POSH Policy

Applicability

This POSH Policy applies to every person engaged with the Company for any work whatsoever, on a regular, temporary, ad hoc basis either directly or through an agent, including contractors, consultants, trainees, apprentices, probationer, and even a visitor.

The Policy is with respect to Prevention, Prohibition & Redressal of Sexual Harassment which may arise in places not limited to geographical location viz. Company's offices / branches but includes all such places or locations where the employees are working like work from home, client location, etc. or acts are conducted in context of working relationships or whilst fulfilling professional duties or which may be visited by an employee during the course of employment including office parties, office trips, office internal messenger, transportation provided by the company for undertaking such visit.

Company's Policy against sexual harassment includes sexual harassment by fellow employees, supervisors, managers as well as agents, contractors, customers, vendors, consultants, partners and, visitors including outsource employees. Any place visited by the employee arising out of or during the course of employment includes transportation provided by the employer for undertaking such journey. In case of Sexual harassment, the impact on the complainant and not the intent of the Respondent is the main ingredient.

Sexual harassment as addressed in this Policy need not necessarily be from a male person to a female person, it can be between individuals of same gender or by person belonging to LGBTQ+ community.

Important Definitions

"Aggrieved woman" means a woman, of any age, visiting (in-person or virtual) the office premises, client, vendor, etc. in relation to workplace whether employed or not, who alleges to have been subject to any act of sexual harassment by the Respondent

"Complainant" shall mean an aggrieved woman of any age and whether employed or not, who has experienced Sexual Harassment or has observed some other person experiencing Sexual Harassment, or who files a complaint of alleged Sexual Harassment.

For the avoidance of any doubt, it is clarified that the Complainant can be any aggrieved woman who is associated with the Company in any capacity, such as a regular employee, part-time employee, contractor, consultant, trainee, or an intern.

"Employee" means a person employed at a Company for any work on regular, temporary, fixed term, contractual, ad hoc or daily wages basis, either directly or through an agent, including a contractor, with or, without the knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise, whether the terms of employment are express or implied and includes a co-worker, a contract worker, probationer, trainee, apprentice or called by any other such name, whether working within the office premises or work from home or from any other place.

"Internal Complaints Committee" means a committee constituted by Company as per this Policy.

"Respondent" shall mean a person of any gender including LGBTQ+ community against whom the Complainant has made a complaint of Sexual Harassment.

"Sexual Harassment" shall mean and include one or more of the following unwelcome acts or behaviour (whether directly or by implication) namely:

• Physical contact and sexual advances such as pinching, patting, rubbing, or purposefully brushing up against another person;
• Staring in a sexually suggestive or offensive manner, or whistling;
• Demand or request for sexual favors;
• Making or using derogatory comments, slurs, or jokes of a sexual nature, verbal sexual advances or propositions, graphic commentaries about an individual's body, sexually degrading words used to describe an individual;
• Making sexual gestures, or displaying sexually suggestive objects, pictures, cartoons, posters, calendars or computer screens or pornography;
• Inquiries about someone's sexual history or their sexual orientation;
• Any other unwelcome physical, verbal or non-verbal conduct of sexual nature;
• Sending suggestive or obscene letters, notes, chats, electronic messages;
• Wearing inappropriate clothes for a video call;
• Scheduling video calls at odd hours without a reasonable cause; or
• Persistently calling or messaging a person at odd hours etc.
• Showing pornography or other offensive or derogatory pictures, cartoons, representations, graphics, pamphlets, or sayings; or
• Any other unwelcome physical, verbal or non-verbal conduct of sexual nature;
• Any form of inappropriate communication at the proper time of work via SMS or email or other such forms of digital communication

In addition to the above, any of the following circumstances, if it occurs in relation to any act or behavior of sexual harassment may amount to sexual harassment:

• Implied or explicit promise of preferential treatment in her/his employment;
• Implied or explicit threat of detrimental treatment in her/his employment;
• Implied or explicit threat about her/his present or future employment status;
• Interference with her/his work or creating an intimidating or offensive or hostile work environment for her/his; or
• Humiliating treatment likely to affect her/his health or safety.

In addition to the instances mentioned hereinabove, any other acts or behavior, which outrages the modesty of a female employee will be considered as sexual harassment.

Any actions or words with a sexual connotation that interfere with an individual's ability to work or create an uncomfortable atmosphere are considered acts of Sexual Harassment.

"Witness" shall mean a person (of any gender) who personally has seen or observed the Complainant experiencing Sexual Harassment or who has knowledge about such an incident.

