STATUTORY POLICY

1.1 POSH POLICY

This Prevention of Sexual Harassment Policy applies to Saffron Network Pvt Ltd, its subsidiaries
and joint ventures over which Saffron Network Pvt Ltd exercises management control. SNPL is
committed to creating a safe work environment free from any form of sexual harassment and
where all employees are treated with dignity and respect.

As per the Sexual Harassment of Women at workplace (Prevention, Prohibition and Redressal)
Act, 2013 and rules thereunder, the Company has framed this policy and adopted the same.
While this policy covers all the key aspects of the Act, for any further clarification, reference shall
always be made to the Act and provisions of the Act shall prevail. This policy aims at prohibiting,
preventing and deterring the commission of acts of sexual harassment at the workplace and
provide the procedure for redressal of complaints pertaining to sexual harassment.

SNPL is committed to the effective dissemination of this policy. All stakeholders and managers
are required to ensure that they and their teams are aware of this policy and encouraged to
adhere to it.

A. APPLICABILITY
This policy extends to all employees of the Company, including those employed on a
regular, temporary, ad-hoc or daily wage basis, either directly or through an agent, including
a contractor, for remuneration or not, and those working on voluntary basis with or without
express or implied terms of employment.
In addition to the above, this Policy also extends to those who are not employees of the
Company who may be affected in the course of any activity related to the work of the
Company or carried out within the premises used for the execution of the Company’s work
or day-to-day operations.

B. SCOPE
The scope of this policy extends to all Workplaces including the offices, branch,
departments, units, project locations, as well as external locations used for the purpose of
work carried out by the Company.

C. SALIENT FEATURES
As sexual harassment is an offence to the dignity of the individual, it constitutes an obstacle
to an efficient environment in which men and women work together, we have set guidelines
and procedures to be followed at such instances occurring at the place of work.

D. DEFINITION
a. “Aggrieved Woman” means in relation to a workplace of a person of any age,
whether employed or not, who alleges to have been subject to any act of sexual
harassment by the Respondent and includes contractual, temporary employees and
visitors.
b. “Complainant” means the aggrieved person or a person having knowledge of the
incident and having the consent of the aggrieved person to file a complaint or the
legal heir of a deceased aggrieved person.
 c. “District Officer” means the District Magistrate or Additional District Magistrate or
the Collector or Deputy Collector as appointed by the appropriate government as a
District Officer for every District to exercise powers or discharge functions under the
POSH Act.
d. “Employee” means a person who is responsible for the management, supervision
and control of the Company’s work and workplace.
e. “ICC” or “Internal Complaints Committee” means and internal committee
constituted as per the Act.
f. “Members” means members of the ICC.
g. “Presiding Officer” means the Presiding Officer of the ICC and shall be a senior level
woman Employee of the SNPL.
h. “Respondent” means a person against whom a complaint alleging sexual offence has
been made.
i. “Parties” means collectively the Complainant and the Respondent.
j. “Workplace” means establishments, enterprises, institutions, offices, branches,
premises, locations or units established, owned and controlled by SNPL or places
visited by the employees out of or during employment including accommodation,
transportation provided by the employer for undertaking such journey.

E. POLICY GUIDELINES
a. All personnel are expected to respect the rights of others and to never encourage
any type of harassment.
b. All are encouraged to advice others of unwelcome behaviour and deter others from
involving in any such activities.
c. All managers at SNPL are required to ensure that nobody is subject to harassment
and there is equal treatment at all levels. They also are required to educate the
employees of unwelcome behaviours and warn them of the consequences of such
action.

F. SEXUAL HARASSMENT
a. Sexual Harassment includes any one or more of the following unwelcome acts or
behaviour, whether directly or by implication:
i. Physical contact and advances.
ii. A demand or request for sexual favours.
iii. Making sexually coloured remarks.
iv. Showing pornography, or
v. Any other unwelcomed physical, verbal or non-verbal conduct of sexual nature.

b. The following circumstances among other circumstances, if they occur or are present in
relation to or connected with any act or behaviour of sexual harassment may amount to
sexual harassment:
i. Implied or explicit promise of preferential treatment in employment.
ii. The implied or explicit threat of detrimental treatment in employment.
iii. The implied or explicit threat about the present or future employment status.
iv. Inference with work or creating an intimidating or offensive or hostile work
environment; or
v. Humiliating treatment likely to affect the lady employee’s health or safety.
 G. COMPLAINT/INTERNAL REDRESSAL COMMITTEE
A Committee known as “Internal Complaints Committee” (ICC) has been constituted by the
Management to consider and redress complaints of Sexual Harassment. A committee of
minimum 4 members, majority of which will be women, is constituted for the proceedings to
take place. In case of non-availability of quorum members due to exigency of official work, it
shall be the
responsibility of HR to get the complaint investigated.

