Payana Policy

We Payana Policy to Prevent and Deal with

Sexual Harassment and Gender

Discrimination

Preamble

Payana is committed to creating an atmosphere in which the staff can work together in an atmosphere free

from sexual harassment.

Article 21 is part of Chapter III of the Indian Constitution and grants the right to life and personal liberty to

everyone. However, the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal)

Act, 2013, (hereinafter referred to as the 2013 Act) grants protection against sexual harassment at the

workplace only to women. Section 2(a) defines the aggrieved “woman,” making it clear that only a woman can

file a complaint of sexual harassment at the workplace. To ensure inclusivity, our policy is inspired by the

legislation brought about by the Indian government through the 2013 Act.

While the title of the Act specifically mentions "women," the definition of sexual harassment under the law is

gender-neutral. It covers any unwelcome sexually determined behavior, regardless of the gender of the victim

or harasser. Therefore, men, transgenders and/or all other individuals are also protected against sexual

harassment at the workplace under this law. The Act mandates the establishment of Internal Complaints

Committees (ICCs) in organizations with 10 or more employees, which are responsible for receiving and

addressing complaints of sexual harassment, regardless of the gender of the complainant.

The Indian Constitution guarantees the right to equality and prohibits discrimination on the basis of gender.

Therefore, any law or policy that discriminates against men or transgender persons in the context of sexual

harassment would be unconstitutional. Indian courts have recognized that sexual harassment can occur

regardless of the gender of the victim or harasser. Several judgments have affirmed the applicability of laws

against sexual harassment to men and transgender individuals.

Scope

It shall be binding on employees, management and also on third parties who come within purview of Payana

and it is expected that it will be implemented immediately and continuously. This sexual harassment policy is a

gender-neutral policy. It extends to all women, men and transgender staff of Payana. All allegations of sexual

harassment will be taken seriously and responded promptly.

The principles and procedures (hereinafter Principles and Procedures) shall apply to all instances of sexual

harassment as provided herein:

 All allegations of sexual harassment by an employee against another employee, in either case,

irrespective of whether the sexual harassment is alleged to have taken place within or outside the

Payana premises.

 All allegations of sexual harassment made by an outsider against an employee if the sexual

harassment is alleged to have taken place either within the premises of Payana or outside the Payana

premises.

 An allegation of sexual harassment made by an employee against a third party if the sexual

harassment is alleged to have taken place within the Payana premises.

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 Any incident of sexual harassment that happened in/during the transportation provided by the office

to be part of the workplace will be treated in the same manner as if it happened in the office

premises.

 Cases of heterosexual as well as same sex harassment.

 Socio economic gender and ethnic discrimination against sexual minorities

These Principles and Procedures shall be the exclusive mechanism for redressal by Payana of alleged instances

of sexual harassment.

SHORT TITLE & DEFINITIONS

This policy shall be called the Policy to Prevent and Deal with Sexual Harassment and Discrimination in Payana.

This policy will come into effect immediately.

DEFINITIONS

(a) “Payana” shall mean and encompass all its units, offices, registered offices and branch offices.

(b) “Workplace” shall mean any place visited by the employee arising out of or during the course of

employment, including transportation provided by the employer for undertaking such a journey.”

subjected to any act of sexual harassment or gender based/ sex based discrimination under the

policy, and wishes to access the complaints mechanism under this policy.

(d) “Respondent” means a person against whom the aggrieved person has made a complaint.

(e) “Sexual Harassment”, as provided in the Act, means any unwanted conduct with sexual undertones

if:

 it occurs or is persistent; or

 it demeans, humiliates or creates a hostile and intimidating environment; or

 it is calculated to induce submission by actual or threatened adverse consequences; and

 includes any one or more of the following unwelcome acts or behaviour (whether directly or by

implication) namely:

 Physical contact and advances; or

 A demand or request for sexual favours; or

 Making sexually coloured remarks; or

 Showing pornographic material, including oral, textual, graphic representations of a sexual nature;

 Any other unwelcome physical, verbal or non-verbal conduct of a sexual nature; or

 Stalking, including cyber stalking, as defined under Section 354D of the Indian Penal Code.

Provided, under these Procedures, the gender identities of the perpetrator and the victim are immaterial.

 When any form of sexual assault is committed where a person uses, the body or any part of it or any

object as an extension of the body in relation to another person without the latter’s consent or

against that person’s will (for ex., use of a stick or other object to touch the body part of a person).

