II Year BA L.L.

B – Semester IV
2nd - Internal Assessment – Prevention of Sexual
Harassment Act

Drafting a POSH Policy

Topic
HOTEL

NAME: BHOOMI TANK, KUVAL P. AMBERKAR

DIVISION: D
PRN: 23010125328, 23010125329
COURSE: BA LL.B. (H)
BATCH: 2023-2028
Implemented March 2023 | Version 1.2

TABLE OF CONTENTS

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I. Introduction
Enacted in compliance with The POSH Act, 2013 and its implementing regulations, this
policy is known as the "Policy on Prevention, Prohibition and Redressal of Sexual
Harassment at the Workplace" (hereinafter "Policy").

At the Palm Garden Boutique Hotel, we're dedicated to creating a welcoming, courteous, and
safe environment. Our zero-tolerance policy for sexual harassment is reaffirmed in this
policy, which also provides explicit guidelines for reporting and remedy. All workers will be
safeguarded, and a respectful and dignified workplace will be maintained.

The Act's provisions will take precedence in the event of any discrepancies or in cases where
a topic is not specifically addressed. Any employee found in violation of the Policy will be
liable to strict action.

II. Applicability
All women and transgender individuals working for Palm Garden Boutique Hotel and its
affiliated firms in India, whether now or in the future, are covered by this policy. It includes
people who work regularly, temporarily, ad hoc, or for a daily salary, either directly or
through an agent (including contractors), whether the organization is aware of their
employment, and whether they are compensated for their labour. Coworkers, contract
workers, associates, probationers, trainees, apprentices, and anybody working under any
other designation are all included in this, regardless of whether the conditions of employment
are explicit or implicit.

All third parties who are permitted to be on the Palm Garden Boutique Hotel's property are
also covered by this policy, including visitors, guests, clients, customers, vendors, service
providers, and anybody else who interacts with the hotel or its staff in a professional capacity,
such as interview subjects, event participants, or meeting attendees.

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III. Definitions

TERM DEFINITION

Employee Refers to any individual working at the hotel, whether directly or

through an agency, including those engaged through contractors,
on a regular, temporary, ad hoc, or daily salary basis, with or
without compensation. The term includes coworkers, probationers,
trainees, interns, volunteers, and others engaged in hotel-related
activities.

Employer Refers to the individual in charge of overseeing, managing, and

controlling the hotel's grounds. Here, it refers to the general
manager or any anyone chosen by Palm Garden Boutique Hotel to
be in charge of overseeing, managing, and controlling the hotel's
grounds.

Refers to the Palm Garden Boutique Hotel and any of its affiliated
Company
divisions, subsidiaries, or businesses that are run by the same
person or organisation in India (henceforth referred to as the
"Hotel" or "Palm Garden").

"Affiliates" are defined as:

(i) Any Palm Garden branch or extension that is under its

supervision; and/or
(ii) Any organisation that is entirely or partially managed,
owned, or run by Palm Garden or its promoters in India.

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 Shall refer to any location where any activity related to the Palm
Workplace
Garden Boutique Hotel is conducted. It will comprise, but not be
restricted to:
i. All buildings, sites, businesses, organisations, offices,
divisions, branches, or units created, owned, leased, or
managed by Palm Garden Boutique Hotel.
ii. Any exterior venue, including but not limited to client sites,
vendor premises, or hospitality partner properties, where
Palm Garden-related activities are carried out.
iii. Any event, conference, seminar, off-site meeting, training,
cultural, recreational, or social gathering where behaviour
or remarks might compromise someone's dignity, mental
health, or working relationships.
iv. Back offices, service entrances, staff quarters, kitchens,
housekeeping zones, guest areas, hotel cars, staff
transportation and other operating parts of the hotel.
v. Any location an employee visits as a result of or while
working for Palm Garden Boutique Hotel or its affiliates,
including transportation.
vi. Any type of virtual workspace, such as company message
systems, tools for collaboration at work, or video
conferencing software for hotels.
vii. Any misconduct that takes place on social media, email,
text messaging, or other electronic platforms, whether or
not it takes place during or after business hours.
viii. Any encounter, whether in person or virtually, that affects
professional relationships or fosters a hostile or frightening
work environment, even when it takes place outside of
hotel grounds or business hours.

