CosmicCues (OPC) Private Limited
Policy on Prevention of Sexual Harassment (POSH)
Policy Number: HR-POL-008
Version: 1.0
Effective Date: 27 August 2025

1. Our Unwavering Commitment

CosmicCues is unequivocally committed to creating and maintaining a workplace where all individuals can work with dignity, free from any form of sexual harassment. We have a zero-tolerance policy for any act that falls under the definition of sexual harassment. A safe, respectful, and inclusive environment is essential for our success. This policy provides a clear and fair process for addressing and redressing any such concerns.

2. Who and Where This Policy Applies

This policy applies to every individual associated with the company, including the Director, all employees (full-time, contract, interns), consultants, vendors, clients, and visitors.

The "Workplace" is defined broadly to include our physical office, client locations, company-sponsored events, business travel, and all digital communication platforms used for work (email, messaging apps, video calls). 

3. What Constitutes Sexual Harassment

Sexual harassment is any unwelcome act or behavior (whether direct or implied) of a sexual nature. As per the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("POSH Act"), this includes:

 Physical contact and advances. 
 A demand or request for sexual favors. 
 Making sexually colored remarks. 
 Showing pornography. 
 Any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature. 

Furthermore, circumstances involving an implied or explicit promise of preferential treatment, threat of detrimental treatment, or creating a hostile work environment in relation to the acts above are also considered sexual harassment.

4. The Internal Committee (IC) and Redressal Process

4.1. Constitution of the Internal Committee (IC)

While the POSH Act generally mandates an IC for establishments with 10 or more employees, CosmicCues, in order to comply with the mandatory conditions for exemption from the Industrial Employment (Standing Orders) Act, 1946, as applicable to IT/Startup establishments in Karnataka, shall constitute a formal Internal Committee (IC) from its inception, regardless of its employee strength. The IC will be the sole and exclusive body for receiving and redressing all complaints of sexual harassment within the workplace. 

4.2. Composition of the IC

The IC shall be constituted as per Section 4 of the POSH Act and will comprise:
 A Presiding Officer: A woman employed at a senior level within the Company. 
 Employee Members: Not less than two members from amongst the employees. preferably committed to the cause of women or having experience in social work or legal knowledge.
 An External Member: A member from a non-governmental organization or a person familiar with issues relating to sexual harassment. 

At least one-half of the total members of the IC shall be women. The names and contact details of all IC members will be clearly displayed on the office notice board.

4.3. The Complaint and Inquiry Process

 Step 1: Filing a Written Complaint: An aggrieved person may make a written complaint of sexual harassment to the IC within three (3) months of the date of the incident (or the last incident in a series). 
 Step 2: Inquiry by the IC: Upon receiving a complaint, the IC will proceed to conduct an inquiry in accordance with the provisions of the POSH Act, adhering to the principles of natural justice. The inquiry shall be completed within a period of ninety (90) days. 
 Step 3: Inquiry Report and Recommendations: Upon completion of the inquiry, the IC will provide a report of its findings to the employer. If the allegations are proven, the IC will recommend appropriate action, which may include disciplinary measures up to and including termination of employment. 

5. Guiding Principles

 Confidentiality: The identity of the aggrieved person, the respondent, and witnesses, along with all proceedings, will be kept strictly confidential. Any breach of confidentiality will result in disciplinary action.
 Non-Retaliation: The Company strictly prohibits any form of retaliation against an individual for filing a complaint in good faith or for participating in an investigation.
 Protection Against False Complaints: If the IC finds that a complaint was made with malicious intent, the complainant may be subject to disciplinary action as per the provisions of the POSH Act.

6. Annual Compliance and Disclosure

The Company is committed to full transparency and accountability. While maintaining all necessary internal records is a critical practice, it is noted that as a One Person Company (OPC), the Company is currently exempt from the specific requirement under Rule 8 of the Companies (Accounts) Rules, 2014, to include POSH compliance statements in its Board's Report. The Company will, however, maintain all necessary internal records to ensure full readiness for future compliance and to fulfill its reporting obligations to the District Officer as required by the POSH Act. 

7. Responsibilities

 Company's Responsibility: To provide a safe workplace, constitute and support the IC, ensure this policy is widely disseminated, provide awareness training, and take action on the IC's recommendations.
 Employee's Responsibility: To treat all individuals with dignity and respect, refrain from any behavior that constitutes sexual harassment, and cooperate fully with any IC inquiry.

8. Policy Review

This policy will be reviewed annually by the Director to ensure it remains effective, relevant, and fully compliant with all applicable laws.