[Guidelines (modal) for preparation of final document suitable for individual educational institutes affiliated to NTR University of Health

Sciences, Vijayawada]

Regulations to Combat Sexual Harassment at work places

In affiliated colleges of NTR University of Health Sciences

Name of the Institution Place of the Institution Month & Year of Preparation

:____________________________________ : ____________________________________ : ___________________________________

Month & Year of Implementation : ___________________________________

INDEX 1 2 3 Introduction Background Section 1: 1) Scope 2) Definitions 3) Prohibition of Sexual Harassment 4 Section 2: 4) Appointments a) Sexual Harassment Policy Advisor: b) Complaints Committee: c) Facilitators: 5) Powers and Duties of appointed members a) The Powers and duties of SHPA b) Duties of Complaints Committee c) Role and Functions of the facilitators Section. 3: 6) Definition of Sexual harassment 7) Recourses under the Rules 8) Mediation Section 4: The Inquiry 9) Filing of formal request for inquiry 10) Initiation of enquiry 11) Conducting Inquiry 12) Relevant factors to be considered 13) Adverse Inference 14) Action on the Inquiry 15) Time Frame 16) Review 17) Malafide Complaint Section 5: 18) Corrective actions a) For Faculty / Staff b) For Students 19) Criminal Proceedings Section 6: Miscellaneous 20) Maintenance of records 21) Recusal 22) Confidentiality 23) Minor infringement not to invalidate proceedings 24) Victimization 25) Support Structures 26) Review of the Regulations Annexure 1 Annexure 2 Salient points 2

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Combat Sexual Harassment at work places

INTRODUCTION: In order to provide a pleasant & congenial working environment, it is important that we at (name of the College) maintain a workplace characterized by mutual respect. Each member/student of the (name of the College) shall live a life free of sexual harassment irrespective of their gender, race, caste, class, sexual orientation, disability and status; According to the Protection of Human Right Act, 1993 "human rights" means the rights relating to life, liberty, equality and dignity of the individual guaranteed by the Constitution or embodied in the International Covenants and enforceable by courts in India. It is necessary and expedient for employers in work places as well as other responsible persons or institutions to observe certain guidelines to ensure the prevention of sexual harassment of women as to live with dignity is a human right guaranteed by our constitution. It has been laid down by the Supreme Court that it is the duty of the employer or other responsible persons in work places or other institutions to prevent or deter the Commission of acts of sexual harassment and to provide the procedure for the resolution, settlement or prosecution of acts of sexual harassment by taking all steps required. Women who either draw a regular salary, receive an honorarium, or work in a voluntary capacity - in the government; private sector or unorganised sector comes under the purview of these guidelines.

Regulations to

BACKGROUND
The (name of the College) is committed for high values and morals. The (name of the College) aims for the campus environment where every person/student feels respected and can lead a life in dignity, free from vulnerability. The Constitution of the India insists in protecting and nurturing the dignity of the individual. The international convention on the elimination of all forms of discrimination against women 1979, had spelled out certain ideals in this regard. Supreme Court of India has laid down principles and guidelines in the case of Vishaka and others Vs. Rajasthan and others 1997 regarding sexual harassment. The Supreme Court of India quoted regarding the role of employer. It shall be the duty of the employer or other responsible persons in work places or other institutions to prevent or deter the commission of acts of sexual harassment and to provide the procedures for the resolution, settlement or prosecution of acts of sexual harassment by taking all steps required. The (name of the College) has established the following principles and procedures namely Regulations to Combat Sexual Harassment. These Regulations aim to combat sexual harassment and create confidence in the mind of staff/Student at the (name of the College) campus. The (name of the College) has established has laid out the principles and procedures as per Supreme Court of India guidelines to combat sexual Harassment at work places, hereinafter referred to as the Regulations .

