HBL Global’s Policy on the Sexual harassment at Workplace

In terms of a Notification dated 23rd April 2011, the salient features of the Sexual harassment
at Workplace Prevention, Prohibition and Redressal Act, 2013 is being published with a view
to give effect to the letter and spirit of the said act.
The Act aims to provide protection against sexual harassment of women at workplace and for
the prevention and redressal of complaints of Sexual Harassment and for matters connected
therewith or incidental thereto.
Sexual harassment results in violation of the fundamental rights of a woman to equality under
Article 14 and 15 of the Constitution of India and her right to life and to live with dignity
under article 21 of the Constitution and right to practice any profession or to carry on any
occupation, trade or business which included a right to a safe environment free from sexual
HBL always had a policy on prevention of sexual harassment at the workplace and guidelines
for dealing with cases reported.
Further, in view of the Provisions of the sexual harassment at workplace Prevention,
Prohibition and Redressal Act, 2013 (hereinafter called ‘the Act’) HBL has constituted an
Internal Complaints Committee.
As a responsible and equal opportunity employer, HBL is committed to create a culture of
conducive, fair and harmonious environment amongst its employees. Sexual Harassment
besides being a criminal offence is a major impediment towards establishing this culture.
Such unacceptable behavior at workplace not only destroys the human dignity and Freedom,
but also causes anxieties and insecurities amongst women employees.
Objective and Purpose:
HBL recognizes its responsibility towards safeguarding and protecting women at workplace
from harassment, either by an internal or external source, whether at its administrative units
or offices or any place visited by the employee during the course of employment. It is also
committed to provide and ensure a safe, harassment free working environment to all its
women employees including contract employees and trainees. HBL undertakes to provide a
Safe working environment at the workplace which shall include safety from the persons
coming into contact with them at the workplace.
In an effort to promote and protect the well-being of all women employees, HBL has put in
place an objective code of conduct, applicable to all employees of HBL. All the employees of

HBL shall be governed and are expected to conform to the following code of conduct at the
1. No employees shall indulge in an act of sexual harassment of any woman at work.
2. Every employee is duty bound to deter/prevent any commission of acts sexual
harassment of women at the workplace.
3. A breach of any of the provisions of the code of conduct shall amount to committing
misconduct and it is liable for appropriate disciplinary action as deemed fit.
A) Definition ofSexual Harassment
Sexual Harassment includes any one or more of the following unwelcome acts or behaviors
(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 pornography; or
Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.

B) Internal Complaints Committee
As stated earlier, it is the endeavor of HBL to deal with issues of Sexual Harassment in a
more focused manner and take such deterrent action against erring employees. Towards
ensuring this objective, HBL has constituted a dedicated Internal Complaints Committee
(ICC) to deal with cases of sexual harassment of women at workplace.
In Consonance with statutory provisions, the ICC has been constituted to cater to all regions
and all administrative units or offices. The ICC shall consist of the following members to be
nominated by the employer, namely
i. A presiding officer who shall be a woman employed at a senior level at workplace form
amongst the employees.
ii. Not less than two members from amongst employees.
iii. One member from amongst non-government organization / organization committed to
the cause of women.
iv. Provided that at least one-half of the total members so nominated shall be woman
v. The Presiding officer and every member of the ICC shall hold office for such period,
not exceeding three years, from the date of their nomination.
The composition of the ICC is in place in accordance with the legal guidelines provided.
Complaints Mechanism
1. Any aggrieved woman may make, in writing a complaint of sexual harassment at
workplace to the Internal committee, within a period of three months from the date of the
Incident and, in case of a series of incident, within a period of three months from the date of
the last incident.

