Legal & Compliances

The Policy intends to ensure that no employee is subjected to Sexual Harassment and it is applicable to all employees of Orchid Medical Centre Private Limited. The POSH policy will apply to all employees across genders, creed, and races whether full time, part time, interns or on contract, irrespective of its nature of industry or location.

Sexual Harassment is any unwelcome sexually behaviour or pattern of conduct, that would cause discomfort and/or humiliate a person at whom the behaviour was directed. The behaviour includes but are not limited to the following:

• - Unwelcome sexual advances including verbal, non-verbal and physical conduct (explicit or implicit).
• - Physical contact and advances including touching, stalking, molestation, etc.
• - Demand or request for sexual favours (during or after office hours).
• - Sexually coloured remarks or sexual remarks about a person’s body or clothing.
• - Unwelcome hand gestures and eve-teasing.
• - Showing pornography and participation in indecent/sexual messages through any medium.
• - Preferential treatment meted out to employees on sexual grounds.
• - Any other unwelcome physical, verbal, or non-verbal conduct of sexual nature.

(a) Indirect Sexual Harassment

• - Creating an intimidating, hostile or offensive work environment.
• - Unreasonably interfering with one’s work performance (like pornography in public places, foul language, or innuendos, etc.).
• - This kind of sexual harassment need not be directed at a single person particularly.

(b) Direct Sexual Harassment

Sexual Harassment by a person in position of power or influence constitutes direct sexual harassment when:

• - Submission by an individual is made either an explicit or implicit term or condition of employment.
• - Submission or rejection of such conduct is used as a basis for employment decisions affecting the employee such as promotions, demotions, salary rises, etc.

(a) The internal complaints committee (ICC):

The ICC is notified to cover and take responsibility for all employees in the workplace in this regard. The ICC is responsible for the following:

• - Initiating and conducting inquiry as per the established procedure. Submitting the findings and recommendations of the inquiry.
• - Coordinating with the employer to ensure implementation of the appropriate recommendations or actions.

The committee should comprise:

• - Presiding Officer should be generally women employee at any level in the workplace.
• - Two other members, from amongst employees committed to this cause with extensive legal prowess.
• - One external member (from an NGO or likewise) familiar with the issues of sexual harassment.

While the minimum number of members in the ICC should be 4 as per the POSH Act, the ICC can have more members across the workplace.

(b) Lodging a Complaint :

• - The complainant can reach out to the immediate officer or any member of ICC, either personally or through a formal email communication, regarding the harassment faced.
• - Sufficient precautions will be taken by the organization to ensure that complete confidentiality is maintained, and no form of discrimination is faced by the employee who has escalated the complaint.

(c) The Resolution Process:

• - The ICC shall investigate all complaints thoroughly and promptly, in a free and fair manner.
• - Investigation may include private interviews or a formal inquiry process.
• - A complaint can be resolved through conciliation only if the aggrieved employee approves of the same.
• - The ICC shall communicate the course of action to be taken to the employer. If no substantial action is arrived at, the same is communicated as well.
• - The courses of action may include Counselling, Warnings or Reprimand, tendering of apology, withholding of promotions/ increments, suspension, termination etc.
• - The Employer should present the course of action within 30 days and the same should be intimated to the ICC.

The ICC shall in each calendar year prepare, in such format as may be prescribed, an annual report and submit the same to the employer and the District Officer (as defined in the Act).

The report shall have the following details:

• - Number of complaints of Sexual harassment received in the year.
• - Number of complaints disposed of during the year.
• - Number of cases pending for more than 90 days.
• - Number of workshops or awareness program against Sexual Harassment carried out.
• - Nature of action taken by the employer or District Officer.

If the victim wants to make a formal complaint or if the informal complaint mechanism has not led to a satisfactory outcome for the victim, the formal complaint mechanism should be used to resolve the matter.

The designated person who initially received the complaint will refer the matter to a senior human resources manager to instigate a formal investigation. The senior human resources manager may deal with the matter him/herself, refer the matter to an internal investigator in accordance with this policy.

The person carrying out the investigation will:

• - interview the victim and the alleged harasser separately.
• - interview other relevant third parties separately.
• - decide whether or not the incident(s) of sexual harassment took place.
• - produce a report detailing the investigations, findings and any recommendations.

if the harassment took place, decide what the appropriate remedy for the victim is, in consultation with the victim (i.e.-an apology, a change to working arrangements, a promotion if the victim was demoted as a result of the harassment, training for the harasser, discipline, suspension, dismissal).

