Greenpeace India is committed to provide a work environment free from discrimination and to prohibit  harassment of its employees including sexual harassment. Greenpeace India will fully comply with applicable law  rules and regulations in the area of sexual harassment and that such behavior against women is prohibited by  the law as set down in “The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal)  Act, 2013” and Rules framed thereunder being the “The Sexual Harassment of Women at Workplace”  (hereinafter referred to as “Act”) as well as the terms of employment. Commission of any act of sexual  harassment as defined in the Act and in this Policy shall result in strict disciplinary action. Every employee working with us is valuable, and we would like to promote a culture that is inclusive, respects  individuals, and have a healthy environment where the genders complement each other towards accomplishing  the goals of the Organization. 
Through this policy we aim to outline: 
–       Methods to be used for gender sensitization 
–       Process for employees to raise Sexual Harassment issues 
–       Redressal procedure 
–       Responsibility & accountability of the different stakeholders


A. Objective  
a) This policy is being revamped and reintroduced to enable and support equal opportunities to all and  the freedom to express and call out any form of Sexual harassment at workplace.  
b) Green Peace India is committed  to creating an enabling environment where all employees can work  without any fear of sexual discrimination and sexual harassment.  
c) Sexual  Discrimination,  harassment,  abuse  in  any  form  and  nature  is  absolutely  prohibited.  The  company would like to provide a safe environ and maintain a culture where no employee indulges in  practices  that are  detrimental  to  the  core values  of Greenpeace which is  to act with accountability,  mutual trust, and respect for individuals,  
d) The intent of having this policy is to outline the measures in place for preventing any form of Sexual  Harassment and to assist in dealing with such issues that may arise at the workplace  
e) This policy covers & provides for strict disciplinary action against any victimization of the employee  who is complaining or the alleged harasser that may result from a complaint. 
B. Scope & Applicability 
f) The policy will cover all Employees, Consultants, Interns & Volunteers  
▪ Working  in  all  offices  and/ or  other  premises  /  locations  where  Greenpeace  operates,  and  conducts its business 
▪ Participating in any social, business or any other events, training/workshops where the conduct or  conversation  or  comments  may  have  an  adverse  effect  on  interpersonal  relations  and  create  workplace hostility disrupting the core values of the organization.


• ‘Employee’: Employees of Greenpeace are persons working in the organization for any work on regular,  temporary or ad-hoc basis, and includes probationers, consultants, interns and volunteers and job seekers.  • ‘Employer:’ All  references  to ‘employer’  in  this  policy  shall  be  construed  as  a  reference  to  the Entity  with  whom the Contractual agreement exists for the ‘Employee’ of Greenpeace. 
‘Respondent’: Respondent is a person against whom a complaint of sexual harassment has been made. • ‘Aggrieved’: It is a person of any age whether employed or not, who alleges to have been subjected to any  act of Sexual Harassment by the respondent. 
‘Sexual harassment’: Sexual harassment includes but is not limited to would mean any one or more of the  following unwelcome sexual acts, behavior, gestures or comments (whether directly or by implication): 
▪ Unwelcome physical, verbal, non-verbal conduct, contact and advances of sexual nature:  
Example: unwelcome physical intimacy such as pinching, inappropriate t 
touching, brushing or patting, etc. 
▪ Demand or request for sexual favors, directly or indirectly, including demands or requests made in  person or through phones, SMS, emails or any other mode of communication  
▪ Making  sexually  coloured  remarks,  including  explicit  or  sexist  jokes  and  comments  with  the  intention of harassing the woman 
▪ Showing pornography – in the form of pictures, cartoons, videos, written material, emails etc.  
Sexual harassment would also include the following circumstances, where these occur in connection with any of  the above acts or behaviours: 
▪ Promise or preferential treatment in the person’s employment 
▪ Interference  with  the  person’s  work  or  creating  an  intimidating  or  offensive  or  hostile  work  environment for the person. 
▪ Threat about the person’s present or future employment status. 
▪ Humiliating treatment likely to affect the person’s health or safety 
Note- The  above  examples  are  not  exhaustive  and  sexual  harassment may  cover many  other  acts  that  are  of  sexual nature or have the effect of creating a hostile working environment.  
Workplace: Workplace includes the GREENPEACE head office and all its branches in different parts of the  country,  and  any  place  visited  by  the  employee  arising  out  of  or  during  the  course  of  employment,  including travel for official purpose both within the country and outside the country.