Details of Committee members:

Sr No. Name Role Designation Department Email ID Contact No.

Note: Additionally, external women member from non-government organizations or

associations or freelancers committed to the cause of women will be a part of above
committee.

H. LODGING A COMPLAINT
a. Any aggrieved woman may make, in writing a complaint of sexual harassment at the
workplace to Internal Redressal Committee (ICC) along with any documentary evidence
available, names of witnesses, within three months from the date of incident and in case
of a series of incidents, within three months from the date of last incident.
b. If the employee cannot make such a complaint in writing, the Presiding Officer or any
other member of ICC would render all reasonable assistance to the woman for making
the complaint in writing.
c. The aggrieved woman fails to submit the written complaint within three months from
the date of the incident, the ICC may extend the time limit up to three months and in
that case, the reason of such extension shall be recorded in writing.
d. It is always advised to not delay in filing the complaint if any such untoward incident
happens at the workplace to conduct a thorough investigation and take prompt action.
e. Even though there is no exact form of making the complaint, the Complainant is advised
to:
i. Submit the complaint to the ICC members and not to the Employer or HR
representative.
ii. To write the complaint in simple language.
iii. To include details of the exact incident, date and time, witness, etc.
 iv. To include circumstances preceding and following the incident.
v. Include whether the Complainant responded/resisted to the actions of the
respondent and details thereto.
vi. Submit maximum pieces of evidence supporting the complaint including
relevant emails, screenshot of SMS’s, call details, photographs, recordings,
etc.
vii. Not state any false or incorrect facts.
viii. State the relief that is sought from the employer.
f. If the aggrieved woman is unable to make a complaint on account of her physical or
mental incapacity or death or otherwise, her legal heir or such other person as
authorized may make a complaint to the ICC.
g. Complaint shall be submitted by the complainant to the ICC in writing or shall be
submitted electronically at __________________________________. The complaint can
also be submitted physically to an ICC member.
h. If the complaint is received by a persona other than the member of the ICC, upon
receiving such a complaint, it is the responsibility of the complaint receiver to report the
same to the committee immediately.
i. If the complaint is made against a guest or any other person who is not an employee of
the SNPL, the ICC shall advice the complainant to file a complaint with the police
immediately. The option of whether the complaint should be filed with the police or not
is left with the complainant, but the support of SNPL in filing the complaint will always
be ensured.
j. Upon receipt of the complaint, one copy of the complaint shall be sent to the
Respondent within 7 days.
k. Upon receipt of the copy of the complaint, the Respondent is required to reply to the
complaint along with a list of supporting documents, and names and addresses of
witness within 10 working days.
l. The ICC maintains a register to endorse the complaint received by it and keeps content
highly confidential, if it so desires, except to use the same for discreet investigation.
m. Upon receiving such a complaint, the ICC shall act swiftly to find the veracity and take
further actions as required.

I. RECEIVING A COMPLAINT

The recipient of the complaint is required to keep the following points in mind while receiving
the complaint:

a. Shall make sure that the complaint has been listened to completely without any
prejudice.
b. Inform the complainant that the proper escalation, investigation and prompt actions will
be taken on such complaint.
c. If possible, the complaint shall be written down as narrated by the complainant itself
and shall confirm the same upon completion by getting the signature at the end of the
sheet.

J. PROTECTION AGAINST VICTIMIZATION

The following will be obligations of the SNPL, during the processing/investigation of the
Compliant:
 a. In the event the accused is the n the event the Accused is the Complainant’s Reporting
Manager/senior, the Company will review the possibility of relocating the employee
within the Company and ensure that the Complainant is not being evaluated by the
Accused.
b. Ensure that any sort of retaliation against the Complainant or witnesses is strictly
prohibited. Any act of reprisal, including internal interference, coercion and restraint, by
the Accused, whether directly or indirectly, will result in appropriate action against the
Accused by the Complaints committee in consultation with the Management.
c. In case the Accused is a third party interacting with the company, such accused shall not
be allowed to enter the company premises except for the purpose of attending any
meeting/interaction as and when required by the Complaints Committee.
d. Post Conclusion of the Investigations of the Complaint, the Company will observe the
following:
i. If the Accused is found to be guilty, the Accused shall not write the
evaluation/reports of the Complainant, if he/she is otherwise authorized to
do so and the accused may be suspended for such term or may be
terminated as per the discretion of the ICC on case-to- case basis.
ii. In case the Accused is a third party interacting with the company, and found
to be guilty, the Accused shall not be allowed to enter the Company
premises.
iii. In the event, the Complaints Committee after investigation of a Complaint in
accordance with the procedure prescribed herein, concludes that the
Complaint was false and made with mollified intention by the Complainant,
then the Complaints Committee shall take such appropriate measures, in
consultation with the Management, against the complaint, as it may deem
necessary.

