Adhikar Microfinance Pvt Ltd is committed to creating and maintaining a healthy working environment for its employees, enabling them to work without fear of prejudice, gender discrimination and sexual harassment. The fundamental rights guaranteed in the constitution of India are of sufficient amplitudes to encompass all facets of gender equality; therefore, Adhikar believes that all its employees have right to be treated with dignity.


Conduct or behavior which constitutes sexual harassment include, but are not limited to:

a. Physical conduct

  • Unwelcome physical contact including patting, pinching, stroking, kissing, hugging, fondling, or inappropriate touching
  • Physical violence, including sexual assault
  • Physical contact, e.g. touching, pinching
  • The use of job-related threats or rewards to solicit sexual favours

b. Verbal conduct

  • Comments on a worker’s appearance, age, private life, etc.
  • Sexual comments, stories and jokes
  • Sexual advances
  • Repeated and unwanted social invitations for dates or physical intimacy
  • Insults based on the sex of the worker
  • Condescending or paternalistic remarks
  • Sending sexually explicit messages (by phone or by email)

c. Non-verbal conduct

  • Display of sexually explicit or suggestive material
  • Sexually-suggestive gestures
  • Whistling
  • Leering


Complaints procedures:

Anyone who is subject to sexual harassment should, if possible, inform the alleged harasser that the conduct is unwanted and unwelcome. If a victim cannot directly approach an alleged harasser, he/she can approach one of the designated staff members responsible for receiving complaints of sexual harassment. This person could be another supervisor, a member of the human resources department, etc.

If a victim cannot directly approach an alleged harasser, he/she can approach one of the designated staff members responsible for receiving complaints of sexual harassment. This person could be another supervisor, a member of the human resources department, etc.

When a designated person receives a complaint of sexual harassment, he/she will:

  • Immediately record the dates, times and facts of the incident(s)
  • Ascertain the views of the victim as to what outcome he/she wants
  • Ensure that the victim understands the company’s procedures for dealing with the complaint
  • Discuss and agree the next steps: either informal or formal complaint, on the understanding that choosing to resolve the matter informally does not preclude the victim from pursuing a formal complaint if he/she is not satisfied with the outcome
  • Keep a confidential record of all discussions
  • Respect the choice of the victim
  • Ensure that the victim knows that they can lodge the complaint outside of the company through the relevant country/legal framework

a. Informal complaints mechanism

If the victim wishes to deal with the matter informally, the designated person will:

  • Give an opportunity to the alleged harasser to respond to the complaint
  • Ensure that the alleged harasser understands the complaints mechanism
  • Facilitate discussion between both parties to achieve an informal resolution which is acceptable to the complainant, or refer the matter to a designated mediator within the company to resolve the matter.
  • Ensure that a confidential record is kept of what happens
  • Follow up after the outcome of the complaints mechanism to ensure that the behaviour has stopped
  • Ensure that the above is done speedily and within 7 days of the complaint being made

b. Formal complaints mechanism

If the victim wants to make a formal complaint or if the informal complaint mechanism has not led to a satisfactory outcome for the victim, the formal complaint mechanism should be used to resolve the matter.

The designated person who initially received the complaint will refer the matter to a senior human resources manager to instigate a formal investigation. The senior human resources manager may deal with the matter him/herself, refer the matter to an internal or external investigator or refer it to a committee of three others in accordance with this policy.


Implementation of this policy:

The Internal Committee shall consist of the following members to be nominated by the employer:

  • Presiding Officer- Shall be a woman, employed at a senior level at workplace from amongst the employees. Provided that in case a senior level woman employee is not available, the Presiding Officer shall be nominated from other offices or administrative units of the work place. Provided further that in case the other offices or administrative units of the workplace do not have a senior level woman employee, the Presiding Officer shall be nominated from any other work places of the same employer or other departments or other organisation.
  • Not less than two members from amongst employees preferably committed to the cause of women or who have had experience in social work or have legal knowledge;
  • 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:
  • Provided that at least one-half of the total Members so nominated shall be women.

Adhikar Microfinance Pvt. Ltd. will ensure that this policy is widely disseminated to all relevant persons. It will be included in the staff handbook. All new employees must be trained on the content of this policy as part of their induction into the company.

Every year, Adhikar Microfinance will require all employees to attend a refresher training course on the content of this policy. It is the responsibility of every manager to ensure that all his/her employees are aware of the policy.


Monitoring and evaluation:

Adhikar Microfinance recognises the importance of monitoring this sexual harassment policy and will ensure that it anonymously collects statistics and data as to how it is used and whether or not it is effective.

Supervisors, managers and those responsible for dealing with sexual harassment cases will report on compliance with this policy, including the number of incidents, how they were dealt with, and any recommendations made. This will be done on a yearly basis. As a result of this report, the company will evaluate the effectiveness of this policy and make any changes needed.


Annual Calendar:

The Internal Committee, shall in each calendar year prepare, a calendar and an annual report and submit the same to the employer.

  1. Meeting: The committee will meet once in every quarter as per the prior notification by the Presiding Officer.
  2. Minutes of the Meeting: The minutes of the meeting will be prepared by the committee member and the report of the meeting will be shared to the employer within 10 days from the date of commencement of the meeting.
  3. Function of the Committee: The committee will function as per the laid down rules / principles.

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