I. Preventive Measures 
Greenpeace India as the Employer shall abide by the law of the land and comply with the provisions of the  “The  Sexual  Harassment  of  Women  (Prevention,  Prohibition  and  Redressal)  Act  (2013)”    and  the  Vishaka  Judgment (1997) . 
All employee Contracts will carry clause on the workplace intolerance to sexual harassment 
The Joining formalities will include a write-up on gender sensitivity and provide access to detailed available  information on Green Net that will be followed up for compliance upon completion of 30 days 
Gender  Sensitization  trainings  will  be  imparted  to  all  Employees  by  way  of  e-learning modules,  self-paced  tutorials. 
Regular checks will be done through Quizzes to check on the awareness levels of all employees on the Policy,  their duties and responsibility towards safe and healthy working  
All employees will be provided with a laminated ‘visit card’  that will carry  the contacts of  the ICC  to use in  case of Emergency 
Awareness Posters will be made available on Employee Communication Boards in all Offices. 
It is also the duty and personal responsibility of all employees to ensure their behavior and all acts are not  contrary to this policy.   
Keeping the workplace safe is the responsibility of the Senior Management Team, Human Resources Team,  Managers, and Employees and  the constituted ICC by providing recommendations and suggestions  from  to  time to time to ensure safe environment for all and particularly women employees. 
II. Responsibility of the Stakeholders involved: 
Senior Management Team (SMT)  
i. Provide a safe working environment at the workplace 
ii. Display at all conspicuous place in the workplace the penal consequences of sexual harassments and  the details of the ICC 
iii. Treat  sexual  harassment  as  a  misconduct  under  its  service  rules  and  initiate  action  for  such  misconduct 
iv. The office commits to ensure that it will not allow retaliation against any employee who complains of  sexual harassment or provides information in connection with any such complaint. 
v. Provide assistance to the ICC for conducting inquiries and holding their periodic meetings. vi.Action on the recommendations of the ICC should be taken within 10 working days.   
vii. Provide support to the complainant to initiate action under Indian Penal Code or under any other law  if the complainant desires  to do so. Sexual harassment is a civil offence.  If the offence is of a criminal  nature,  i.e.  rape,  stalking  etc.  (which  have  been  made  criminal  offences  in  the  new  Criminal  amendment Act) it should be reported to the police and an FIR lodged.

viii. Monitor the timely submission of reports by the ICC. 
ix. Include in the Annual Report of GREEN PEACE India the number of cases of sexual harassment filed in  the year and their status; and provide the list of programs and communication on gender sensitization  at the workplace  