K. RESOLUTION THROUGH CONCILIATION

a. Once the complaint is received, before initiating the inquiry, the committee may take
steps to conciliate the complaint between the complainant and the respondent. This is
only if requested by the aggrieved person.
b. No monetary settlement can be made as a basis of conciliation.
c. In case a settlement is arrived at, the committee records & reports the same to the
employer for taking appropriate action. Resolution through conciliation is to happen
within 2 weeks of receipt of complaint.
d. The committee shall provide copies of the settlement to complainant & respondent.
Where a settlement is arrived at, no further inquiry is to be conducted by the
committee.

L. ENQUIRY
a. The Committee shall initiate an inquiry in the following cases:
i. No conciliation is requested by the Complainant.
ii. Conciliation initiated has not resulted in any settlement between the parties.
iii. Complainant inform the ICC of the failure of the Respondent in complying
with the settlement entered through conciliation.
b. The ICC initiates the inquiry within 7 days of receipt of the written complaint/closure of
conciliation/repeat complaint.
c. The inquiry shall be initiated in the following manner:
 i. The Complainant shall submit the written complaint along with supporting
documents and names of witnesses to ICC.
ii. Upon receipt of such a complaint, a copy shall be sent to the Respondent
within 7 working days to the ICC.
iii. Respondent upon receiving such complaint shall submit the reply along with
supporting documents and a list of witnesses within 10 working days of
receipt of such complaints.
iv. The ICC shall provide every reasonable opportunity to the Complainant and
the Respondent for putting forward and defending their respective case.
v. The inquiry shall be completed by the ICC within a total of 90 days from the
receipt of the complaint.
vi. No legal practitioner will be allowed to represent any party at any stage of
the inquiry procedure.
vii. All statements made before the ICC employees, witnesses or other persons
in relation to an investigation shall be minuted and signed by the person
making the statement.
viii. It shall be incumbent on every Employee to respond to queries of ICC
honestly and present the facts in an objective and unbiased manner.
ix. The ICC shall conduct an inquiry into the matter of the principles of natural
justice and shall hear both parties and their submission before taking any
decision.
x. Where the conduct of Sexual Harassment amounts to a specific offence
under the Bharatiya Nyaya Sanhita Bill,2023 or under any other law, it shall
be the duty of the ICC to immediately inform the Complainant of her right to
initiate action in accordance with the law with appropriate authority and to
give guidance and support on the same. Any such action or proceeding
initiated shall be in addition to proceedings initiated and/or any action taken
under this Policy.
xi. In conducting the inquiry, a minimum of 3 members including the Chairman
shall be present.
xii. The inquiry report has to be issued within 10 days from the date of
completion of the inquiry to both the management and the concerned
parties.
xiii. SNPL is required to act on the recommendations of the ICC within 60 days of
receipt of the inquiry report.
xiv. The aggrieved party can appeal against the decision of the Committee within
90 days from the date of recommendations of the concerned forum/court.

M. INTERIM RELIEF

During pendency of the inquiry, on a written request made by the complainant, the committee
may recommend to the employer to:

a. Transfer the complainant or the respondent to any other workplace.

b. Grant leave to the aggrieved person of maximum 3 months, in addition to the leave
he/she would be otherwise entitled.
c. Prevent the respondent from assessing complainant’s work performance.
d. Grant such other relief as may be appropriate.
 e. Once the recommendations of interim relief are implemented, the same is informed to
the committee.

N. TERMINATION OF ENQUIRY

The ICC have the right to terminate the inquiry proceedings or to give ex-parte decision on the
complaint, if the Complainant or the Respondent fails, without sufficient cause to present herself
or himself for three consecutive hearings convened by the Chairperson, as the case may be,
provided that such termination or ex-parte order may not be passed without giving a notice of
15 days to the concerned party.

