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Anti-Sexual Harassment Policy.

BT is committed to look into all allegation of sexual harassment bought to its notice by its employees/ interns/ volunteers/ board members/ partners/ stakeholders/ vendors/ consultants, thoroughly and investigate it in a time bound manner, with due regard to confidentiality.

An atmosphere of mutual respect among employees is necessary for Breakthrough (BT) to function as an organisation. Any violation of mutual trust, any form of threats or exploitation, damages the process by undermining the essential vision that BT has. All employees must feel personally secure for real transformation and social norm change to take place externally. As a place of work Bt premises must be free of discrimination and harassment in all of its forms, including threats and exploitation. All employees must be assured that BT will take action to prevent such misconduct and that anyone who engages in such behaviour is subject to disciplinary procedures. BT has a legal obligation to provide a harassment/discrimination free environment, and is committed to maintaining a working environment which is free of inappropriate and disrespectful conduct of a derogatory nature regarding anyone.

The policy applies to all employees/ interns/ volunteers/ board members/ partners/ stakeholders/ vendors/ consultants (full time and part time).Each member of the BT team is expected to support efforts to keep the organisation free of sexual harassment.


Right to live with dignity is a universally recognized human right. Any kind of sexual harassment violates the right to live with dignity.


Acts amounting to Sexual Harassment:

  • Unwanted physical contact and advance
  • A demand or request for sexual favours
  • Sexually coloured remarks
  • Exposing anyone to pornographic material audio or visual or print
  • Any other unwelcome physical, verbal or non-verbal conduct of sexual nature


Sexual harassment at the workplace includes but is not limited to:

  • Implied or overt promise of preferential treatment in employment; or
  • Implied or overt threat of detrimental treatment in employment; or
  • Implied or overt threat about present or future employment status; or
  • Conduct of any person which interferes with work or creates an
  • Intimidating or offensive or hostile work environment or
  • Humiliating conduct constituting health and safety problems


Medium of sexual harassment

A person can be guilty of sexual harassment if any unwelcome sexually determined behaviour is committed through any of the following ways:

  • Comments
  • Remarks
  • Jokes
  • Letters
  • Phone calls
  • Emails
  • Chats on any electronic/social media medium
  • Gestures
  • Remarks
  • Showing of pornography clipping
  • Lurid stares
  • Physical contact
  • Molestation
  • Stalking
  • Sounds or display of a derogatory nature


Principles BT follows in dealing with SH

  • Encourages any employee who feels they have been harassed to contact his/her reporting officer or HR Centre immediately
  • Recognises comments and behaviour which do not offend one person can offend another
  • Accepts individuals may react differently and expects this right to be generally respected
  • Treats all complaints of sexual harassment seriously and promptly, with due regard to confidentiality
  • Will take disciplinary action will be taken against any employee if the Internal Complaints Committee found the allegation against the employee to be true


In order to foster a fearless environment, BT shall take proactive steps in preventing sexual harassment and resolving disputes of such nature.

  • To undertake workshops and training programmes at regular intervals to sensitise all employees
  • To pursue the complaint and the safety of the complainant
  • To assure confidentiality of the case
  • To have a functional Internal Complaints Committee to deal with the cases relating to Sexual Harassment
  • To inform the employees about the Internal Complaints Committee by displaying the same at conspicuous place at all BT premises
  • Provide necessary facilities to the Internal Committee as the case may be, for dealing with the complaint and conducting inquiry
  • To provide counselling services to the complainant
  • Assist in securing the attendance of respondent and witnesses before the Internal Committee or the local Committee


BT has the legal responsibility to prevent sexual harassment. Therefore, center heads, state heads, managers and supervisors have a responsibility to:

  • monitor the working environment to ensure acceptable standards of conduct are observed at all times
  • model appropriate behaviour themselves
  • treat all complaints seriously and take immediate action to investigate and resolve the matter
  • refer complaints to another manager or head of HR, if they do not feel they are the best person to deal with the case (e.g. if there is a conflict of interest or if the complaint is particularly complex or serious)


All employees have a responsibility to:

  • comply with the organisation’s sexual harassment policy
  • offer support to anyone who is being harassed and let them know where they can get help and advice (they should not approach the harasser themselves)
  • maintain complete confidentiality if they provide information during the investigation of a complaint (employees who spread gossip or rumours may expose themselves to defamation action)


Redressal Mechanism


Making a Complaint:

If you believe you are being, or have been, harassed, follow the procedure below:

  • Promptly and clearly confront the individual.  If you feel comfortable doing so, you should let the person know that the remark or conduct is unwelcome and unacceptable.  Explain what happened in your own words, how it made you feel, how others feel about it (if applicable), and how you would prefer to be treated. Keep a record of the incident(s).
  • If the unwelcome behaviour continues after you have confronted the individual that his /her behavior is offensive to you, or if you feel direct confrontation is inappropriate on the first occurrence of such behavior, report the situation immediately to your reporting officer or the HR Centre or the Internal Complaints Committee of BT.
  • You can never go wrong by reporting the situation.  If no investigation is necessary, BT will simply monitor the situation.
  • You are entitled to work in an office free of unlawful harassment and discrimination and you should fully assert that right.