Section. 1: 1)Scope The Principles and Procedures set out herein shall apply to all instances of sexual harassment as provided a) Occurring in the (name of the College) Campus, irrespective of the parties; b) Between or among staff members of the (name of the College), irrespective of their location; c) Where the complaint is made by a third party against a member of the (name of the College) d) Where Complaints made by student against a faculty member in the campus. e) Where Complaints made by student against a Student in the campus. f) Where third party member is involved in an activity pertaining to the (name of the College) irrespective of their location. These Principles and Procedures laid out in these Regulations shall be the exclusive mechanism in alleged instances through which the (name of the College) combats the sexual harassment. Except where, the Principal advise the complainant to decide on the alternate mechanism under which she/he will proceed to any other institutional, civil/criminal remedies available to her/him in the (name of the College) as well as under the law. 2) Definitions a) Day shall be understood as one working day. b) Faculty for the purposes of these Regulations includes all persons in teaching positions working part time, full time regardless of the duration. She/He can be a guest faculty, visiting faculty, teaching assistant or any person involved in the organization of a program, seminar, workshop or similar event for events conducted or organized by the (name of the College) . c) Staff for the purposes of these Regulations includes all persons appointed to any positions of the (name of the College) , regardless of duration and type of work. d) Students include individuals enrolled or admitted for any course in any year including Internship . e) Unwelcome sexual conduct includes any unwelcome sexual advances, unwelcome acts of physical intimacy, unwelcome requests for sexual favors, including oral, textual, graphic representations of a sexual nature to a person; f) Sexual harassment: A person shall be guilty of sexual harassment under these Rules when She/he indulges persistently in conduct known to him/her to be unwelcome sexual conduct or should reasonably have been known to such person to be unwelcome sexual conduct or She/he indulges in conduct that may reasonably be perceived by the victim as unwelcome sexual conduct. g) Victimization: shall be understood to mean any adverse action relating to employment, or evaluation, or entitlement to services/opportunities. by an individual, group of individuals or organization against individuals because they have, in good faith, reported instances of sexual harassment or participated in or have been witnesses to proceedings to redress an alleged instance of sexual harassment. 4

h) Complaints Committee (CC): Committee appointed to go through the complaints relating to Sexual harassment and advise the authorities for relevant action i) Sexual Harassment Policy Advisor (SHPA): The Advisor appointed by The Principal to ensure proper and effective implementation and administration of these Regulations . 3) Prohibition of Sexual Harassment Sexual Harassment is prohibited and shall be dealt with under these rules. Section. 2: 4) Appointments
a)

Sexual Harassment Policy Advisor: The Principal shall appoint a senior member - - Preferably Female who has been working in the (name of the College) for reasonable period to act as a Sexual Harassment Policy Advisor (hereinafter SHPA). The Advisor shall ensure proper and effective implementation and administration of these Regulations. Complaints Committee: The Principal in consultation with the Sexual Harassment Policy Advisor shall constitute a Complaints Committee (CC), which shall consist of three members. Two senor faculty/staff members of the (name of the College) among which at least one shall be a women member, the third member shall be an independent person and not be a member of the (name of the College). In all cases majority of the members shall be women and a Lady member shall head it. In addition to this, depending upon the nature and circumstances of an individual case, the Principal may appoint one additional member. In no case a student be member of the Committee Facilitators: The Principal shall appoint at least six facilitators. Four from various cadres of staff members (Teaching & non teaching) of (name of the College). Two Facilitators shall be from student body. Subject to availability proper male female ratio shall be maintained

b)

c)

All the appointed persons will perform their duties for a period of two years. No honorarium is paid for these individuals. In case of necessity the Principal can replace member/s or reconstitute the Committee any time. On issue basis the Complaints Committee can co-opt extra member/s for assistance. A Prior permission of the Principal shall be taken in writing in this regard. In these matters the Principals decision is final. 5) Powers and Duties of appointed members d) The Powers and duties of SHPA i. She/he shall ensure the proper constitution and functioning of the Complaints Committee (CC) along with the Principal. ii. She/he shall ensure implementation of these Regulations in (name of the College) and regularly review the functioning and effectiveness of the Regulations. iii. She/he shall exercise such other powers and perform such other duties as may be conferred or imposed on her/him by or under this policy. iv. She/he shall formulate strategies for spreading awareness of present policy among all members of (name of the College) v. She/he shall assist the victim throughout the process of inquiry. 5

vi.

