2026 India POSH Policy

This policy has been framed keeping in mind the requirements of applicable law and judicial pronouncements including The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (the “Act”), and The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013, (the “Rules”) and keeping in mind the reasonable and appropriate conduct expected out of the employees and representatives of the Company. While care has been taken to frame the policy considering the applicable law, nothing herein shall be construed as intended to dilute or interfere with the provision of any law, should there be any inconsistency between this policy and applicable law. In case of any conflict between this policy and the applicable law or judicial pronouncements, the applicable law or judicial pronouncements will prevail.

14.2 It may be noted that the applicable law in India primarily envisages the affected party (say “Complainant”) to be a woman; however, keeping in mind the gender-neutral approach of the Company, this policy is framed on the basis that the Complainant could be a person of any gender. It is however clarified that this is not to be interpreted in any manner as diluting the applicability of any applicable law when the Complainant is a woman.

14.3 The scope of this policy covers all categories of employees of the Company, including regular employees, part-time employees, temporary employees, and also includes a co-worker, consultant, contract worker, probationer, trainee and apprentice at their workplace or on client sites whether or not they are considered as an “employee” for purposes of any other law (herein for purposes of this policy, referred to as “Employee”, for ease of reference).

Since employees may interact with their colleagues and carry out their work even from home, “home” will come under the ambit of “Extended Workplace”.

14.4 The term “Sexual Harassment” will have such meaning as the applicable law mayprovide from time to time and includes the following unwelcome acts or behaviour (whether directly or by implication) such as:  

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

Sexual harassment may consist of unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature when one or more of the following occur:

• Submission or rejection of such conduct is made a term or condition of an individual’s employment;
• Submission or rejection of such conduct is used for the basis for an employment decision, such as promotion, demotion, termination, or compensation; or
• Such condition interferes with an employee’s work performance or creates a hostile, intimidating, or offensive work environment.

14.5 In order to address a sexual harassment allegation, the Company uses a processdesigned to treat the complainant with dignity and respect, and to provide as a timely resolution to the matter. The Company has established an official Internal Committee (“IC”) as follows, in order to facilitate this process.