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Third Party Refers to any person or organisation that engages with the Palm
Garden Boutique Hotel in a commercial, service, or professional
capacity but is not an employee of the hotel. This covers, among
others, visitors, suppliers, contractors, subcontractors, service
providers, clients, customers, consultants, independent contractors,
business associates, partners, interns or trainees who are not
directly employed by the hotel, and anybody else who is on the
property or using the Palm Garden Boutique Hotel's operations for
formal, business, or collaborative purposes.

Aggrieved Refers to any woman of any age, whether or not she is employed,
Person including transgender women and other people who identify as
female, who alleges sexual harassment at the hands of the
Respondent.

Respondent Refers to an individual or group of individuals against whom a

sexual harassment complaint has been filed under this policy.

Internal Refers to a committee that inquires and takes suitable action on

Complaints complaints on Sexual Harassment (hereinafter referred to as the
Committee “ICC”).

Presiding Refers to an individual senior female employee of the hotel who is

officer (PO)/ the head of ICC.
Chairperson

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 Retaliation Refers to any negative action done to a witness or aggrieved
person because they reported a sexual harassment event or helped
with an investigation into a sexual harassment complaint. This
includes coercion to drop the charges, threats to report, testify, or
take part in the proceedings, and intimidation. Any offender may
face disciplinary action, including written warnings, transfers,
demotion, suspension, or termination.

IV. What is Sexual Harassment

Any verbal or physical action, as well as any communication that has unwanted,
inappropriate, or needless sexual overtones, would be considered sexual harassment. It may
include, but is not restricted to, any of the following:

a. Requests and demands for sexual favours,

b. Unwelcome sexual approaches that are verbal, physical, or visual,
c. Sexually suggestive statements, hints, and innuendos,
d. Sexual assault,
e. Sexually suggestive remarks, sex-related jokes, insults, or comments,
f. Offensive, explicit remarks about someone's body intended for them or spoken in
their presence,
g. Inappropriate and unwanted questions concerning someone's sex life,
h. Unwelcome gestures or whistles aimed at particular individuals,
i. Physical contact or contact with any part of the body,
j. Physical restraint against any portion of the body,
k. Physical restraint against one's will and any other action that might infringe upon
one's privacy,
l. Sexually suggestive or offensive behaviour that is offensive to the receiver, such as
taunts, insults, or gestures, as well as offensive posters, cartoons, images, or
drawings, emails, SMS, MMS, WhatsApp messages, and/or videos, among other
things.

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V. Circumstances of Sexual Harassment
Furthermore, if any of the following situations arise or are present in connection with any act
or conduct of sexual harassment, they may also qualify as sexual harassment:

i. Advantages or positive results at work are promised to the employee, either directly or
indirectly, in return for adhering to such behaviour;
ii. Employees who refuse to participate in or acquiesce to such behaviour face explicit or
implicit threats of unfavourable treatment;
iii. The person's current or potential work circumstances are threatened, either spoken or
inferred;
iv. The behaviour makes it difficult for the employee to do their duties or creates an
intimidating, degrading, or hostile work environment;
v. Demeaning behaviour is inflicted upon the individual, which may have an impact on
their mental or physical health.

Any unwanted sexually suggestive action or behaviour, whether verbal, nonverbal, or

physical, is considered sexual harassment and may be considered misbehaviour in the
following situations:
i. If compliance with such conduct is offered, directly or indirectly, as a requirement for
obtaining or keeping employment benefits, such as considerations for work
assignments, training access, promotions, or attendance monitoring;
ii. When a worker's reaction to such behaviour, whether favourable or unfavourable, is
taken into consideration when making choices about their employment, career
progression, or termination;
iii. When the behaviour in issue interferes with the person's ability to function
professionally or creates a hostile, demeaning, disrespectful, or psychologically
dangerous work environment.
iv. Sexual favouritism occurs, wherein an individual in a position of authority rewards
employees who comply with or reciprocate sexual advances, while denying legitimate
opportunities such as promotions, performance ratings, or salary increments to those
who do not.

