Within a period of 7 (Seven) working days from the date of receipt of the Complaint by the Internal Committee, a copy of the Complaint and supporting document is required to be forwarded to the Respondent.

• The Respondent upon receipt of the Complaint and such document(s) would be required to file his reply along with supporting documents, name(s) of witness/s (if any) and their address(s) within a period of 10 working days.
• The Internal Committee as the case may be will conduct the enquiry in accordance with the principles of natural justice and basis the facts and circumstances of each case.

1. Settlement Option prior to initiation of Inquiry:

1. • Prior to initiation of Inquiry, the Internal Committee may at the instance of, and pursuant to specific requests of the Complainant, initiate conciliation proceedings for the resolution of the Complaint of Sexual Harassment.
   • In the event, the Complainant and Respondent agree to settle the matter by conciliation; the Internal Committee will discharge its functions in the capacity of an advisory body. The following steps shall be taken for resolution of a Sexual Harassment complaint by conciliation:
     1. The Internal Committee will hold meetings with the Respondent and Complainant independently/separately (in person/ virtual/ over call as deemed fit) for facilitating the conciliation process.
     2. The Complainant may choose to proceed with the conciliation in the presence of the Respondent (same room) or independently. The Internal Committee will decide on the manner in which the conciliation proceedings will be conducted based on any specific requests from the Complainant and based on assessment of the gravity of Sexual Harassment alleged.
     3. The Internal Committee will have an advisory role on the content of the dispute and the outcome of the resolution.
   • The Complainant is at liberty to withdraw from the conciliation process at any stage during the course of the conciliation process. However, the Aggrieved Employee shall intimate such decision of withdrawal in writing to the Internal Committee.
   • In cases where a settlement is successfully arrived at, the Internal Committee will record the terms of settlement and no further inquiry shall be conducted by the Internal Committee.
   • A copy of the terms of settlement so arrived at shall be sent to the Aggrieved Employee and the Respondent for the purpose of obtaining signatures. Once both signatures are obtained, a copy of the signed terms of settlement shall be sent to Anthem management so as to enable implementation of the terms of settlement.

2. Complaint withdrawal: 

The Complainant is at liberty to withdraw the Complaint of Sexual Harassment, at any time during the course of the Inquiry by giving reasons in writing for withdrawal of the Complaint.

1. • In cases where the Complainant chooses to withdraw the Complaint, the Internal Committee will dispose of the Complaint as withdrawn. A copy of the report of the Internal Committee recording reasons for withdrawal of the Complaint shall be sent to the Complainant as well as the Respondent for obtaining signatures. A signed copy of the report shall then be made available to the management of Anthem.
   • The Inquiry shall, on such withdrawal, be terminated, save in instances in which the Internal Committee is informed, knows, or has reason to believe, that the reasons for such withdrawal are the consequences or effect of coercion and intimidation exerted on the Complainant by the Respondent(s), or any person on the Respondent’s behalf. In such an instance, the Internal Committee may in its discretion and for reasons recorded in writing, continue the Inquiry in accordance with the procedure outlined in this Redressal Policy.
   • In matters where post receipt of the Complaint and initial preliminary enquiries by IC it is found that the concern has been incorrectly raised, it will be the responsibility of the IC to clarify and advise the Complainant and route the investigation under Workplace Harassment or Code of Conduct, as applicable. The decision of the IC must be recorded and also shared with the Complainant. 
   • No compensation will be paid in matters resolved through conciliatory process.

3. Formal Inquiry Procedure:

1. • In case the Internal Committee proceeds to make an Inquiry into the Complaint, the same shall be undertaken by giving a hearing to both the Complainant and the Respondent and by giving them an opportunity to cross-examine each other’s witnesses.
   • A formal notice would be sent to the Aggrieved Employee and the Respondent intimating the date, place and time for hearing of the Complaint and the proceedings proposed to be conducted on that particular day.
   • At the commencement of the hearing the Internal Committee shall:

1. Hear and record the respective versions of the Incident(s) of Sexual Harassment. The Complainant and the Respondent will be allowed to make both oral and documentary submissions.
2. Hear both the Parties independently in cases where the Internal Committee, based on an assessment of the gravity of the alleged Sexual Harassment, is satisfied that it would be necessary to minimize direct contact between the Aggrieved Employee and Respondent.
3. The Internal Committee shall have the option and may at its discretion electronically record and transcribe the proceedings at the hearing or prepare minutes of the meeting of the Inquiry. However, in cases where the Internal Committee decides to implement the option of electronically recording the proceedings, the parties being inquired during the course of the Inquiry, shall be notified prior to the date of the hearing and consent in this respect must be obtained.
   • The proceedings so recorded and the transcriptions thereof shall be kept confidential by the Internal Committee to the extent possible, while at the same time allowing the Internal Committee to conduct its proceedings effectively.