She/he shall prepare an annual report of all activities undertaken and submit the same to the Principal, which shall be available to anyone on request.

i.

ii. iii. iv.

v. vi. vii.

viii.

e) Duties of Complaints Committee The Complaints Committee can review the Regulations to combat sexual harassment time-to-time under the guidance of SPHA. The modifications made are to be endorsed by the Principal before incorporating into the Regulations . Complaints Committee shall maintain confidentiality. Complaints committee can co-opt extra members basing on the need of the case, in consultation with the SPHA & with the permission of the Principal. The complaints committee can receive complaints directly from individuals, or through the facilitators, the Principal. The committee will guide the individual directly or may ask the facilitators to provide counseling and other required assistance The complaints committee will conduct enquiry on the written complaint received (Proforma-Annexure1). It has powers to call any staff member in any position for the conduct of enquiry (Proforma-Annexure2). The committee will submit the enquiry report to the Principal with suggestions to resolve the issue and/or recommendations for punishment. The committee can take the help of drawings, photograph, audio or video if required they can visit any place in the (name of the College). However these things are to be ratified by the Principal. Financial needs if any are to be sanctioned by the Principal In the case of a complaint registered against a committee member She/He Will not be functioning during the enquiry sessions of that complaint and not take part in the decisions making.
i.

f) Role and Functions of the facilitators Facilitators shall ensure implementation of the Regulations in (name of the College) and regularly review the functioning and effectiveness of the Regulations . ii. Facilitators shall maintain confidentiality. iii. Facilitators shall Provide information on other relevant internal/external remedies and any limitation periods that may apply to such remedies, iv. Whether or not a person files a formal request for inquiry, provide supportive counseling as needed v. Facilitators shall act as a counselor, as a mediator; and be the receiver of the formal request for inquiry, which may be the first step towards approaching the inquiry mechanism under the Regulations vi. Facilitators shall act as a first known point of contact. She/He assists in clarifying the nature of the concern. She/He gives information on options and possible outcomes available under the Regulations vii. Facilitators shall assist in drafting and filing of a formal request for inquiry 6

viii. ix.

Facilitators shall explore possible strategies/options available in resolving the situation and also explore strategies to safeguard against victimization Facilitators shall support the aggrieved party throughout the resolution process,

Section. 3:
6) Definition of Sexual harassment The supreme court of India has defined the sexual harassment in the fallowing way For this purpose, sexual harassment includes such unwelcome sexually determined behaviour (whether directly or by implication) as: a) Physical contact and advances; b) A demand or request for sexual favours; c) Sexually coloured remarks; d) Showing pornography; e) Any other unwelcome physical, verbal or non-verbal conduct of sexual nature. Where any of these acts is committed in circumstances where under the victim of such conduct has a reasonable apprehension that in relation to the victim's employment or work whether she is drawing salary, or honorarium or voluntary, whether in Government, public or private enterprise such conduct can be humiliating and may constitute a health and safety problem. It is discriminatory for instance when the woman has reasonable grounds to believe that her objection would disadvantage her in connection with her employment or work including recruiting or promotion or when it creates a hostile work environment. Adverse consequences might be visited if the victim does not consent to the conduct in question or raises any objection thereto. 7) Recourses under the Rules Any person who feels that She/He has been the victim of unwelcome conduct of a sexual nature and or sexual harassment may choose to: (i) Resolve the matter through the mechanism laid down in the Regulations, and/or (ii) Take recourse to any other institutional, civil/criminal remedies available to her/him in the (name of the College) as well as under the law. Provided that where the victim requests any corrective action to be taken against any person for sexual harassment, the matter shall be referred to the Complaints Committee and the Committee shall conduct the inquiry and act in accordance with these rules. If the aggrieved party chooses to resolve the matter through the mechanism laid down in the Regulations, She/He shall first contact facilitator of her/his own choosing 8) Mediation A) In the vent that the aggrieved party, after consultation with the facilitator, requests mediation, the facilitator shall inform in confidence the person/s against whom the concern has been raised about the nature of the concern. 7

B) The facilitator shall initiate mediation proceedings only on obtaining consent of the parties concerned. C) The mediator shall be a facilitator who is agreeable to all parties concerned D) If the parties are unable to; agree on whether to have mediation or on the proceeding/result of the mediation, they may, at any point, prefer a request for inquiry.