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V. Internal Complaints Committee
V.1. Composition of Internals Complaints Committee-

a. Presiding Officer: A female senior employee of the company is required to serve as

the PO.
The PO of the ICC may be nominated from another office, department, or institution
of the company, including any related hotels or administrative units, if a senior-level
female employee is not available within the same workplace.
To maintain independence and prevent any power imbalance during the inquiry
processes, an external member with the necessary professional expertise and
credentials will be chosen as the PO in situations where the Respondent occupies a
position senior to the designated PO.
b. Internal Members: From among the employees who are dedicated to the cause of
women, transgender people, or experienced individuals in social work or law, at least
two ICC members must be chosen.
c. External Member: The ICC must have 2 external members chosen from among
associations or nongovernmental organizations (NGOs) dedicated to the rights of
women, transgender people, or those with knowledge of sexual harassment issues.
d. 50% Women: Women must make up at least half of all members nominated to the
ICC.
e. The hotels' HRMS platform shall regularly display the list of ICC Members.

V.2. Tenure of ICC Members-

a. The term of office for ICC members is two years from the date of nomination.
b. An ICC member may leave the organization at any time by submitting a written
resignation to the hotel.
c. The PO or any other ICC member who works for the company will automatically
leave their position when they leave the company or when their two-year term is over.

V.3. Scope of ICC-

a. To receive complaints, including anonymous reports of sexual harassment at work,

b. To institute and carry out an investigation by the established procedure as outlined in
this policy document and applicable under the Act,

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 c. To suggest to the employer the appropriate course of action, including punitive or
corrective measures,
d. To work with the employer to carry out the appropriate course of action,
e. To maintain strict confidentiality throughout the process,
f. To submit biannual reports in the format specified,
g. The ICC shall be responsible for assisting in the formulation and dissemination of
policies aimed at the prevention and prohibition of sexual harassment at the
workplace, and shall take steps to ensure that such policies are communicated
effectively to all employees.
h. The ICC shall coordinate and facilitate regular workshops, orientation sessions, and
awareness programmes to educate employees about the provisions of the POSH Act,
2013, and to ensure that all ICC members receive appropriate training as mandated
under the Act.

V.4. Removal or Replacement of ICC Members-

a. A PO or any member of the ICC shall cease to hold office and be disqualified from
continued membership under the following circumstances:
b. Upon conviction or official inquiry for any infraction under current statutory laws;
c. In the case of any violation or non-compliance with the terms mentioned in this
policy;
d. If convicted in an internal disciplinary action, or if one is still in progress;
e. In the event that it is proven that the person has abused their position in a way that
jeopardises the Committee's integrity or impacts the public interest;
f. In the event that a vacancy results from resignation, death, disability, disqualification,
or termination of employment, the company will designate a successor in compliance
with the relevant laws and nomination protocols.

VI. Procedure of Complaint

VI.1. Resolution through Conciliation

i. If the aggrieved person requests it, the ICC will act to conciliate a settlement between
her and the respondent after receiving a complaint. Conciliation attempts to settle

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 disputes peacefully; it does not indicate that the Respondent accepts the complaint.
Conciliation cannot be based on a monetary settlement.
ii. The ICC shall document any settlement made and provide it to the Company for
further action.
iii. Both the Respondent and the Aggrieved Person shall receive copies of the settlement.
iv. The ICC shall stop investigating when a settlement is put into effect.

