#POSH Policy and Internal Committee Constitution

POL-IN-306 | Version 1.0.0 | Last Modified On 31 July 2026

Made under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the Rules made under it. Published because it is required to be displayed, and because it is one of the first documents an Indian hospital's vendor-onboarding pack asks a supplier for.

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#1. Statement

Edsol Edtech Pvt. Ltd. prohibits sexual harassment at the workplace. Every woman at the workplace is entitled to a workplace free of it, and every complaint is inquired into under the procedure in this Policy.

This Policy is not a substitute for the law and does not narrow it. Where anything in this Policy is inconsistent with the Act or the Rules, the Act and the Rules prevail.

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#2. Scope

2.1 Who is protected. Any aggrieved woman at the workplace, whether or not she is employed by Edsol Edtech Pvt. Ltd.. This includes employees, contractors and their personnel, interns, trainees, apprentices, probationers, visitors, and a woman at a customer hospital or a supplier's premises where the respondent is a person acting for Edsol Edtech Pvt. Ltd..

2.2 Who is bound. Every person acting for Edsol Edtech Pvt. Ltd., employees, directors, contractors, consultants, interns and agency personnel, under POL-IN-301 clause 7 and POL-IN-303 clause 5.4.

2.3 What counts as the workplace. The Company's premises; any place visited by an employee arising out of or during employment, including transport provided by the employer; a customer hospital's premises; a supplier's or partner's premises; a conference, training, off-site or client event; and remote and virtual working environments: video calls, chat, e-mail and messaging applications are the workplace.

2.4 A complaint by a man or by a person of any gender identity is dealt with under the Code of Conduct (POL-IN-305) and POL-IN-307, through the same reporting channels, with the same protections against retaliation and the same procedural fairness. The statutory forum in this Policy is that provided by the 2013 Act, which is available to a woman; the Company's own standard of behaviour is gender-neutral and is enforced as such.

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#3. What sexual harassment is

Any one or more of the following unwelcome acts or behaviour, whether directly or by implication:

1. physical contact and advances;
2. a demand or request for sexual favours;
3. making sexually coloured remarks;
4. showing pornography;
5. any other unwelcome physical, verbal or non-verbal conduct of a sexual nature.

The following, in relation to or connected with any sexual act, also amount to sexual harassment:

6. implied or explicit promise of preferential treatment in employment;
7. implied or explicit threat of detrimental treatment in employment;
8. implied or explicit threat about present or future employment status;
9. interference with work, or creating an intimidating, offensive or hostile work environment;
10. humiliating treatment likely to affect health or safety.

"Unwelcome" is judged from the perspective of the woman who experienced it, not from the intention of the person who did it. Conduct in a group chat, a video call or a private message to a colleague is within this definition.

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#4. The Internal Committee

4.1 Constitution. The Internal Committee ("IC") is constituted under section 4 of the Act by order of the Founder. It comprises:

4.2 Where a senior-level woman employee is not available, the Presiding Officer is nominated from another office or administrative unit, and where that is not possible, from another workplace of the same employer, in accordance with section 4(2) of the Act. Where the Company cannot lawfully constitute an IC because it employs fewer than ten persons, or because the complaint is against the employer, the complaint is made to the Local Committee constituted by the District Officer for Pensieve registered address district, and Edsol Edtech Pvt. Ltd. will assist the complainant to reach it. The current position is recorded at Section 11.

4.3 The External Member is paid the fees or allowances prescribed by the Rules, by the Company. The External Member is not an employee, is not selected by the respondent's reporting line, and is not retained on terms that could compromise independence.

4.4 Disqualification. A member ceases to hold office where the member contravenes section 16 (prohibition on publication), is convicted of an offence or has an inquiry pending, is found guilty in a disciplinary proceeding, or has abused their position. The vacancy is filled within a reasonable time and in any event before the next inquiry.

4.5 Recusal. A member who is the respondent, a witness, in the respondent's or complainant's reporting line, or otherwise conflicted, recuses from that inquiry and a substitute is nominated for it.