Section 4: The Inquiry 18) Filing of formal request for inquiry a) Any alleged victim of unwelcome sexual conduct or sexual harassment who considers the mediation process to have been unsatisfactory and/or unsuccessful, or does not wish to initiate/proceed with a mediation, may make a request for inquiry to the Principal, SHPA or directly to any member of the Complaints Committee. Any mediation proceeding shall terminate upon the filing of such request. Where the Principal, SHPA or a Facilitator receives a request, she/he shall pass on the request to the Complaints Committee. The formal request for inquiry shall normally be made in writing in the manner prescribed in (Proforma-Annexure1). Annexed to this, or through a verbal statement made to and transcribed by any faculty member or facilitator and signed by the complainant. 19) Initiation of enquiry a) Within 3 days of the receipt of the formal request for inquiry, the Complaints Committee shall furnish a copy of the formal request for inquiry to all parties and also furnish a notice requiring all parties concerned to submit their written submission within 7 days of having received the notice. Along with the written submission, the parties shall also submit copies of the written statements of all their respective witnesses. b) Within 3 days of the receipt of the written submissions and written statements of the witnesses, the panel shall provide to each party a copy of the written submission and written statement of the witnesses submitted by the other party/parties c) Within 7 days all parties shall submit to the Complaints Committee their replies to the documents that have been served on them. The replies may also include a list of questions that the party wishes the inquiry panel to ask the other party/parties or their witnesses d) Provided that where a request for inquiry has been made, withdrawal of the same shall not be permitted except with the permission of the SHPA when satisfied that the individual concerned is not acting under duress. e) The Complaints Committee may in order to understand the context of the case request advice from a facilitator of the respective constituency who has not facilitated that particular case. 8

b) c)

20) Conducting Inquiry

a)

Within one day of the completion of the requirements of Initiation of enquiry the panel shall call for an oral hearing. Each party shall be given a chance to give an account of the events leading to the request for inquiry, before the Complaints Committee The Complaints Committee shall have the power to ask questions which it deems fit of the parties during the oral hearing, which may also include any questions which have been submitted by the other party under Initiation of enquiry

b)

c) The parties may also adduce any documentary evidence at the time of the oral hearing.
d)

After hearing all the parties concerned, and upon perusal of documentary evidence (if any) and all the documents that have been filed by the parties under Initiation of enquiry, the Complaints Committee may terminate the proceedings if it is of the opinion that no prima facie case exists. The Complaints Committee may call upon any or all or additional witnesses and ask them any such questions as it may deem fit, which may also include any questions which have been submitted by the other party under Initiation of enquiry

e)

f) The Complaints Committee shall have the power to inspect any records maintained under these Regulations with regard to the inquiry in question After hearing all the parties concerned and all the witnesses, and upon perusal of documentary evidence (if any), the Complaints Committee shall, within one week, submit a report to the Principal containing its factual findings and a determination of whether this Regulations have been violated. The inquiry, including the applicable standard of proof, shall be guided by the consideration that it is not a criminal proceeding or a proceeding of any court of law. 21) Relevant factors to be considered a) The Past sexual history of the parties shall not be taken into account while establishing and/or deciding on the incidence of sexual harassment. b) In determining the punishment, the inquiry panel shall consider the previous record of the perpetrator under the Regulations (if any), and the extent of victimization (if any). 22) Adverse Inference An adverse inference shall be drawn against an alleged perpetrator of unwelcome sexual conduct or sexual harassment where a) The alleged perpetrator is in an official position of authority, supervisory, evaluatory, or otherwise and

b)
c)

d)

The person making the complaint of sexual harassment as a person over whom such authority is exercised and The harassment is of a nature where submission to or rejection of sexual advances or overtures, or requests for sexual favors are made a ground for any decision relating to employment, academic pursuit extra or co curricular activity or entitlement to services/opportunities at (name of the College). Student office bearers or representatives shall not be considered as persons in positions of such authority solely by virtue their holding these positions.

23) Action on the Inquiry The Principal shall review the recommendation submitted by the Complaints Committee and shall implement the recommendation after making sure that the inquiry or the Corrective Action are not vitiated by any gross irregularity, illegality or malafides. Principal shall implement the recommendation. b) If the Principal decides to reject the findings and recommendations of the Complaints Committee, the Principal shall return the entire proceedings to the Complaints Committee for re-consideration or further inquiry on any aspect setting down in writing the reasons for her/his rejections. c) On receipt of a communication from the Principal under Rejection as said above, the inquiry panel shall consider the issue identified by the Principal and reconsider its prior decision in response to the issues raised by the Principal and, if the Complaints Committee feels necessary, make further inquiry into the matter. Upon completion of its consideration the Committee shall submit its conclusions and recommendations to the Principal. d) If the Principal is satisfied that the findings and recommendations of the Committee as resubmitted, that they were satisfactorily addressed the concerns raised by the Principal, shall implement the recommendations. e) If the Principal is still of the view that the findings and recommendations resubmitted by the Committee suffer from any gross irregularity or illegality or malafides, the Principal shall implement the recommendations of the Committee or constitute a fresh Committee f) Final orders made by the Principal shall be communicated in writing to the concerned parties who shall also be supplied with a copy of the report of the inquiry, the findings and the proposed Corrective Action. Copies of depositions of witnesses shall be made available for perusal to a party concerned with such deposition on request. The proceedings under these Procedures shall; be treated as strictly confidential and shall not be divulged by any staff member or any of the parties to any one. 24) Time Frame The total time frame for the inquiry process from the time inquiry is initiated to the recommendations being made by the Complaints Committee shall not exceed three months and from then on to the final decision by Principal shall not take more than one additional month. In rare circumstances, the inquiry panel or the Principal may, for reasons to be recorded in writing extend the time limit, which shall be communicated, to all parties concerned. 25) Review 10 a)