Explanation 1: Unwelcome act or behaviour extends

 to a person

 in a person’s presence whether or not the representation concerns the person

 about a person (when malicious)

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Explanation 2: “Unwelcome” covers all forms of conduct where the aggrieved person has not given consent,

expressly or impliedly, to the behaviour being complained thereof. The silence of the aggrieved person or lack

of protest at the time of the incident or afterwards shall not by itself be taken as proof of consent.

Explanation 3: The following circumstances, among other circumstances, if it occurs or is present in relation to

or connected with any act or behavior of sexual harassment may amount to sexual harassment:-

 implied or explicit promise of preferential treatment in his/her employment/ career; or

 implied or explicit threat of detrimental treatment in his/her employment/career; or

 implied or explicit threat about his/her present or future employment/career status; or

 interference with his/her work or creating an intimidating or offensive or hostile environment for

him/her; or

 humiliating treatment likely to affect his/her health (including mental health) or safety.

When any such conduct as defined above is committed by a third party or outsider in relation to a member of

Payana, or vice versa.

(f) Third Party Harassment” refers to a situation where sexual harassment occurs as a result of an act or

omission by any third party or outsider, who is not a member of Payana, but a visitor at Payana offices

in some other capacity or for some other purpose or reason.

(g) “Victimization” shall be understood to mean any adverse action by a person, group of persons or an

organization, against individual/s because they have, in good faith, reported instances of sexual

harassment or participated in or have been witnesses to proceedings or support persons to redress an

alleged instance of sexual harassment on behalf of the aggrieved person.

Provided that this definition shall not apply in the case of the respondent, their witnesses or support person.

Explanation: “adverse action” shall include, but not be limited to

 making such participation a ground for adverse action relating to employment, academic participation

or evaluation, extra or co- curricular activities or entitlement to services/opportunities.

 directly or indirectly using intimidation and/or undue influence so as to dissuade or deter such

participation.

 creating a hostile environment for the complainant and their witnesses.

(h) “Employee” for the purposes of this policy means any person on the staff/ full time or part-time

consultant/ volunteer/ intern of Payana

(i) “NGO” means any Non-Governmental Organisation registered as a public trust or a society operating

on a secular, nonprofit basis, not attached directly or indirectly to any political party and involved in

work concerning amelioration of status of sexual minorities.

(j) “Management” means the General Body or Governing Body or Executive Committee of Payana or the

managing body by whatever name called.

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PART I- PROCESS:

Recourse under the Rules: Any Aggrieved Person may choose to:

 resolve the matter through the mechanism laid down in the Policy and/or

 take recourse to any other institutional civil/criminal remedies available to her/him under the law.

Provided that where the aggrieved Person requests any corrective action to be taken against any person for

sexual harassment, the matter shall be referred to the Internal Complaints Committee and the

Committee shall conduct the inquiry and act in accordance with these rules.

Constitution of Internal Complaints Committee on Sexual Harassment

The Act provides for two kinds of complaints mechanisms:

1) Internal Complaints Committee (ICC) and

2) Local Committee (LC)

1) Internal Complaints Committee (ICC)

As per the Act, every workplace employer shall, by written order, form a Committee to be known as the

"Internal Complaints Committee", which shall consist of a senior-level woman from the workplace who shall be

the presiding officer, two employees who are fully well equipped with knowledge of gender-neutral laws and

societal norms (internal member), and one external person from NGOs committed to the cause of women. It is

also essential that the ICC consists of 50% women.

In every office of Payana having a minimum operational staff/employee strength of at least 10 or above, it

shall establish an ICC to deal with complaints of sexual harassment. In case Payana does not have a female in a

senior role, this may be managed by ensuring that the external NGO person may herself be nominated by the

Executive Committee as its Chairperson.

In case compliance to the gender requirements of the ICC’s membership is not possible in the context of

Payana, any deviation shall be on record that as this is not practicable (with adequate proof) and that no other

employee at Payana met the aforementioned criteria, leaving the Organisation with little choice but to select

two transgender persons as the two members one of whom being in a senior position shall be the Chairperson

of the ICC.

The ICC will be composed of the following members:

(1) shall consist of 5 persons including

 2 persons proposed by the employees in consensus from amongst themselves

 2 persons nominated by the management of Payana for each branch/ project office or main office

 1 representative of any external NGO to be appointed by the management.

