Policy on Prevention of Sexual Harassment at workplace


Ace Micromatic Group of Companies believes in the right of all its employees to work with dignity, in a safe and secured environment. All persons working with the Group are expected to treat their co-workers with respect, dignity and in a professional manner. The objective of this policy is to provide all employees of the Ace Micromatic Group of Companies with a safe work environment, free from sexual harassment.


While the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 deals only with complaints of sexual harassment of women at the workplace, but the Company extends protection from sexual harassment to all of its employees (as defined below) irrespective of their gender.

This policy applies to all categories of employees including temporary workmen, trainees and employees on contract basis worked at work place. The protection also extends if the harassment is done by our clients or suppliers or any other business associates.


The Company protects all its employees from sexual harassment and will take all appropriate measures to project the dignity of employees by taking suitable action against person harassing. Sexual harassment at workplace is a misconduct which will be dealt with by the Company in accordance with this Policy and Act


(a).“Employee“ means any person employed by the company either on its rolls or through contractors including casual workers and trainees

(b).“Company” means Ace Designers Limited

(c).“Workplace” includes:

i. All offices or other premises where the Company’s business is conducted i.e., employees working at CNC machine division and Foundry division including when employees are commuting from their home to work and back;

ii. any site away from the Company’s premises where any activity related to the Company’s business is organized, or arranged for, by the Company; and

iii. any place visited by an employee arising out of or during the course of employment like customer place, vendor place etc., , including any transportation provided by the Company for undertaking such journey.

(d).“Sexual Harassment” means any one or a series of incidents involving

i. Unsolicited or unwelcome sexual advances (verbal, written or physical);

ii. demand or request for sexual favours;

iii. any other type of sexually-oriented conduct;

iv. verbal abuse or ‘joking’ that is sex-oriented; and

v. any conduct that has the purpose or the effect of interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment and/or submission to such conduct is either an explicit or implicit term or condition of employment and/or submission or rejection of the conduct is used as a basis for making employment decisions.

*The following circumstances, among other circumstances, if it occurs, or is present in relation to or connected with any act or behavior of sexual harassment may amount to sexual harassment:—

i. implied or explicit promise of preferential treatment in employment; or

ii. implied or explicit threat of detrimental treatment in employment ; or

iii. implied or explicit threat about present or future employment status; or

iv. interference with work or creating an intimidating or offensive or hostile work environment; or

v. humiliating treatment likely to affect health or safety


*(Above clause is inserted vide amendment on 19th September 2020)

(e).“Internal Complaints Committee (ICC)” means Internal Complaints Committee constituted by the Company as per clause VII of this policy:


All employees of the Company have a personal responsibility to ensure that their behaviour is not contrary to this policy. Further all employees are encouraged to reinforce the maintenance of a work environment free from sexual harassment.


An appropriate complaint mechanism in the form of “Internal Complaints Committee” is constituted for time-bound redressal of the complaints made by the victim.


The Company has reconstituted a Complaints Committee for redressal of sexual harassment complaints (made by the victim) and for ensuring time bound justice for such complaints.

*Till further notice, the Complaints Committee comprises of the following members out of which at least half of the total members shall be women:

(a) Mrs. Manisha G Kannur (Executive Director) - Presiding Officer

(b) Mrs. Madhavi Chandrashekar (Executive Director) - Member

(c) Mr. Thirumalesh Kumar (Head – Human Resource) - Member

(d) Mrs. Pushpa S (Women employee) - Member

(e) Mrs. Padmini (External Person) - Member

(The committee is reconstituted vide amendment on 19th September 2020)

Presiding Officer and every member of the Complaints Committee shall hold office for a maximum of 3 years from the date of their nomination.

HR Department will nominate new members after the expiry of their term for succeeding terms and one of the Managing Director approves the constitution of new Committee from time to time. However, until the constitution of new committee, existing members will continue as committee members notwithstanding the expiry of three years term.

However, if the complaint is against a member of the Committee or if the alleged harasser is in a position that is superior to the presiding officer of the Committee, to ensure a free and fair enquiry that is free from any real or perceived conflict of interest, the Committee receiving the compliant will escalate the complaint to Managing Director who will then entrust the investigation of the complaint to another appropriate committee nominated for this purpose, or in case the complaint is against any Director of the Company, then the compliant will be forwarded to the Local Complaints Committee as per applicable law.