a) An alleged victim or a person with respect to whom corrective Action is to be taken pursuant to the Section above may, within fifteen working days of receiving a communication of such Corrective Action, or a person who feels aggrieved by any decision of the Committee or the Principal under these procedures review such action or decision on the ground that such corrective Action and the Inquiry on which it is based is vitiated by gross irregularity or illegality. The reasons for requesting the review shall clearly and fully set out in the request along with all supporting documentation. b) The Principal may entertain a request for review after the expiry of the fifteen day period referred above, if she / he is satisfied that the concerned requestor had sufficient cause, beyond his/ her control, for not submitting the appeal in time. c) Upon the written request of the person seeking a review the Principal may provide an opportunity to such person for oral representations to be made to elaborate and explain the written submission without raising new grounds. After due consideration of the request for review and any oral representation, the Principal shall either i. Confirm the actions taken already by Principal or ii. Principal may order for a fresh inquiry or reconstitute the Committee to conduct a fresh inquiry. In all cases, the Principal shall set down the reasons for his / her final decision in writing, which shall be made available to the Committee, the person requesting for the review and the other part/ parties. The Principals decision on the review shall be final. Where the Principal so deems necessary, he/she may delay the implementation of the decision for such period not exceeding one month. 17) Malafide Complaint

In the event that the formal request for inquiry is proved to be malafide, the Committee shall recommend to the Principal that the person found guilty of such malafied be required to issue a written public apology, which is to be displayed prominently on all notice boards in the (name of the College). Section 5: 18) CORRECTIVE ACTIONS a) For Faculty / Staff i. Warning, reprimand or censure. ii. Public written apology by the perpetrator, which shall be displayed prominently on all notice boards in the (name of the College) iii. Where an alleged instance of sexual harassment amounts to misconduct in employment as defined by the relevant service rules, appropriate disciplinary action shall be initiated in accordance with those service rules. iv. Fine up to Rs.5,000, which amount shall be paid into a separate account to be maintained by the SHPA and which amount shall be used to achieve the objectives of this Regulations . v. Transfer vi. Withholding increments 11

vii. Withholding promotions. viii. Suspension. ix. Demotion. x. Termination

b) For Students The committee may recommend any or a combination of the fallowing penalties i. ii. iii. iv. v. vi. vii. viii. ix. Warning Public written apology by the perpetrator, which shall be displayed prominently on all notice boards in the (name of the College) Curtailing of privileges Barring on the him/her from representing the College in curricular / co curricular activities Removal of positions he/she holding in College/Hostel Fine up to Rs.2,500 , which amount shall be paid into a separate account to be maintained by the SHPA and which amount shall be used to achieve the objectives of this Regulations. Suspension from college for a period 3 (Three) weeks Suspension from college for a Maximum period of 1 (One) year Removal from the College

19) Criminal Proceedings Where an alleged instance of sexual harassment amounts to a specific cognizable offence under the Indian Penal Regulations, 1860, or any other law, the (name of the College) may, in addition to the proceedings under these Regulations, initiate appropriate proceedings in accordance with the law by making a complaint with the appropriate authorities. Section 6: Miscellaneous 20) Maintenance of records The records of inquiry proceedings under these Regulaitons shall be kept in the custody of the Principal and records of all other proceedings shall be kept with the Sexual Harassment Policy Advisor except as required in this Part. A) The facilitator shall maintain confidential records of all proceedings that are initiated under this rule, such records shall include: (i) The profile of the complainant and the respondent. (ii) The nature of the concern. (iii) A brief account of the steps taken to address the concern and (iv) The result of any process undertaken under these Regulations , except inquiry proceedings.

