondent an access to the Workplace
• Suspension/cancellation of Contract, work orders, assignments etc.
• Asking the respondent to undergo a counselling session or carrying out community service.

• Where the IC arrives at the conclusion that the allegation against the respondent is malicious or the aggrieved woman or any other person making the complaint has made the complaint knowing it to be false or; the aggrieved woman or any other person making the complaint has produced any forged or misleading document or; during the inquiry any witness has given false evidence or produced any forged or misleading document, IC may recommend to the employer to take action against the such aggrieved woman or such person who has made the complaint under sub-section (1) or sub-section (2) of section 9 or the witness who has given false evidence or produced any forged or misleading document, as the case may be, in accordance with the provisions of Rule 9 of the Rules 2013.
• Provided that mere inability to substantiate a complaint or provide adequate proof need not attract action against the complainant. Provided further that the malicious intent on part of the complainant shall be established by the Internal Committee after due inquiry alone, before any action is recommended.

In the event that any person is aggrieved from the recommendations made by the IC or non-implementation of such recommendations, he/she may appeal to the appropriate authority, as specified by the law, within a period of 90 (ninety) days of the recommendations.

• The contents of the complaint, the identity and the addresses of the aggrieved woman, respondent and witnesses, any information relating to conciliation and inquiry proceedings, recommendations of the Internal Committee and the action taken by the employer shall not be published, communicated or made known to the public, press and media in any manner.
• If any person contravenes the provisions of confidentiality, the employer shall recover a sum of Rs. 5000/- (Rupees Five Thousand) as penalty from such person.
• Provided that the information may be disseminated regarding the justice secured to any victim of sexual harassment without disclosing the name, address, identity or any other particulars calculated to lead to the identification of the aggrieved woman and witnesses.