• - follow up to ensure that the recommendations are implemented, that the behavior has stopped and that the victim is satisfied with the outcome.
• - if it cannot determine that the harassment took place, he/she may still make recommendations to ensure proper functioning of the workplace.
• - keep a record of all actions taken.
• - ensure that the all records concerning the matter are kept confidential.
• - ensure that the process is done as quickly as possible and in any event within 7 days of the complaint being made.

Outside complaints mechanisms

A person who has been subject to sexual harassment can also make a complaint outside of the Company. They can do so through labor court or judicial court.

Sanctions and disciplinary measures

Anyone who has been found to have sexually harassed another person under the terms of this policy is liable to any of the following sanctions.

• - verbal or written warning
• - adverse performance evaluation
• - reduction in wages
• - transfer
• - demotion
• - suspension
• - dismissal

The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial. Certain serious cases, including physical violence, will result in the immediate dismissal of the harasser.

Awareness sessions are to be organized to formulate and widely disseminate an internal policy or charter or resolution or declaration for prohibition, prevention and redressal of sexual harassment at the workplace intended to promote gender sensitive safe spaces and remove underlying factors that contribute towards a hostile work environment against employees.

The primary objective of our CSR policy is to support the development of a healthier, more equitable society. Our efforts are directed at increasing access to affordable healthcare, promoting preventive health education, supporting underserved communities, improving environmental sustainability, and upholding the highest standards of ethical conduct.

Through this policy, [Hospital Name] also seeks to create long-term value for patients, employees, partners, and the broader community by aligning social impact initiatives with our vision and values.

This CSR policy applies to all employees, departments, units, and affiliated entities of Orchid Medical Centre Private Limited. It encompasses all CSR programs undertaken by the hospital, whether directly implemented or in collaboration with external partners such as non-governmental organizations (NGOs), community-based organizations, or government agencies.

4.1. Constitution:

Pursuant to the provisions of Section 135 of the Act, the Board of Directors shall constitute the Corporate Social Responsibility (CSR) Committee. The Members of CSR shall be appointed by the Board of Directors of the Company which must consist of at least two or more Directors. Accordingly, the constitution of CSR Committee formed by the Company is as follows:

4.2. Functions and Powers of Committee:

To effectively implement the objectives of the Company with respect to CSR, the Committee is vested with the following functions and powers:

• a. Formulate CSR Policy and recommend the same to the Board of Directors of the Company for approval;
• b. Recommend CSR activities as stated under Schedule VII of the Act;
• c. Approve to undertake CSR activities, if necessary, in collaboration with group companies/other Companies/firms/NGOs etc., and to separately report the same in line with the CSR Rules;
• d. Recommend the CSR Budget;
• e. Spend the allocated CSR amount on the CSR activities once it is approved by the Board of Directors of the Company in accordance with the Act and the CSR Rules;
• f. Create transparent monitoring mechanism for implementation of CSR initiatives in India. Submit the Reports to the Board in respect of the CSR activities undertaken by the Company;
• g. Monitor CSR Policy from time to time;
• h. Monitor activities/charter of Internal Working and Monitoring Group (WG) who are authorized to ensure that the CSR activities of the Company are implemented effectively;
• i. Authorize executives of the Company to attend the CSR Committee Meetings, if necessary.

4.3. Meetings of the Committee:

For smooth functioning of the Committee, the members shall meet as below to discuss such matters and to take such decisions as may be necessary;

• a. The CSR Committee shall hold a minimum number of two meetings in a year;
• b. The members of the Committee may mutually agree between them regarding time and place for the said meetings;
• c. The quorum for the CSR Committee Meeting shall be one-third of its total strength (any fraction contained in that one-third be rounded off as one) or two members, whichever is higher.;
• d. The Members of the Committee may participate in the meeting either in person or through video conferencing or other audio-visual means as may be convenient.

4.4. CSR Spend:

The Companies Act, 2013 prescribes that the companies which meet the criteria specified U/s. Sec. 135 shall allocate certain portion of its annual net profits (calculated as per Sec. 198) during the three immediately preceding financial years to be spent on CSR Activities that fall under the categories specified under Schedule VII of the Act.

4.5. CSR Expenditure:

Net profit for the purpose of allocation towards CSR means profit more fully described under Rule 2(f) of the CSR Rules. The CSR expenditure shall include all expenditure including contribution to corpus or on projects or programs relating to CSR activities approved by the Board of Directors on the recommendation of its CSR Committee but does not include any expenditure on an item not in conformity or not in line with activities stated under Schedule VII of the Act.