VI.2. Resolution through Formal Inquiry

a. A written complaint can be submitted to the ICC within a period of three months from the
date of the incident. In cases involving a series of such incidents, the complaint may be
submitted within three months from the date of the last occurrence of such an event.
Complaints may be submitted physically or via the official ICC email:
[email protected].

b. Where the ICC is satisfied that the aggrieved person was unable to file the complaint
within the prescribed timeframe due to exceptional circumstances, the ICC may extend the
said period by three months maximum after recording reasons for doing so.

c. Wherever feasible, the aggrieved party should give precise and comprehensive details
about the occurrences, dates, and parties involved. The following information may be
provided when submitting a complaint:

i. Time, date, location, and other details about the supposed incident, topic, or
issue;
ii. The respondent's name and information (the individual the complaint is directed
at);
iii. Names and contact information of any potential witnesses;
iv. Documentary proof, if it's accessible, like emails, SMS, WhatsApp
conversations, CCTV footage, audio and video recordings, etc.
v. Any further proof or supporting documentation.

d. If the aggrieved person is physically incapable of filing the complaint,

i. A friend or family member;

ii. A coworker;
iii. An officer of the State Women's Commission or National Commission for Women;
iv. Any person with knowledge of the incident may file the complaint with the aggrieved
person's written consent.

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e. When the aggrieved person is mentally incapacitated, in such cases,

i. A friend, family member, or coworker;

ii. A special educator;
iii. A licensed psychiatrist or psychologist;
iv. A guardian or authority whose care the aggrieved person is receiving treatment;
v. Any individual with knowledge of the incident in conjunction with any of they may
file a complaint.

f. If the aggrieved person is no longer alive, anybody who knows about the occurrence may
register a complaint with the written approval of the aggrieved person's legal successor.

VI. 3. Anonymous Complaint

An anonymous complaint may be taken into consideration by the ICC if it includes specific,
reliable, and verifiable information about the alleged sexual harassment incident or incidents,
such as the approximate date, time, location, type of incident, and identities of the parties
involved.

i. Upon receiving such a complaint, the ICC shall have the discretion to conduct a
preliminary assessment to determine whether there exists sufficient material to
warrant initiating a discreet inquiry or reaching out to the potential Aggrieved Person,
if identifiable.
ii. An anonymous complaint that is vague, unsubstantiated, or lacking in necessary
particulars shall not be acted upon by the ICC.
iii. The ICC ensure that, in the event the identity of the complainant is subsequently
known or discovered during the inquiry process, such identity shall be kept strictly
confidential in accordance with the provisions of the POSH Act, 2013.
iv. In the event that the ICC finds any anonymous complaint to have been filed with
malicious intent, false information, or to wilfully malign any individual, the IC may
record its findings in writing and recommend appropriate action as per the provisions
of this policy, without compromising the integrity or safety of genuine complainants.

VI.4. Interim relief

i. During pendency of the inquiry, the Aggrieved person may through a written
request ask the ICC to pass interim reliefs and the ICC may after perusal of such
request recommend the employer to:

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 a. Move the Respondent or the Aggrieved Person to a different department,
position, Palm Garden Boutique Hotel, or city;
b. Give the aggrieved party a maximum of three months of leave on top of the
leave to which she would normally be entitled;
c. Stop the Respondent from evaluating the resentful woman's performance at
work or composing her private report and giving it to another worker;
d. Provide whatever further relief that may be necessary;

Once the recommendations of interim relief are implemented, the same is informed to the
committee.

VI.5. Procedure for conducting inquiry

a. The ICC shall, within seven working days of receiving the complaint, serve a copy of
the complaint submitted by the Aggrieved Person to the Respondent.
b. In cases where the complaint is received through electronic communication, the PO
shall forward the complaint to the Respondent, along with strict instructions to
maintain confidentiality and refrain from discussing the matter with any other
individual.
c. Within ten working days after receiving the complaint materials, the Respondent must
provide a written response to the complaint, a list of supporting documentation, and
the names and contact information of any witnesses.
d. Should the aggrieved person or respondent choose to call any witness or witnesses,
they must notify ICC in writing of the names of the witnesses they intend to call.
e. Copies of any papers that the aggrieved woman wishes to present as evidence before
the ICC must be provided. Likewise, the Respondent must provide copies of any
papers they choose to submit as evidence before the ICC. To confirm that these
documents are genuine, both must sign the corresponding paperwork.
f. The ICC will have the same authority to make an investigation under the POSH Act
2013 as a Civil Court under the Code of Civil Procedure, 1908, specifically:
i. Summoning someone, making sure they show up, and having them testify
under oath.
ii. Requiring that records be found and produced; and
iii. Anything more that could be required.
g. If the aggrieved person or respondent does not show up for the three consecutive
sessions called by the PO without sufficient cause, the ICC may end the investigation