(2) Wherever possible, at least 50% of the members shall be women/ transwomen.

(3) Wherever possible, the members of the ICC shall select from themselves a woman/ transwoman to

the position of Chairperson of the ICC.

(4) The term of office of the ICC shall be for a maximum of three years from the date of their first

appointment as the ICC

(5) Provided, however, that a person shall cease to hold office as a member of the ICC if he or she ceases

to be an employee in case of any vacancy due to resignation, termination, death, or for any other

reason whatsoever, the same shall be filled immediately in accordance with the procedure prescribed

in sub clause 1 of this section.

(6) The names of the current ICC members along with their contact number, email and address shall be

displayed at all times in a prominent manner on a conspicuous part of every Payana premises.

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DISQUALIFICATION FROM MEMBERSHIP, VACANCY, TERMINATION

1. Disqualification of Chairperson And Members: A person shall be disqualified from being appointed,

elected, nominated or designated as, or continuance as a member of the ICC if:

 there is any complaint concerning sexual harassment pending against him or her; or

 if he or she is found guilty of sexual harassment or gender based discrimination

2. Vacancy of a Member Owing To Absence Without Permission: If any ICC member or Chairperson is

absent from the ICC for three consecutive meetings, his or her office shall thereupon become vacant.

3. Resignation of a Member: A member of the ICC may resign his or her office at any time by tendering

his or her resignation in writing to the Chairperson, and such person shall be deemed to have vacated

his or her office as soon as the Chairperson has received the resignation.

MEETINGS OF THE ICC

 The meetings of the ICC shall be of two kinds:

(1) meetings to enquire into complaints regarding sexual harassment or discrimination;

(2) ordinary meetings to serve the duty of the ICC

 The ICC shall meet at least twice every year, with a minimum gap of five months between two

successive meetings. These bi-annual meetings are in addition to the meetings convened for hearing

complaints. The Chairperson may call for these ordinary meetings to plan and recommend for

trainings on prevention of sexual harassment and gender based discrimination

 The quorum for any meeting of the ICC shall be 100% of its members. If the quorum is not present at

any meeting, it shall be adjourned to a subsequent date of not more than 7 working days and if at the

subsequent meeting a quorum is still not present, the meeting shall proceed with those who are

present and the proceedings of such a meeting will not be challenged on the ground of absence of

quorum. All such proceedings which are conducted in the absence of a quorum shall be recorded in

writing clearly providing the reasons which caused the deviation.

 In any case, any meeting of the ICC for the purpose of enquiring into a complaint shall not proceed

without the presence of the external NGO representative, unless such a representative informs in

writing that the meeting can proceed in their absence.

POWERS AND DUTIES OF ICC

The powers and duties of the ICC shall be as follows, namely:

 To enquire into individual grievances concerning sexual harassment and to take suitable action in the

manner and mode more particularly provided in Sections 14 to 21 of the Act.

 To recommend to the Executive Committee appropriate action(s) to be taken against the Respondent

/ Accused in the case of the accused being found guilty.

 To organise regular workshops and training programmes for the members of the ICC in consultation

with the Executive Committee

 To maintain adequate records of the complaints/proceedings including a complaint register and

proceedings of any hearings of inquiries into grievances

Under the circumstances, where the staff/ full time consultants/ employee strength is below 10 at a branch,

Payana shall examine if it has at least 10 employees within a district or project jurisdiction and thereby form

the ICC to comply with the provisions of the Act.

According to section 5 of the Act, the State Government shall establish a Local Committee (LC) in every district

in order to help look into and address complaints of sexual harassment from the unorganized sectors, from

businesses where there is no ICC or when the complaint is against the employer.

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Under the 2013 Act, if an office of an organization does not have 10 or more personnel, and therefore no ICC

has been formed, the recourse for an employee who wants to file a complaint is to file a complaint with the

LCC within the district where their workplace is located. The LC is responsible for receiving and redressing

complaints of sexual harassment. Payana shall make adequate arrangements to inform their employees about

the existence of an LC and provide their current details at periodical intervals accordingly at each of its offices

displayed in a prominent and accessible location.

If the LC is not functional or available, the employee can file a complaint with the District Officer (a designated

authority responsible for addressing complaints related to sexual harassment in the absence of ICCs or LCs),

who is responsible for the implementation of the Act in the district. The District Officer is mandated to inquire

into the complaint and take appropriate action.

Approaching the Police: In cases of serious sexual harassment or in case Payana fails to take action against the

accused despite the recommendation to do so by the ICC, the employee also shall have the option to file a

complaint with the police under relevant provisions of the Indian Penal Code (IPC) or other applicable laws.

The Indian Penal Code (IPC), Section 354 deals with assault or criminal force to a person with intent to outrage

modesty, which can apply to instances of sexual harassment irrespective of the gender of the victim. While this

section does not specifically mention workplace harassment, it can be invoked in cases of sexual harassment

including that which occurs outside the workplace.

Sexual Harassment Training

a. Payana shall, on the recommendation of the ICC and in association with persons qualified for the

purpose, organize and conduct an annual workshop for the training of all its personnel.

b. The purpose of such workshop shall be:

 to impart basic counselling skills (especially for ICC members);

 to equip its personnel and especially ICC members with a functional understanding of the policy;

 to sensitize personnel and ICC members to systemic discrimination of persons and intersecting issues

of caste, sexuality, disability and other intersectionalities;

 to impart any other skills or knowledge which may be considered appropriate by the Organisation in

order to ensure the efficient functioning of this policy.

PART II –

1. PROCEDURE FOR INITIATING PROCEEDINGS

(a) Any employee will have a right to lodge a complaint concerning sexual harassment and sex

discrimination against another employee or an outsider with any of the members of the ICC.

(b) Such a complaint may be oral or in writing.

whom the complaint is made.

(d) The complainant will be afforded full confidentiality at this stage.

(e) Immediately upon receipt of the Complaint, and within not more than 2 working days, the member of

the Committee to whom the Complaint is made shall communicate the same to the Chairperson of

the ICC. However, if the Complainant so desires, his or her name shall be kept confidential and shall

not be divulged to the other members of the ICC for as long as it is prudent to do so.

(f) If a complaint is made against a member of the ICC, they shall not participate in the enquiry in the

capacity of an ICC member. Such vacancy shall be temporarily filled and, the ICC shall proceed to look

into the complaint with a substitute member nominated by the EC.

2. PROCEDURE FOR INITIATING ACTION

(a) Within a period of five working days from the date of communication of the written complaint, the

Chairperson shall convene a meeting of the ICC to examine the complaint and conduct an enquiry.

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(b) The complainant, respondent and witnesses shall be given advance intimation of the meetings/

hearings/ proceedings.

representative or both.

(d) At the first meeting, the Complainant or her/his representative shall be heard and the ICC shall

decide whether the complaint merits to be proceeded with. The Complaint will be dropped only if

the Complaint on the face of it does not disclose an offence of sexual harassment or sex

discrimination.

(e) In case the ICC decides to proceed with the Complaint, the wishes of the Complainant concerning

the issue shall be taken into account. If the complainant so wishes, the accused will be called to a

meeting of the ICC, and if necessary, warned about his/her behaviour and the matter concluded with

a recording to that effect made in the Complaints Register of the ICC.

(f) If the complainant, however, wishes to proceed ahead with the complaint beyond a mere warning to

the accused, the same will be proceeded with in the manner prescribed subsequently in this policy.

3. PROCEDURE FOR IMPOSING MINOR PUNISHMENT

In case the ICC decides to impose a minor punishment, the accused shall be given in writing an opportunity to

explain within one week why he or she should not, for good and sufficient reasons, be punished for the act of

sexual harassment or sex discrimination on his or her part. The nature and quantum of punishment if any to be

imposed on him or her shall be decided after considering the explanation, if any given by the accused.

4. PROCEDURE FOR IMPOSING MAJOR PUNISHMENT

(1) If the ICC finds the explanation of the accused not satisfactory or if no explanation is given by the

accused, it will decide to hold an enquiry against the accused.

(2) If an accused is alleged to be guilty of sexual harassment or sex discrimination and if there is reason to

believe that in the event of the guilt being proved against him or her, he or she is liable for imposition

of any major penalty, the ICC shall, first decide whether to place the accused employee under

suspension, and if the employee is so placed, he or she will receive 50% of salary during this period.

(3) If a person is charged with serious physical molestation or rape, he or she shall be immediately placed

under suspension pending the completion of the investigation and enquiry (during which they shall

continue to receive 50% of salary until the conclusion of the hearing). The ICC shall, within 3 days,

decide whether the charged person shall be placed under suspension or not and it shall communicate

its decision and the reasons for the decision to the Management which shall then implement the

decision forthwith.

