Effective

Policy Number Policy/Guideline Name Version No.

Date

TSAL/Mar20/PP/2.0 POSH Policy 2.0 1-Mar-2020

Department/Role Name Signature

Prepared By DGM - HR Rasmeeta Nayak

Reviewed By SVP HR & Corp Affairs Deepa Chadha

Approved By Chief Executive Officer Leslie Thng

S. Date of Version
Description of Change Decision in
No. Release No.

1. Formulation of formal 1st Sep Ver 1.0

guidelines for 2014
Prevention of Sexual
Harassment at
workplace

2.
Updation of the revised
1st
composition of the Ver 2.0 Mail approval by CEO
March
Internal Committee.
2020
These changes are as
per law which requires
rotation of the
members of the
committee.
GUIDELINES AND PROCESSES
1. Background

Sexual harassment at workplace is a form of discrimination and violation of fundamental right

which presupposes availability of safe secure and enabling environment for an ‘inclusive
growth’. The Sexual Harassment of Women at Workplace (Prevention, Prohibition and
Redressal Act 2013 are the guiding principles of this policy.

2. Objective

With a preventive as well as prescriptive intent, the objective of this policy is to lay clear
guidelines & provide right direction in case of any reported incidence of sexual harassment
across TATA SIA (VISTARA) offices / place of work (including airport / aircraft), and take
appropriate decision in resolving such issues. It also strives to prescribe a code of conduct
which every employee has to be aware of and strictly abide by it and the policy is gender
agnostic to that extent.

3. Definition

Sexual Harassment includes any one or more of the following unwelcome acts or behaviour,
whether directly or by implication –
a. Physical contact or advances or
b. Demand or request for sexual favors or
c. making sexually colored remarks or
d. Showing pornography or
e. Any other unwelcome physical verbal or nonverbal conduct of sexual nature
Any of the above acts would tantamount to ‘Sexual Harassment’, within or outside Company
Premises. Please refer ‘Annexure A’ for detail coverage of what will be deemed as acts of
sexual harassment.

‘Outside the company premises will include any place visited by an employee arising out of or
during the course of employment including transportation provided by the employer for
undertaking such a journey. This would thus also cover any location where an
employee/associate may be on official tour/hotel, customer call, customer interface etc.
In addition, the policy also includes in its scope, any act of misdemeanour akin to moral
turpitude impacting the repute or productivity of the organization in or outside company
premises.
Service Rule for the purpose of the policy refers to Employment Agreement, Policies &
Guidelines.

Basis the severity of the case, ‘Employer’ wherever used shall mean Corporate HR for all
implementation of Committee recommendations and in certain cases may also include Division
Heads of the organization including Office of the CEO.

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GUIDELINES AND PROCESSES
4. Applicability
All employees of TATA SIA Airlines (VISTARA) including:
a. On rolls/fixed time, trainees, and temporary/outsourced associates direct or engaged through
agencies and those working on voluntary or honorary capacity.
b. Individuals on deputation, retainer ship /consultancy, on contractual employment with or
without the knowledge of the Principal Employer irrespective whether the terms of contract
are explicit or implied.
Besides the above the scope of the policy also covers any person in relation to the company
premises and thus extends to include visitors, job applicants and vendor partners.

5. Guidelines
No employee / associate shall indulge in the acts of commission or omission which shall be
deemed to be acts of Sexual harassment. It shall also be applicable in respect of all allegations
of sexual harassment made by an outsider against an employee/associate or vice versa.
The following circumstances among other circumstances if present in relation to or connected
with any act or behaviour of sexual harassment may amount to sexual harassment

a. Implied or explicit promise of preferential treatment in his\her employment; or

b. Implied or explicit threat of detrimental treatment in his\her employment; or
c. Implied or explicit threat about his\her present or future employment status; or
d. Interferes with his\her work or creates an intimidating or offensive or hostile work
environment for him\her; or
e. Humiliating treatment likely to affect his\her health or safety

In the event of such an eventuality, the matter shall be examined into by the POSH Committee
who shall give their recommendations to the Corporate HR.

5.1 POSH Redressal Committee - Constitution

There is a two-level committee at TATA SIA as per the prescribed format of the Act. There is
an Apex Committee at Corporate Office as well as Local Committees at the stations. Listed
below are the details:

Constitution of the Apex POSH Committee at Corporate Office

a. The Committee shall comprise of 5 nominated members.

b. The Committee shall be represented by both the genders and shall be such that at least 50%
members are women.
c. The Chairperson/Presiding Officer of the Committee shall be a senior female colleague and
would not be lower than the Manager level.

