Prevention of Sexual Harassment (PoSH) Policy

1. Policy Statement

SpinSci is committed to providing a workplace that is free from sexual harassment and discrimination. We maintain a zero-tolerance policy towards sexual harassment and are dedicated to creating a safe, respectful, and inclusive environment for all employees, contractors, clients, and partners.

2. Scope and Applicability

This policy applies to all employees, contractors, consultants, vendors, clients, and any other individuals who interact with SpinSci in any capacity. It covers conduct that occurs:

• At the workplace or during work-related activities
• At company-sponsored events or functions
• During business travel or client meetings
• In virtual or remote work environments
• Through electronic communications (email, chat, video calls)

3. Definition of Sexual Harassment

Sexual harassment includes any unwelcome sexual advances, requests for sexual favors, or other verbal, physical, or visual conduct of a sexual nature when:

• Submission to such conduct is made a term or condition of employment
• Submission to or rejection of such conduct affects employment decisions
• Such conduct has the purpose or effect of unreasonably interfering with work performance
• Such conduct creates an intimidating, hostile, or offensive work environment

Examples of Sexual Harassment Include:

• Unwanted sexual advances or propositions
• Sexual jokes, comments, or innuendos
• Display of sexually suggestive materials
• Unwanted physical contact or touching
• Sexual gestures or leering
• Requests for sexual favors in exchange for employment benefits
• Retaliation against someone who reports harassment

4. Reporting Procedures

Internal Reporting

Employees who experience or witness sexual harassment should report it immediately to:

• Direct supervisor or manager
• Human Resources department
• Designated PoSH committee members
• Any member of senior leadership

External Reporting

Complaints can also be filed with external authorities including local law enforcement, Equal Employment Opportunity Commission (EEOC), or other relevant regulatory bodies.

5. Investigation Process

All complaints will be investigated promptly, thoroughly, and impartially. The investigation process includes:

• Immediate acknowledgment of the complaint
• Confidential and impartial investigation
• Interview of all relevant parties and witnesses
• Documentation of all findings
• Timely resolution and appropriate corrective action
• Protection against retaliation for all parties involved

6. Disciplinary Action

Any employee found to have engaged in sexual harassment will be subject to appropriate disciplinary action, up to and including termination of employment. Disciplinary measures will be proportional to the severity of the offense and may include:

• Verbal or written warnings
• Mandatory training or counseling
• Transfer or reassignment
• Suspension without pay
• Termination of employment

7. Protection Against Retaliation

SpinSci strictly prohibits retaliation against any individual who reports sexual harassment, participates in an investigation, or opposes discriminatory practices. Retaliation is a serious violation of this policy and will result in disciplinary action.

8. Training and Awareness

All employees are required to complete regular training on sexual harassment prevention, recognition, and reporting procedures. This training includes information about this policy, legal requirements, and the company's commitment to maintaining a harassment-free workplace.

9. Confidentiality

All complaints and investigations will be handled with the utmost confidentiality to the extent possible while ensuring a thorough investigation. Information will only be shared with those who need to know for the purpose of investigation and resolution.

10. Support and Resources

SpinSci provides support and resources for individuals affected by sexual harassment, including:

• Employee Assistance Program (EAP)
• Counseling services
• Legal guidance and support
• Workplace accommodations if needed
• Referrals to external support organizations

11. Policy Review and Updates

This policy will be reviewed annually and updated as necessary to ensure compliance with applicable laws and best practices. All employees will be notified of any changes to this policy.

12. Contact Information

For questions about this policy or to report concerns, contact: