POSH Policy (Detailed)

Title: Constitution of Internal Committee & Prevention of Sexual Harassment (POSH) Policy
 Date: 13 October 2025


1. Purpose & Scope

1.1. Purpose. To prohibit, prevent and provide a prompt, sensitive and confidential mechanism for redressal of complaints of sexual harassment of women at the workplace in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013 (hereinafter “POSH Act”). India Code
 1.2. Scope. This policy applies to all employees (permanent, temporary, contractual), consultants, interns, trainees, vendors, clients, visitors and any person who is working at BloomchemAG Pvt. Ltd. or interacts with its employees at any workplace, including remote/virtual workplaces and work-related social events.


2. Key Legal Definitions

2.1. Sexual Harassment. For the purposes of this policy, “sexual harassment” includes, but is not limited to: physical contact and advances; demand or request for sexual favours; sexually-coloured remarks; showing pornography; and any other unwelcome physical, verbal or non-verbal conduct of a sexual nature that creates a hostile or intimidating work environment. (Definition derived from Section 2(n) and Vishakha principles). ApniLaw+1


3. Applicability / Statutory Requirement

3.1. As per the POSH Act, every employer of an establishment where ten (10) or more persons are employed is required to constitute an Internal Committee (IC). BloomchemAG Pvt. Ltd. complies with this requirement by constituting the Internal Committee described below. India Code


4. Constitution of Internal Committee (IC) — Office Order

Effective: With immediate effect from 13 October 2025. Tenure — three (3) years from date of this order (unless earlier reconstituted).


Notes on composition: The Presiding Officer must be a senior woman employee; the IC must have at least 3 members from the employer and one external member from an NGO or someone familiar with sexual harassment/social welfare/legal issues, as per statutory guidance. Comptroller and Auditor General of India+1


5. Roles & Responsibilities of the Internal Committee

·   Receive and record complaints of sexual harassment in writing or via email/helpline.

·   Conduct fair, impartial and timely inquiries and submit findings and recommendations to Management.

·   Maintain confidentiality of complainant, respondent and witnesses.

·   Recommend interim reliefs (if needed) to the employer during inquiry.

·   Maintain records of complaints, inquiry reports, actions taken and send annual report as required.

·   Conduct awareness, training and outreach programs for employees.


6. Duties & Responsibilities of the Employer (BloomchemAG)

·   Provide a safe work environment and ensure no discrimination or victimization for complainants/witnesses.

·   Display the POSH policy at conspicuous locations and on company intranet.

·   Organize periodic awareness/training programs on POSH for employees.

·   Provide necessary support and protection to complainant(s) during and after inquiry.

·   Implement IC’s recommendations in a timely manner and take disciplinary action where required. Safe Spaces


7. Complaint Mechanism — Step-by-Step

7.1 How to Lodge a Complaint

1.     In Writing: The complaint must be in writing (Form A - simplified format below) and dated, with details of the incident(s), names, dates, places and any witness details. Complaints may be emailed to corphr@bloomchemag.com or submitted to any IC member in person.

2.     Helpline: For immediate assistance, call our POSH helpline: 9999999999 (HR desk) during working hours.

3.     Alternate Filing: If the complainant is unable to make a written complaint, a verbal complaint may be recorded by any member of the IC and reduced to writing with the complainant’s signature/thumb impression.

4.     Third-Party Filing: A complaint can be filed by a co-worker, friend, relative, an officer of the National Commission for Women, or any person who has knowledge of the incident, if the aggrieved woman is unable to file herself.

7.2 Time Limits for Filing

·   A complaint should normally be filed within three (3) months from the date of the incident, or from the date of the last incident in a series of incidents.

·   The IC may extend this period by a further three (3) months if it is satisfied that there are sufficient reasons for the delay. (Statutory provision). India Briefing+1


8. Inquiry Procedure — Step-by-Step (Indicative Timelines)

The IC will endeavour to complete the process fairly, confidentially and promptly.

1.     Receipt & Acknowledgement (Day 0–3): IC records complaint, assigns a reference number, and acknowledges receipt to the complainant within 3 working days. IC provides a copy of the complaint to the respondent and asks for a written response within 10 working days.

2.     Preliminary Assessment / Conciliation (Optional) (Day 3–10): Where appropriate and with consent of complainant, the IC may attempt conciliation. If settlement is reached, terms are recorded and the IC will submit the settlement report to the employer; no further inquiry is required. The IC will still ensure settlement is voluntary and not coerced.

3.     Constitution of Inquiry (Day 10–15): If no conciliation or settlement, the IC proceeds with a formal inquiry. The IC has powers similar to a civil court for summoning witnesses and documents.

