POLICY ON PREVENTION OF SEXUAL HARASSMENT (P.O.S.H.

) AT WORKPLACE

I. COMMITMENT:

Our Company is committed to providing work environment that ensures every employee is treated
with dignity and respect and afforded equitable treatment.

The Company is also committed to promoting a work environment that is conducive to the
professional growth of its employees and encourages equality of opportunity.

The Company will not tolerate any form of sexual harassment and is committed to take all necessary
steps to ensure that its employees are not subjected to any form of harassment.

II. SCOPE:

This policy applies to all employees of the Company.

III. DEFINITION OF SEXUAL HARASSMENT:

Sexual harassment may be one or a series of incidents involving unsolicited and unwelcome sexual
advances, requests for sexual favours, or any other verbal or physical conduct of sexual nature.

Sexual Harassment at the workplace includes:

1. unwelcome sexual advances (verbal, written or physical)

2. demand or request for sexual favours

3. any other type of sexually-oriented conduct

4. verbal abuse or ‘joking’ that is sex-oriented

5. any conduct that has the purpose or the effect of interfering with an individual’s work
performance or creating an intimidating, hostile or offensive work environment and/or submission
to such conduct is either an explicit or implicit term or condition of employment and /or submission
or rejection of the conduct is used as a basis for making employment decisions. Inappropriate
conduct could also be a joke, a prank or even a compliment. These gestures also lead to harassment
although the intention of the individual might not be to offend the other person.

6. Body Shaming.

IV. RESPONSIBILITIES REGARDING SEXUAL HARASSMENT:

All employees of the Company have a personal responsibility to ensure that their behaviour is not
contrary to this policy.

All employees are encouraged to reinforce the maintenance of a work environment free from
sexual harassment.
V. COMPLAINT MECHANISM:

An appropriate complaint mechanism in the form of “Complaints Committee” has been created in
the Company for time-bound redressal of the complaint made by the victim.

VI. INTERNAL COMMITTEE (IC):

The Company has instituted a Internal Committee for redressal of sexual harassment complaint
(made by the victim) and for ensuring time bound treatment of such complaints. Initially, and till
further notice, the Complaints Committee will comprise of the following five members:

Sr No. Name Status Email ID

1 Gauri Kundnani Presiding Officer [email protected]
2 Vibha Rawal Member [email protected]
3 Akhtar Shah Member [email protected]
4 Annaram Jat Member [email protected]
5 Chitra Panikker External member [email protected]

The Presiding Officer reserves the right to nominate more members of appropriate seniority and
rank in the committee to conduct such enquiries to ensure equal representation of the gender as
that of the complainant or for any other valid reason.

The Complaints Committee is responsible for:

• Investigating every formal written complaint of sexual harassment

• Taking appropriate remedial measures to respond to any substantiated allegations of sexual

harassment

• Discouraging and preventing employment-related sexual harassment

VII. PROCEDURES FOR RESOLUTION, SETTLEMENT OR PROSECUTION OF ACTS OF SEXUAL

HARASSMENT:

The Company is committed to providing a supportive environment to resolve concerns of sexual

harassment as under:

A. Informal Resolution Options When an incident of sexual harassment occurs, the victim of such
conduct can communicate their disapproval and objections immediately to the harasser and request
the harasser to behave decently. If the harassment does not stop or if victim is not comfortable with
addressing the harasser directly, the victim can bring their concern to the attention of the
Complaints Committee for redressal of their grievances. The Complaints Committee will thereafter
provide advice or extend support as requested and will undertake prompt investigation to resolve
the matter.
B. Complaints:

1. An employee with a harassment concern, who is not comfortable with the informal resolution
options or has exhausted such options, may make a formal complaint to the Presiding Officer of the
Complaints Committee constituted by the Management. The complaint shall have to be in writing
and can be in form of a letter, submitted within 3 months from the date of the incident and in case
of a series of incidents, within a period of 3 months from the date of the last incident. The
Complaints Committee can extend the timeline for filing the complaint, for reasons to be recorded in
writing, by a period of 3 months. Alternately, the employee can send complaint through an email.
The employee is required to disclose their name to enable the Presiding Officer to contact them and
take the matter forward. Complaint against any member of the Complaints Committee should be
sent directly to the Directors of the Company.

2. The Presiding Officer of the Complaints Committee will proceed to determine whether the
allegations (assuming them to be true only for the purpose of this determination) made in the
complaint fall under the purview of Sexual Harassment, preferably within 30 days from receipt of the
complaint.

In the event, the allegation does not fall under the purview of Sexual Harassment or the allegation
does not constitute an offence of Sexual Harassment, the Presiding Officer will record this finding
with reasons, and communicate the same to the complainant.

3. If the Presiding Officer of the Complaints Committee determines that the allegations constitute an
act of sexual harassment, he/ she will proceed to investigate the allegation with the assistance of the
Complaints Committee.

4. Where such conduct, on the part of the accused, amounts to a specific offence under the law, the
Company shall initiate appropriate action in accordance with law by making a complaint with the
appropriate authority.

5. The Complaints Committee shall conduct such investigations in a timely manner and shall submit
a written report containing the findings and recommendations on action to be taken to the Directors
not later than 90 days from the date of receipt of the complaint. The Directors will take decision on
the corrective action based on the recommendations of the Complaints Committee and keep the
complainant informed of the same.

Corrective action may include any of the following:

a. Formal apology

b. Counselling

c. Written warning to the perpetrator and a copy of it maintained in the employee’s file.

d. Change of work assignment / transfer for either the perpetrator or the victim.
e. Suspension or termination of services of the employee found guilty of the offence

6. In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for
appropriate disciplinary action by the Management.

VIII. CONFIDENTIALITY: The Company understands that it is difficult for the victim to come forward
with a complaint of sexual harassment and recognizes the victim’s interest in keeping the matter
confidential. To protect the interests of the victim, the accused person and others who may report
incidents of sexual harassment, confidentiality will be maintained throughout the investigatory
process to the extent practicable and appropriate under the circumstances.

IX. ACCESS TO REPORTS AND DOCUMENTS: All records of complaints, including contents of
meetings, results of investigations and other relevant material will be kept confidential by the
Company except where disclosure is required under disciplinary or other remedial processes.

X. PROTECTION TO COMPLAINANT / VICTIM: The Company is committed to ensuring that no

employee who brings forward a harassment concern is subject to any form of reprisal. Any reprisal
will be subject to disciplinary action.

The Company will ensure that the victim or witnesses are not victimized or discriminated against
while dealing with complaints of sexual harassment.

However, anyone who abuses the procedure (for example, by maliciously putting an allegation
knowing it to be untrue) will be subject to disciplinary action.

XI. CONCLUSION: In conclusion, the Company reiterates its commitment to providing its employees,
a workplace free from harassment/ discrimination and where every employee is treated with dignity
and respect.