ANTI-HARASSMENT POLICY AND PROCEDURES

POLICY STATEMENT

West Bengal Highway Development Corporation strives towards maintaining a harassment-free workplace that endorses appropriate conduct among all employees and employees appointed through a third party. In keeping with that, the Company seeks to enforce certain Non-Discrimination and Anti-HarassmentPolicy and Complaint Procedures in order to facilitate an environment free from discrimination, harassment and sexual assault.

Discrimination or harassment pertaining to race, gender, color, creed, religion, age, national origin, ethnicity, disability, sex, sexual orientation, marital status, citizenship status, or on any other legally prohibited factor is illicit and would lead to defamation of the Company.

Such discrimination or harassment violates the norms laid out by the Company and any person expressing immoral conduct of such kind is liable to be penalized.

This policy applies to any individual entangled with the Company's affairs, regardless of whether the alleged transgressor is an employee or not.

Objectives of WBHDCL

WBHDCL aims to :

provide a safe working environment and protection of women against sexual harassment at workplace.

Prevention of harassment at the premises of the Company.

Redressal of complaints of sexual harassment.

APPLICABILITY

This anti-harassment policy extends to all employees including employees employed on a contractual basis and the employees appointed through a third party contractor such as a contract worker, probationer, trainee, apprentice or called by any other such name, and our Company endeavors to provide its women employees with an ethical working environment free from sexual harassment.

This anti-harassment policy is also applicable to the persons who may not be an employee of the Company but visits the Company for official purpose such as customers, visitors etc., subject to harassment or sexual harassment at the workplace (defined hereinafter) of the Company.

SCOPE

This policy is restricted to the following areas for all employees appointed by the Company or through a third party:

Any business locations of the Company.

Any external place visited by the employee arising out of or during the course of employment such as any place of business etc

Any mode of transport provided by the Company for commencing any journey for business purpose.

DEFINITIONS

Harassment : Offending or humiliating someone physically or verbally or non verbally, disturbing, pestering, or troubling repeatedly, threatening or intimidating someone or indulging in unwelcome raillery or insolent remarks on someone's race, gender, color, creed, religion, age, national origin, ethnicity, disability or sexual orientation.

Sexual Harassment : Offensive or humiliating behaviour that is related to a person’s sex; behaviour of a sexual nature that creates an unwelcome, hostile or offensive work environment; or behaviour of a sexual nature that could outrage the modesty of an individual.

Aggrieved woman : a woman of any age whether employed or not, who alleges to have been subjected to any act of sexual harassment by the respondent.

Respondent : A respondent is a person against whom a Complainant has made a complaint.

Complainant : A Complainant is an aggrieved individual of the Company who makes a compliant alleging Sexual Harrassment.

Workplace :

any department, organization, undertaking, establishment, enterprise, institution, office, branch or unit of the Company, which is established, owned, controlled or wholly/substantially financed by funds provided by WBHDCL.

any place visited by the employee arising out of or during the course of employment in any mode of transport provided by the employer for undertaking such journey.

any official event attended by the employee.

any site office/office/site of the contractor or any consultancy agency or business of similar nature, executing the contract of WBHDCL.

Employee : An employee means a person employed with the Company at a workplace for any work on regular, temporary, adhoc or daily basis, either directly or through an agent/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 contract worker, probationer, trainee, apprentice or called by any other such name.

POLICY IMPLEMENTATION AND REVIEW

The policy will be implemented after the approval of the Board of Directors of WBHDCL and may be reviewed by the Board of Directors of the Company on timely basis. The Company reserves the right to amend, abrogate, modify, recind/reinstate the entire policy or a part of it at any time.

This policy came into force w.e.f 15th January, 2016 when the Board has adopted in its meeting.

RESPONSIBILITY OF THE EMPLOYEES OF THE COMPANY

An employee of our Company should :

Know the anti harassment policy of WBHDCL properly.
Beware of inappropriate and offensive behavior and avoid the same.
Refuse to visit places, do things that makes you uncomfortable.
Abstain from taking biased decision which may contradict the spirit of the policy.
Maintain confidentiality regarding any aspect of an inquiry to which an associate may be a party to.

An employee of our Company should not :

Sexually suggest comments or comment on physical attributes.
Singing or humming vulgar songs.
Offensive language that insults or demeans a colleague.
Request for sexual favours, coerced acts of a sexual nature.
Request for dates or repeated pressure for social contacts.
Graffiti in office premises.
Use offensive gestures, starring, whistling with the intention to discomfort an employee.
Display sexually explicit posters, pictures, offensive books, magazines, calendars, or any derogatory written materials at ones workplace.
Electronically communicate with an employee that will violate this Policy, such as phone calls, emails, text messaging and internet use.
Physically contact or intentionally touch another employee in order to discomfort a person.
Display any unnecessary affection that would discomfort an employee.

COMPLAINT REPORTING AND RESOLUTION

Any person associated with WBHDCL who believes she has been subjected to harassment, may submit a written complaint to the persons designated by the management of the Company.

The written complaint should specify the parties involved, describe the nature of harassment including the time and place of occurrence of the same and identify by name or description any witnesses. Each and every written complaint should be confidentially treated and provided directly and only to the appropriate designated individuals.

Any employee making a false complaint or allegation shall be strictly penalized by the management of the Company.

Each and every complaint will be dealt with:

Confidentiality: Any allegation brought to the attention of the Company will be privately investigated. However, the Company may disclose certain information to the accused and to other witnesses for the purpose of gathering required information. In such a circumstance, the Company will limit the disclosure to the maximum extent possible.

Cooperation: WBHDCL believes that the associates of the Company would fully cooperate in the whole process of investigation. Any employee of the company refusing to cooperate in the investigation process is subject to disciplinary action.

PENALTY

WBHDCL reserves the right to terminate the employment of any employee engaging in improper harassing behavior.