If the complaint relates to alleged sexual harassment to an employee by a third party, customer, client, supplier or other business associates of the Company (i.e. by someone who is not an employee for the purpose of this Policy), the complaint shall be referred to the HR Manager of that establishment for appropriate action. After discussion with the employee and review of the circumstances, Management may take appropriate action against the said third party if it deems appropriate for the safety of the Company’s employees. If the complainant employee so desires, the Management will also cause to initiate action under the Indian Penal Code or any other law for the time being in force in the workplace where the incident of sexual harassment took place.

Internal Complaints Committee is responsible for:

  • Investigating every formal written complaint of sexual harassment;
  • Taking appropriate remedial measures to respond to any substantiated allegations of sexual harassment; and
  • Discouraging and preventing employment-related sexual harassment.


The Company is committed to provide a supportive environment to resolve concerns of sexual harassment as under:

(a) Informal Resolution Options:

When an incident of sexual harassment occurs, the victim of such conduct can communicate their disapproval and objections immediately to the harasser and request the harasser to behave decently.

If the harassment does not stop or if victim is not comfortable with addressing the harasser directly, the victim can bring his/her concern to the attention of the Complaints Committee for redressal of their grievances. The Complaints Committee will thereafter provide advice or extend support as requested and will undertake prompt investigation to resolve the matter.

(b) Complaints:

1) An employee with a harassment concern, who is not comfortable with the informal resolution options or has exhausted such options, may make a formal complaint to the Presiding Officer of the Complaints Committee constituted by the Management.

2) The complaint shall be in writing and can be in form of a letter, preferably within 3 months by the Committee from the date of occurrence of the alleged incident. However, the committee on its own discretion may extend the time limit for making a complaint on case to case basis. The complaint shall be sent in a sealed envelope. Alternately, the employee can send complaint through an email. The employee is required to disclose their name, department, division and location they are working, to enable the Presiding Officer to contact them and take the matter forward.

3) The Presiding Officer of the Complaints Committee will proceed to determine whether the allegations (assuming them to be true only for the purpose of this determination) made in the complaint fall under the purview of Sexual Harassment at the earliest possible time but not later than 20 days from receipt of the complaint.

4) In the event, the allegation does not fall under the purview of Sexual Harassment or the allegation does not constitute an offence of Sexual Harassment, the Presiding Officer will record this findings with reasons and communicate the same to the complainant.

5) If the Presiding Officer of the Complaints Committee determines that the allegations constitute an act of sexual harassment, Presiding Officer will proceed to investigate the allegation with the assistance of the Complaints Committee.

6) Where such conduct, on the part of the accused, amounts to a specific offence under the law, the Company initiates appropriate action in accordance with law by making a complaint to the appropriate authority.

7) Subject to the foregoing provisions of this Policy, the Committee shall have power to regulate its own procedure, including quorum required for conducting each enquiry.

8) *During the pendency of an inquiry on a written request made by the aggrieved person, the Committee, as the case may be, may recommend to the employer to—

(a) Transfer the aggrieved person or the respondent to any other workplace; or

(b) grant leave to the aggrieved person up to a period of three months; or

(c) grant such other relief to the aggrieved person as may be prescribed.

(Above clause is inserted vide amendment on 19th September 2020)

9) The Committee shall conduct its enquiry in a timely manner and shall complete its enquiry not later than ninety (90) days from the date of receipt of the complaint.

10) The Committee shall submit a written report containing its findings and recommendations to the HR Head of the Company as soon as possible, in any event not later than Ten days from the completion of the enquiry.

11) A copy of the findings of the Committee shall be provided to the complainant and the respondent to enable them to make representation against the findings before the Committee. While sharing the report, the Committee may make such details as is it deems necessary anonymous as may be required to protect the confidentiality of the persons involved in the inquiry.

Corrective action may include any of the following:

  1. Formal apology;
  2. Counselling;
  3. Written warning to the perpetrator and a copy of it maintained in the employee’s file;
  4. Change of work assignment/transfer for either the perpetrator or the victim; and
  5. Suspension or termination of services of the employee found guilty of the offence or
  6. Such other suitable action as the committee may deems fit as prescribed under the Act;

In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for appropriate disciplinary action by the Management.

(For more details, refer to the process flow given in Annexure A)


The Company understands that it is difficult for the victim to come forward with a complaint of sexual harassment and recognizes the victim’s interest in keeping the matter confidential.

To protect the interests of the victim, the accused person and others who may report incidents of sexual harassment, confidentiality will be maintained to the extent practicable and appropriate under the circumstances.