Human Resources: 
i. Will be the custodian of this Policy, and will have the responsibility to review the policy with the SMT and  ICC  on  an  annual  basis  and  on  receipt  of  any  feedback  from  time  to  time  make  modifications  and  communicate to employees. 
ii. Will also  be  responsible  for  referencing and incorporating  the Greenpeace India’s  philosophy  on Sexual  Harassment and the actions for non-compliance in all employment contracts, Greennet, and the external  Organizations website.  
iii. Help the SMT to constitute the ICC as required / prescribed under the Act and to ensure fair  representation of employees and with at least one external member who is eminent and is a  knowledgeable individual. 
iv. Facilitate and organize workshops and awareness programs at regular intervals for sensitizing employees  with the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and  Redressal) Act 2013 
v. Ensure that all sexual harassment complaints are handled by the ICC for redressal vi. Extend support, and provide any information that the ICC would require for conducting their enquiries. 
I. It is mandatory for employees to attend training, workshops on awareness, education and refresher in e learning and / or class room formats. Non attendance or participation will be construed as misconduct            II. Employees may also suggest and make recommendations to help have a gender neutral workplace free  of bias, prejudice and preference. 
III. An employee who believes he or she or any other employee is a victim of sexual harassment must  immediately report such incident to the designated ICC. 
IV. Any employee who is called upon to testify or as a witness must extend support, and provide any  information that the ICC would require for conducting their enquiries. 
ICC :  
i. Investigating every formal written complaint of sexual harassment. 
ii. Provide recommendations to any substantiated allegations of sexual harassment.  (Provide link to the actions that ICC can suggest) 
iii. Maintain confidentiality at all times 
iv. Maintain documentation of the complaint, the investigation and the recommendation for action and the  action taken.
v. Maintain reports of appeals if any. 
vi. Prepare a quarterly report and then an annual report. 
vii. Try for restorative justice rather than retributive justice. 
viii. Keep abreast of any new developments with regard to changes in law, government circulars etc.  ix. The ICC may take up anonymous or third party complaints, if they see the need. x. Advise the SMT & HR on how to take steps, ways, and measures that will help discourage and prevent  employment-related sexual harassment to ensure the workplace is safe. 
i. The Board of Greenpeace India play a key role in ensuring that the policy implementation is followed in  letter and sprit. 
ii. The Board will also take regular updates on the functioning of the ICC & the periodic reports that the  ICC will provide. 
iii. The Board will recommend, suggest  & mandate amendments to the policy as & when they feel  necessary.


Greenpeace India has instituted a central Redressal Committee, which is known as the ‘INTERNAL  COMPLAINTS COMMITTEE’ (ICC) for addressing all complaints of Sexual Harassment to ensure timely  investigation and action with adequate representation from all branches, locations. 
The Internal Complaints Committee will comprise of the following: 
§  Presiding Officer – Shall be a woman employed at a senior level at workplace amongst the employees. 
§  Two members – Shall be amongst employees preferably committed to the cause of woman or who have an  experience in social work or have legal knowledge. 
§  One Member – amongst Non-Governmental Organizations or associations committed to cause of woman or a  person familiar with the issues relating to sexual harassment. 
Provided that at least one half of the total Members so nominated shall be women. Additional members will be  added as may be required from time to time. 
The nomination will be made by the management committee and reviewed from time to time. 
At least 50% of the ICC shall be constituted by persons drawn from departments other than the Human    Resources department of the organization.

Contact Details Of ICC Members

SNo Role email ID
Presiding Officer [email protected]
Members[email protected]

I. Any  employee  may  make  a  complaint  of  sexual  harassment  in  writing  to  the  ICC  within  three  months from  the  date  of  the  incident,  and  in  case  there  is  continuous  harassment,  within  a  period  of  three months from the date of the last incident. 
II. If there is a delay beyond three months, the ICC may extend the time limit on being satisfied about the circumstances  that  prevented  the  complainant  from  filing  a  complaint  within  the  prescribed  period  by another 3 months. 
III. If  the  complaint  is  of  a  grave  nature,  the  ICC  may  act  on  its  own  without  constraint  of  time  limit,  or explanations  about  delay,  complying  with  the  highest  standards  of  due  diligence.  However,  in  all  cases when a  delayed  complaint  is  taken  up,  the  committee will explain  its  reasons  in writing  in  its  order,  to justify doing so. 
IV. The complainant can send a complaint, along with supporting documents and list of witnesses with their names and contact details to the ICC mail ID or to any members or all of the members. 

V. The complainant can send a complaint, along with supporting documents and list of witnesses with their  names and contact details to the ICC mail ID or to any members or all of the members.  
VI. Any  ICC  member charged  with  sexual  harassment  in  a  written  complaint  must  step  down  as  member  during the inquiry into that complaint. An ad-hoc member shall be appointed in his/her place. 
VII. In  case,  either  the  complainant  or  respondent  are  close  friends  of  any  of  the  ICC  members,  they  may  recuse themselves. 


