Prevention of Sexual Harassment (POSH) Policy

Effective Date: 17 June 2026

Applicable to: All students (ages 3-8), parents/guardians, staff, and visitors of Ultra

1. Purpose

Ultra (“the School”) is committed to providing a workplace free from sexual harassment for all women employees, and a campus free from sexual harassment for parents and visitors. This Policy is framed under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“POSH Act”) and its Rules.

2. Scope

This Policy applies to all women employees (permanent, contract, part-time, probationary), trainees, and interns at the School, and covers acts of sexual harassment by colleagues, supervisors, vendors, contractors, parents, or visitors occurring at the workplace, during School-related travel, or at School-related events.

3. What Constitutes Sexual Harassment

Sexual harassment includes any one or more unwelcome acts such as physical contact or advances, a demand or request for sexual favors, sexually colored remarks, showing pornography, or any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature.

4. Internal Committee (IC)

As required under Section 4 of the POSH Act, the School has constituted an Internal Committee comprising:

• A Presiding Officer — a senior woman employee.
• At least two members from amongst employees, preferably with experience in social work, women's welfare, or legal knowledge.
• One external member from an NGO or association committed to women's welfare, or with relevant expertise on sexual harassment matters.

At least half of the Internal Committee's members are women. Members serve a term of up to 3 years. Current Internal Committee details: Presiding Officer [Name/Contact]; Members [Names/Contact]; External Member [Name/Organization/Contact].

5. How to Raise a Complaint

1. A written complaint may be submitted to the Internal Committee within 3 months of the incident (extendable by the IC for reasons recorded in writing).
2. The complaint may be submitted by the aggrieved woman herself, or, where she is unable to do so, by a person authorized on her behalf as per the Act.
3. The Internal Committee may attempt conciliation only if specifically requested by the complainant, and not as a precondition to inquiry.

6. Inquiry Process

• The Internal Committee completes its inquiry within 90 days of the complaint, following principles of natural justice and providing both parties an opportunity to be heard.
• The identity of the complainant, respondent, and witnesses is kept strictly confidential throughout the process.
• The Internal Committee submits its findings and recommendations, and the School acts on them within 60 days of receiving the report.

7. Interim Relief

During the pendency of an inquiry, the Internal Committee may recommend interim measures such as transfer of either party, granting leave to the complainant, or restricting contact between the parties, to ensure the complainant's safety and comfort.

8. Protection Against Retaliation

No employee will face adverse consequences for raising a good-faith complaint or for participating in an inquiry as a witness. False or malicious complaints, if proven, may attract disciplinary action.

9. Awareness & Training

The School conducts orientation for new employees and periodic awareness sessions for all staff on this Policy and their rights and responsibilities under the POSH Act.

10. Annual Reporting

The School's Internal Committee prepares an annual report on the number of complaints received and resolved, submitted to the School management and, as required, to the District Officer.

11. Contact

To raise a concern under this Policy, contact the Internal Committee Presiding Officer: [Name/Email/Phone].