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GUIDELINES AND PROCESSES
d. Preference of membership will be given to employees who are committed to cause of women
or who have had experience in social work or/and have legal knowledge/background.

e. The Committee will also have one member from amongst Non-Governmental organizations or
associations committed to the cause of women or a person familiar with the issues relating to
sexual harassment. The member appointed from such non-government organization or
association shall be paid the prescribed fees or allowance holding the proceedings of the
Committee

Constitution of the Local POSH Committee at Corporate Office

a. All stations have one or two members trained on the Act as well as the role and responsibility
of an Internal Committee member at local stations.
b. However due to the small number of employees at stations a full local committee cannot be
set up. Therefore, members from the local station committee as well as members from the
Apex Committee will come together and form a Local Committee in case of a complaint from
the station. For E.g.: if a station has 2 members who are Local Committee members, 2
members from the Apex Committee will be nominated by the Chairperson of the Apex
Committee to ensure the correct composition of Local Committee as per the directives of the
Act. This will however only be done if the local members are not the directly or indirectly
involved or impacted parties to the complaint as otherwise it would prove biased.
c. The Chairperson however will always be the same as the Chairperson of the Apex Committee
and Local Committee so as to ensure a consistency as well as neutrality to the process.

Please refer ‘Annexure C’ for detailed guidelines on the composition of the POSH Apex
Internal Committee as well as POSH Local Committee.

5.2 Inquiry: Procedures & Time Frame

While all employees/associates should adhere to the code of conduct stipulated above, in the
unlikely event of any employee/associate violating the same, the Redressal System would be
as follows

a. Any aggrieved employee/associate may make a written complaint of sexual harassment at

workplace to the constituted Committee within three months from the date of last incident
and in case of series of incidents within period of three months from the date of last incident.
If the complaint cannot be made in writing the Presiding Officer (Chairperson) of the
Committee will provide reasonable assistance to the aggrieved employee to record the
complaint.
b. The period of 3 months can be extended by the Committee if it is satisfied that the
circumstances prevented the aggrieved to file the complaint within the given period. However,
the reason for extension of the time period must be stated in writing.

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GUIDELINES AND PROCESSES
c. The legal representative of the aggrieved may make a complaint in the event of her death or
physical or mental incapacity.
d. The enquiry should be completed within 60 days.

e. The Committee is to conduct an inquiry of the complaint in accordance to the service rule
(Tata Code of Conduct, the relevant legislation/ Act, Employment Agreement, and Policies &
Guidelines) applicable to the alleged perpetrator.
f. The involved parties must be given an opportunity of being heard and a copy of the findings
must be made available to the parties to enable them to represent for (in order to
substantiate) or against (in order to appeal) the findings before the Committee.
g. The Committee shall be vested with powers of a civil court under the Code of Civil
Procedure, 1908 in respect of -
• Summoning and enforcing the attendance of any person and examining him/her on oath
• Requiring the discovery and production of documents and
• Any other prescribed matter
h. In case of complaints involving offences under the Indian Penal Code, the Committee should
advise the complainant to file a complaint with the police immediately. This is to be in
conjunction with The Sexual Harassment of Women at Workplace (Prevention, Prohibition
and Redressal) Act 2013

5.3 Prohibition of Publication

a. The content of the complaints, identity and address of the aggrieved, alleged perpetrator,
witnesses and any other information relating to the conciliation, inquiry, proceedings,
recommendations of the redressal Committees and the action taken are not to be published
or communicated.

b. However, information may be disseminated regarding the issue and action taken without
disclosing the identity or related particulars leading to the identification of the parties.
c. In case any person dealing with the complaint, inquiry or action is found guilty of doing so;
suitable action may be initiated in accordance to the service rules (Tata Code of Conduct,
Employment contract, Policies & Guidelines).

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GUIDELINES AND PROCESSES
Annexure A

Acts of Sexual Harassment

The following acts are considered inappropriate within the TTL working environment and
employees/associates are advised and expected not to indulge in the same.

1. Verbal Harassment
a. A demand or request for sexual favours.
b. Comments about a person’s sex or private life.
c. Sexually colored remarks
d. Verbal abuses

2. Physical harassment (also covered under the Indian Penal Code):

a. Offensive gestures.
b. Touching in a sexual manner.
c. Assault or coerced sexual acts.

3. Written or graphic harassment:

a. Unsolicited forwarding of pornographic pictures/content through any media such as
email/SMS/MMS etc.
b. The display of sexually suggestive objects, pictures, magazines, posters or cartoons in
the work-area.
c. Written communication that has sexual implications/overtones

4. Emotional harassment
a. Behavior that isolates or is discriminatory towards or excludes a person on the
grounds of his or her sex.
b. Demanding sexual favours in return for, or with a promise of favorable performance
appraisals, promotions, sustained employment and provision of employment

The above list is not exhaustive and any other kind of unwelcome physical, verbal or non-
verbal conduct of sexual nature would be considered inappropriate. The point of
consideration would be the effect that the conduct of one person has on another rather than
whether the behaviour was intentionally offensive or not.