Receiving a Complaint:

When a reporting officer or member of ICC receives a complaint, he/she should follow the procedure below:

  • Take all reports of harassment or discrimination seriously.  Demonstrate that you care and are concerned
  • Maintain confidentiality and protect the rights of both the complaint and the accused.
  • Be supportive and sensitive; assure the complaint that you will give the situation prompt attention and do so
  • State your commitment to BT’s Equal Employment and Anti-Harassment policies and explain that no retaliation will occur
  • Offer the complaint to approach the  Internal Complaints Committee of BT in case the complaint is not comfortable talking about his/her experience
  • Treat the complaint confidentially and allow the complainant to bring another person to the interview if he/she chooses to
  • Encourage the individual to talk specifically about what happened. Ask the complainant for the full story, including what happened step by step
  • Take notes, using the complainant’s own words and ask the complainant to check your notes to ensure your record of the conversation is accurate
  • Contact the Internal Complaints Committee of BT.  Do not conduct a further investigation on your own unless directed to do so.
  • Take the next step, even if the complaint does not want you to, you should promptly report this situation to the Chairperson of the Internal Complaints Committee in BT.  The Internal Complaints Committee in BT will handle the matter from that point forward and will determine what course of action, should be taken.


If you observe harassment or discrimination or are told about it:

  • Speak up and let the offender know how you as an impartial observer, view the behavior. Show your care and concern.
  • Be specific regarding the comment or behavior, and tell the individual why it made you uncomfortable.  Refer to the organization’s policy and/or our mission and values in addition to your own perceptions.
  • Report the situation in accordance with the reporting procedures set forth above.


Potential Outcomes


If the complaint is found to be justified, the complainant may be entitled to any or all of the following:

The complainant may receive:

  • Commitment that the behaviour will cease
  • Apology (verbal or written) by the respondent
  • Re-credit of any leave taken due to the harassment
  • Payment of medical and counselling expenses
  • Transfer, with no job disadvantage or advantage (if possible and in case the complainant doesn’t want to work with the accused in the same office premises


The committee may recommend the following penalties on a person found guilty of sexual harassment.

Warning, Reprimand or Censure

  • Fine
  • Withholding of increments or promotion
  • Reduction to a post in the lower pay scale or to a lower stage of increment
  • Suspension from service from two to six months without pay
  • Removal/dismissal from service


The Vice President & Country Director based on the findings and the recommendations of the Internal Complaints Committee will be taking the final decision.

In the event of a false accusation, the employee claiming to be a victim will be liable for disciplinary action as follows –

  • Recorded & severe warning (can be given by the reporting officer and by the Vice President & Country Director based on the findings ofInternal Complaints Committee)
  • Suspension from work without salary (can only be given by the Vice President & Country Director based on the findings of the Internal Complaints Committee)


In accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, Breakthrough has set up an Internal Complaints Committee as per the redressal mechanism provided in the Act.  The following staff members will constitute the ICC:

  • Sunita Menon – Presiding Officer
  • Ditipriya Ghosh – Member
  • Krati Prakash – Member
  • Mousumi Kundu – Member
  • Alok Bharti – Member


With one external member:

  • Soumya Bhowmik, Independent Thoughts

The key highlights regarding the Committee:

  • A written complaint of sexual harassment can be filed within a time limit of 3 months from the time of the incident. This may be extended to another 3 months if the aggrieved woman employee can prove that grave circumstances prevented her from doing the same.
  • An Oral Complaint will be reproduced in writing. It shall be duty of the ICC/member before whom an oral complaint is made to reduce the said complaint in writing and read out the complaint to the aggrieved woman employee in the language requested by the aggrieved woman employee and obtain the signature of the aggrieved woman employee.
  • The Committee will conduct its inquiry as stipulated under the Act and Rules there under
  • The Committee is required to complete the inquiry within a time period of 90 days.
  • On the completion of the inquiry, the ICCshall provide a report of its findings within a period of ten days from date of completion of the inquiry. On completion of the inquiry, the report will be sent to the President who is to take action on the report within 60 days.
  • The identity and complaint of the aggrieved woman employee, respondent, witness and any other party involved shall not be published anywhere and will not be communicated to any third party under strict confidentiality. Any breach to this will be liable for a penalty of written & severe warning or dismissal
  • The Internal Complaints Committee shall in each calendar year prepare an annual report and submit to the President & CEO


BT is committed to look into all allegation of harassment bought to its notice by its employees/ interns/ volunteers/ board members/ partners/ stakeholders/ vendors/ consultants, thoroughly and investigate it in a time bound manner, with due regard to confidentiality.

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