Prevention of Sexual Harassment (POSH) Policy

Medigence Solutions Pvt. Ltd. & Levitant Global Design
Original Effective Date: 01/08/2025
Revised Effective Date: 01/04/2026

1. Purpose

Medigence Solutions Pvt. Ltd. and Levitant Global Design (“the Company”) are committed to creating a safe, respectful, and inclusive workplace for all employees.
This policy aims to prevent, prohibit, and address incidents of sexual harassment in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, and to promote a culture of dignity, equality, and mutual respect.

2. Scope

This policy applies to:

  • All employees (irrespective of gender), including permanent, temporary, interns, trainees, and consultants
  • Employees of both Medigence Solutions Pvt. Ltd. and Levitant Global Design • Vendors, contractors, clients, and third parties associated with the Company It covers incidents that:
  • Occur at the workplace or any work-related setting (including client locations, offsite meetings, travel, and events)
  • Occur in virtual/remote work environments
  • Involve any individual associated with the Company
  • Are reported by any gender or sexual identity

3. Definition of Sexual Harassment

As per the Act, sexual harassment includes any unwelcome act or behavior (whether directly or by implication), such as:

  • Physical contact or advances
  • Demand or request for sexual favors
  • Making sexually colored remarks
  • Showing pornography or inappropriate content
  • Sending offensive emails/messages
  • Any unwelcome physical, verbal, or non-verbal conduct of a sexual nature It also includes situations where:
  • Submission to such conduct is made a condition of employment
  • It interferes with work performance
  • It creates an intimidating, hostile, or offensive work environment

4. Internal Committee (IC) / Internal Complaints Committee (ICC

A joint Internal Committee (IC/ICC) has been constituted in compliance with the Act to address complaints across both organizations.

Committee Members:

  • Presiding Officer: Ms. Meeta Patel
  • Member: Ms. Mansi Patel
  • Member: Ms. Uchita Chouhan
  • Member: Mr. Urvish Patel
  • Member: Ms. Tithi Shah
  • External Member: Adv. Maitri Patel (Advocate)

    The Committee will function independently and ensure fair, unbiased, and timely resolution of complaints.

5. Complaint Redressal Process

The Company encourages early reporting to ensure timely action.

Step 1: Reporting

  • Complaints must be submitted in writing (email or hard copy) to the IC/ICC
  • Complaint should be filed within 3 months of the incident (extendable up to 6 months under valid circumstances)

Step 2: Acknowledgment
The IC/ICC will acknowledge the complaint within 3 working days

Step 3: Inquiry

  • A fair and confidential inquiry will be conducted within 90 days
  • Both complainant and respondent will be given an opportunity to be heard
  • Evidence and witnesses will be examined


Step 4: Report & Action

  • Final recommendations will be submitted within 10 days of completion of inquiry
  • Appropriate action will be taken by the employer based on findings

6. Interim Relief

During the inquiry, the IC/ICC may recommend:

  • Transfer of either party
  • Leave up to 3 months for the complainant
  • Change in reporting structure
  • Work-from-home arrangement (if feasible)

7. Disciplinary Action

If the complaint is proven, actions may include:

  • Written apology
  • Warning or reprimand
  • Salary deduction
  • Withholding promotion or increment
  • Suspension or termination

    The action will be proportionate to the severity of misconduct.

8. Protection Against Retaliation

The Company strictly prohibits retaliation against anyone who:

  • Files a POSH complaint in good faith
  • Participates in an investigation or inquiry

    Any form of intimidation, threat, or retaliation will be treated as misconduct and subject to disciplinary action.

9. False or Malicious Complaints

While the Company encourages genuine complaints:

  • False or malicious complaints may lead to disciplinary action
  • However, inability to substantiate a complaint does not automatically mean it is false

10. Confidentiality

All complaints, identities, evidence, and outcomes will be kept strictly confidential. Any breach of confidentiality by the complainant, respondent, witnesses, or IC/ICC members may result in disciplinary action.

11. Awareness & Training

  • All employees will undergo mandatory POSH awareness training annually
  • The policy will be shared during onboarding and displayed at workplace locations and internal platforms

12. Record Keeping

All complaints, proceedings, and resolutions will be:

  • Documented and maintained securely
  • Retained for a minimum of 3 years, as per legal requirements

13. Responsibilities

Employees

  • Maintain professional and respectful conduct
  • Report incidents promptly
  • Cooperate during inquiries

Management

  • Ensure a safe work environment
  • Support IC/ICC proceedings
  • Implement recommendations effectivel

14. Policy Review

This policy will be reviewed annually or as required based on changes in law or organizational structure.

15. Approval & Authorization

Role Name Designation Signature
Prepared By Drashti Badheka HR Manager
Reviewed By Tithi Shah Operations Manager
Concurred By Meeta Patel Director
Approved By Urvish Patel Director
TOP