4.6 Capability. Every IC member completes training on the Act and on conducting an inquiry, before sitting on one, and refresher training annually. Recorded in REG-GL-209.

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#5. How to complain

5.1 To whom. In writing to the Presiding Officer at Posh presiding officer email, or to Posh committee email, or by handing a written complaint to any IC member. A complaint made verbally, or to any manager or to the Founder, is reduced to writing with the complainant's assistance and routed to the IC the same working day.

5.2 Time limit. Within three months of the incident, or of the last incident in a series. The IC may extend by a further three months where it records reasons in writing that circumstances prevented filing earlier. Edsol Edtech Pvt. Ltd. will not use the time limit to avoid dealing with a complaint that should be dealt with; where a complaint is out of time, the IC states in writing why it did not extend.

5.3 Assistance. Where the complainant cannot make a complaint herself by reason of physical or mental incapacity, or death, a complaint may be made by the persons the Rules permit.

5.4 Number of copies. Six copies of the complaint with supporting documents and the names and addresses of witnesses, as the Rules require. The IC will help a complainant who cannot produce these; a procedural shortfall never causes a complaint to be refused.

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#6. Procedure and timelines

6.1 Absence. Where either party fails, without sufficient cause, to be present for three consecutive hearings, the IC may terminate the proceeding or give an ex parte decision, after fifteen days' written notice.

6.2 Outcomes where the complaint is proved. The IC may recommend action under the Company's service rules (POL-GL-322), which may include a written apology, warning, reprimand, censure, withholding of a promotion or increment, termination, counselling or community service, and may recommend that a sum be deducted from the respondent's salary and paid to the complainant, having regard to the matters the Act specifies.

6.3 Where the complaint is not proved. The IC records that no action is required. A complaint that fails is not, by that fact, a false complaint, and no adverse consequence follows from having made it. Action for a malicious complaint or knowingly false evidence is available only where the IC so concludes on inquiry, having recorded its reasons, and the mere inability to substantiate a complaint is expressly not enough.

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#7. Confidentiality: section 16

The identity and address of the aggrieved woman, the respondent and the witnesses, any information about the conciliation or inquiry proceedings, and the recommendations and action taken, must not be published, communicated or made known to the public, press or media in any manner. Contravention attracts the penalty in section 17 and is gross misconduct under POL-GL-322.

7.1 Information may be disseminated regarding the justice secured, without disclosing any identifying detail.

7.2 No confidentiality clause in any contract, settlement or separation agreement made by Edsol Edtech Pvt. Ltd. prevents a person from making a complaint under this Policy, giving evidence to an IC or a Local Committee, or reporting a matter to a statutory authority. Any such clause is void to that extent (POL-IN-302 clause 6.3).

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#8. No retaliation

Retaliation against a complainant, a witness or an IC member is prohibited and is itself gross misconduct. This includes a change in work allocation, exclusion from a project, an adverse appraisal, a withheld increment or social exclusion. A person who believes they have been retaliated against reports it under POL-IN-308 and the IC is informed.

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#9. Employer's duties: section 19

Edsol Edtech Pvt. Ltd. will: provide a safe working environment; display at a conspicuous place the penal consequences of sexual harassment and the composition of the IC; organise awareness workshops and orientation for employees and capacity-building for IC members; provide the IC with the facilities to conduct an inquiry; assist in securing the attendance of the respondent and witnesses; make the information the IC requires available to it; assist a complainant who chooses to file a criminal complaint, including under the Bharatiya Nyaya Sanhita, 2023; treat sexual harassment as misconduct under the service rules and initiate action accordingly; and monitor the timely submission of the IC's reports.

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#10. Records, reporting and audit

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#11. Current constitution status

Where Posh ic required is "no" because the Company employs fewer than ten persons, this Policy still applies in full and complaints are routed to the Local Committee. Edsol Edtech Pvt. Ltd. does not treat the statutory threshold as a reason to have no policy, no procedure and no named contact. A hospital asking this question is entitled to a substantive answer either way.

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