Prevention of Sexual Harassment (POSH) Policy

BASIS OF THE POLICY

Sexual harassment at the workplace results in violation of the fundamental rights of a woman:

• To equality under Articles 14 and 15 of the Constitution of India
• To life and to live with dignity under Article 21 of the Constitution
• To practice any profession or to carry on any occupation, trade or business which includes a right to a safe environment free from sexual harassment.

Protection against sexual harassment and the right to work with dignity are universally recognized human rights by international conventions and instruments such as Convention on the Elimination of all Forms of Discrimination against Women, which has been ratified on 25 June 1993 by the Government of India.

STEP2GEN TECHNOLOGIES PVT LTD is an equal employment opportunity company and is committed to creating a healthy working environment that enables employees to work without fear of prejudice, gender bias and in a harassment free workplace to all employees without regard to race, caste, religion, colour, ancestry, marital status, gender, age, nationality, ethnic origin or disability. The Company also believes that all employees of the Company have the right to be treated with dignity. Sexual harassment at the work place or other than work place if involving an employee or employees is a grave offence and is therefore, punishable.

This Policy extends to all employees of STEP2GEN TECHNOLOGIES PVT LTD and any other company which may be incorporated in future with applicability of STEP2GEN TECHNOLOGIES PVT LTD, HR policies - hereinafter referred to as ‘Company’ / ‘Organization’ in this policy. It is deemed to be incorporated in the service conditions of all employees of the Company in India. Local country laws will take precedence over this policy, in other geographies, if applicable.

PART - A

INTRODUCTION

At STEP2GEN TECHNOLOGIES PVT LTD, all employees are expected to uphold the highest standards of ethical conduct at the workplace and in all their interactions with business stakeholders. This means that employees have a responsibility to:

• Treat each other with dignity and respect
• Follow the letter and spirit of law
• Refrain from any unwelcome behavior that has sexual connotation (of sexual nature)
• Refrain from creating hostile atmosphere at workplace via sexual harassment
• Report sexual harassment experienced and/or witnessed to appropriate authorities and abide by the complaint handling procedure of the company.

This policy has been framed in accordance with the provisions of “The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013” and rules framed there under (hereinafter “the Act”). Accordingly, while the policy covers all the key aspects of the Act, for any further clarification reference shall always be made to the Act and the provisions of the Act shall prevail.

If any aspect relating to sexual harassment not explicitly covered in this policy is provided for by the law, then the law will be applicable. In case of any conflict between the policy and the law, the law will prevail.

This policy provides protection against sexual harassment of women at workplace and the prevention and redressal of complaints of sexual harassment and matters related to it.

SCOPE

This Policy extends to all employees of the Company and is deemed to be incorporated in the service conditions of all employees of the Company in India. Local country laws will take precedence over this policy, in other geographies, if applicable.

DEFINITIONS

Sexual harassment may occur not only where a person uses sexual behavior to control, influence or affect the career, salary or job of another person, but also between co-workers. It may also occur between an employee and someone that employee deals within the course of his/her work who is not employed by the Company.

“Sexual Harassment” includes any one or more of the following unwelcome acts or behavior (whether directly or by implication), but not limited to:

• Unwelcome sexual advances involving verbal, non-verbal, or physical conduct, implicit or explicit
• Physical contact and advances including (but not limited to) touching, stalking, sounds which have explicit and /or implicit sexual connotation/overtones, molestation
• Teasing, Voyeurism, innuendos and taunts with implicit sexual connotation, physical confinement and /or touching against one’s will
• Demand or request for sexual favors
• Sexually colored remarks or remarks of a sexual nature about a person’s clothing or body
• Display of pictures, signs etc. with sexual nature/ connotation/ overtones in the work area and work-related areas
• Showing pornography, making or posting vulgar / indecent / sexual pranks, teasing, jokes, demeaning or offensive pictures, cartoons or other materials through email, SMS, MMS, gestures etc.
• Repeatedly asking to socialize during off-duty hours or continued expressions of sexual interest against a person’s wishes
• Giving gifts or leaving objects that are sexually suggestive
• Eve teasing, innuendos and taunts, physical confinement against one’s will or any such act likely to intrude upon one’s privacy; Persistent watching, following, contacting of a person; and
• Any other unwelcome physical, verbal or non-verbal conduct of sexual nature

Aggravating Circumstances

• Implied or explicit promise of preferential treatment in employment
• Implied or explicit threat of detrimental treatment in employment
• Implied or explicit threat about the present or future employment status
• Interference with the person’s work or creating an intimidating or offensive or hostile work environment
• Humiliating treatment likely to affect health or safety

ROLES AND RESPONSIBILITIES

It is the responsibility of all to respect the rights of others and to never encourage harassment. It can be done by:

• Refusing to participate in any activity which constitutes harassment
• Supporting the person to reject unwelcome behavior
• Acting as a witness if the person being harassed decides to lodge a complaint

PART - B

INTERNAL COMPLAINTS COMMITTEE (IC) CONSTITUTION

To prevent instances of sexual harassment and to receive and effectively deal with complaints pertaining to the same, Internal Complaints Committees (IC) have been appointed for the company. The detail of the committee is notified to all covered persons at the location (workplace). The committee at each location comprises of:

• Presiding Officer: A woman employed at a senior level in the organization or workplace
• At least 2 members from amongst employees committed to the cause of women or having legal knowledge
• One external member from legal fraternity or non-governmental organizations
• At least one half of the total members nominated being women

LODGING A COMPLAINT

An aggrieved woman may make, in writing, a complaint of sexual harassment at workplace to the Internal Committee within a period of 3 months from the date of incident/ last incident. The Internal Committee can extend the timeline by another 3 months for reasons recorded in writing.

RESOLUTION & INQUIRY PROCEDURE

The IC follows established natural justice principles for both conciliation and formal inquiries:

• Inquiry completed including submission of report within 90 days of commencement.
• Strict confidentiality maintained throughout the investigation.
• Interim relief options (transfer, leave up to 3 months) available during inquiry.

ANNEXURE A

Internal Complaints Committee (IC) Members