I. On receipt of a complaint, the ICC will record it in a register maintained for this purpose, and the Presiding  Officer will call a meeting of the ICC for further action.   
II. The ICC shall prepare a prima facie report, with reasoned observations, recording the following:
           ● Whether the complaint is one of sexual harassment. 
● Whether it would constitute sexual harassment at the workplace, if proved 
● Whether the complaint falls within the jurisdiction of the ICC 
● Any recommendations pending inquiry  
III. Within  seven  working  days  from  the  date  of  the  receipt  of  the  complaint,  the  ICC  will  send  to  the  respondent  a  copy  of  the  complaint  and  the  documents  received  from  the  complainant.  If  the  complainant fears that there would be violence if her/his name is revealed. Then the ICC will request the  respondent to ask questions that will be routed through the ICC as an email, and if the respondent does  not acknowledge receipt of the same, then it shall be sent in a written from. If the respondent does not  receive the documents for three times, an ex-parte decision will be taken on the matter 
IV. The respondent is required to submit, within ten days of receipt of the complaint a reply to the complaint  along with a list of supporting documents, and the names and addresses of witnesses. 
V. In case  there is a  request  from  the complainant before initiating  the inquiry,  the ICC  shall  take  steps  to  conciliate the matter between the complainant and the respondent. The ICC will exercise caution and due  diligence to ensure that the conciliation is not adverse to the complainant. No pressure shall be brought  to  bear  on  the  complainant  to  agree  to  a  conciliation.    Conciliation  cannot  be  made  on  the  basis  of  monetary settlement. If a settlement is arrived at, the ICC has to record the same and  forward it to the  employer for necessary action, and give copies of the settlement to the complainant and the respondent.


I. In case no conciliation is arrived at, the ICC shall then initiate an inquiry and submit a report within three months.  The ICC has the same powers as are provided for civil courts under the Code of Civil Procedure for summoning persons and documents, and may set the procedure for conduct of proceedings. 
II. The HR Head  or any  other  responsible  person  that  can  secure  confidentiality  will  provide all  necessary assistance to the ICC including securing the attendance of the respondent as the case may be. 
III. The employer will also make available all necessary facilities to the ICC for dealing with the complaint. 
IV. In case there is any need for travel for either the Complainant or the Respondent, then the costs of travel & the stay will be borne by the organization. 
V. Both  parties  have  a  right  to  produce  oral  or  documentary evidence  in  their  favor. In  order  to maintain neutrality,  and  to  provide  a  process  that  is  intimidation  free  the  witnesses  of  both  the  parties  maybe examined, cross examined and questioned by the ICC. 
VI. Both parties have an option of taking assistance of a next friend of their choice, except legal counsel. The complainant/respondent shall intimate to the ICC the name and particulars of the person whom she/he desires  to  be  the  assistant.  The  ICC  has  a  right,  with  reasons  to  be  recorded  in  writing,  to  reject  the particular assistant proposed. 
VII. The ICC shall maintain a record sheet of the proceedings on each day of inquiry and will communicate to the concerned Complainant & Respondent  the final decision that is arrived at 
VIII. The members of the ICC, SMT, HR, Complainant, and Respondent shall maintain strict confidentiality at all times, of the identity of the complainant and the respondent, details in the complaint and the evidence produced, as well as any other particulars that would identify the complainant and details of the incident 
IX. The ICC shall have  the right  to  terminate  the inquiry proceedings or  to give an ex parte decision on  the complaint, if the complainant or respondent fails to present herself or himself without sufficient cause for three  consecutive  hearings  convened  by  the  Presiding  Officer,  after  giving  a  seven  days’  notice  to  the party concerned. 


The inquiry shall not be invalidated on account of delays in one or more of the stages in the inquiry procedures,  on  account  of  reasonable  grounds  or  circumstances  beyond  the  control  of  any  of  the  parties  or  the  ICC,  the  inquiry must continue and remains valid. It is important that the reason for delay be noted in the minutes of the  inquiry meeting as well as in the final opinion and later, in the annual report submitted to the employer.


