1 Anti-harassment

To ensure a work environment free of harassment

Objective based on gender, race, religion, national origin, age,
sexual orientation or other protected classifications

Release Date November 15, 2006

Reference No CTEL/HR/xx/06

Effective
D
a November 15, 2006
t
e

Approved By VP – Global Delivery Centre

Classification Internal

2 Policy
3 1. CTEL is committed to providing and maintaining a work environment that is
free of harassment based on gender, race, religion, national origin, age,
sexual orientation or other protected classifications. Harassment may take
different forms, and may involve, but is not limited to, visual displays,
suggestive remarks, jokes, gestures, sexual demand, emails, propositions, or
unwanted physical contact.

4 2. Each individual has the right to work in a professional atmosphere that

promotes equal employment opportunities and prohibits discriminatory
practices, including harassment. Therefore CTEL expects that all relationships
among persons in the workplace will be free of bias, prejudice and
harassment. Whatever form the harassment takes, the Company will not
permit any employee to harass others with whom he/she has business
interactions including but not limited to other employees, visitors and
vendors, or permit any outsider to harass its employees. This is true, not only
in the workplace, but during business trips and business-related social events.
All employees, supervisors and managers must comply with this policy and
take appropriate measures to ensure that such conduct does not occur.

5 3. An employee who believes that he/she has experienced or observed

harassment (sexual or any other discriminatory harassment) should
confidentially report the incident immediately (within 48 hours of the incident)
to his or her Manager, any member of the Sr, Management, Head – HR.
 Although reports could be made verbally, employees are strongly encouraged
to make any such reports in writing, since it will assist in the investigation
process. Under no circumstances need an employee report the harassment to
a person whom he or she is accusing of inappropriate behavior. It is expressly
against CTEL’s policy to retaliate against an employee for filing a complaint or
for cooperating in an investigation of complaint of harassment.

6 4. CTEL promises to promptly and thoroughly investigate all reports of

harassment as discreetly and confidentially as possible. However,
investigation of such complaint will generally require disclosure to the accused
individual. The goal is to conduct a thorough investigation, to determine
whether harassment has occurred and to eliminate any hostile or offensive
working condition and decide actions to take against the offending
individual(s).

7 5. If CTEL determines that a violation of this policy has occurred, it will take
appropriate disciplinary action, which can include counseling, warning,
suspension, or any action up to and including termination of employment.
Compliance to this policy is a condition of each employee’s employment.

Guidelines

1 1. Definition
Harassment includes any behavior based on gender, race, religion, national
origin, age, sexual orientation or other protected classifications, directed towards
a specific person(s), and which affects working environment adversely.
Harassment may take place at work, work related event or activity or outside
work and may occur during or after office hours

2. Examples
This list is illustrative and not exhaustive.
a. Any form of pressure for sexual activity or
b. Unwanted sexual advances or
c. Use of sexual innuendoes
d. Physical aggression, assault
e. Unwelcome touching, hugging, patting or pinching
f. Continuous taunting
g. Intentional disturbance by making noise
h. Verbal sexual abuse disguised as humor
i. Display of sexually explicit pictures, pornography, cartoons, graffiti,
drawings
j. Repeated references to various parts of the body at inappropriate times
 k. Request for dates when the other person has made it clear that she or he
is not interested
l. Constant sexual joking
m. Sexist language
n. Unwelcome whistling or any other suggestive gestures or remarks
o. Making of express or implied promises, rewards or benefits for complying
with sexual favors or making threats, reprisals or denial of opportunity for
refusal to so comply.

2 3. Responsibilities
All the employees of the Company will have the responsibility of implementing
this policy along with the Functional Heads (FH), the Senior Management team
(SM), and the members of the Grievance Committee (GC).
1. Responsibilities of Employees
0 a) To report the instances of harassment to the FH / SM / GC
1 b) To cooperate in the cases of investigation.
2 c) To abide by the directions given by the FH /SM /GC
3 d) Not to use this policy to make frivolous or malicious charges against
fellow employees
3 2. Responsibilities of the FH/GC
0 a) To create awareness of this policy in their divisions and projects.
1 b) To encourage the employees in their divisions and projects to report
the instances of harassment, if any.
2 c) To refer to the Grievances Committee the cases of harassment.
3 d) To take the necessary disciplinary action against the erring employees.
4 3. Responsibilities of the Grievance Committee
0 a) To set up the procedure for redressal of the complaints reported.
1 b) To conduct independent investigation of the cases of the harassment
reported.
2 c) To bring formal or informal resolution of the complaints reported.
3 d) To take the necessary disciplinary action against the employees.