4.6. Failure to spend the CSR Money:

If the Company fails to spend the required amount in a particular financial year, it is the duty of the Committee to submit a report in writing to the Board of Directors specifying the reasons for not spending the amount, which in turn shall be reported by the Board of Directors in their Annual Report pertaining to that particular Financial Year. Surplus,if any, arising out of the CSR projects or programs or activities shall not form part of the business profit of the Company.

Pursuant to Schedule VII of the Act and the CSR Rules, the Company shall undertake CSR activities included in its Annual CSR Plan, as recommended by the CSR Committee at the beginning of each year. The Committee is authorized to approve any modification to the existing Annual CSR Plan or to propose any new program during the financial year under review.

a. Access to Healthcare and Community Well-being:

One of our key priorities is to make healthcare accessible to vulnerable and marginalized populations. We actively organize free medical camps, mobile clinics, health check-up drives, and outreach programs in rural and underserved urban areas. These programs are aimed at early detection, timely intervention, and treatment of common illnesses, chronic conditions, and preventable diseases.

We also provide subsidized or free treatment for patients from economically weaker sections, ensuring that financial barriers do not hinder access to essential healthcare services.

b. Preventive Healthcare and Health Education:

Orchid Medical Centre Private Limited is committed to promoting a culture of preventive healthcare. We conduct regular awareness campaigns and health education sessions in schools, workplaces, and community centers, focusing on topics such as hygiene, nutrition, immunization, maternal and child health, mental health, and lifestyle diseases.

We also support the training and upskilling of healthcare workers, paramedics, and volunteers, thereby strengthening the healthcare ecosystem and building community resilience.

c. Environmental Responsibility:

Being in the healthcare sector, we are acutely aware of our environmental footprint. We adopt sustainable practices across all hospital operations, including energy conservation, water management, and responsible biomedical waste disposal.

We are committed to implementing eco-friendly infrastructure and promoting green hospital practices such as digital record-keeping, paperless systems, and waste reduction initiatives. Our goal is to reduce our environmental impact and contribute to a healthier planet.

d. Employee Engagement and Inclusive Workplace:

Our CSR efforts are strengthened by the active involvement of our employees. We encourage our staff to participate in volunteering programs, awareness drives, and community outreach efforts. Internal wellness programs, mental health support, and continuous professional development are also integral to our employee welfare initiatives.

We strive to maintain an inclusive and respectful workplace, promoting diversity and ensuring equal opportunities for all employees, regardless of gender, background, or ability.

e. Partnerships and Community Collaboration:

We recognize that impactful change is often achieved through collaboration. Orchid Medical centre Private Limited works closely with NGOs, academic institutions, local governments, and other healthcare providers to design and implement effective social programs. These partnerships help us reach more beneficiaries, ensure greater accountability, and scale up successful interventions.

CSR activities at [Hospital Name] are guided and monitored by a designated CSR Committee. The Committee is responsible for identifying focus areas, selecting programs, allocating resources, evaluating progress, and ensuring that all initiatives align with our mission and comply with relevant regulations.

The CSR budget is determined annually and may be based on statutory requirements or voluntary commitments, depending on the hospital’s legal structure and financial capacity. All projects are selected based on their relevance, potential impact, sustainability, and alignment with our CSR objectives.

All CSR initiatives are subject to regular monitoring and evaluation. Key performance indicators are established to assess the effectiveness and impact of each program. Feedback from beneficiaries and stakeholders is incorporated to improve future efforts.

An annual CSR report is prepared and reviewed by the CSR Committee and the senior management. This report outlines key initiatives undertaken, resources utilized, outcomes achieved, and learnings gathered. Where applicable, the report will be made publicly available to promote transparency and stakeholder engagement.

Orchid Medical Centre Private Limited is committed to complying with all applicable laws and regulations related to corporate social responsibility, including the [Companies Act 2013, Section 135 – if based in India]. All CSR activities are conducted with integrity, respect for human rights, and adherence to medical and ethical standards.

We ensure that all vendors, partners, and collaborators involved in our CSR programs follow the same high standards of transparency, compliance, and ethical conduct.

This CSR policy shall be reviewed annually, or as required, to ensure that it remains aligned with evolving legal requirements, community needs, and organizational priorities. Any amendments will be approved by the CSR Committee and the Board of Directors or appropriate authority.