Posh Policy

POLICY ON PREVENTION OF SEXUAL HARASSMENT (POSH)

  1. Purpose:

    Firelab Diamonds Pvt. Ltd. is committed to providing a safe, secure, and respectful workplace free from sexual harassment and discrimination. The Company has adopted this Policy in accordance with the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("POSH Act").

    The Company follows a zero-tolerance approach towards any form of sexual harassment at the workplace.

  2. Scope:

    This Policy applies to:

    • All permanent employees
    • Probationers
    • Trainees and Apprentices
    • Contractual Employees
    • Consultants
    • Interns
    • Temporary Staff
    • Visitors, Vendors and Service Providers

    The policy covers incidents occurring:

    • At the workplace
    • During official travel
    • Company-sponsored events
    • Meetings, conferences, training programs
    • Virtual/online work-related interactions
  3. Meaning of Sexual Harassment:

    Sexual Harassment includes any unwelcome act or behaviour (whether direct or implied) of a sexual nature that affects an individual's dignity, creates a hostile work environment, or interferes with work performance.

    The following acts may constitute Sexual Harassment:

    1. Physical contact and advances.
    2. Demand or request for sexual favours.
    3. Making sexually coloured remarks.
    4. Showing pornography or sexually explicit content.
    5. Any other unwelcome physical, verbal, non-verbal, written or electronic conduct of a sexual nature.
  4. Forms of Sexual Harassment:
    1. Physical Harassment
      • Unwanted touching, hugging, patting or brushing against a person.
      • Physical advances of a sexual nature.
      • Blocking movement or invading personal space.
    2. Verbal Harassment
      • Sexually suggestive comments or jokes.
      • Inappropriate remarks regarding appearance.
      • Repeated requests for dates despite refusal.
      • Offensive comments about gender.
    3. Non-Verbal Harassment
      • Staring, leering or making inappropriate gestures.
      • Displaying offensive posters, pictures or screensavers.
      • Sending unwanted gifts with sexual implications.
    4. Digital / Online Harassment
      • Sending inappropriate emails, messages, images or videos.
      • Sharing offensive content through WhatsApp, social media or other digital platforms.
      • Online stalking or repeated unwanted communication.
    5. Quid Pro Quo Harassment
      • Seeking sexual favours in exchange for employment benefits, promotions, increments, transfers, confirmations, or other work-related advantages.
  5. Employee Responsibilities:

    Every employee shall:

    • Treat colleagues with dignity and respect.
    • Always maintain professional conduct.
    • Refrain from any form of sexual harassment.
    • Cooperate during investigations.
    • Respect confidentiality of complaints and proceedings.
  6. Complaint Filing Process:

    Any aggrieved employee may file a complaint through any of the following channels:

    A. Written Complaint
    Submit a written complaint to any member of the Internal Committee (IC).

    B. Email Complaint
    Send an email: posh@fireflydiamonds.com

    C. She-Box Portal
    Employees may also file complaints through the Government of India’s She-Box Portal: https://shebox.wcd.gov.in

    Complaint Timeline

    • Complaint should preferably be submitted within 3-months from the date of the incident.
    • In case of a series of incidents, within 3-months from the last incident. In case the person is unable to file it within the 3-month period, they can approach the Internal Committee who may grant a 3-month extension and record reasons for such extension in writing.
  7. Confidentiality:

    The Company shall maintain strict confidentiality regarding:

    • Identity of complainant
    • Identity of respondent
    • Witness statements
    • Inquiry proceedings
    • Recommendations and actions

    Any breach of confidentiality may attract disciplinary action

  8. Protection Against Retaliation:

    No employee shall be subjected to retaliation, victimization, discrimination, intimidation, or adverse employment consequences for filing a complaint or participating in an inquiry.

  9. Disciplinary Action:

    Where allegations are proved, the Company may take disciplinary action including:

    • Apology letter
    • Written warning
    • Strict warning from HR
    • Withholding promotion/increment
    • Transfer
    • Termination of employment
    • Counselling
    • Community service
    • Any other action deemed appropriate under Company Rules and applicable law
  10. Internal Committee (IC) – Firelab Diamonds

    The Company has constituted the following Internal Committee for prevention and redressal of sexual harassment complaints:

    Firelab Diamonds Pvt Ltd - POSH Internal Committee Members - Year -2026
    Sr. No. Name Position Held Mobile Number E-mail Id
    1 Lahiri Vemula Presiding Officer 9920095579 lahiri.vemula@fireflydiamonds.com
    2 Sayali Dhotre Committee Member 7776987310 sayali.dhotre@fireflydiamonds.com
    3 Sukanya Kasturi Committee Member 9819814850 data.admin@fireflydiamonds.com
    4 Snehal Shewale Committee Member 9867650614 snehal.shewale@fireflydiamonds.com
    5 Saurin Shah Committee Member 7715900906 saurin.shah@fireflydiamonds.com
    6 Dr. Sandya Advani External Member 9769766036 sandya@poshsystems.com
  11. Policy Review

    This Policy shall be reviewed periodically and amended as required under applicable laws and organizational requirements.

Declaration
Firelab Diamonds Pvt. Ltd. is committed to ensuring a workplace where every employee is treated with dignity, respect, and equality. Any act of sexual harassment is strictly prohibited and shall be dealt with seriously in accordance with the POSH Act, 2013.

 

Approved by: Management
Firelab Diamonds Pvt. Ltd.