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B)

The inquiry panel shall maintain confidential records all the proceedings that take place before it, which will include copies of all documents submitted at each proceeding.

21) Recusal Any person conducting any proceedings under this rule shall recusal herself/himself if she/He feels that her/his objectivity may be compromised due to any reason or conflict of interest.

22) Confidentiality a) All proceedings, documents and records maintained under these Regulations shall be confidential. A pseudonym shall be used in place of the victims name. However the names of the harasser shall be retained in order to consider previous records of the same person in determining punishment. b) All persons involved in the proceedings under the Regulations including the parties, faculty, witnesses, facilitators, mediators, members of the inquiry panel and the Principal shall be under a duty to respect and maintain confidentiality. c) No decision taken under this rule, except the final decision of Principal shall be made public. 23) Minor infringement not to invalidate proceedings No minor infringement of procedure shall invalidate any proceeding under this rule unless it is shown to cause prejudice to any of the parties. 24) Victimization Victimization, intimidation or bringing undue influence whether directly or indirectly including attempts to do so of persons seeking redress under this regulations, witnesses, or any other persons involved in the conduct of proceedings under this regulaitons , shall be treated as Major Misconduct and be the subject of disciplinary proceedings by the (name of the College). 25) Support Structures The (name of the College) shall endeavor to provide support structures in the form of: (i) A well published list of phone numbers and addresses which may be contacted in emergencies. (ii) An orientation programme for new students in order to familiarize them with the regulations ; (iii) Acquainting new staff to the regulations ; (iv) Counseling the members of the (name of the College) community on ways of preventing and coping with sexual harassment; (v) Counseling for the victim. (vi) Providing support to initiatives in addressing issues of gender and sexuality 26) Review of the Regulations These regulations shall be reviewed at least once in two years.

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Annexure 1 To The Principal (name of the College) Dear Madam/Sir, I/We, ________________________________________ (Name/s) request conduct enquiry as provided under the regulations to combat sexual harassment of the (name of the College) I/We would request this inquiry to be conducted to look into the acts of ____________________________________________(Names of Responding Party/Parties). [The facilitator who acted as a first known point of contact and/or as a mediator in this context was/were ______________________________________(Name/s of facilitators/mediators)]* *Only required if a facilitator was involved. Yours Sincerely, Signature/Thumb print Date: Place:

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Annexure 2 (To be sent in a closed Cover through the Principal) Mr./Ms __________________________________working as__________________ In the section___________________________ at College________________________ is required to attend an enquiry On_______________ At________________ to be conducted by the Complaints committee As per provisions laid out under the Regulations to combat sexual harassment of the (name of the college) Brief Description of the Requirement:

Signature of The Committee Member

Name of the College:____________________________________ Regulations to Combat Sexual Harassment-2005 Salient points Appointments For 2years period, No honorarium Principal Appoints Sexual Harassment Policy Advisor (SHPA). SHPA advises Principal on appointing 3 members Complaints Committee. The CC Can Co Opt any individual for a specific need A Woman shall head the CC, A member can be from NGO Principal appoints three Facilitators to mediate and help the Victims.

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The Complaint The Victim Approaches: Facilitator>>Refer to CC after Counseling, helping, mediating SPHA >> redirects to CC Through Facilitator Complaints Committee>>Directly handle or advice to meet Facilitator Principal >>Refer to CC The facilitator Helps victim, Guides victim, Mediate & Cooperates CC in enquiry Enquiry Complaints Committee meets both parties & Conduct enquiry CC Recommend suggestions and/or punishments to the Principal. Review of enquiry In case of need the Principal can ask CC for Review of enquiry CC shall Review and Resubmit Time Frame Maximum 3 Months Extendable in extreme circumstances to another month with Permission from Principal Corrective Action Principal implements Caution Adverse interference Malafide Compliant Previous records of individuals Victimization Desirable Training for facilitators if possible Counseling and orientation programs Phone No to be contacted in case of emergency are to be well displayed Proper maintenance of records Opening of a separate account to be maintained by the SHPA and which amount shall be used to achieve the objectives of these Regulations. Preparation of Annual Report by SPHA Periodical Review of Regulations

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