The nature of action recommended should be proportionate to the gravity of the incident. 
• The ICC may provide interim reliefs and direct the employer to do the following; 
paid leave for a period of one month to the complainant; 
• Restrain the respondent from reporting on the work performance of the complaint; • Restrain the respondent from supervising the complainant’s activity 
• Or any other relief that the ICC deems fit, on its own initiative or upon the request of the complainant. 
• Where the ICC arrives at a conclusion that the allegation against the respondent has been proved, it shall recommend  to  the  employer  to  take  any  action,  including  a  written  apology,  warning,  reprimand, censure, withholding of promotion, withholding of pay  rise, payment of compensation,  terminating  the respondent from service or undergoing a counseling sessions or carrying out community service. 
• The ICC may also  recommend payment of compensation  to  the complainant by  the  respondent and/or the organization. The following factors shall be taken into account in determining the compensation: 
❖ The mental trauma, pain, suffering and emotional distress caused to the aggrieved person; ❖ The loss in the career opportunity due to the incident of sexual harassment; 
❖ Medical expenses incurred by the victim for physical treatment or counseling; 
❖ Feasibility of such payment in lump sum or in installments. 


Any person aggrieved (complainant or respondent) from the recommendations related to the quantum or nature  of penalties made by the ICC, or the non-implementation of such recommendations by the employer, may file an  appeal within three months of the recommendations made by the ICC.: 
– As a first step to the ED of the organization, who will refer the matter back to the ICC and take a suitable decision on the matter to be communicated back to the aggrieved persons / parties, within 10 days of the appeal having been made. 
– In case the above does not satisfy the aggrieved, then they can appeal again 
– Within 10 working days, and  the matter will be  reviewed by  the ED with  the SMT and at least 2 Board Members and responded to the aggrieved in 10 working days 
– After all the above efforts, the aggrieved is still dissatisfied, then they appeal to the Court or the Tribunal


A. Meetings 
a) The ICC is mandated to meet to hold inquiries into complaints of sexual harassment. b) The ICC will meet at least three times a year in addition to meetings held for inquiry. c) The quorum for the purpose of all meetings of the ICC including inquiries is 3. 
d) Any decision should be carried out by simple majority of those present and voting. The external member shall have the casting vote in the event of equality of votes. 
B. Findings 
The ICC  presiding  officer will  share  the  findings along with  the  recommendations  of  cases  that  the ICC handles with the ED & the HRD of Greenpeace India 
C. Reports 
▪ The ICC must submit a quarterly report to the SMT who shall present it to the Board of Greenpeace India. 
▪ The ICC must submit an annual report to the SMT in the month of April 
The following details should be provided in the Quarterly & the Annual Report 
a) Number of complaints of sexual harassment received in the year; 
b) Number of complaints disposed of during the year; 
c) Number of cases pending for more than ninety days; 
d) Nature of action taken by the employer.


a) Prohibition of publication or disclosing the content of complaint or inquiry proceedings 
The contents of the complaint made, the identity and addresses of the aggrieved, respondent and witnesses, any  information  relating  to  conciliation and inquiry  proceedings,  recommendations  of ICC and  the action  taken  by  the employer  shall  not  be  published,  communication  or  made  known  to  the  public,  press  or  media  in  any  manner.  
Any person who violates the above shall be penalized by the employer with such amount as may be prescribed in  the applicable statutory rules. 
However justice secured to any victim of sexual harassment can be disseminated without disclosing the details  mentioned above.

b) Action for false and malicious complaints 
In the event of the  ICC after the due diligence of its investigation ascertains that the complainant or the  witnesses have provided information that are malicious, and false then, it may recommend to the employer to  take necessary action as appropriate from a censure to termination as the case maybe . 
c) Further reference & guide 
Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 
d) Policy Implementation and Review 
This policy will be periodically revised and is subject to modification. Any amendment or waiver of any provision  of this Code must be approved in writing by the Organization’s Board of Directors, or such other committee as  may be decided, and promptly disclosed on the Company’s website and in applicable regulatory filings pursuant  to applicable laws and regulations, together with details about the nature of the amendment or waiver.