"Workplace" shall include any place of work i.e. the head office / corporate office or any branch office and it shall also include any place where the Complainant or the Respondent visits in connection with his/her work, during the course of and/or arising out of employment/ contract/ engagement with the Company, including transportation provided for undertaking such a journey or the place from where the employees are working remotely. Also, in the present era of digital workspace, the employees are working remotely from their homes or in different branches of the same organization, so the definition of workplace also includes digital platform. Workplace also includes office parties, off sites, outbound training, client meetings, training sessions, travel for office purposes.

The above-mentioned definitions are provided in this Policy for the ease of understanding and are not exhaustive in nature. Upon the receipt of any complaint, the ICC will first analyze whether it amounts to a complaint of 'sexual harassment' and whether it has occurred at the 'workplace' as is defined more specifically in the POSH Act. The ICC's decision on these matters will be final.

The Internal Committee (IC)

As per guidelines set out in the POSH Act, an Internal Committee ("IC") has been constituted for the Company and will be responsible to carry out the functions and obligations under this POSH Policy.

The IC shall comprise a Presiding Officer who shall be a senior woman employee; at least two employee members meeting the statutory eligibility requirements; and one external member who meets the statutory requirements. At least one-half of the total IC members shall be women.

Employee members shall be persons who are committed to the cause of women or who have experience in social work or have legal knowledge, as required by Section 4(2)(b). The external member shall be from an NGO, association or person familiar with issues relating to sexual harassment, as contemplated by Section 4(2)(c).

The tenure, appointment, replacement, resignation and other terms shall be governed by the POSH Act and applicable internal governance documents. The current IC constitution and contact details shall be maintained separately and communicated to employees.

The present constitution of the IC for accepting complains from Women employees under POSH Act, 2013 from November 2, 2026, onwards for a period of three (3) years is as follows:

Complaint of Sexual Harassment

If you (an Aggrieved woman) experience any form of Sexual Harassment or, if you believe someone associated with the Company is experiencing any form of Sexual Harassment, you should immediately report the same to the IC Members. Kindly note that as per The Sexual Harassment of Women at Workplace (Prevention, Protection and Redressal) Act, 2013, an Aggrieved Woman can complain to IC. Hence, all the sexual harassment complaints raised by women employees will be treated under the Act.

Please note that if you are filing a complaint of someone else's behalf, it is important that you obtain a written consent from that person for filing such a complaint.

A detailed procedure of filing the complaint is given below.

If the respondent is not an employee of the Company, the Company will provide appropriate assistance to the aggrieved woman, if she so chooses, in filing a complaint in relation to the offence under applicable criminal law or any other law for the time being in force.

When a complaint is filed by or against an employee of the Company's client / vendor, then the IC will converge with the client's / vendor's IC to investigate the complaint. Complainant's IC has the jurisdiction to conduct investigation and respondent's IC can request for participation in the investigation.

Mechanism of Reporting an Incident of Sexual Harassment

The Complainant who believes that she has experienced or subjected or observed Sexual Harassment shall report the incident immediately to the IC or to the management of the Company. Such a complaint must be filed within three (3) months from the incident and in case of series of incidents, within a period of three (3) months from the date of the last incident, in the prescribed format in Exhibit A.

If any complaint is filed after these given timelines, the IC may refuse to entertain the same.

The IC upon a written application made to it and if it is satisfied that the circumstances were such which prevented the Complainant from filing a complaint within the prescribed period, may extend the time limit for making the complaint for further three (3) months from the expiry of the initial timelines.

The Complainant shall submit all necessary supporting documents and the names and addresses of the witnesses while submitting any Complaint to the ICC.

Where such complaint cannot be made in writing, the Presiding Officer or any Member of the ICC shall render all reasonable assistance to the Complainant for making the Complaint in writing.

If the Complainant is unable to make a complaint because of his/her physical or mental incapacity, a complaint may be filed by anyone of the below stated person(s), provided that such person is not a legal practitioner:

• Any legal heir
• Any relative or friend;
• Any co-worker;
• An officer of the National Commission for Women or State's Women Commission;
• A special educator;
• A qualified psychiatrist or psychologist;
• The guardian or authority under whose care the Complainant is receiving treatment or care;
• Any person who has knowledge of the incident, with the written consent of the Complainant.
• In case the Complainant is dead, a complaint may be filed by his/her legal heir or any person who has knowledge of the incident, with the written consent of the Complainant's legal heir.
• A complaint against any member of the IC should be sent directly to any other member of the ICC. Any involved ICC members will have to recuse themselves under the POSH legal mandates.
• The Complainant is required to disclose the name and contact details to enable the ICC to contact and take the matter forward.
• While the ICC will examine anonymous complaints (if any), it must be recognized by the Complainant that it may prove to be difficult for the ICC to objectively investigate and take the matter forward in an effective manner. However, the ICC will investigate and address all complaints irrespective of how they are made.
• All complaints, whether in hard-copy or email form, should be clear and should include details of the incident or incidents, supporting documents, names of individuals involved and the names and addresses of the witnesses. The ICC will send a copy of the complaint to the Respondent, who shall have the opportunity to submit a reply together with a list of documents and names and addresses of witnesses.
• If the Complainant would like to initiate action under the applicable criminal law, they may inform the ICC of the same, and the Company shall provide necessary assistance to file such a complaint.

