Prevention of Sexual Harassment (POSH) Policy

1 Purpose & Legal Basis

FOGS Consultants is committed to providing a safe, respectful and dignified workplace for every employee, contractor, intern, candidate and visitor. This Policy is framed in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("POSH Act") and the rules made thereunder, and applies regardless of gender.

2 Scope & Applicability

This Policy applies to all employees, contractors, consultants, interns, trainees, candidates and third-party personnel engaging with FOGS Consultants, whether at our offices, client sites, remote work locations, work-related travel, or at work-related social events. It covers conduct by colleagues, managers, clients, vendors and any other person encountered in the course of work.

3 Definition of Sexual Harassment

Sexual harassment includes any one or more unwelcome acts or behaviour, whether directly or by implication, such as physical contact and advances, a demand or request for sexual favours, sexually coloured remarks, showing pornography, or any other unwelcome physical, verbal or non-verbal conduct of a sexual nature.

4 Internal Committee (IC)

FOGS Consultants has constituted an Internal Committee (IC) as mandated under the POSH Act, comprising a Presiding Officer, employee members, and an external member with relevant expertise. The IC is responsible for receiving, inquiring into, and recommending action on complaints of sexual harassment.

• Composition and contact details of the IC are circulated internally and available from HR on request
• The IC operates independently of the reporting employee's management chain to ensure impartiality

5 Reporting a Complaint

A complaint may be raised in writing (including by email) to the Internal Committee or HR within three months of the incident (extendable by the IC in appropriate circumstances). If the aggrieved person is unable to make a complaint in writing, the IC will render reasonable assistance.

• Complaints can be submitted via the designated HR email, in a sealed letter, or in person to any IC member
• A friend, relative, co-worker, or counsellor may assist in filing the complaint where the aggrieved person is unable to do so themselves

6 Inquiry Process & Timelines

On receipt of a complaint, the IC will complete the inquiry within 90 days. Both parties will be given an opportunity to be heard, and either party may request conciliation before the inquiry begins (no monetary settlement will be made as basis for conciliation). The IC will submit its findings and recommendations to management within 10 days of completing the inquiry, and appropriate action will be taken within 60 days thereafter.

7 Confidentiality & Protection Against Retaliation

The identity of the complainant, respondent, and witnesses, along with details of the complaint, inquiry proceedings, and recommendations, will be kept strictly confidential, except as required to conduct the inquiry or by law. Retaliation, victimisation, or adverse treatment of anyone who reports harassment in good faith, or who participates in an inquiry, is strictly prohibited and will itself be treated as misconduct.

8 False or Malicious Complaints

Where the IC concludes that a complaint was made knowingly false or with malicious intent, or that false or misleading evidence was produced, appropriate action may be taken against the person who made the complaint or produced the evidence, in accordance with the POSH Act. A complaint that is not proven is not, by itself, treated as false or malicious.

9 Awareness & Training

FOGS Consultants conducts periodic orientation and awareness sessions for employees and IC members, and displays this Policy along with IC contact details at the workplace and on internal communication channels, as required under the POSH Act.

10 Contact & Escalation

Complaints or queries relating to this Policy may be directed to the Internal Committee or HR. Where a complaint concerns a member of the IC, the aggrieved person may approach any other IC member or escalate directly to HR leadership.