O. CRIMINAL PROCEEDINGS

In case the act under sexual harassment amounts to a specific offence under the Indian Penal
code, 1860 or under any other applicable law, the Management shall initiate appropriate action,
in accordance with law, by making a complaint with the appropriate authority.

P. MALICIOUS ALLEGATIONS
a. Where the ICC arrives at a conclusion that the allegation against the Respondent is
malicious or the Aggrieved woman or any other person making the complaint has made
the complaint knowing it to be false or the Aggrieved woman or any other person
making the complaint has produced any forged or misleading document, it may
recommend to the management to take appropriate action against such person.

b. The action recommended against such malicious complaints shall be similar to that of
punishments if such complaint was substantiated against the Respondent.

c. Inability to substantiate a complaint or provide adequate proof need not mean that the
complaint is false or malicious.

Q. AWARENESS

Awareness sessions are to be organized to:

a. 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.
b. Carry out orientation programs and seminars for the Members of the ICC.
c. Conduct capacity building and skill building programs for the Members of the ICC.
d. Declare the names and contact details of all the Members of the ICC.
e. Use modules developed by the State Governments to conduct workshops and
awareness programs for sensitizing the employees with the provisions of the Act.

R. LEGAL COMPLIANCE
 Information about the following should be included in the Annual Report of the Company in
year.

a. Number of complaints of Sexual harassment received in the year.

b. Number of complaints disposed of during the year.
c. Number of cases pending for more than 90 days.
d. Number of workshops or awareness program against Sexual Harassment carried out.
e. Nature of action taken by the employer or District Officer.

S. MODIFICATION & REVIEW OF THE POLICY

a. SNPL reserves the right to modify and, or, review the provisions of this Policy, so as to
comply with applicable legal requirements, internal policies, or with a view to align/after
the provisions of the policy to the extent deemed necessary by company from time to
time.
b. SNPL expects the cooperation of all personnel in making this policy work. The company’s
intent in preparing, implementing, and distributing this policy is to help ensure compliance
with the state and local laws. This policy is not intended to impose any contractual
obligations on the company or any of its personnel. Questions about this policy should be
directed to Human Resources.

1.2 EMPLOYEE INFORMATION & KYC COMPLIANCE

a. At SNPL, we are committed to maintaining the accuracy, correctness, and completeness of

all Personal Data entrusted to us. This ensures compliance with regulatory policies,
particularly Know Your Customer (KYC) requirements. We understand that the accuracy of
this data heavily relies on the information provided by the relevant Individuals.

b. To facilitate this, we require all employees to adhere to the following to ensure we are in
line with KYC regulations and our commitment to employee data accuracy:

i. Accurate and Complete Data Submission: All employees must provide SNPL with
precise, non-misleading, updated, and comprehensive Personal Data. This
includes necessary consents for disclosure to SNPL.
ii. Timely Updates: It is essential for all employees to promptly update SNPL
whenever the Personal Data provided earlier becomes incorrect or outdated.
This ensures that our records remain current and compliant with regulatory
standards.

By adhering to these guidelines, both SNPL and its employees contribute to maintaining the
integrity and security of personal information, thus upholding regulatory policies such as KYC
requirements.

1.3 EMPLOYMENT OF MINORS

a. SNPL strictly follows ‘No Child Labour Policy’ and supports the elimination of such child
labour practices. It therefore endorses the need for appropriate initiatives to progressively
eliminate these abuses.
b. The Company strictly follows the Child Labour (Prohibition and Regulation) Act, 1986
(“CLA”) and rules and regulations thereunder. The Act prohibits the engagement of
children in certain employments and regulates the conditions of work of children in certain
other employments.
c. As per the CLA, a child means a person who is under the age of 14 years. SNPL does not
employ any person below the age of fourteen years at their workplace. SNPL prohibits the
use of child labour and forced or compulsory labour at its office.
d. This policy is thoroughly adopted by SNPL and clearly communicated to all employees in a
manner in which it can be understood through induction programmes and policy manuals.
The implementation of the policy is the responsibility of the company’s human resources
department and the security staff, who do not permit minors to enter the office. There is
zero tolerance policy towards its breach. Employment contracts and other records,
documenting all relevant details of the employees, including age, are maintained and are
open to verification by any authorised personnel or relevant statutory body.
e. If you or any employee you know falls under the definition of a child, you should
immediately inform the HR department.