• The IC is specifically chartered to:
  • Investigate every formal written allegation of sexual harassment,
  • Order appropriate and timely remedial measures to respond to any substantiated allegation of sexual harassment,
  • Discourage and prevent employment-related sexual harassment.
• Making complaints to IC
  • The Complainant may make a complaint in writing to the IC within 3 months from the date of incident, and in case of series of incidents, within a period of 3 months from the date of last incident.
  • If required by the Complainant, the members of the IC shall render required assistance to make the complaint in writing.
  • If the Complainant is unable to make the complaint within 3 months, the IC may extend the time in appropriate cases, for a further period of 3 months.
  • Where the aggrieved person is not able to make a complaint on account of her/his physical or mental incapacity or death or otherwise, any other person as specified in the Rules may make a complaint.
  • The complaint may be made with the Presiding Officer or any other member of the IC.
  • If the aggrieved person approaches any other employee of the Company in relation to sexual harassment, such employee is required to direct the aggrieved person to approach the IC and provide required assistance.
  • SHe portal enablement for POSH-related reporting/support.
  • SHe Portal provides a confidential and accessible channel for employees to seek guidance, raise concerns, or report incidents related to workplace harassment and inappropriate behavior.
  • Employees can access the portal to confidentially raise concerns, seek guidance, or submit workplace harassment-related complaints. The portal serves as an additional reporting channel alongside SEI's Internal Committee, HR, and Ethics reporting mechanisms.
• Conciliation
  • The IC may, before initiating an inquiry and at the request of the Complainant, take steps to settle the matter between the Complainant the respondent through conciliation, in accordance with the applicable law including the Act.
  • It may be noted that no monetary settlement shall be made the basis of conciliation.
  • IC will provide copies of such settlement to both parties and if settlement is arrived at, no further inquiry shall be conducted by the IC.
  • If conciliation was not required or not successful, it will proceed to inquiry.
• Inquiry into Complaint
  • Where the respondent is an Employee, the IC shall proceed to conduct the inquiry.
  • At the time of filing the complaint, the Complainant shall submit to the IC 6 (six) duly signed copies of the complaint along with supporting documents and the names and addresses of the witnesses.
  • On receipt of the complaint, the IC shall send one of the copies received from the complainant to the respondent within a period of seven (7) working days.
  • IC shall require the respondent to file her/his reply to complaint along with his/her list of supporting documents, and names and addresses of the witnesses, within a period not exceeding ten (10) working days from the date of receipt of the copy of the complaint and other documents.
  • IC, may, only at the request of the Complainant, take steps for conciliation as above, before initiating an inquiry under the provisions of the Act. Provided that no monetary settlement shall be made as a basis of conciliation.
  • IC shall proceed to make inquiry into the complaint if the aggrieved person informs the IC that any term or condition of the settlement has not been complied with by the respondent, or if no request of settlement was made.  
  • For the purpose of making inquiry, the IC shall have the same powers as are vested in a civil court under the Code of Civil Procedure, 1908 when trying a suit in respect of the following matters:
    • Summoning and enforcing the attendance of any person and examining him on oath;
    • Requiring the discovery and production of documents; and
    • Any other matter which may be prescribed by the Rules.
  • The IC shall have the right to terminate the inquiry proceedings or to give an ex-parte decision on the complaint
  • If the Complainant or the respondent fails, without sufficient cause, to present herself/himself for three consecutive hearings of the IC, as the case may be: provided that such termination or ex-parte order may not be passed, without giving a notice in writing, fifteen days in advance, to the party concerned. oThe statements and other evidence obtained in the inquiry process will be considered confidential materials and will be duly marked and filed.
  • The parties shall not be allowed to bring in any legal practitioner to represent them before the IC. An officer of the Company may be designated to provide advice and assistance to the parties if requested by them.
  • Minimum 3 (three) members of the IC will be present for conducting the inquiry, including the Presiding Officer. If for any reasons, the Presiding Officer is not present, the remaining members may choose one among them to the Presiding Officer for such inquiry.
  • Appropriate opportunity will be given to all parties to present their position and the IC will follow the principles of natural justice as follows:
  • No one can be a judge in his own cause, which means that no person can judge a case in which they have an interest.
  • Hear both the parties before arriving at a decision, that is, every person must be given an fair opportunity to have a hearing and be allowed to present his or her own case
  • IC will frame appropriate guidelines or instructions in relation to an inquiry, from time to time and will inform the parties.
  • The IC shall require all parties to maintain confidentiality, to the extent possible.
  • The IC shall endeavor to complete the inquiry within a maximum period of ninety days and all parties shall be expected to cooperate in the inquiry.  
  • The IC shall be empowered to do all things necessary to ensure a fair hearing of the complaint including all things necessary to ensure that affected persons and witnesses are neither victimized nor discriminated against while dealing with a complaint of sexual harassment.
  • During the pendency of an inquiry, the IC may take such steps as it may consider reasonable, after considering the provisions of the Act and the rules as follows: o Transfer the aggrieved person or respondent to any other work place; o Grant leave to the aggrieved person up to a period of three (3) months; o Restrain respondent from reporting on the work performance of the aggrieved person and assign the same to another person.
  • On completion of an inquiry the IC shall provide a report of its findings to the Managing Director of the Company (unless the Managing Director is the respondent, in which case, the report shall be submitted to any other Director on the Board of the Company), and such report be made available to the concerned parties. IC shall endeavor to provide such report within 10 (ten) days of completing of the inquiry. oIf the IC arrives at the conclusion that the allegation against the respondent has not been proved, it shall recommend to the Managing Director (unless the Managing Director is the respondent, in which case, the recommendation shall be submitted to any other Director on the Board of the Company), that no action is required to be taken in the matter.  
  • If the IC arrives at a conclusion that the allegation against the respondent is false or malicious or the aggrieved person or any other person making the complaint has produced any forged or misleading document, it may recommend to the Managing Director (unless the Managing Director is the respondent, in which case, the report shall be submitted to any other Director on the Board of the Company), to take action against the aggrieved or the person who has made the complaint, in accordance with the provisions of the service rules or applicable law.
  • If the IC arrives at the conclusion that the allegation against the respondent has been proven, it will make appropriate recommendations to the Managing Director (unless the Managing Director is the respondent, in which case, the report shall be submitted to any other Director on the Board of the Company), as may be appropriate as per the Handbook, policies or applicable law, including (i) requiring the respondent to issue a written apology, (ii) issuing a warning, reprimand or censure, to the respondent, (iii) withholding promotion or pay rise or increment of the respondent, (iv) terminating the employment of the respondent etc.

SEI is committed to maintaining a respectful, inclusive, and safe workplace for all employees. While the POSH Act in India primarily addresses complaints from women, male associates who experience, witness, or have concerns regarding inappropriate workplace behavior, harassment, bullying, or conduct inconsistent with SEI's values may report such concerns to the SEI India Ethics Committee at EthicsSEIIndia@seicx.com Employees can raise concerns confidentially, seek guidance, and request support without fear of retaliation