Anti-Harassment and Non-Discrimination Policy
Everyone at TSS has the right to work without being harassed, bullied or treated unfairly. We have zero tolerance for harassment and discrimination. This policy explains what that means, how to report it, and what happens after you do.
Document
Policy number
TSS-HR-02
Version
1.0
Effective from
1 September 2026
Next review
March 2027
Owner
Human Resource Team
Approved by
Board of Directors
Applies to
Every employee, including trainees during induction, and every intern, including interns under 18, as well as contractors and Directors, and clients, vendors and visitors in their dealings with us.
Issued by
Thakur Systems & Structures Private Limited, CIN U62011PN2026PTC254650
Related policies
Code of Conduct and Ethics (TSS-HR-01), Employee Grievance Policy (TSS-HR-09), Whistleblower Policy (TSS-HR-06), Performance Management and Discipline Policy (TSS-HR-05)
1. WHERE THIS POLICY APPLIES
This policy applies wherever work happens: in the office, at client sites, while travelling for work, at work events, on video calls, and in email, chat groups and social media whenever colleagues or work are involved. Working from home does not change any of it.
2. NON-DISCRIMINATION
We make decisions about hiring, pay, training, work assignments, reviews, promotion, leave and termination on the basis of ability, performance and conduct, and nothing else. We do not treat anyone less favourably because of their:
gender, gender identity or expression, or sexual orientation;
caste, religion, race, colour, ethnicity, place of birth or origin, or language;
age, marital status, pregnancy or family responsibilities;
disability, health condition or HIV status;
or any other characteristic protected by law.
Indian laws that protect these rights include the Constitution of India, the Rights of Persons with Disabilities Act, 2016, the Transgender Persons (Protection of Rights) Act, 2019, the HIV and AIDS (Prevention and Control) Act, 2017, and the Code on Wages, 2019, which requires equal pay for the same or similar work regardless of gender.
Reasonable adjustments. If you have a disability or a health condition and need a change in how you work, such as different equipment, hours or work location, tell the HR team. We will work out reasonable adjustments with you and keep the details confidential.
3. WHAT COUNTS AS HARASSMENT
Harassment is unwanted behaviour that humiliates, intimidates, degrades or offends someone, or creates a hostile environment for them. It is judged by its effect on the person receiving it, not only by what the other person says they meant. Examples include:
insults, slurs, name-calling, or “jokes” about someone’s caste, religion, gender, region, appearance, disability or accent;
bullying, such as shouting, public humiliation, constant unfair criticism, deliberately leaving someone out, or setting someone up to fail;
threats or intimidation, in person or online;
sharing offensive images, memes, videos or messages, including in group chats;
spreading rumours about someone’s personal life;
repeatedly messaging someone after they have asked you to stop;
treating someone badly because they complained, or because they supported someone who did.
4. SEXUAL HARASSMENT
Sexual harassment at the workplace is covered by the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (the “POSH Act”). Under that Act, sexual harassment includes any one or more of the following unwelcome acts or behaviour, whether directly or by implication:
physical contact and advances;
a demand or request for sexual favours;
making sexually coloured remarks;
showing pornography;
any other unwelcome physical, verbal or non-verbal conduct of a sexual nature.
It also counts as sexual harassment when such behaviour comes with a promise of better treatment or a threat of worse treatment at work, interferes with someone’s work, or makes the workplace intimidating, offensive or hostile for them.
The POSH Act protects women. At TSS we apply the same standard, and take the same care, with complaints from anyone, whatever their gender.
If the person harassed is under 18, the Protection of Children from Sexual Offences Act, 2012 (the “POCSO Act”) also applies, whatever their gender. Sexual harassment or abuse of anyone under 18 is a crime under that Act.
5. HOW TO REPORT
You can report harassment or discrimination that happened to you, or that you saw happen to someone else. You do not need proof to report. You only need to tell us honestly what happened.
Who to tell. Your team lead, the HR team or a Director. If your complaint is about one of them, go to someone else on that list, or to the Chairman of the Board of Directors.
How. Put it in writing if you can: what happened, when and where, who was involved, and any witnesses. If writing it down is difficult, tell us in person and we will help you put it in writing.