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GUIDELINES AND PROCESSES
Annexure B

1. Obligation of Committee: Report Submission

a. Upon completion of the inquiry, the Committee shall submit its findings along with its
recommendations within 15 working days from the completion of the inquiry.
b. The Report must be made available to the concerned parties.
c. The Committee may recommend either that no action is required in the matter if it concludes
that the allegation has not been proven; incase it concludes that the allegation has been
proven it is required to recommend to
• Take action for sexual harassment as a misconduct in accordance with the applicable service
rules (TCOC, Employment contract, Policies & Guidelines) or as prescribed
• Deduct from the compensation of the perpetrator appropriate sum to be paid to the aggrieved
member or her legal representatives
d. The recommendations of Committee have to be acted upon by Employer within 60 days of the
receipt of the same.
e. The Committee for each calendar year, would prepare an annual report on number of
complaints filed and disposal thereof and submit the same to CEO.
f. The office of CEO shall collate the Companywide information on number of complaints filed,
disposed of and/ or pending inquiry and forward such details to the Company Secretary for
inclusion in Annual Report of TATA SIA Airlines Ltd.

2. Obligation of Employer

a. Adequate awareness of the policy in the work place of including the penal consequences of
sexual harassment and the consequences.
b. Organize regular workshops and awareness programs to sensitize employees on the provisions
of the policy and orientation programs for the members of the redressal Committee
c. Provide necessary facilities to the redressal Committee, extend assistance to secure
attendance of the respondent, witnesses and make available information as required by the
Committee
d. Monitor timely submission of Annual Reports by the Committee
e. Provide assistance to the complainant if she chooses to make a complaint in the matter under
the IPC or any other Act in force.
f. Administer and revise the aforesaid policy in accordance to the applicable legislation in force
from time to time.

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GUIDELINES AND PROCESSES
Annexure C

Apex Internal Committee Members effective 1st March 2020

Sonia Bharadwaj
(AVP - Customer
External (NGO)
Engagement)
Chairperson

Ira Anand Baiju Nair

Rasmeeta Nayak
Kartik Dawar (Manager - Crew (VP -Revenue
(DGM - Human
(Sr. Manager - Legal) Training & Service Accounting & Fraud
Resources)
Development) Prevention)

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GUIDELINES AND PROCESSES
Local Internal Committee Members effective 1st March 2020

Local IC members
Emp Code Name E-Mail Location
279 Mr. Amardeepsinh Rana amardeepsinh.rana@airvistara.com AMD
1568 Mr. Munish Kotwal munish.kotwal@airvistara.com ATQ
631 Lakshmi Kumari LAKSHMI.KUMARI@AIRVISTARA.COM BBI
828 Mr. Nikhil Walia nikhil.walia@airvistara.com BKK
424 Mr. Santhosh Kumar Nair santhosh.nair@airvistara.com BLR
5204 Mr. Milind Nevrekar milind.nevrekar@airvistara.com BOM
3840 Mr. Naveen Kapoor naveen.kapoor@airvistara.com BOM
1955 Mr. Nitin Nishant nitin.nishant@airvistara.com CCU
1117 Ms. Liz Varghese Liz.varghese@airvistara.com COK
1185 Mr. Gautam Mehta gautam.mehta@airvistara.com CMB
247 Ms. Madhumita Pandey Madhumita.pandey@Airvistara.com DEL
2502 Mr. Samir Bharat Saraiya samir.saraiya@Airvistara.com DEL
3767 Mr. Moirangthem Sonamani Singh moirangthem.singh1@airvistara.com DIB
360 Ms. Pooja Hussain pooja.hussain@airvistara.com DXB
470 Mr. Litan Majumder litan.majumder@airvistara.com GAU
433 Mr. Rahul Bhongade rahul.bhongade@airvistara.com GOI
352 Mr. Hari Prasad hari.prasad@airvistara.com HYD
492 Mr.Binod Tamang binod.tamang@airvistara.com IXB
841 Mr. Pratap Keshari Mahapatra pratap.mahapatra@airvistara.com IXC
1087 Ms. Archana Koul archana.koul@airvistara.com IXJ
1885 Mr. Lobsang Nyandak lobsang.nyandak@airvistara.com IXL
381 Mr. Anup Rajeshbhai Trivedi anup.trivedi@airvistara.com IXR
5077 Mr. Vinesh Wadhwani vinesh.wadhwani@airvistara.com IDR
5224 Mr.Manoj Kumar Gupta manoj.gupta@airvistara.com IXZ
851 Mr. Sanjay Mattoo sanjay.mattoo@airvistara.com KTM
709 Mr. Pankaj Mehrotra pankaj.mehrotra@airvistara.com LKO/JDH/UDR
575 Mr. Ganesh Kumar ganesh.kumar@airvistara.com MAA
1611 Mr. Satender Singh satender.singh@airvistara.com PNQ
430 Mr. Mohd Aslam mohd.aslam@airvistara.com PAT
3746 Mr. Manmeet Singh Barham manmeet.barham@airvistara.com RPR
2428 Mr. Irfan Ul Rasool irfan.rasool@airvistara.com SXR
274 Mr. Ian Mark Chacko ian.chacko@airvistara.com SIN
476 Mr.Vipin Kumar V.G vipin.kumar@airvistara.com TRV
483 Ms. Niharika Singh niharika.singh@airvistara.com VNS/HJR