I. Commitment
Sona Biscuits Limited is committed to ensuring that all persons engaged with the Company work in an inclusive, safe, fair, respectful, and conducive environment, where every person receives dignified, respectful, and equitable treatment.
The Company maintains a zero-tolerance approach towards sexual harassment. This policy educates employees about what constitutes harassment and preventive measures, and establishes a fair and confidential redressal mechanism.
II. Scope
Without prejudice to the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, the policy applies to all persons engaged with the Company, including:
- Full-time, part-time, probationers, trainees, apprentices, interns, and contract personnel
- Women visiting Company premises
- Service providers, vendors, consultants, customers, and business associates
Where harassment by third parties occurs during official duties, the Company will take necessary steps to support the affected person and prevent recurrence.
III. Definition and Interpretation
Act: The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the Rules framed thereunder, as amended.
Aggrieved Party: Any employee, trainee, intern, contract worker, visitor, or service provider alleging harassment.
Employee: A person employed at a workplace for any work, on a regular, temporary, ad hoc, or daily wage basis, directly or through an agent, whether remunerated or voluntary.
Respondent: Any employee, contract worker, visitor, or service provider against whom a complaint of harassment is made.
Sexual Harassment: Unwelcome acts or behaviour (directly or by implication), including 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.
Categories of Sexual Harassment
1. Physical harassment: physical contact and advances; intentional touching, pinching, grabbing, or brushing against another’s body; sexual assault; cornering, trapping, or blocking another’s pathway; any unwelcome physical conduct of a sexual nature.
2. Written or graphic harassment: showing or displaying pornographic or sexually explicit material; circulating written or electronic communications with sexual implications; leering or sexually suggestive gesturing; displaying sexually explicit visuals, posters, cartoons, graffiti, or digital content.
3. Verbal harassment: demanding or requesting sexual favours in exchange for employment benefits (“quid pro quo” harassment); sexually coloured remarks, slurs, or comments; sexually suggestive or offensive jokes or innuendoes; comments about a person’s body, attire, or appearance in a sexual manner; derogatory language, threats, or suggestive remarks.
Workplace includes:
- All offices, plants, factories, or premises where the Company conducts business or operations
- Company-related activities at other sites, including official travel, off-site meetings, Company events, training sessions, and customer or vendor locations
- Virtual or digital workspaces, including emails, calls, video conferences, or social media used for official communication
IV. Complaint Mechanism
An Internal Committee (IC) has been constituted to prevent, prohibit, and redress sexual harassment in accordance with the Act. The Committee ensures a fair, impartial, and time-bound investigation while maintaining strict confidentiality.
V. Internal Committee
The IC’s composition meets the requirements of the Act at all times. The Presiding Officer may nominate additional members of appropriate seniority to ensure equal gender representation or for other valid reasons supporting a fair inquiry. The IC is responsible for:
- Receiving and investigating formal complaints of sexual harassment
- Conducting fair and unbiased inquiries as per the procedure under the Act
- Recommending appropriate disciplinary or corrective measures
- Promoting awareness and preventive measures
The Head Office IC serves all administrative units, branch offices, factories, and establishments.
VI. Governance and Complaint Mechanism
A. Informal resolution
The aggrieved person may communicate disapproval directly to the harasser and request that the behaviour stop. If harassment continues or direct confrontation feels unsafe, the person may approach the IC for advice, assistance, or redressal.
B. Formal complaint
The aggrieved person may submit a written complaint to the IC, with supporting documents and names and addresses of witnesses, within three (3) months of the incident, or of the last incident in a series. The IC may extend this by a further three (3) months if circumstances prevented timely filing. Complaints may be submitted by email; complainants must disclose their name, department, division, and location. The aggrieved person retains the right to pursue legal remedies under applicable law.
C. Redressal process
On receipt of a complaint, the Presiding Officer determines whether the allegations fall within the definition of sexual harassment. If so, the respondent is required to submit a written explanation and a formal inquiry follows. If not, the determination is recorded with reasons and communicated to the complainant.
D. Enquiry
The IC promptly commences the inquiry and informs both parties. The respondent submits a written explanation within ten (10) days. The IC endeavours to complete the inquiry within three (3) months from the date of the complaint and submits a reasoned report to the Competent Authority within ten (10) days of its conclusion, with copies to both parties.
E. Recommendations and actions
If the allegation is not proven, the IC recommends that no action is required. If proven, the IC recommends appropriate action as per service rules, which may include:
- Formal apology
- Counselling
- Written warning, maintained in the employee file
- Change of work assignment or transfer
- Suspension or termination
- Withholding of promotion
VII. False Claims
Where it is established that a complaint was made with malicious intent or with false evidence, appropriate disciplinary action may be taken against the complainant or witnesses concerned. Care is taken to ensure that genuine complaints are never discouraged and that the process remains fair and unbiased.
VIII. Confidentiality
Every participant in the complaint process, including the aggrieved party, respondent, witnesses, and Committee members, must maintain strict confidentiality regarding the complaint, the identities of parties, and any conciliation, inquiry, or recommendation. The Company strictly prohibits retaliation or victimisation against anyone raising concerns or participating in a complaint.
IX. Access to Reports and Documents
All complaint-related records are maintained confidentially and disclosed only when necessary for disciplinary action or other remedial processes as per Company policies and applicable law.
X. Protection to Complainant / Victim
The Company ensures that employees raising concerns or lodging complaints, and witnesses participating in the process, are protected from reprisal, retaliation, victimisation, or discrimination.
XI. Reporting Mechanism
The Internal Committee meets at least once a year, maintains records of its proceedings, and prepares an Annual Report containing the number of complaints received and disposed of, the nature of action taken, and other details required by law. The IC also provides periodic updates to the Audit Committee and the Board.
XII. Reporting Channels
Email: hr@sobisco.com, cs@sobisco.com
Write to: Internal Committee, Presiding Officer, Sona Biscuits Limited, 15A Hemanta Basu Sarani, Continental Chambers, 5th Floor, Kolkata 700001, West Bengal
Contact: (+91) 33 4045 5555
XIII. Conclusion
The Company reaffirms its commitment to providing a safe and respectful workplace free from harassment and discrimination, and expects every employee to treat colleagues with dignity.