Policy on Prevention of Sexual Harassment at Workplace


The objective of this policy is to create and maintain safe work environment, free from sexual harassment and discrimination for all its employees. As per the guidelines of “The Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013. At Cereb Media Company, we have zero tolerance for sexual harassment. We value each and every employee working with us and wish to protect their dignity and self – respect. In doing so we are determined to promote a working environment in which persons of both genders, complement each other as equals in an environment that encourages maximum productivity and to keep the personal dignity. Cereb Media aims to adopt zero tolerance, attitudes against any kind of sexual harassment or discrimination caused by any employee during their tenure in Cereb Media Company towards any other person being an employee of Cereb Media Company, Client, Vendor and Contractor in company premises.


“Aggrieved Person” means a person in relation to work place whether employed or not, who alleges to have been subject to any act of sexual harassment by the Respondent;

“Company” means Cereb Media Company;

“Employee” means a person employed at a workplace for any work on regular, temporary, ad hoc or daily wages basis, either directly or through an agent, including a contractor, with or, without the knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise, whether the terms of employment are express or implied and includes a co-worker, a contract worker, probationer, trainee, apprentice or called by any other such name;

“Internal Complaints Committee” means a committee constituted by Company as per this Policy;

“Respondent” means a person against whom the aggrieved person has made a complaint;

“Sexual Harassment” includes any one or more of the following unwelcome acts or behaviour (whether directly or by implication) such as:

  1. Physical contact and advances; or
  2. A demand or request for sexual favours; or
  3. Making Sexually coloured remarks; or
  4. Showing pornography or other offensive or derogatory pictures, cartoons, representations, graphics, pamphlets or sayings; or
  5. Any other unwelcome physical, verbal or non - verbal conduct of sexual nature;

“Workplace” includes any department, organization, undertaking, establishment, enterprise institution, office or branch unit . Any place visited by the employee arising out of or during the course of employment including transportation provided by the employer for undertaking such journey.


Every complaint received shall be forwarded to internal complaint committee formed under the policy for redressal. The investigation shall be carried out by Internal Complaints Committee constituted for this purpose. Internal Complaints Committee has been constituted of the following members as nominated by the Company:

  1. A woman employee employed at a senior level amongst the employees shall act as President of the committee.
  2. Not less than 2 members from amongst employees preferably committed to the cause of women OR who have had experience in social work OR have legal knowledge.
  3. One member shall be from amongst Non-governmental organizations OR associations committed to the cause of women OR a person familiar with the issues relating to sexual harassment.

The Presiding Officer and every member shall hold office for such period, not exceeding three years, from the date of their nomination as may be specified by the employer.


A complaint shall be submitted in writing to shcomplaints@cerebmedia.in or to any member of the Internal Committee mentioned herein within 3 months of occurrence of an act of Sexual Harassment. If the respondent is direct supervisor of the complainant, or person influencing the career growth of the complainant, the reporting structure will be changed till the time the enquiry is completed.


An amicable resolution of the complaint is possible only with the written consent of the complainant.
Within 24 hours of closing the case file, the internal committee shall present the same to and inform its decision to the Founders/Managing Director.
In case of decision establishing the offence of Sexual Harassment of the complainant, within working days, the internal committee shall recommend Disciplinary action against the offender considering the nature and extent of injury caused to the complainant, prior complaints or repetition of offence etc and the impact of the offence on the company profile as a whole.
The position of the offender and the criticality of the position occupied by the offender shall not be any hindrance to the disciplinary action taken against the offender.
The disciplinary action that shall be commensurate with the nature of the gravity of the offence shall include but not limited to,


Written apology from offender,

Bond of good behavior


Debarring from supervisory duties

Denial of employee benefits like increments/promotion/salary correction etc.

Cancellation of specific work Assignment



Annual report summarizing complaints and Redressal of Sexual harassment shall be prepared by designated person. The said report as well as all documents regarding Sexual Harassment complaints shall be in the custody of designated person and will be termed as ‘Strictly Confidential’.


  1. The Committee shall on completion of the enquiry provide a report of its findings within 10 days from the date of completion of the enquiry and such report shall be made available to the concerned parties.
  2. If the allegation against the respondent has not been proved, the Committee may recommend that no action needs to be taken in the matter.
  3. If the Internal Complaints Committee arrives at the conclusion that the allegation against the respondent has been proved, it shall recommend to:
    Take action for sexual harassment as a misconduct.
    To tender written apology to the complainant, issue warning, withholding of promotions / increments of the Respondent, terminating the Respondent.
    To deduct from salary / wages of the respondent or issue direction for payment; such sum as it may consider appropriate to be paid to the aggrieved person or to their legal heirs, as it may determine.
  4. Such action will be taken within 60 days of the receipt of report.


  1. All the Employees, Agents, Customers, Vendors, Partners and Visitors shall have access to this Policy at any given point of time and clarification related to this Policy shall be addressed by the HR team.
  2. A brief shall be given to all existing employees regarding the features of this Policy immediately on formulation of the Policy and to new employees in Cereb Media Company during their initial Induction.
  3. The Company shall comply with all other details as set out under Section 19 of the Act to ensure that all employees are provided with the safe working environment at the workplace.
  4. The Company shall display the notice showing the name of the Internal Complaints Committee members at its every establishment at a conspicuous place.


The complaints relating to Sexual Harassment shall be handled and investigations will be conducted under the principles of natural justice, basis of fundamental fairness, in an impartial and confidential manner so as to protect the identity of all viz., the person bringing the charge, potential witnesses, and the person accused of improper behaviour. Also, all efforts shall be taken to ensure objectivity and thoroughness throughout the process of investigation.
The identity and address of the aggrieved person, respondent and witnesses must not be published or disclosed to the public or media.
The decision of Company shall be final and binding on all. However, the same is without prejudice to any recourse that Company or the individual concerned may have against the respondent and it shall not limit or restrict the rights of the Complainant and/or Company to pursue, nor shall they be precluded from pursuing, such further and other legal actions as may be available.