Posh Policy |Myloancare


(Formerly known as My Finance Care Advisors Private Limited)

Prevention of Sexual Harassment (PoSH) Policy

(Revised W.e.f. Oct - 2022)

What is Sexual Harassment?

Sexual harassment includes such unwelcome sexually determined behavior (whether directly or by implication) as:

a) physical contact and advances; b) a demand or request for sexual favors; c) sexually colored remarks; d) showing pornography; e) any other unwelcome physical verbal or non-verbal conduct of sexual nature.

Where any of these acts is committed in circumstances where the victim has a reasonable apprehension that in relation to the victim’s employment or work whether she is drawing salary, or honorarium or voluntary, whether in government, public or private enterprise such conduct can be humiliating and may constitute a health and safety problem.

It is discriminatory for instance when the woman has reasonable grounds to believe that her objection would disadvantage her in connection with her employment or work including recruiting or promotion or when it creates a hostile work environment.

Adverse consequences might be visited if the victim does not consent to the conduct in question or raises any objection thereto.

Thus, sexual harassment need not involve physical contact. Any act that creates a hostile work environment - be it by virtue of cracking lewd jokes, verbal abuse, circulating lewd rumours etc. counts as sexual harassment.

The creation of a hostile work environment through unwelcome physical verbal or non-verbal conduct of sexual nature may consist not of a single act but of a pattern of behavior comprising many such acts.

  • 1. What should you do if you believe you are facing sexual harassment?

    It is important that the victim report such behavior as soon as possible and not wait for it to become worse. In order to provide a free and fair access to remedy, an “Internal Complaints Committee” or ICC is in place. The victims can reach out to any of the members of the ICC. The ICC must take immediate steps to provide relief to the victim and recommend action that needs to be taken against the alleged violator. The ICC must maintain complete confidentiality about the identity of the victim. Current members of the ICC are:

  • Customer Acceptance Policy:
  • 1. Presiding Officer – Divya Mehta – 8448981306 / divya.mehta@myloancareindia.in

    2. Member – Anu Chhikara – 8826565054 / anu.chhikara@myloancareindia.in

    3. Member – Khushbu Sharma – 9911014978 / hr@myloancareindia.in

    4. External member – Mrs. Suman Dhupar - 9811807804

  • 2. MyLoanCare position on Sexual harassment?
  • We have zero tolerance for any instance of sexual harassment in the firm. The employment contracts provide for instant termination of employees found guilty of sexual misconduct. Any victims of sexual harassment can approach the ICC for remedial action. ICC shall take immediate cognizance (within 24 hours) and investigate the matter. The enquiry must be completed and its report submitted to the management within 7 days. ICC is authorized to recommend to the management any interim action to protect the interest of the victim and against the alleged violator. ICC may mediate to arrive at a settlement between the victim and the alleged violator. Both must be given a chance to present their case before the ICC. In case the alleged violator does not make himself/ herself available before the ICC, the ICC is authorized to take an ex-party decision.

    In case the victim would like to make a police / legal complaint, the ICC shall provide all necessary support for the same. ICC shall not discourage the victim from making a compliant. Medical/ legal / any other support needed by the victim shall be provisioned for by the ICC. The ICC is also free to itself report a matter to the police/ LCC/ district nodal officer as it may deem appropriate.

    Expenses towards running of the ICC and discharge of its duties shall be borne by the Company.

    ICC’s recommendations shall be given to the management (Directors) of the company in writing and shall be binding. ICC can deliberate all matters and complaints among its members. ICC is also empowered to recommend changes in existing anti sexual harassment guidelines of the Company.