Capital Trade Links Limited (‘the Company’ or ‘CTL) is committed to providing a work environment free from harassment of any kind and in particular, a work environment that does not tolerate sexual harassment.

Any form of sexual harassment is not tolerated by CTL and the Company is committed to take all necessary steps to ensure that its employees are not subjected to any form of harassment. We respect dignity of everyone involved in our work place, whether they are employees, suppliers or our customers.

This policy applies to all categories of employees of the Company, including permanent management and workmen, temporaries, trainees and employees on contract at their workplace or at client sites. The Company will not tolerate sexual harassment, if engaged in by clients or any other business associates.

The workplace includes:.

I. All offices or other premises where the Company’s business is conducted.

II. All company-related activities performed at any other site away from the Company’s premises.

III. Any social, business or other functions where the conduct or comments may have an adverse impact on the workplace or workplace relations.

Sexual harassment may be one or a series of incidents involving unsolicited and unwelcome sexual advances, requests for sexual favours, or any other verbal or physical conduct of sexual nature. Sexual Harassment at the workplace includes:

• Unwelcome sexual advances (verbal, written or physical);
• Demand or request for sexual favours;
• Any other type of sexually-oriented conduct;
• Verbal abuse or ‘joking’ that is sex-oriented;

Any conduct that has the purpose or the effect of interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment and/ or submission to such conduct is either an explicit or implicit term or condition of employment and/ or submission or rejection of the conduct is used as a basis for making employment decisions.

All employees of the Company have a personal responsibility to ensure that their behavior is not contrary to this policy. All employees are encouraged to reinforce the maintenance of a work environment free from sexual harassment. We require all employees to make sure that they maintain mutual respect and positive regard towards one another.

An appropriate complaint mechanism in the form of “Complaints Committee” has been created in the Company for time-bound redressal of the complaint made by the victim.

Every complaint received shall be forwarded to Internal Complaints Committee formed under the policy for redressal for investigation. Internal Complaints Committee has been constituted of the following members as nominated by the Company:

a) A woman employee employed at a senior level amongst the employees shall act as Presiding officer of the committee.

b) Not less than 2 members from amongst employees preferably committed to the cause of women OR who have had experience in social work OR have legal knowledge.

c) One member shall be from amongst Non-governmental organizations OR associations committed to the cause of women OR a person familiar with the issues relating to sexual harassment.

Atleast half the total members of the Committee have to be women. The Presiding Officer and every member shall hold office for such period, not exceeding three years, from the date of their nomination as may be specified by the employer.

The Company is committed to providing a supportive environment to resolve concerns of sexual harassment as under:

INFORMAL RESOLUTION OPTIONS:

When an incident of sexual harassment occurs, the victim of such conduct can communicate their disapproval and objections immediately to the harasser and request the harasser to behave decently. If the harassment does not stop or if victim is not comfortable with addressing the harasser directly, the victim can bring their concern to the attention of the Complaints Committee
for redressal of their grievances. The Complaints Committee will thereafter provide advice or extend support as requested and will undertake prompt investigation to resolve the matter.

COMPLAINTS

1. An employee with a harassment concern, who is not comfortable with the informal resolution options or has exhausted such options, may make a formal complaint to the Presiding Officer of the Complaints Committee constituted by the Management. The complaint shall have to be in writing and can be in form of a letter, preferably within 15 days from the date of occurrence of the alleged incident, sent in a sealed envelope. Alternately, the employee can send complaint through an email. The employee is required to disclose their name, department and division, to enable the Presiding Officer to contact them and take the matter
forward.
2. The Presiding Officer of the Complaints Committee will proceed to determine whether the allegations (assuming them to be true only for the purpose of this determination) made in the complaint fall under the purview of Sexual Harassment, preferably within 30 days from receipt of the complaint.
3. In the event, the allegation does not fall under the purview of Sexual Harassment or the allegation does not constitute an offence of Sexual Harassment, the Presiding Officer will record this finding with reasons and communicate the same to the complainant.
4. If the Presiding Officer of the Complaints Committee determines that the allegations constitute an act of sexual harassment, he/ she will proceed to investigate the allegation with the assistance of the Complaints Committee.
5. Where such conduct, on the part of the accused, amounts to a specific offence under the law, the Company shall initiate appropriate action in accordance with law by making a complaint with the appropriate authority. 

6. The Complaints Committee shall conduct such investigations in a timely manner and shall submit a written report containing the findings and recommendations to the Managing Director as soon as practically possible and in any case, not later than 90 days from the date of receipt of the complaint. The Managing Director will ensure corrective action on the recommendations of the Complaints Committee and keep the complainant informed of the same.
Corrective action may include any of the following:
a. Formal apology;
b. Counseling;
c. Written warning to the perpetrator and a copy of it maintained in the employee’s file;
d. Change of work assignment/transfer for either the perpetrator or the victim;
e. Suspension or termination of services of the employee found guilty of the offence;
f. In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for
appropriate disciplinary action by the Management.

The Company understands that it is difficult for the victim to come forward with a complaint of sexual harassment and recognizes the victim’s interest in keeping the matter confidential.

To protect the interests of the victim, the accused person and others who may report incidents of sexual harassment, confidentiality will be maintained throughout the investigatory process to the extent practicable and appropriate under the circumstances.

All records of complaints, including contents of meetings, results of investigations and other relevant material will be kept confidential by the Company except where disclosure is required under disciplinary or other remedial processes.

The Company is committed to ensuring that no employee who brings forward a harassment concern is subject to any form of reprisal. Any reprisal will be subject to disciplinary action. The Company will ensure that the victim or witnesses are not victimized or discriminated against while dealing with complaints of sexual harassment.

However, anyone who abuses the procedure (for example, by maliciously putting an allegation knowing it to be untrue) will be subject to disciplinary action.

In conclusion, the Company reiterates its commitment to providing its employees, a workplace free from harassment/ discrimination and where every employee is treated with dignity and respect.