Keep evidence. Save messages, emails and screenshots. Do not delete chats.
The police. You can go to the police at any time. Some forms of harassment, including sexual harassment, are offences under the Bharatiya Nyaya Sanhita, 2023.
If the person is under 18. Anyone who knows or suspects that someone under 18 has been sexually harassed or abused must report it to the police, meaning the Special Juvenile Police Unit or the local police station, as the POCSO Act requires, and must tell the HR team or a Director straight away. TSS will make sure the report is made. Our own process never replaces it. Child Helpline 1098 is also free and open 24 hours a day.
6. COMPLAINTS OF SEXUAL HARASSMENT UNDER THE POSH ACT
While fewer than ten people work at TSS. The POSH Act requires an employer to set up an Internal Committee once ten or more people work for it, counting employees, trainees, interns and contract staff. Until then, a woman who has faced sexual harassment at TSS can complain to the Local Committee that the District Officer for Pune has set up for smaller workplaces. Complaints against a Director go to the Local Committee in any case. The HR team will give you its contact details, help you file the complaint if you would like help, and cooperate fully with the Committee. You can also tell the HR team or a Director, and we will act to protect you straight away.
Once ten or more people work at TSS. We will set up an Internal Committee as the POSH Act requires, with a senior woman employee as presiding officer, at least two other employees, and one external member from an organisation committed to women’s causes or a person familiar with sexual harassment issues. At least half of its members will be women. Its members and their contact details will be displayed in the office and shared with everyone.
Time limit. A complaint should be made within three months of the incident, or of the last incident in a series. The Committee can extend this by up to another three months if there were good reasons for the delay.
Conciliation. Before an inquiry starts, the person complaining can ask for the matter to be settled through conciliation. A money settlement cannot be the basis of conciliation.
Interim relief. While the inquiry is going on, the Committee can recommend steps to protect the person complaining, such as a transfer or up to three months of leave, in addition to any other leave they are entitled to.
Inquiry. The Committee must complete its inquiry within 90 days.
Action. We will act on the Committee’s recommendations within 60 days of receiving them.
Appeal. Anyone unhappy with the Committee’s recommendations can appeal within 90 days, as the POSH Act provides.
7. WHAT HAPPENS AFTER YOU REPORT OTHER COMPLAINTS
For all complaints other than sexual harassment complaints handled by a Committee:
Acknowledgement. We will acknowledge your complaint within two working days.
Protection while we look into it. If needed, we will change working arrangements to protect you, for example by moving meetings, changing who you report to, letting you work remotely, or granting paid leave.
A fair inquiry. The HR team, or a Director if the HR team is involved, will look into the complaint promptly and fairly. Both sides will be heard and will have the chance to respond to what the other says. We aim to finish within 30 days.
Outcome. You and the person complained about will be told the outcome in writing. If the complaint is upheld, action can include a warning, training, a change of role or reporting line, or dismissal, under the Performance Management and Discipline Policy.
Appeal. If you are not satisfied, you can appeal as set out in the Employee Grievance Policy.
8. CONFIDENTIALITY
We keep complaints, the identities of the people involved and of witnesses, and the details of any inquiry confidential, and share them only with those who need to know in order to deal with the matter. For sexual harassment complaints, the POSH Act specifically prohibits publishing or making these details known.
9. NO RETALIATION
Nobody will be punished, sidelined or treated worse for raising a concern in good faith, for supporting a colleague who did, or for giving evidence. Retaliation is itself a serious breach of this policy and will be treated as gross misconduct.
10. FALSE COMPLAINTS
A complaint that cannot be proved is not a false complaint. We will only act against someone who knowingly makes a false complaint or gives false evidence, and only after an inquiry has shown this.
11. AWARENESS AND RESPONSIBILITIES
Awareness. We run sessions on this policy during induction and at least once a year, and we display the key points of the POSH Act in the office, as the Act requires.
Everyone. Treat others with respect, and speak up when something is wrong.
Team leads and Directors. Set the example. Act immediately on any concern raised with you, and never ignore or discourage a complaint.
The HR team. Handle complaints fairly, keep records, run awareness sessions, and support everyone involved.