2. Any aggrieved woman may complain of sexual harassment at work to ICC, at e-mail id
HBL.POSHcell@hdfcbank.com. The complainant is required to disclose their name,
employee code, contact details, department and location they are working in, to enable the
ICC to contact them and take the matter forward.
3. The ICC may, before initiating an inquiry and at the request of the aggrieved woman, take
steps to settle the matter between her and the respondent through conciliation provided that
no monetary settlement shall be made as basis of conciliation.
4. Where a settlement has been arrived at under sub-section 2 above, the ICC shall record the
settlement so arrived and forward the same to HBL to take action as specified in the
5. Where a settlement is arrived at under sub –section 2 above no further inquiry shall be
conducted by the ICC.
6. The ICC shall, where the respondent is an employee, proceed to make inquiry into the
complaint in accordance with the provisions of the service rules applicable to the respondent,
in such manner as may be prescribed.
7. Provided that where the aggrieved woman informs the ICC, that any term or condition of
the settlement arrived at under sub-section 2 has not been complied with by the respondent,
the ICC or the Local committee shall proceed to make an enquiry into the complaint.
8. Provided further that where both parties are employees, the parties shall, during the course
of inquiry, be given an opportunity of being heard and a copy of the findings shall be made
available to both the parties enabling them to make representations against the findings
before the committee.
9. For the purpose of making an inquiry the Internal committee, shall have the same powers
as are vested in a civil court under the Code of Civil procedure, 1908 when trying a suit in
respect of the following namely
i. Summoning and enforcing the attendance of any person and examining him on oath;
ii. Requiring the discovery and production of documents; and
iii. Any other matter which may be prescribed
iv. The enquiry shall be completed within a period of ninety days.
Inquiry into the Complaint
1. During the pendency of an inquiry, on a written request made by the aggrieved woman,
the ICC may recommend to HBL
i. Transfer the aggrieved woman or the respondent to any other workplace; or
ii. Grant leave to the aggrieved woman up to a period of three months; or
iii. Grant such other relief to the aggrieved woman as may be prescribed.
2. The Leave granted to the aggrieved woman under this section shall be in addition to the
leave she would be otherwise entitled.

3. On the recommendation of the ICC, HBL will Implement the Recommendations made
under clause (1 above) and send report of such implementation to the ICC.
4. On the Completion of an inquiry under this ACT, the ICC shall provide a report of its
findings to HBL within a period of ten days from the date completion of the enquiry and
such report be made available to the concerned parties.
5. Where the ICC arrives at the conclusion that the allegation against the respondent has not
been proved, it shall recommend to HBL that no action is required to be taken in the

Where the ICC arrives at the conclusion that the allegation against the respondent has
been proved, it shall recommend to HBL to take action for sexual harassment as
misconduct in accordance with provisions of the service rules applicable to the
respondent or recommended any action as provided by the Act.

6. HBL is required to act upon the recommendation within 60 days of its receipt,
7. Where the ICC arrives at a conclusion that the allegation that the against the
respondent is malicious or the aggrieved woman or any other person making the
complaint has made the complaint knowing it to be false or the aggrieved woman or
any other person making the complaint has produced any forged or misleading
document, it may recommend to HBL to take action against the woman or the
person who has made the complaint, in accordance with the provisions of the service
rules applicable to her or him.
Provided that a mere inability to substantiate a complaint or provide adequate proof need not
attract action against the complainant under this section.
Provided further, that the malicious intent on the part of the complainant shall be
established after an inquiry in accordance with the procedure prescribed, before any
action is recommended.
Where the ICC arrives at the conclusion that during the inquiry any witness has
given false evidence or produced any forged or misleading document, it may
recommend to HBL, to take action in accordance with the provisions of the service rules
applicable to the said witness.
Any person aggrieved from the recommendations made by the ICC or nonimplementation of such recommendations may prefer an appeal to the court or tribunal in
accordance with the provisions of the service rules applicable to the said person.

The appeal shall be referred within a period of ninety days of the recommendations.

Annexure 1
Members of the Internal Complaints Committee
Central Committee Members

Kashmira Patel
Smily Mehra
Ruchi Mahawar
One member representative from 1to1helpnet

Regional Committee members

North Region: Ankita Mishra
East Region: Satadeepa Guha
South Region : Pushpa Kumari Sajja
West Region: Shilpy Saxena

Version 1 – Oct 2015