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 process or issue an ex-parte ruling on the complaint. However, the ICC must provide
the party or parties written notice fifteen days prior to the termination or ex-parte
ruling.
h. The Aggrieved person, Respondent, and witnesses will all get written notice from ICC
of the times and dates of its meetings.
i. The ICC shall meet with the aggrieved person and the respondent at a convenient
Palm Garden Boutique Hotel or at any other place that the ICC designates for such
sessions.
j. Every step of the investigation process shall be meticulously recorded and deemed as
confidential, with access restricted individuals on a need-to-know basis.
k. To verify their legitimacy, the individuals involved, and the ICC must approve the
investigation's procedures and the witness statements.
l. No lawyer may be brought in by the aggrieved person or the respondent to represent
them in court at any point throughout the ICC procedures.
m. The investigation must be finished by ICC within a reasonable amount of time, but no
more than ninety days. Within ten days of that time, the Employer shall get a final
report from ICC that includes recommendations if the accusations are true or if the
complaint is malicious or untrue. The parties the respondent and the aggrieved person
shall also have access to this report.
n. After receiving the ICC's final report, the Employer must implement recommendation
within sixty days.

VI.6. Punishment

No action shall be taken if the accusations by the Aggrieved Person are proven untrue or is
determined to be without merits by the ICC.

After providing a closure report to both the Aggrieved Person and Respondent (only if the
conversation has already started with the Respondent), the case is closed if the Aggrieved
Person withdraws the complaint before to or during the ICC procedures.

When the committee determines that the accusation against the respondent has been proven
true, it advises the employer to take the appropriate steps to address sexual harassment as
misbehaviour in line with the relevant service rules and regulations. These steps might
include:

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 i. Disciplinary action including obtaining written apology, reprimand, warning,
censure; Withholding of promotion/ pay raise/ increment;
ii. Termination of employment;
iii. Suspension;
iv. Counselling;
v. Community service;
vi. Or any other action that the employer may deem fit.

The ICC will advise the Employer to withhold from the Respondent's income the amount it
deems suitable to be given to the Aggrieved Person or their heirs.

i. The ICC shall consider the following when deciding how much should be given to
the aggrieved person:
ii. Emotional misery, agony, suffering, and mental trauma;
iii. Incurred medical costs;
iv. The loss of a professional chance;
v. The respondent's income and financial situation.
vi. Viability of making such a payment in instalments or in whole.

VI. Confidentiality
i. All matters relating to a sexual harassment complaint shall be treated with the utmost
confidentiality. This includes, but is not limited to, the details of the complaint, the
identities and addresses of the Aggrieved Person, the Respondent, and any witnesses,
as well as the content and outcome of any conciliation or inquiry proceedings. The
inquiry report, along with the recommendations of the ICC and any action taken
pursuant thereto, shall not be disclosed or disseminated to the public, press, or media
in any manner whatsoever.
ii. Every participant in the ICC investigation will be required to sign a secrecy oath, the
specifics of which will be determined by the ICC.
iii. When someone is proven to have broken the confidentiality agreement, there shall be
severe repercussions, which may include but are not limited to wage deductions or
withholdings, permanent or temporary termination from the company, and other
disciplinary actions.

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 iv. In accordance with the Act, government authorities shall be provided with pertinent
information.