5 4. Constitution of the Grievance Committee

The GC will comprise of four members as nominated by the Chief Executive
Officer of the Company. The GC must include atleast 2 women employees as
members. The VP, GDC will act as an advisor to the GC.
The initial composition of the GC is as follows:

Chairperson Head Of HR
Rishikesh Shinde(Senior Executive –
Member
Recruitment)
Member Sudip Kar, Program Manager
Advisor VP, GDC
 1 1. When lodging a complaint an employee must be prepared to provide the
Grievance Officer with precise and detailed information on the nature of
behavior in question and furnish evidence or witness, if any.
2 2. The employee complaining of harassment shall be entitled to have an
employee of his/her choice accompany him/her at the time of making the
complaint and at all subsequent meetings/proceedings.
3 3. CTEL shall provide all support to an employee who reports harassment at
work from outsiders or persons not employees of CTEL.
4 4. In case of a verbal complaint the Grievance Officer will investigate the
matter and if in his/her opinion the matter is not serious enough to require a
formal resolution he/she may attempt to bring an informal resolution.
5 5. If the grievance cannot be resolved informally, the grievant will submit the
complaint in writing to the Grievance Officer. The Grievance Officer may assist
the complainant in this process. Formal complaints must set out specific facts
of the case and be signed by the complainant. A signed complaint constitutes
personal verification that the complaint is accurate and complete.

5. Confidentiality
Cases that involve allegations of sexual harassment are especially sensitive, and
special attention will be given to the issue of privacy for all individuals.
Information will be released only on need-to-know basis. Investigation at times
may compromise total confidentiality.

6. Retaliation
This policy strictly prohibits any kind of intimidation or harassment of individuals
who have filed complaints, instituted proceedings, assisted in investigations, or
formally or informally objected to discriminatory practices, irrespective of the
final outcome. CTEL will take strict action against those employees who would
indulge in such retaliatory actions.

7. Frivolous or False Charges

This policy shall not be misused to bring frivolous or malicious charges against
fellow employees. Strict disciplinary action shall be taken against any person
bringing a charge of harassment in bad faith.

Procedure

1 1. Employee who suffers harassment will report to the instance of harassment

to his/her FH Head/Reporting Manager or to the Grievance Officer (GO). The
employee may file a verbal complaint or written complaint. The employees
are advised to file a written complaint rather than a verbal complaint.
2 2. The FH or the Reporting Manager will report the case to the GC. The GC
may bring about an informal resolution or formal resolution depending on
whether the complaint is reported verbally or in writing.
3 3. Informal Resolution Informal resolution of complaints is aimed at
stopping the discriminatory action(s) in a mutually agreed manner. It is more
educational than legal in intent, for both the complainant and the alleged
harasser. Very often the persons complained against may agree to actions
such as apologies, reprimands or voluntary resignations, without going
 through the formal disciplinary procedures.
4 4. Formal Resolution The concerned Grievance Officer discusses the case
with the Chairperson, GC. On the advice of the Chairperson, copies of the
written complaint will be handed over to the concerned FH for information and
to the respondents mentioned in the complaint. Such written complaints
should be submitted as early as possible but NOT later than a week from the
date of the harassment incidence.
5 5. The respondent shall have a right to submit a written response to the
complaint, to the Grievance Officer within a week from having received it.
He / she shall also have a right to be heard personally by the Grievance
Officer.
6 6. The Grievance Officer shall study the complaint and the response and
recommend a course of action towards establishing facts of the case, to the
Chairperson. On approval from the Chairperson, the Grievance Officer shall
constitute an investigation committee that will not have more than three
members with at least half/two members being women. Investigation
committee will submit written record of the entire proceedings with a report
on recommended action to the Chairperson. The Chairperson will review the
report, discuss the findings with the investigation committee and if in order,
forward the same to the FH with a copy to the Head - Human Resources for
further action.
7 7. Final decision of the case shall be communicated to the Complainant,
within 60 days of the receipt of formal complaint.
8 8. Appeal
9 When as a result of the disciplinary action an employee feels injustice has
been done to him/her, such employee may resort to making an appeal to the
Chair person of the Company for review. On the merit of the contents of the
appeal the Chair person will take a decision and communicate the same to the
employee concerned within 15 days of receipt of the appeal.
10 9. Settlement in the Court of Law
11 When either or one of the parties involved is not satisfied with the decision
they can take the matter to the court at their own risk and cost. Absence of
employees during such proceedings will be treated as leave.
12 10. Disciplinary Action
13 Based on the conclusions of the investigation the GC will suggest appropriate
disciplinary action to the FH, which can include counseling, warning,
suspension, or any action up to and including termination of employment. The
FH will implement the action with the support of the Head - Human
Resources.

CTEL shall in appropriate cases, where conduct amounts to a specific offence under
the Indian Penal Code or other relevant law/statute, initiate requisite and appropriate
action in accordance with the law by making a complaint with the appropriate
authority.

Grievance Procedure