(4) Within 3 days of the first meeting of the ICC, it shall communicate to the accused by hand delivery

duly acknowledged or by Registered Post Acknowledgement Due (RPAD) the allegations and demand

from him or her a written explanation within 7 days from the date of receipt of the statement of

allegations.

(5) The meetings of the ICC will be held during the office hours.

5. PROCEDURE FOR CONDUCTING INQUIRY

(1) The ICC shall prepare a charge-sheet containing specific charges and shall hand over the same

together with the statement of allegation and the explanation of the accused, to the complainant as

well as to the accused by hand delivery duly acknowledged or by registered post acknowledgement

due, within 3 days of the ICC having decided to conduct the enquiry.

(2) (a) Within 10 days after the accused receives the copies of the charge-sheet and the statement of

allegations,-

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 If the accused desires to tender any written explanation to the charge-sheet, he or she shall submit

the same to the Chairperson of the ICC in person or send it to him or her by Registered Post

Acknowledgement Due (RPAD).

 If the complainant or the accused desire to examine any witnesses they shall communicate in writing

to the Chairperson the name(s) of witness(es) whom they propose to so examine;

 If the complainant desires to tender any documents by way of evidence before the ICC, they shall

supply true copies of such documents to the accused. Similarly if the accused desires to tender any

documents in evidence before the ICC he or she shall supply true copies of such documents to the

complainant.

(b) Within 3 days after the expiry of period of 10 days specified in clause (a), the ICC shall meet to

proceed with the enquiry and give 7 days’ notice by hand delivery duly acknowledged or by registered

post acknowledgement to the complainant and the accused to appear for producing evidence,

examining witnesses, etc., if any.

accused, for putting forward and defending their case.

(d) Rights of the complainant and accused :

 The complainant shall have the right to lead evidence and the right to cross-examine witnesses

examined on behalf of the accused.

 The accused shall have the right to be heard in person and lead evidence. He or she shall also have

the right to cross-examine witnesses examined on behalf of the complainant.

 Sufficient opportunities shall be given to examine all witnesses notified by both the parties.

(e) All the proceedings of the ICC shall be recorded and the same together with the statement of the

witnesses shall be endorsed by both parties in token of authenticity thereof. Upon the refusal of

either party to endorse the same, it shall be endorsed by the Chairperson.

(f) The enquiry shall ordinarily be completed within a period of 90 days from the date on which the Show

cause notice is given to the accused.

(g) The complainant and the accused will be responsible to see those nominees and the witnesses if any,

are present during the enquiry. However, if the ICC is convinced about the absence of either of the

parties to the disputes or any of the members of the ICC on any valid ground the ICC shall adjourn

that particular meeting of the committee. The meeting so adjourned shall be conducted even in the

absence of the person concerned if he or she fails to remain present for the said adjourned meeting.

(h) The Chairperson of the ICC shall forward to the complainant and the accused as the case may be a

summary of the proceedings and copies of statements of witnesses, if any, by hand delivery duly

acknowledged, or by registered post acknowledgement due, within four days of the completion of the

above steps and allow them a time of seven days to offer further explanation, if any.

(i) The complainant or the accused as the case may be, shall submit their further explanation to the

Chairperson of the ICC within a period of seven days from the date of receipt of the summary

proceedings etc., either personally or by registered post acknowledgement due.

(j) On receipt of such further explanation or if no such further explanation is offered within the aforesaid

time, the ICC shall complete the enquiry.

(k) The ICC shall arrive at findings of guilt of the accused on the basis of majority.

(l) While arriving at findings, the ICC may consider as relevant any earlier complaints against the person

charged. However, the complainant’s past sexual history shall not be enquired into during the

proceedings before the Committee.

6. PROCEDURE UPON ARRIVING AT FINDINGS

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 The ICC shall communicate its decision on the basis of its findings to the Management for specific

action to be taken against the accused within 10 days after the date fixed for the receipt of further

explanation.

 It shall also forward a copy of the same by hand delivery duly acknowledged or by registered post

acknowledgement due to the complainant and to the accused.

 The decision of the ICC shall be implemented by the Management, which shall issue necessary orders

within 7 days of the date of receipt of decision of ICC, by hand delivery duly acknowledged, or by

registered post acknowledgement due.