VII. Malicious Complaints:

i. It is forbidden to abuse this POSH Policy to falsely accuse coworkers of being
malevolent or unfounded.
ii. If, upon thorough inquiry, the ICC concludes that the complaint was lodged with
malicious intent, was knowingly false, or supported by forged or misleading evidence,
it may recommend that the employer initiate suitable disciplinary action against the
Complainant or Aggrieved Person, as applicable.
iii. Such disciplinary measures may include, but are not limited to, a formal written
apology, issuance of a warning or reprimand, adverse impact on appraisals or
promotion, withholding of increments, termination of employment, referral to
counselling, or assignment of appropriate community service.
iv. The ICC shall consider that a complaint's inability to be proven does not always
indicate malevolent intent when making its determination. A distinct investigation is
required to prove malicious intent.

VIII. Filing of Complaint with Police

No person shall be prevented by these rules and procedures from concurrently filing a police
complaint on any act that constitutes a legal offense. In this regard, the company shall offer
support if requested by the aggrieved person.

IX. Appeal
Any party aggrieved by the implementation, non-implementation, or outcome of the
recommendations issued by the In ICC may prefer an appeal to the designated appellate
authority, as provided under the applicable provisions of the Act. Such an appeal shall be filed
within a period of ninety days from the date on which the recommendations were
communicated.

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X. Awareness and Sensitization
As part of the Palm Garden Boutique Hotel's efforts to create a respectful and safe work
environment, it will make sure that all staff members receive training on sexual harassment
issues and are aware of their rights, responsibilities, and the processes set forth in this policy
and the POSH Act, 2013.

i. The Human Resources Department and ICC shall oversee establishing and upholding
a secure workplace free from sexual harassment.
ii. Regular workshops and awareness campaigns shall be held to educate staff members
about the policies outlined in this document.
iii. Employees should be able to readily access the names and phone numbers of ICC
members.

CATEGORY OF TRAINING REQUIREMENT TIMELINE

EMPLOYEE

New Employees It is necessary for all new hires to complete Within ninety days of
harassment prevention training. Modules on commencement of their
the concept of sexual harassment, instances employment.
of banned behaviour, reporting procedures,
and the POSH Act of 2013's redressal
process will all be covered in the course.

Employees Workers moving into supervisory or Within ninety days of

transitioning into management positions will receive further commencement of their
managerial or training. The focus of this training will be on employment.
supervisory roles managerial staff's legal responsibilities, their
roles in preventing and handling complaints,
and the repercussions of non-compliance.

All Employees Every employee must complete refresher Once a year

(Periodic training on a regular basis, including

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 Refresher) following significant changes to this policy
or the relevant legislation.

All the training courses covered by this policy can be taken online or in person. The Human
Resources Department will keep track of all training obligations and document and record
each session, including attendance, materials utilized, and completion status.

To consider any changes to relevant legislation, court rulings, and current best practices in
workplace conduct and gender sensitization, the ICC will regularly evaluate and revise the
training curriculum in coordination with the Human Resources Department.

If required training sessions are missed without good reason, it will be considered a violation
of the terms of employment under this policy and may result in appropriate administrative
and disciplinary action

XI. Roles and Responsibilities of the Employer

a. In compliance with the POSH Act, 2013 and the company's Code of Conduct, the
employer must create, publish, and uphold a sexual harassment policy that is available
to all workers.
b. In addition to leading the policy's distribution, periodic evaluation, and any required
adjustments, the employer is responsible for making sure that human resources staff
members are taught to comprehend, apply, and advocate for this policy.
c. The employer shall be responsible for making sure that all members of the ICC have
their names, phone numbers, and email addresses clearly visible in reception areas, on
notice boards, and on the company's digital communication channels.
d. The employer will regularly host awareness programs, workshops, and refresher
courses that will be given both in-person and online to educate staff and management
on how to spot, stop, and report sexual harassment.
e. No information shall be shared with anyone not authorized by this policy, unless it is
necessary for an investigation or required by law. The Employer shall regard all
complaints, records, and inquiry processes under this policy as secret.