1. • The Internal Committee shall make an inquiry into the Complaint in accordance with the principles of natural justice. The principles of natural justice include: (a) communication of the allegations against the Respondent; (b) equal opportunity to the Parties to present 
   • their respective cases; (c) fair procedure and procedural due process; and (d) impartial and unbiased proceedings.
   • In case the Respondent is consecutively not presently for three hearings of the Internal Committee, then the Internal Committee can proceed ex-parte i.e. commence proceeding without the presence of the Respondent.
   • The concerned parties before the Internal Committee, including the Aggrieved Employee, the Respondent and the witnesses shall not be permitted to be represented through legal practitioners/advocates.
   • The Internal Committee during the course of hearing the Aggrieved Employee, Respondent and their witnesses, may:
     1. Orally examine and seek detailed information, explanation and reasoning from both the Aggrieved Employee and the Respondent on the complaint, reply and oral submissions made by the Parties.
     2. Examine the documentary proof submitted by both Aggrieved Employee and the Respondent and seek detailed information and explanation from them connection with any evidence so submitted.
     3. Orally examine and seek detailed information from the witnesses in connection with any material question relating to the complaint of Sexual Harassment.
     4. The inquiry into a complaint of Sexual Harassment shall be completed as soon as   possible and in any event within a period of 90 (Ninety) days from the date of receipt of the complaint.

4. Conclusion of Inquiry and Preparation of Report

1. • On completion of the Inquiry, the Internal Committee by way of a reasoned report may:
     1. Dismiss the complaint of Sexual Harassment as being malicious or false; or
     2. Dismiss the complaint of Sexual Harassment in cases where the Internal Committee arrives at a conclusion that the allegations against the Respondent have not been proved; or
     3. Find the Complaint of Sexual Harassment proven and give findings to that effect. Where the Internal Committee finds and arrives at a conclusion that allegations against the Respondent are substantiated and proved, the Internal Committee shall make recommendations to the management , which may include:

1. • 1. 1. Taking action for Sexual Harassment as a misconduct in accordance with Act.
        2. Deducting salary or wages of the Respondent in such sum as may be considered appropriate to be paid to the Aggrieved Employee as compensation.

1. • 1. 1. 1. The recommendation for deduction of salary is not mandatory and any such deductions may only be made at the discretion of the Internal Committee. While determining the sums to be paid (if any) to the Aggrieved Employee, the Internal Committee shall be guided by the existing statutory guidelines.
           2. Where the Internal Committee arrives at a conclusion that the allegations made in the complaint of Sexual Harassment against the Respondent are substantiated and proved, the Internal Committee shall recommend to the management of Anthem to take disciplinary action, up to and including termination of services of such employee.

1. • Recommendation of the Internal Committee is to be acted upon by Anthem management within a period of 60 (Sixty) days from the date of its receipt.

5. Punishment for Sexual Harassment

1. • Upon receipt of inquiry report submitted by Internal Committee, a panel consisting of Management, Legal and HR, will consider and examine the findings and the recommendations of the Internal Committee contained in the report and implement the recommendations in accordance with the internal procedure and rules of Anthem within a period of 2 (Two) months from the date of receipt of the inquiry report.
   • Punishment awarded to the guilty Respondent would be in accordance with the terms of the employment agreement and commensurate with the nature of the offence committed. The punishment awarded to a guilty Respondent may include termination of service and directing registration of First Information Report (“FIR”) with the police authorities, if deemed fit. The punishment may include:
     1. Written apology;
     2. Warning;
     3. Reprimand/Censure;
     4. Withholding of promotion;
     5. Withholding of pay rise/increments;
     6. Termination.

