1.01 Swarna Tollway Private Limited (hereinafter referred to as the Company) is committed for creating a healthy working environment that enables employees to work without fear of prejudice, gender bias and sexual harassment. All employees have a right to work in an environment free from the demoralizing effects of harassment or unwelcome offensive or improper conduct. All employees of the Company have the right to be treated with dignity. The Company treats sexual harassment at the workplace as a serious misconduct and grave offence and whoever commits the said offence is liable for disciplinary action and punishment, which may include termination from the service, depending on the gravity of the case.


2.01 This Policy extends to all employees of the Company and is deemed to be incorporated in the service conditions of all employees and comes into effect immediately.

2.02 "Sexual harassment" would mean and include any one or more of the following unwelcome acts or behavior (whether directly or by implication) namely:

  • i. Physical contact and advances; or
  • ii. A demand or request for sexual favours; or
  • iii. Making sexually coloured remarks; or
  • iv. Showing pornography; or
  • v. Any other unwelcome physical, verbal or non-verbal conduct of sexual nature;

2.03 The following circumstances, among other circumstances, if it occur or is present in relation to or connected with any act or behavior of sexual harassment may amount to sexual harassment:-

  • Implied or explicit promise of preferential treatment in her employment; or
  • Implied or explicit threat of detrimental treatment in her employment; or
  • Implied or explicit threat about her present or future employment status; or
  • Interference with her work or creating an intimidating or offensive or hostile work environment for her; or
  • Humiliating treatment likely to affect her health or safety;
  • 2.04 Workplace includes any place visited by an employee arising out of or during the course of employment including transportation provided by the Company for undertaking such journey.


    3.01 If an allegation of sexual harassment against the respondent has been proved, the respondent shall be liable for such-punishment as may be recommended by the Internal

    Regd. Office: D.No. 6-3-1090, 4th Floor 'C' Block, TSR Towers, Rajbhavan Road, Somajiguda , Hyderabad - 500082, Telangana, INDIA Tel/ fax: +91 40 4027 6607, 4027 5507, Tel : +9140 2341 5841, CIN No. U45203TG2001PTC036706

    Compliance Committee (hereinafter referred to as the Internal Committee), under Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (hereinafter referred to as the Act), which may include one or more of the following:

    a. Written apology;
    b. Reprimand or censure;
    c. Withholding of promotion;
    d. Withholding of pay rise or increments;
    e. Deduction of such sums from the salary or wages, as the Internal Committee may

    consider appropriate to be paid to the aggrieved woman or to her legal heirs as compensation. If the deduction is not possible and the respondent fails to pay the said amount, the order will be forwarded to the District Officer for recovery of the sum as an arrear of land revenue;

    f. Termination from the service, with or without the compensation indicated in subclause (e) above;

    3.02 The above mentioned punishments are in addition to but not in derogation of the punishments, if any, for which the respondent will be liable under other applicable laws.


    4.01 An Internal Committee has been reconstituted by the Company to consider and redress complaints of Sexual Harassment. The Presiding Officer and Members of the Internal Committee are as follows:

    4.02 In respect of the complaint(s) received from any of the site office / project location of the Company, a member representing the respective site office / project location may be co-opted by the Internal Committee from time to time.

    4.04 A quorum of 3 members is required to be present for the proceedings to take place. The quorum shall include the Presiding Officer and at least two members, one of whom shall be a woman.


    5.01 Any aggrieved woman shall make, in writing, a complaint of sexual harassment at workplace, duly signed, to the Internal Committee. The said complaint shall be filed in six sets along with supporting documents and the names and addresses of the witnesses. The said complaint may be given to any member of the Internal Committee within a period of three months from the date of incident. However, the Internal

    Ms. A. Jayasri – Presiding Officer Mr. P.K. Raman Sai - Member Mr. Satya Sibam Sahoo - Member Mr. Kishore Kumar Karanam - Member Mr. T. Krishna Kishore - Member Ms. V. Mrudula - Independent Member.”

    Committee, for the reasons to be recorded in writing, may extend the time limit for a period not exceeding another three months, if it is satisfied that the circumstances were such which prevented the woman from filing a complaint within the initial period of three months.

    5.02 If the aggrieved woman is unable to make a complaint for any reason, the said complaint may be filed in such manner, and by such other persons, as may be specified under Rule

    6 of Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 (hereinafter referred to as the Rules) or alternatively, the aggrieved woman may contact the Presiding Officer for suitable advice in this matter.

    5.03 Aggrieved woman in relation to a workplace means a woman, of any age whether employed or not, who alleges to have been subjected to any act of sexual harassment by the respondent.

    5.04 The Internal Committee may, before initiating any inquiry and at the request of the aggrieved woman, take steps to settle the matter between her and the respondent through conciliation.

    5.05 On receipt of the complaint, the Internal Committee shall send a copy of the complaint received from the aggrieved woman, to the respondent within a period of seven working days.

    5.06 The respondent shall file his reply to the complaint along with his list of documents, and names and addresses of witnesses, if any, within a period not exceeding ten working days from the date of receipt of the copy of the complaint.

    5.07 The Internal Committee shall make inquiry into the complaint in accordance with the principles of natural justice.

    5.08 The Internal Committee shall, after giving fifteen days notice to the party concerned, have the right to terminate the inquiry proceedings or to give an exparte decision on the complaint, if the complainant or respondent fails, without sufficient cause, to present herself or himself for three consecutive hearings convened by the Presiding Officer.

    5.09 The parties shall not be allowed to bring in any legal practitioner to represent them in their case at any stage of the proceedings before the Internal Committee.

    5.10 On completion of an inquiry, the Internal Committee shall provide a report of its findings and its recommendations to the employer, within a period of ten days from the date of completion of inquiry and such report be made available to the concerned parties.

    5.11 On receipt of the report from the Internal Committee the employer will take action against those persons, who are guilty in respect of the complaint of sexual harassment.

    6. GENERAL

    6.01 The Internal Committee shall maintain a register of complaints showing the date of complaint, names of the complainant and respondents, brief of the complaint, brief of inquiry proceedings and recommendations.

    6.02 The Internal Committee shall, for each calendar year, prepare and submit to the employer, an annual report, which shall have the following details:

    • Number of complaints of sexual harassment received in the year;
    • Number of complaints disposed off during the year;
    • Number of cases pending for more than ninety days;
    • Number of workshops or awareness programmes against sexual harassment carried out;
    • Nature of action taken by the employer;

    6.03 The information in respect of complaint of sexual harassment, the identity and addresses of the aggrieved woman, respondent and witnesses, any information relating to conciliation and inquiry proceedings, recommendations of the Internal 􀁙ommittee and the action taken by the employer shall be kept confidential.

    6.04 If the Internal Committee arrives at the conclusion that the allegation against the respondent is malicious or the woman alleged to have been aggrieved or any other person making the complaint has made the complaint knowing it to be false; or has produced any forged or misleading document, it may recommend to the employer to take any one or more of the actions specified in Clause 3.01 above.