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Anti-Sexual Harassment Policy – Zerlon Semi Private Limited

Anti-Sexual Harassment Policy

​

Effective Date: 10.03.2026

 

Applicability: All employees, interns, consultants, trainees, vendors, and stakeholders at Zerlon Semi or at any location where Company business is conducted.

1. Purpose & Objective

Zerlon Semi Private Limited is committed to providing a safe, respectful, and inclusive workplace free from sexual harassment.

The purpose of this policy is to:

  • Prevent and prohibit sexual harassment at work

  • Promote dignity, equality, and a harassment-free environment

  • Establish a framework for addressing complaints

  • Comply with the Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013

2. Scope

This policy applies to:

  • All employees (permanent, contractual, temporary)

  • Interns and trainees

  • Consultants, vendors, contractors

  • Off-site, remote, field, and work-related travel locations

 

Anywhere – physical or virtual – where work-related interactions occur.

3. Definition of Sexual Harassment

Sexual harassment includes (but is not limited to):

A. Physical Conduct

  • Unwelcome touching, patting, hugging, brushing

  • Requests for intimacy

  • Assault

B. Verbal Conduct

  • Sexual jokes, comments on appearance

  • Unwanted advances or suggestive remarks

  • Derogatory remarks about gender or body

C. Non-Verbal / Visual Conduct

  • Leering, staring

  • Sending inappropriate messages/photos

  • Displaying sexually explicit images

D. Quid pro quo

  • Conditioning employment benefits on sexual favors

 

E. Hostile Work Environment

  • Any conduct that creates an intimidating or offensive environment

 

This definition is aligned with Section 2(n) of the POSH Act.

4. Zero Tolerance Policy

Zerlon Semi has a zero tolerance approach to sexual harassment in any form.

Any violation will attract strict disciplinary action, including termination, irrespective of position or seniority.

5. Internal Complaints Committee (ICC)

In compliance with the POSH Act, Zerlon Semi will constitute an Internal Complaints Committee (ICC) with:

 

Composition

  • Presiding Officer (Senior Woman employee)

  • At least two other employees (gender-sensitive)

  • External member (trained in gender/psychology/legal)

 

Functions

  • Receive and examine complaints

  • Conduct inquiries in a fair, confidential manner

  • Recommend corrective actions

  • Ensure compliance with legal timelines

6. Filing a Complaint

Who Can File

  • Any employee affected directly or indirectly

  • Anyone who witnesses or becomes aware of an incident

 

How to File

  • Written complaint (email or physical)

  • Within 3 months of the incident

  • Every complaint is acknowledged within 3 working days

 

Confidentiality

All details are kept strictly confidential to the extent possible.

7. Inquiry Process

  • ICC reviews complaint and may ask for preliminary clarification

  • A formal inquiry will normally be completed within 90 days

  • Both Complainant and Respondent will be heard

  • Decisions are based on evidence and fair evaluation

  • ICC submits a written report with recommendations

8. Disciplinary Actions

Depending on severity and findings, actions may include:

  • Verbal / written warning

  • Transfer or suspension

  • Mandatory training or counseling

  • Termination of employment

  • Reporting to law enforcement if applicable

9. Protection Against Retaliation

9. Protection Against Retaliation

 

No employee shall be:

  • Disciplined

  • Disadvantaged

  • Humiliated

  • Retaliated against

 

for reporting in good faith or participating in the investigation.

10. Counseling & Support

Zerlon Semi shall facilitate:

  • Counseling support for the Complainant

  • Medical support if required

  • Guidance on legal remedies outside the ICC process

11. Awareness, Prevention & Training

The Company will conduct periodic:

  • POSH awareness sessions

  • Training workshops for employees and managers

  • ICC training on legal framework and inquiry techniques

12. Record Keeping

The ICC will maintain records of:

  • Complaints received

  • Inquiry proceedings

  • Recommendations made

  • Actions taken

 

Records shall be preserved for at least 7 years.

13. Monitoring & Review

This policy will be reviewed periodically to:

  • Ensure compliance with evolving law

  • Improve effectiveness and awareness

  • Incorporate feedback from ICC or leadership

14. Contact & Reporting

For filing complaints, enquiries, or guidance:

 

Internal Complaints Committee (ICC) – Zerlon Semi

Zerlon Semi Private Limited

Email: legal@zerlonsemi.com

Phone: +91 70266 33266

Address: Zerlon Semi Private Limited, 15, Ramlakshman Nagar, Sowripalayam, Coimbatore-641028

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