Policy Modified and made Effective from :  18th Nov 2015
For :  All Staff of Greenpeace India
Responsible for Monitoring and ownership : India Executive Director
Approval pathway :  Greenpeace India SMT , Greenpeace India Board


Qn. I am quite at discomfort with the way a colleague of a different sex interacts with me, I am not able to  label it as sexual, but I am not all at ease at all with the behavior. 
Ans.  You have a couple options: 
– You may contact your HR partner, and discuss the situation. The HR Partner may based on your account of the things will plan the steps to assist you in the matter: 
▪ If it appears to be having a bearing to Sexual Harassment as outlined in section III( e) of the POSH policy, then it will be forwarded to the ICC 
▪ If it does not appear on the face of it t both of you as a case of Sexual Harassment then it may involve with the HR Partner talking to your colleague to get a perspective, and also convey your anxiety without divulging your identity and let the individual know that behavior has to be altered, with a note to the Manager, and a copy of the same will be retained in the Personnel file . In case you do not see a change you may report the matter back to the HR, who will then take the matter up with the Manager of the individual and in consultation with the Senior 
Management will take appropriate steps which may range from a strong warning with consequences to holding an enquiry and if the findings show unacceptable norms of behavior amounting to misconduct / impropriety then termination will also be pronounced. 
However, you are equally empowered to take up the matter if you also see this happening to another  colleague who is not comfortable in taking it the notice of the HR or the Manager. And the options as  above would apply as well. 
Qn. I have not been a good performer and I feel harassed by my manager,  what recourse do I have and what  support can I get from the Management 
Ans. If you are poor or a non-performer, there are other organizational remedies to support and help you to  improve your productivity. Under no circumstances do we encourage any form and type of harassment. 
Please do not hesitate to discuss the issue with the Manager of your Manager and HR, so that you are  helped to focus on improving your performance rather than get under the pressure of harassment of any  sorts, and if you feel its Sexual abuse then take it directly to the ICC. 
Qn.  This policy makes reference to the constitutional statute and it is more towards sexual harassment of  women, what do people of other genders do if they are sexually harassed as well, can they too take to the  process narrated in the POSH policy ? 
Ans.  This policy is although created in the lines required under the legal Act, it will be applicable across all  genders, and there will be no variance in the way the process will be followed. Green peace believes in  Equal Opportunity and treating all staff under the same laid out organizational standards.
Sexual Harassment Policy ( Version 31 Last modified: Tuesday, November 17, 2015 
Page owner: Mr. Hafiz Mecci 
Printed: Tuesday, November 17, 2015 
Page 14 
Qn. How will you ensure that there is no misuse of this policy? 
Ans. We want to build a healthy workplace where people come for achieving the shared objectives of the  Organization and would want everybody to contribute to the spirit of working together in a professional  and ethical manner. 
Policies and guidelines are put in place reiterating our Philosophies and to deal with things that are  detrimental to the set principles of working and operating the Organizational mission. 
The affirmative and punitive actions will apply for misuse and misleading of any workplace policy that is  set to help us to work in a professional manner. 
Qn. I had a very close relationship with a colleague at work, but owing to some differences, I decided to be a  supporting colleague, but the other person now harasses me, and I have said that I will take it to HR and  my colleague says that there are evidences that are available which will prove my allegation false. 
Ans.  Developing good relationships at the workplace is healthy and during the course of interactions at the  workplace, possibilities exist for people to get close to some more than others, however at no point  should anybody take advantage of a relationship that is terminated and use that pretext to harass or  sexually abuse the other.  
This will be treated as a serious breach and we would urge you to report the matter irrespective of the  gender or the matter can be reported on behalf of the Victim. 
If it is general abuse please report to the Manager and /or the HR, and if its Sexual assault/ abuse write in  directly to the ICC.  

Please note everyone’s cooperation is required to keep the workplace healthy and free from any form  of abuse or harassment.