POSH Policy

1. PURPOSE:

PharmNXT is committed to fostering a workplace culture built on respect, dignity, and equality for every
individual. The organisation recognises that a safe, secure, and gender-neutral environment is fundamental
to employee well-being and professional productivity.

Although the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal)
Act, 2013 (POSH Act) is legally applicable to women, PharmNXT adopts a broader and progressive
approach by extending the same level of protection to all employees, including women, men, and third-gender
employees.

2. SCOPE:

This policy is applicable to all individuals affiliated with PharmNXT in any capacity. It covers:

2.1 Personnel Covered

• All male, female, and third-gender employees.
• Contract staff and outsourced personnel.
• Trainees, apprentices, and interns.
• Visitors, vendors, service providers, and consultants.

2.2 Workplace Coverage

The definition of “workplace” includes, but is not limited to:

• Manufacturing areas.
• Office areas, cabins, meeting rooms, and document rooms.
• Cafeteria, dining areas, washroom.
• Company-organised events, trainings, conferences, and off-site locations.
• Transportation provided by the company.
• Any location where employees interact for work-related purposes.

2.3 Digital Workplace

Given the increasing use of digital communication, the policy also applies to:

• Email communication.
• Social media platforms.
• Microsoft Teams or similar collaboration tools.
• Any internal communication or digital environment approved or used by the organisation.

3. LEGAL FRAMEWORK:

This policy is framed in alignment with:

• The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act,
  2013 – POSH Rules, 2013.
• PharmNXT extends the same internal reporting and disciplinary structure to male and third-gender
  employees in cases of harassment, even though the Act specifies women.

4. DEFINITION OF SEXUAL HARASSMENT:

Sexual harassment refers to any unwelcome act or behavior, whether direct or implied, that is sexual in
nature. It includes physical, verbal, visual, or digital misconduct. Examples include, but are not limited
to:

4.1 Physical Conduct

• Inappropriate touching.
• Brushing against someone deliberately.
• Attempts to initiate physical intimacy.
• Blocking movement or cornering someone.

4.2 Verbal Conduct

• Sexually coloured remarks or jokes.
• Comments about a person’s body, attire, or appearance.
• Unwanted sexual advances or propositions.
• Suggestive or offensive conversations.

4.3 Non-Verbal & Visual Conduct

• Showing inappropriate or explicit images/videos.
• Obscene gestures, whistling, or leering.
• Displaying sexually suggestive materials.
• Staring or invading personal space.

4.4 Digital Misconduct

• Sending inappropriate messages, emoji’s, memes, or attachments.
• Cyberstalking.
• Unsolicited late-night or privately intrusive messages.
• Sharing offensive content through workplace platforms.

Any behaviour that creates a hostile, intimidating, embarrassing, or offensive work environment qualifies
as harassment.

5. APPLICABILITY TO MALE & THIRD-GENDER EMPLOYEES:

While the POSH Act is legally centred on the protection of women, PharmNXT recognises that harassment can
affect individuals of any gender.

Therefore, the organisation ensures:

• Male and third-gender employees may lodge sexual harassment complaints.
• Their complaints will be handled with the same seriousness, confidentiality, and procedural
  fairness as those of female employees.
• Investigations involving male or third-gender complainants will be addressed under the organisation’s
  Code of Conduct, using the IC structure for neutrality and consistency.

This approach reinforces the organisation’s commitment to a truly gender-neutral and equitable work
environment.

6. INTERNAL COMMITTEE (IC):

In compliance with the POSH Act, PharmNXT has established an Internal Committee (IC) and
an External Committee member, empowered to address all sexual harassment complaints.

6.1 IC Structure:

The Internal Committee consists of a Presiding Officer, and 8 Internal Committee members, with 4 members
representing PharmNXT Biotech and the other 4 members representing PharmNXT EkUse.

6.2 IC Responsibilities

• Receiving and acknowledging complaints.
• Maintaining complete confidentiality during and after proceedings.
• Conducting fair, neutral, and unbiased inquiry processes.
• Ensuring both complainant and respondent receive equal opportunity to be heard.
• Preparing detailed findings and submitting recommendations to management.
• Ensuring compliance with statutory timelines and promoting awareness.

6.3 Members of IC:

7. COMPLAINT PROCEDURE:

7.1 Who can file a complaint?

• Any woman employee (as per POSH Act).
• Any male or third-gender employee (as part of company’s extended policy).
• Contract staff employees.
• Witnesses may file on behalf of the aggrieved person.
• In severe cases, legal heirs may file.

7.2 How to file a complaint?

• Complaint must be submitted in written in Sexual harassment complaint form – Annexure-I.
• Should be filed within 3 months of the incident.
• Email submissions to be sent to
  
  posh.pnxt@pharmnxtbiotech.com
  
• IC may extend the timeline if justified by circumstances (e.g., trauma, medical issues).

7.3 Inquiry Process

• IC acknowledges the complaint within 7 working days.
• Notice is issued to the respondent.
• Inquiry is completed within 90 days.
• Both parties may present evidence or witnesses.
• IC submits a final report to Management.
• Management takes appropriate action within 60 days of receiving recommendations.

8. ANNEXURES:

Annexure I: SEXUAL HARASSMENT COMPLAINT FORM

9. CONFIDENTIALITY:

All individuals involved in the complaint process – including complainant, respondents, witnesses, and
IC members – must maintain strict confidentiality. Details of the case must not be disclosed to colleagues
or external parties. Any breach of confidentiality will result in disciplinary action.

10. NON-RETALIATION:

PharmNXT strictly prohibits any form of retaliation or victimisation against individuals who:

• File a complaint.
• Participate as witnesses.
• Assist in an inquiry.

Retaliatory actions such as intimidation, threats, demotion, altered duties, or negative performance
treatment will not be tolerated and will attract serious disciplinary consequences.

11. DISCIPLINARY ACTION:

Depending on the seriousness of the misconduct and IC findings, the organisation may take one or more
of the following measures:

• Written apology.
• Counselling or correctional training.
• Warning or reprimand.
• Salary deduction or withholding increments.
• Suspension.
• Transfer to another department or shift.
• Termination of employment.
• Legal action as applicable under Indian law.

12. TRAINING AND AWARENESS:

To build a culture of awareness and responsibility:

• Annual mandatory POSH training for all employees.
• Specialised capacity-building programs for IC members.
• Awareness sessions for employees focusing on acceptable workplace behaviour and reporting
  procedures.
• Display of POSH posters, do’s and don’ts, and reporting guidelines.
• On boarding orientation for all new hires.

13. RECORD KEEPING:

HR shall maintain all POSH-related records—including complaints, inquiry proceedings, recommendations,
and action reports—for a minimum period of three years, stored securely to protect confidentiality.

14. POLICY REVIEW:

This policy will be reviewed annually, or earlier if required by changes in legislation, organisational
needs, or based on IC recommendations.

15. DECLARATION:

PharmNXT reaffirms its commitment to providing a harassment-free, gender-neutral, safe, and respectful
workplace. The organisation values every employee equally and upholds a culture of dignity, trust, and
integrity. All employees are encouraged to uphold this policy and contribute toward building a positive
and inclusive working environment.