Inquiry into the Complaint

The Company promises to promptly and thoroughly investigate all reports of Sexual Harassment as discreetly and confidentially as possible. However, investigation of such complaint will generally require disclosure to the Respondent.

The objective of the POSH Policy is to conduct a thorough investigation, to determine whether Sexual Harassment has occurred and to eliminate any hostile or offensive working condition and decide actions to take against the Respondent.

The IC shall make an inquiry into the complaint in accordance with the principles of natural justice and in compliance with the applicable law.

On receipt of complaint, the IC shall decide the place and time for hearing the complaint and shall intimate the date, time, and place of hearing to the Complainant and Respondent.

On receipt of the complaint, the IC shall send one copy of the complaint to the Respondent within a period of seven (7) working days from the receipt of the complaint.

The Respondent shall then file his/her reply to the complaint along with the list of documents and names and addresses of the witnesses within a period of ten (10) working days from the date of receipt of the copy of the complaint from ICC.

IC shall investigate in detail into the matter of the complaint. The IC shall have the right to call the person against whom the complaint is made or any other witnesses as when necessary.

The ICC shall have the right to terminate the inquiry proceedings or to give an ex-parte decision by giving fifteen (15) days of written notice to the Complainant and the Respondent if the Complainant and/or Respondent fails to present himself or herself for three (3) consecutive proceedings.

The Complainant or Respondent shall not be allowed to bring in any legal practitioner to represent them in the proceedings before the IC.

A complaint will be resolved within three (3) months i.e. 90 days from receipt of the complaint by the ICC.

The IC will record its decisions and recommendations as per the format given under Exhibit B, and accordingly, inform the same to the Complainant and the Respondent.

For conducting the enquiry, the quorum of the IC shall be of three members including the presiding officer.

The Internal Committee may initiate an inquiry before, and at the aggrieved woman's request attempt to settle the matter through conciliation. However, the Internal Committee shall ensure that:

• Monetary settlement will not be made as the basis of conciliation.
• Where a settlement has arrived, the settlement terms shall be signed by both the parties and shall be provided with a copy of them.
• Where a settlement has arrived as mentioned hereinabove, no further enquiry shall be conducted by the Internal Complaints Committee.

For making an inquiry under the POSH Act, the IC shall have the same powers as are vested in a Civil Court under the Code of Civil Procedure, 1908, namely:

• Summoning and enforcing the attendance of any person and examining him on oath;
• Requiring the discovery and production of documents; and
• Any other matter which may be necessary.

During such enquiry, upon written request by the aggrieved person, the committee may at its discretion recommend:

• To transfer the aggrieved person or the respondent to another workplace.
• Grant leave to the aggrieved person of up to three months which is in addition to leave to which she is otherwise entitled. Provided, the aggrieved person must tender justified reasons for such transfer or leave, such as threat to work in the workplace.

The management of the Company shall act upon the recommendations of the IC immediately but not later than sixty (60) days of the receipt of the recommendations of the IC.

Conciliation

Upon a request made by the Complainant, before initiating an inquiry into any alleged complaint, the IC may take steps in accordance of the Act to resolve the matter between the Complainant and Respondent, through conciliation.

In case the Respondent agrees to actions such as apologies or voluntary resignation, without going through the formal disciplinary procedures, then on the basis of such actions, the Complainant and the Respondent may arrive at a resolution of the complaint informally. The terms of the agreement will be recorded and the complaint will be closed.

Where the parties have arrived at a conciliation, no further inquiry shall be conducted by IC. IC shall record the details of the conciliation and forward the same to the Director (Chirag Jain) for necessary action within ten (10) working days of the conciliation.

It is to be noted that no complaint of Sexual Harassment shall and will be resolved by way of monetary settlement in case of conciliation.

Subject to point (a) above, if the complaint has not been resolved through conciliation, IC may proceed to initiate a formal inquiry into the complaint at the written request of the complainant.

Disciplinary Action

The Committee shall, on completion of the enquiry provide a report of its findings within 10 days from the date of completion of the enquiry and such report shall be available to the parties concerned.

Based on the conclusions of the investigation, the IC will suggest (as a part of the written report in case of formal resolution) appropriate disciplinary action to the management of the Company; which can include written apology, counselling, carrying out community service, warning, reprimand or censure, suspension, transfer from project/location (of Complainant or the Respondent), withholding of promotion, deducting the salary or any such sum as it may deem necessary, withholding of pay rise or increment, direct the Respondent to pay to the Complainant such sum considering the trauma suffered, loss in career, medical expenses incurred, income or financial status of the Complainant or any action up to and including termination of employment.

