Prevention of Sexual Harassment (POSH) Policy
Workplace framework to prevent, prohibit and redress sexual harassment, under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013.
Scope
This policy applies to all entities of KW Group and to all employees — including probationers, interns, trainees and consultants — regardless of role, seniority or employment status. No woman shall be subjected to sexual harassment at the workplace; such harassment is a grave offence and is punishable.
Workplaces covered
The corporate and head office at Block B-97, Sector-63, Noida 201301, serving all KW Group entities; the KW Delhi-6 site office at Main Road, NH-58 Bypass, Raj Nagar Extension, Ghaziabad, Uttar Pradesh 201017 (KW Homes Private Limited); and the KW Blue Pearl site office at Plot No. 2, D.B. Gupta Road, near Faiz Chowk, Jhandewalan, Karol Bagh, Delhi 110005 (Madhyam Housing Private Limited). Workplace also covers any place visited in the course of employment, including Company-provided transport.
Internal Complaints Committee
The Internal Complaints Committee was reconstituted with effect from 1 January 2025. A separate committee serves each workplace, chaired by a Presiding Officer who is a senior woman employee and including an external member. Members are listed in Annexure A below and are trained to handle complaints under the Act and Rules.
Who may complain
Any aggrieved woman at a KW Group workplace — of any age, whether employed by the Company or not — may approach any member of the Committee. Where she is unable to complain herself because of mental or physical incapacity or any other reason, the representative prescribed under the Act or Rules may file on her behalf. Any concern amounting to sexual harassment received by any Company official or employee must be forwarded to a Committee member within one week of receipt.
How to complain
Submit the complaint in writing to any Committee member, stating the name of the aggrieved woman or complainant, the name of the respondent, details of the incident or incidents, any evidence, and the names of witnesses. Send a copy with supporting documents and witness details to hr1@kwgroup.in. The Committee forwards a copy to the respondent within seven working days, and the respondent must reply with documents and witness details within ten working days of receiving it.
Time limit
Complain within three months of the incident, or within three months of the last incident in a series. The Committee may extend this by up to a further three months where it is satisfied that circumstances prevented a timely complaint, recording its reasons in writing.
Conciliation
Before an inquiry begins, and only at the aggrieved woman's request, the Committee may attempt to settle the matter by conciliation. No monetary settlement may form the basis of a conciliation. Where a settlement is reached, no further inquiry is conducted — but if the respondent fails to comply with any term, the Committee proceeds with the inquiry or refers the complaint to the police as it deems fit.
Interim measures
During an inquiry, on the written request of the aggrieved woman or complainant, the Committee may recommend that the employer transfer either party to another team, department or location; grant her paid leave of up to three months or until the investigation concludes, whichever is earlier; restrain the respondent from reporting on her performance or writing her appraisal; require the respondent to work from home or from another office; or grant any other relief prescribed under the Act or Rules. The employer implements the recommendation and reports the implementation back to the Committee.
Inquiry procedure
The Committee informs the employer that a complaint has been received. At least three members, including the Presiding Officer, must be present to conduct the inquiry; if the Presiding Officer is absent, the members present elect a senior woman employee from among themselves to chair. Legal practitioners may not represent either party at any stage. The inquiry is completed within ninety days, and the Committee submits its report and recommendations to the employer within ten days of concluding it.
Misconduct and action
Sexual harassment; intimidation of a complainant, witness or other person connected with a complaint; malicious allegations; a complaint known to be false; and producing a forged or misleading document before the Committee all constitute misconduct. A mere inability to substantiate a complaint or provide adequate proof is not misconduct. Punishment may include a written apology; a warning, reprimand or censure; withholding of promotion, pay rise or increments; deduction from the respondent's salary to be paid to the aggrieved woman; termination of services; counselling; or community service. The employer acts on the Committee's recommendation within sixty days of receiving the report.
Confidentiality
The contents of a complaint, the identities and addresses of the aggrieved woman, respondent and witnesses, any information about conciliation or inquiry proceedings, the Committee's recommendations and the action taken must not be published or made known to the public, press or media in any manner. Anyone who breaches confidentiality is liable to disciplinary action under the Company's service rules and to the penalty prescribed under the POSH Act 2013.
Awareness and reporting
The Company displays this policy, the Committee's composition and the penal consequences of sexual harassment on the notice boards of all its administrative locations, and holds workshops for employees and training for Committee members at regular intervals. Each calendar year the Committee prepares an annual report for the employer and the District Officer covering cases filed and their disposal, actions taken, complaints pending beyond ninety days, and awareness sessions held. The Directors' Report carries the statement on Internal Committee constitution required by the Companies (Accounts) Rules 2014.
Policy review
The policy is reviewed at the end of each calendar year, or sooner if the law on sexual harassment changes before the scheduled review. It is not exclusive: it incorporates all provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013, including any notification or amendment issued by the government.
Annexure A — Internal Complaints Committee
Head Office
Represents KW Homes Private Limited, Madhyam Housing Private Limited, Accurate Infra Developers Private Limited, KW Security and Services Private Limited.
| Member | Designation | Contact | |
|---|---|---|---|
| Mrs. Chavi Agarwal | Presiding Officer | 8377004575 | mdo2@kwgroup.in |
| Mrs. Pooja Kumari | External Member | 8200542130 | poojatiwary17a@gmail.com |
| Mrs. Tuljapurkar Vaishnavi Charudutta | Member | 9625924816 | mdo3@kwgroup.in |
| Mr. Ankur Sehgal | Member | 8377008639 | hr1@kwgroup.in |
| Mr. Sanjay Kesarwani | Member | 9910455877 | pm11@kwgroup.in |
KW Delhi-6
Represents KW Homes Private Limited, Madhyam Housing Private Limited, KW Security and Services Private Limited.
| Member | Designation | Contact | |
|---|---|---|---|
| Mrs. Chavi Agarwal | Presiding Officer | 8377004575 | mdo2@kwgroup.in |
| Mrs. Pooja Kumari | External Member | 8200542130 | poojatiwary17a@gmail.com |
| Mrs. Tuljapurkar Vaishnavi Charudutta | Member | 9625924816 | mdo3@kwgroup.in |
| Mr. Prashant Kumar Singh | Member | 8588897346 | sm1@kwgroup.in |
| Mr. Sanjay Kesarwani | Member | 9910455877 | pm11@kwgroup.in |
KW Blue Pearl
Represents Madhyam Housing Private Limited.
| Member | Designation | Contact | |
|---|---|---|---|
| Mrs. Chavi Agarwal | Presiding Officer | 8377004575 | mdo2@kwgroup.in |
| Mrs. Pooja Kumari | External Member | 8200542130 | poojatiwary17a@gmail.com |
| Mrs. Tuljapurkar Vaishnavi Charudutta | Member | 9625924816 | mdo3@kwgroup.in |
| Mr. Rajeev Ranjan | Member | 9643107376 | sm2@kwgroup.in |
| Mr. Sanjay Kesarwani | Member | 9910455877 | pm11@kwgroup.in |
About this policy