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 f. A zero-reprisal policy will be implemented by the employer, guaranteeing that
anybody who complains or takes part in an investigation won't face any negative
consequences or retaliation.
g. To detect and resolve such issues before they worsen, the employer will assign
Human Resources to proactively seek input, carry out frequent check-ins, and keep an
eye on workplace culture.
h. The Employer must promptly implement any disciplinary or corrective actions
suggested by the ICC in compliance with this Policy and any relevant service
regulations.
i. Under this policy, the employer is responsible for making sure that all deadlines,
inquiry processes, record-keeping, and reporting adhere to the POSH Act of 2013 and
any other relevant legal obligations.
j. To maintain a safe and courteous workplace, the Employer must evaluate the efficacy
of its POSH framework, which includes policy provisions, training programs, and
grievance-redressal mechanisms, at least once every 12 months and take remedial
action as needed.

XII. Biannual Report

Every calendar year, the ICC is required to write a biannual report in a format that may be
regulated and submit it to the District Officer (as defined by the Act) and the Employer. The
following information will be included in the report:

i. Number of grievances filed throughout a six-month period;

ii. Number of complaints resolved during six months;
iii. Number of cases that have been open for more than ninety days;
iv. Number of awareness-raising events or seminars held;
v. Development and results of the training.
vi. Type of action that the employer took.

XII.1. Meetings of the Internal Complaints Committee

a. At least twice a year, the ICC will meet to discuss how it operates, discuss issues that
have been resolved or are still ongoing, and evaluate how the POSH Policy and
associated awareness campaigns are being implemented.

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 b. Each meeting's agenda will cover, among other things:
i. Revaluation of the submitted complaints and the state of any ongoing
investigations;
ii. Talk about the planned and executed training and sensitization programs;
iii. assessment of the environment and workplace procedures for adherence to
POSH regulations;
iv. Considering any suggested policies, structural flaws, or preventative
actions.
c. Unless an urgent problem requires a shorter notice time, the Presiding Officer or
designated member shall give all ICC members a written notice of the meeting and
the agenda at least seven 7 days in advance.
d. All ICC meetings, whether they are held in person or online, need the participation of
the external member.
e. Any ICC meeting requires a quorum of three members, which must inevitably include
the external member and the presiding officer. A senior female ICC member will chair
the meeting if the presiding officer is not present.

XIII. Amendment
The Company may update, repeal, or change any of its provisions as and when it deems
appropriate. The employees shall be informed of any changes, amendments, or cancellations.

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 ANNEXURE 1
Members of Internal Complaints Committee

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 ANNEXURE 2
COMPLAINT FORMAT
1. Details of aggrieved person

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3. Details of Respondent

4. Details of Incident

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 ANNEXURE 3

List of Palm Garden Group Companies in India

❖ Palm Garden Boutique Hotel Private Limited

❖ Palm Garden Hospitality Services Limited
❖ Palm Garden Resort & Spa Limited
❖ Palm Garden Culinary Experiences LLP
❖ Palm Garden Events & Destination Management Private Limited
❖ Palm Garden Retreats and Villas Private Limited
❖ Palm Garden Travel & Tours Limited
❖ Palm Garden Heritage Hotels Private Limited
❖ Palm Garden Wellness & Ayurveda Retreat LLP
❖ Palm Garden Urban Stay Residences Limited

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 ANNEXURE 4
Copy of Section 75 of Bhartiya Nyaya Sanhita (BNS)

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 ANNEXURE 5
Role of Human Resources Department

The Human Resources Department shall act as a custodian of this Policy and support
the ICC in creating a safe, inclusive, and harassment-free workplace. In particular, HR
shall:

1. Ensure all employees have access to the POSH Policy and related procedures
through internal communication channels.

2. Immediately forward any written complaint received to the ICC and assist in
the inquiry process, while maintaining strict confidentiality.

3. Provide administrative and logistical support to the ICC for timely and fair
disposal of complaints.

4. Coordinate regular awareness and training programmes on prevention of sexual

harassment in collaboration with the ICC.

5. Ensure contact details of ICC members are clearly displayed and accessible at
all times.

6. Implement the final recommendations of the ICC and take necessary corrective
action.

7. Refrain from independently investigating complaints unless directed by the

ICC or Legal Department.

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