All records of complaints, including contents of meetings, results of investigations and other relevant material will be kept confidential by the Company except where disclosure is required under disciplinary or other remedial processes.


An employee lodging a complaint under this Policy in good faith and any person who provides information or evidence as part of an inquiry pursuant to this Policy will be protected from any retaliation, reprisal or discrimination as a result thereof. Any unwarranted pressure, retaliatory or any other type of unethical behaviour by the respondent or any person on behalf of the respondent against the complainant or a witness may be reported to the Committee. Such complaints shall also be investigated by the Committee and the Committee may recommend appropriate disciplinary action if such complaint is found to be genuine.


HR Head of the Company shall consider the report and recommendations of the Committee. If the HR Head requires any further details or clarifications, he/she may call for such additional details or clarifications from the Committee. The HR Head shall act upon the recommendations of the Committee not later than twenty days of receipt of the report of the Committee by him/her and send a report of the same to the Committee.


Any person who is a victim of sexual harassment may, in addition to the above, seek appropriate legal remedies as may be provided under the various laws for the time being in force.

The Committee shall submit an annual report (in the format prescribed by law) for each calendar year to the Managing Director of the Company. The Management will publish the same in the annual report.


The HR Head has specific responsibility for overseeing the implementation of this Policy within the Company and for updating the Managing Director and the Board of the Company on the implementation of this Policy.


i. The Committee shall in each calendar year prepare, in such form and at such time as may be prescribed, an annual report and submit the same to the employer and the District Officer.

ii. the number of cases filed, if any, and their disposal under this Act shall be disclosed in the annual report of the organisation

(Above clause is inserted vide amendment on 19th September 2020)


The Company reiterates its commitment to provide its employees, a workplace free from harassment/discrimination and where every employee is treated with dignity and respect.

The presiding officer has power to decide any doubts arising out of this policy.

Frequently Asked Questions

1) Why this policy is required?

Ace Designers Limited is committed to provide work environment that ensures every employee is treated with dignity and respect and afforded equitable treatment.

2) To whom is this policy applicable?

This policy applies to all categories of employees of the Company, including permanent management, workmen, trainees and employees on contract, engaged at its all divisions (CNC Machine division and foundry division) or at client sites.

3) To whom should the victim compliant?

Victim is required to complain to presiding officer of the Internal Complaints Committee.

4) When the Complaint has to be made and what is the time limit?

Complaint has to be submitted within 3 months from the date of occurrence. However the presiding officer can also accept the compliant after 3 months, provided that there are sufficient reasons for not making the compliant by the victim.

5) Can both men and women be victims of sexual harassment?

Yes, both men and women can be victims of sexual harassment.

6) What is sexual harassment in the workplace?

It is harassment by an employee to his/her co-employee (both men and women) in the following manner,

i. Unsolicited or unwelcome sexual advances (verbal, written or physical);

ii. demand or request for sexual favours;

iii. any other type of sexually-oriented conduct;

iv. verbal abuse or ‘joking’ that is sex-oriented etc., ;

7) How bad must a hostile work environment get before I should complain?

An employee should notify an employer whenever they reasonably believe themselves to be the victim of harassment. If the conduct is severe, it may be enough that it occurred only once. If the conduct is less severe, but occurred over an extended period of time, which too may be sufficient.

8) What if an employee witness inappropriate conduct or someone tells him/her about it?

Anyone who witness inappropriate comments or conduct, even if it is directed at someone else, is encouraged to report it. Moreover any employees who become aware of sexual harassment are required to report it to presiding officer.

9) Will the complaint made be treated confidentially?

The Company shall take every reasonable effort to handle inquiries, complaints and related proceedings in a manner that protects the privacy of all parties. .

10) What if the complainant is retaliated against for complaining about harassment or participating in an investigation?

The Company’s Sexual Harassment Policy strictly forbids retaliation against anyone for making a good-faith harassment complaint. Retaliation is a serious violation that can subject the offender to strict actions by the Company, independent of the merits of the sexual harassment allegation. Anyone experiencing any conduct that he or she believes to be retaliatory should immediately report it to one of the committee members.

11) Who will decide whether the particular activity is harassment or not.

The Presiding officer will decide whether particular activity is sexual harassment or not.

The presiding officer has power to decide all doubts arising out of this policy including in deciding the definition of work place etc.,

Please Note – Complaint Committee will not entertain any anonymous complaints.