4.     Inquiry Proceedings (Day 15–Day 90): The IC will complete the inquiry and submit its findings and recommendations to the employer within 90 days from the date of receipt of the complaint. (Statutory timeline; IC should aim to finish sooner where possible). iccniftem.com+1

5.     Employer Action (Within 60 days of recommendations): Management must act on the IC’s recommendations within a reasonable time (commonly within 60 days) and communicate actions to both parties.

6.     Appeal: Any party may appeal the IC’s findings in a court of competent jurisdiction as per law.

Important: Even if the 90-day timeline is exceeded, courts have held that inquiries can continue — the timeline is a target and not an automatic invalidation of proceedings if delayed for valid reasons. L&E Global


9. Interim Relief & Support Measures

During pendency of inquiry, IC may recommend interim reliefs, including (but not limited to):

·   Transfer of the complainant or respondent to another location.

·   Grant of paid leave to the complainant.

·   Restrictions on work-related interactions between complainant and respondent.

·   Suspension of the respondent (in serious cases).

·   Access to counselling and security measures.


10. Confidentiality & Non-Retaliation

·   All proceedings, records and communications relating to a complaint will be treated as confidential and shared strictly on a need-to-know basis.

·   Retaliation, victimization or intimidation of complainant, witnesses, or IC members is strictly prohibited and will be treated as a separate misconduct attracting disciplinary action.


11. Possible Outcomes & Penalties

·   On finding of guilt, IC may recommend disciplinary actions in accordance with company rules up to and including termination of employment, withholding promotions, deduction from salary, or other actions as permitted by service rules and law.

·   Where the complaint is false or malicious and IC finds intent to malign, the IC may recommend action against the complainant (after careful scrutiny) — but the employer will be cautious before imposing any penalty to avoid victim-blaming.


12. Record-Keeping & Reporting

·   IC shall maintain a register of complaints received, investigations conducted, and actions taken.

·   IC will prepare and submit annual reports as required by the POSH Act and cooperate with district/local authorities when required. (Employers must maintain records and make them available to the appropriate authorities). NABARD


13. Awareness, Training & Prevention

·   BloomchemAG will conduct mandatory POSH awareness and sensitization programs annually (or more frequently) for all employees, managers and contractual staff.

·   The company will disseminate the policy to all new hires, include it in HR on-boarding, and display POSH contact details on notice boards and intranet.

·   Managers will be trained to identify, respond and escalate complaints appropriately.


14. Sample Complaint Form (Form A — Simplified)

(To be filled by the Aggrieved Woman / Complainant)

·   Name of Complainant:

·   Employee ID / Department / Location:

·   Contact details (phone / email):

·   Name of Respondent (if known):

·   Designation & Department of Respondent:

·   Date(s), time(s) and place(s) of incident(s):

·   Detailed description of incident(s) (attach additional pages if required):

·   Names & contact details of witnesses (if any):

·   Any documentary evidence (attach copies):

·   Signature & Date:

(Submit to corphr@bloomchemag.com or any IC member / hand to HR/IC — keep a copy for your record)


15. Where a Complaint Cannot Be Resolved Internally

·   If the IC is not constituted, or the complainant wants to report to an external authority, or the IC refuses to proceed, the complainant may approach the Local Complaints Committee (District Officer) or file a criminal complaint with the police. (Statutory provision for local committee where IC not formed). NABARD


16. Review, Reconstitution & Validity

·   This IC is constituted effective 13 Oct 2025 for a period of 3 years. The Management reserves the right to reconstitute the committee earlier as required. The policy will be reviewed periodically and updated to remain compliant with statutory amendments and best practices.


17. Contact Details (POSH Helpline & IC)

·   POSH Helpline (HR Desk): 9999999999 (Mon–Fri, 10:00–18:00)

·   POSH Email (Complaints & Queries): corphr@bloomchemag.com 

·   Internal Committee (IC) Contact Points: Contact details of each IC member will be displayed on notice boards and intranet.


18. Approval

For BloomchemAG Pvt. Ltd.
 (Authorised Signatory)
 Name: ________________________
 Designation: __________________
 Date: ________________________


Helpful Notes for Implementation (Practical Checklist)

·   Publish and circulate this policy to all employees and place on intranet.

·   Display IC details on notice boards, employee handbook and offer letter annexure.

·   Arrange the first POSH training within 30 days and set an annual calendar.

·   Maintain a confidential POSH file (physical + secure digital) for complaints, minutes and action taken.


Legal & Reference Notes (Selected authoritative sources)

·   The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. India Code

·   Definition & examples of sexual harassment under Section 2(n) / Vishakha guidelines. ApniLaw+1

·   Time-limits for filing complaints and extension provisions (3 months + discretionary extension of 3 months). India Briefing+1

·   Composition and functioning of Internal Committee (Presiding Officer, members, external member, tenure). Comptroller and Auditor General of India+1

·   Inquiry timeline & obligations to attempt to complete inquiry within 90 days.