Adarna Inc. is committed to a workplace free from harassment of any kind. This Policy explains what is not acceptable, how to raise a complaint, and how complaints are handled. It incorporates our obligations under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 — the "POSH Act".
1. Scope
This Policy applies to all employees, interns, apprentices, contractors, consultants and visitors, at our premises, at any location where work is carried out on our behalf, during work travel, at work-related events, and in work-related communication on any platform.
Protection under our Policy extends to every person at our workplace regardless of gender. Where the POSH Act applies specifically, its statutory mechanism is followed in addition.
2. What Harassment Means
Harassment is unwelcome conduct that has the purpose or effect of violating a person's dignity, or creating an intimidating, hostile, degrading or offensive environment. It includes, without limitation:
- Unwelcome physical contact, advances or demands.
- Sexually coloured remarks, jokes, messages or images.
- Showing pornography or sexually explicit material.
- Any unwelcome verbal, non-verbal or physical conduct of a sexual nature.
- Bullying, intimidation, humiliation or repeated belittling.
- Abuse or exclusion based on caste, religion, gender, sexual orientation, disability, language or place of origin.
- Implied or explicit promises of preferential treatment, or threats about a person's employment, connected to any of the above.
Whether conduct is unwelcome is assessed from the perspective of the person experiencing it, not the intention of the person doing it.
3. The Complaints Mechanism
United States federal and state law, including Title VII of the Civil Rights Act of 1964 and equivalent state statutes, prohibits sexual harassment in the workplace. A complaint of sexual harassment may be raised internally with the company as set out in this policy, and may also be filed with the U.S. Equal Employment Opportunity Commission (EEOC) or the relevant state fair-employment agency, and we will assist the complainant in approaching it.
We will constitute an Internal Committee, with a Presiding Officer who is a senior woman employee, at least two members and an external member from an organisation committed to the cause of women, as soon as the statutory threshold is met — and we will publish its composition here when we do.
For harassment that is not sexual harassment under the Act, a complaint may be made directly to the founders at contact@adarna.us.
4. How to Make a Complaint
A complaint should ordinarily be made in writing within three months of the incident, or of the last incident in a series. That period can be extended where there is good reason, and we will not use a technical time limit to avoid addressing something serious.
If you are unable to make the complaint yourself, it may be made on your behalf by a colleague, a relative, a friend, or any other person permitted under the Act. We will provide assistance in writing a complaint if that would help.
5. How Complaints Are Handled
- Confidentiality. The identity of the complainant, the respondent, witnesses and the content of the complaint are kept confidential, as the Act requires. Breaching that confidentiality is itself a disciplinary matter.
- Fairness. Both parties are heard. The respondent is told what is alleged and given a genuine opportunity to respond.
- Interim measures. Where appropriate, we may adjust reporting lines, working arrangements or leave while a complaint is being considered.
- Timeline. Inquiries are completed within ninety days, and action is taken within sixty days of receiving the findings, in line with the Act.
6. No Retaliation
Retaliation against anyone who makes a complaint in good faith, supports a complaint, or participates in an inquiry is a serious breach of this Policy and will be treated as misconduct in its own right. Raising a concern in good faith will never count against you, even if the complaint is not ultimately upheld.
A complaint deliberately made in bad faith, knowing it to be false, is a separate matter and may itself be treated as misconduct — but an unproven complaint is not a false one, and will not be treated as such.
7. Consequences
Substantiated harassment may result in a written warning, mandatory counselling or training, withholding of promotion or increment, transfer, or termination of employment or engagement, proportionate to the seriousness of the conduct. Where a criminal offence may have occurred, the complainant will be supported in approaching the police, and we will cooperate with any investigation.
8. Awareness and Training
We brief everyone on this Policy when they join, and we hold awareness sessions for all staff. Where the Act requires it, we file the prescribed annual report with the District Officer.
9. Questions
Questions about this Policy can be raised confidentially with the founders at contact@adarna.us.