 The management shall also endorse a copy of its order to the Complainant and to the ICC.

7. CONFIDENTIALITY: The ICC shall abide by the following rules relating to confidentiality:

 The entire proceedings of ICC shall remain confidential;

 The complainant’s identity shall remain confidential at all times, including at the time of preparation

and completion of report, unless the complainant expressly opts to disclose his/ her identity. Such an

option of the complainant shall be stated in writing; however the accused shall be informed of the

name of the complainant along with the details of the complaint

 If the accused is not proved guilty, the report of the proceedings shall expressly state: “accused not

found guilty”.

 Reports relating to proceedings of the ICC are private documents and are not liable for public

circulation and shall not be disclosed except to a competent court of law.

8. FALSE AND MALICIOUS COMPLAINTS

If ICC is of the opinion, substantiated by facts, that the complaint with regard to sexual harassment was false,

and had been lodged deliberately and with malicious intent, such an act would amount to misconduct. ICC

shall recommend to the Management appropriate action in this regard.

9. PROTECTION AGAINST VICTIMISATION

(i) In the event of the complainant and the accused both being employees, during the pendency of

the investigation and enquiry, and subsequent to the enquiry, provided the accused is found to

be guilty, the accused shall not:

 Write confidential reports of the complainant,

 Evaluate the performance of the complainant,

 Supervise the work of the complainant; or

 Require the complainant to report to him/her.

(ii) If the accused is an outsider, during the pendency of the investigation and enquiry and even

thereafter, if he or she is found to be guilty, the accused shall not be allowed to enter the Payana

premises except for the purpose of attending the present enquiry.

10. OBLIGATIONS OF THE MANAGEMENT

The management of Payana shall provide all necessary assistance for the purpose of ensuring full, effective

and speedy implementation of this policy. It shall be bound by the provisions of the Act, decision of the ICC

and shall implement their decisions in an expeditious manner.

11. THIRD PARTY HARASSMENT

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In case of third party sexual harassment ICC will actively assist and provide all its resources to the complainant

in pursuing the complaint and ensure his or her safety at least in the Payana premises. Payana will assist the

affected person in terms of support and preventive action as prescribed by the 2013 Act.

12. PUNISHMENT AND CLASSIFICATION OF PENALTIES FOR SEXUAL HARASSMENT

a) Any employee found guilty of sexual harassment shall be liable to be punished.

b) An employee guilty of sexual harassment shall be liable for any of the following penalties which shall be

classified as minor or major by the ICC in its recommendation:

 Reprimand, warning or censure;

 Suspension from office for a period not exceeding one month;

 Withholding of an increment for a period not exceeding one year;

 Termination of service

In addition to these penalties, the employee concerned may also be fined up to Rs. 5000/-, which amount will

be used by the Management for achieving the aims and objectives of this policy. Provided however, that in

addition to any of these penalties, the employee can also be required to give a written apology to the victim,

and upon his or her failure to do so his or her punishment can be enhanced. In case a minor penalty has been

imposed on the accused on an earlier occasion, on a second conviction, he or she may be imposed with a

major penalty depending on the gravity of the second offence.

13. Application of Policy

 The provisions of this policy shall apply notwithstanding any contrary statute, law, circular, or

ordinance.

 The proceedings under this policy shall not be stalled or postponed merely because the complainant

is proceeding against the accused under any other provision of civil or criminal law.

 The provisions of this policy shall not restrict the powers of the Management or the complainant to

proceed against the alleged offender for any misconduct or pursue the criminal or civil remedies.

14. Annual report by ICC:

The ICC will have to prepare an annual report every year containing the following details:

 No. of complaints of sexual harassment received in the reporting year

 No. of complaints of sexual harassment disposed- off during the reporting year

 No of cases pending during the reporting year

 No of workshops/awareness programmes conducted for prevention of sexual harassment at

workplace

Under the 2013 Act, it is mandatory for Payana to include information regarding sexual harassment complaints

in their annual report. This information should cover the number of complaints received by the ICC, the

number of complaints resolved, and the number of complaints pending. This is to ensure transparency and

accountability in addressing workplace sexual harassment.

Additional Reading: Information Technology (Amendment) Act, 2008:

 This law addresses cybercrimes, including online sexual harassment and stalking, providing legal

remedies for victims.

Payana Policy

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