6. Protection against Retaliation and Victimization

1. • A Complaint made in good faith to the Internal Committee including the Reply submitted would be treated as strictly confidential and details of the same would not be published or communicated to the public. The Aggrieved Employee lodging the Complaint and any person providing information or any witness, will be protected from any form of retaliation or victimization.
   • While dealing with Complaints relating to Sexual Harassment, the Internal Committee shall ensure that the Complainant or the witness are not victimized or discriminated against by the Respondent. Any unwarranted pressures, retaliatory or any other type of unethical behavior from the Respondent against the Complainant or witnesses relied on by the respondent or the Aggrieved Employee during the pendency of enquiry proceedings should be reported to the Internal Committee. If the same is proved genuine/bonafide, appropriate disciplinary action will be taken by the Internal Committee against any such complaints which are found genuine.
   •  During the course of inquiry proceedings the Internal Committee on its own or on a written request of the Aggrieved Employee, may recommend to the management of Anthem to:
     1. Transfer the Aggrieved Employee as per his/her request and comfort or the Respondent to any other Workplace;
     2. Restrain the Respondent from reporting on the work performance of the Aggrieved Employee or writing the Aggrieved Employee’s confidential report, appraisals, annual appreciation certificate. These matters should be assigned to another person of appropriate rank and position;
     3. Grant leave to the Aggrieved Employee- for a period of 3 months (paid leave). The leave(s) granted to an Aggrieved Employee under this Redressal Policy shall be in addition to the leaves the Aggrieved Employee would be entitled to on account of being an Employee of Anthem;
     4. Grant any other such relief to the Aggrieved Employee as the Internal Committee may deem fit in the facts and circumstances of the Complaint.
   • Upon completion of Inquiry proceedings, in case the Complaint is found to be malicious and where malafide intention of the Complainant has been clearly established and proved, appropriate actions would be taken against the Complainant in accordance with the decision by the IC & Management.

7. Obligation of the Management:

1. • Adequate publicity and training will be given at Workplace regarding the penal consequence of Sexual Harassment.
   • Workshops and awareness programmers will be conducted at regular interval to sensitize employee regarding provisions of the Act and the Rules.
   • Facilitate the functioning of Internal Committee, including securing the attendance of the Respondent.

8. Powers and Duties of the Internal Committee

The powers and duties of the Internal Committee shall be as follows, namely:

1. • To inquire into Complaints concerning Sexual Harassment and to take suitable action in accordance with the Act.
   • To do all such acts and things as may be necessary to carry out the objects of this Redressal
   • Maintain strict confidentiality with respect to a Complaint and Inquiry proceedings initiated pursuant thereto.
   • Upon completion of Inquiry conducted in relation to Sexual Harassment Complaint, to submit its report and recommendation to Anthem management within 10 days from the date of completion of Inquiry.

9. Complaints made with a Malicious Intent

• This Policy has been adopted as a tool to ensure that in the interest of justice and fair play, Anthem’s Employees have a forum to approach and redress their grievances in the event of instances of Sexual Harassment. However, if on investigation it is revealed that the Complaint was made with a malicious intent and with the motive of maligning the concerned Respondent, tarnishing the Respondent’s image in Anthem or otherwise to settle personal or professional scores, strict action will be taken against the Complainant. A panel consisting of Chief Human Resource Officer, Management; Legal shall consider the Internal Committee’s Report and decide the nature of action to be initiated against the Complainant in accordance with the law. The recommendations of IC shall be final and binding upon the parties and employer. The employees who are victims of such malicious Sexual Harassment Complaints may, in addition to the above, seek legal remedies as may be provided under the various laws for the time being in force.

10. Punishments for Filing of False/Malicious Complaint

• The punishment(s) for filing a malicious/false Complaint or production of false, fabricated or forged evidence before the Internal Committee by a Complaint, may include any disciplinary action not less than termination of services. It is clarified that mere inability to substantiate a complaint or provide adequate proof need not attract action against the Complainant. The punishment(s) enumerated above can be recommended by the Internal Committee against any witness who gives false or forged documentary evidence to the Internal Committee.

11. Record Retention and Periodic Update to Management

1. • Internal Committee shall maintain a record of all incidents related to Sexual Harassment. Such records shall be updated on a half yearly basis and Anthem’s management shall be provided with a copy of the report, once updated.
   • Records shall be maintained and retained as per the statutory requirement.