The Company will implement the actions with the support of the Human Resources Head of the Company. Such action will be taken within 60 days of receipt of report by the management.

If the allegation against the respondent is not proved, the Committee may recommend that no action needs to be taken in the matter.

Other Relief to Complainant During Pendency of Inquiry

The IC at the written request of the Complainant may recommend to the Company:

• To either transfer the Complainant or the Respondent to any other location or recommend work from home;
• Grant leave to the Complainant up to a period of three (3) months or grant such other relief to the Complainant as the IC deems appropriate; or
• Recommend to the manager of the upward hierarchy of the Company to restrain the Respondent from reporting on the work performance of the Complainant or writing her/his confidential report or assign the same to another officer.

Appeal

Any female aggrieved from the recommendations of the IC may prefer an appeal to the appellate authority / Labour Commissioner or regular courts of justice within ninety (90) days of the recommendations given by the IC and any male aggrieved from the recommendations of the IC may prefer an appeal to the regular courts of justice within ninety (90) days of the recommendations given by the IC.

Confidentiality

Cases that involve allegations of Sexual Harassment are especially sensitive, and special attention will be given to the issue of privacy for all individuals.

The contents of the Complaint, the identity, and addresses of the Complainant, Respondent, and witnesses, any information relating to conciliation and inquiry proceedings, recommendations of the IC and the action taken by the Company shall not be published, communicated or made known to the public, press, and media in any manner information will be released only on a need-to-know basis.

Retaliation

This POSH Policy strictly prohibits any kind of intimidation or harassment of individuals who have filed complaints, instituted proceedings, assisted in investigations, or formally or informally objected to discriminatory practices, irrespective of the outcome.

The Company will take strict action against those Employees who would indulge in such retaliatory actions.

The Company will ensure that the Complainant or witnesses are not victimized or discriminated against while dealing with any complaint of Sexual Harassment.

Likewise, the Respondent too will be treated without any prejudice and will be given a fair chance through the procedure.

Individuals are encouraged to report to ICC, if faced with victimization or retaliation. Retaliation and/or victimization constitute misconduct and shall invite disciplinary action.

Frivolous or False Charges

This POSH Policy shall not be misused to bring frivolous or malicious charges against fellow employees.

If the IC arrives at the conclusion that the allegation against the Respondent is malicious or the Complainant has made the Complaint knowing it to be false or the Complainant has produced any forged or misleading document, it may recommend the Company to take action under Section 14 of the POSH Act and applicable rules, including a written apology, warning, reprimand or censure, withholding of promotion, withholding of pay rise or increments, terminating the Complainant from service or undergoing a counselling session or carrying out community service.

Where the IC concludes that a witness knowingly gave false evidence or produced a forged or misleading document during the inquiry, the IC may recommend appropriate action in accordance with Section 14(2) of the POSH Act and applicable service rules.

Mere inability to substantiate an allegation, inconsistency in recollection, or an unsuccessful complaint shall not, by itself, constitute a malicious or false complaint or false evidence.

Criminal Proceedings and Other Legal Remedies

Nothing in this Policy prevents an aggrieved woman from pursuing any remedy available under criminal law or any other applicable law.

Where the alleged conduct may also constitute an offence under applicable criminal law, the Company shall provide such assistance to the aggrieved woman as required by Section 19(g) of the PoSH Act and applicable law. Where the respondent is not an employee, the Company shall take appropriate action in accordance with Section 19(h) and applicable law.

Any criminal proceedings and the statutory POSH inquiry operate under their respective legal frameworks. A POSH complaint does not automatically require initiation of criminal proceedings, and the Company shall not represent the IC inquiry as a substitute for criminal investigation or adjudication.

Prevention and Employer Commitment

The Company is committed to maintaining a safe working environment free from sexual harassment and to undertaking preventive measures required under the POSH Act, including appropriate awareness and sensitisation programmes and communication of the statutory consequences of sexual harassment and the constitution/contact details of the IC.

Detailed preventive activities, training records, statutory displays, annual reporting and other employer compliance activities shall be maintained through the Company's POSH compliance governance process.

Governance and Statutory Compliances

The Company shall maintain the records, reports, training, IC constitution, statutory displays and other documentation required under the POSH Act and Rules.

The IC shall prepare its annual report containing the information prescribed by law. The Company shall comply with its own statutory reporting obligations under Section 22 and applicable reporting requirements.

Operational details shall be governed through the IC Charter, Complaint & Inquiry SOP, Employer Compliance SOP and POSH Compliance Calendar.