POLICY FOR PREVENTION, PROHIBITION AND REDRESSAL OF SEXUAL HARASSMENT AT THE WORKPLACE .

1. BACKGROUND AND OBJECTIVE.

UBDS India ("the Company") is committed to providing and maintaining a work environment that upholds the dignity, safety, and equality of every individual associated with it. The Company has zero tolerance for sexual harassment, and for any conduct that undermines a person's dignity or creates an intimidating, hostile, or offensive working environment.

This Policy ("Policy") is issued in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("PoSH Act" or "Act"), the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 ("Rules"), and subsequent jurisprudence, including *Aureliano Fernandes v. State of Goa* (2023) 4 SCC 632. It sets out the Company's mechanism to prevent, prohibit, and redress sexual harassment at the workplace, and is drafted to be read alongside the Company's Code of Conduct, Whistle-blower Policy (if any), and other applicable HR policies.

This Policy shall be read as forming part of the terms of employment/engagement of every person to whom it applies. In the event of any conflict between this Policy and the PoSH Act or Rules, the provisions of the Act and Rules shall prevail.

2. SCOPE & APPLICABILITY.

This Policy applies to all persons associated with UBDS India in any capacity whether as “employees” – including permanent, temporary, ad hoc, and contractual employees, consultants, interns, apprentices, trainees, probationers, retainers, volunteers, and persons on deputation, whether hired directly or through an agent, whether the terms of employment are express or implied or whether they are employed for remuneration or not - as well as to visitors, clients, vendors, and third parties, at all work-related locations and interactions, whether within or outside India, and whether physical, digital, hybrid, or remote.

This Policy applies to anywhere that work is taking place on behalf of Company, or where workplace relationships exist or interactions arise due to employment or association with Company. "Company" for the purposes of this Policy is interpreted broadly, and includes: all Company offices, branches, project sites, and establishments; any place visited by an employee arising out of or during the course of employment, including client sites, business travel, transportation provided by the Company, hotels and guest houses used for official purposes, and offsites or event venues; and virtual/digital workspaces, including official calls, messaging platforms, video conferences, work-related social events (physical or online) or digital platforms where work-related interactions and relationships occur, and any dwelling unit being used for work (e.g., during remote/hybrid working).

Statutory scope - a legal clarification.

Legal redressal under the PoSH Act is available specifically to women (Section 2(a) read with Section 9). The Company, as a matter of policy and good governance, extends parallel, comparable protection and process under this Policy to persons of all genders. Wherever this Policy refers to statutory rights, remedies, or powers (such as the Internal Committee's powers under Section 11(3), or the right of appeal under Section 18), these remain available, as a matter of law, only to aggrieved women; for aggrieved persons of other genders, equivalent protections are extended as a matter of Company policy and contractual commitment, not as an independent statutory right.

2.1 Applicability threshold and Local Committee.

This Policy, and the Internal Committee constituted under it, applies to every office or branch of the Company employing ten (10) or more employees, as required under Section 4(1) of the Act. Where any office or branch of the Company employs fewer than ten (10) employees, or where the complaint is against the employer itself, or where the complaint is made by a domestic worker, or if the IC is unable to accept the complaint for valid reasons, the aggrieved person may approach the Local Committee ("LC") constituted by the District Officer for the relevant district under Section 5 and Section 6 of the Act. The Company will render all reasonable assistance to any employee wishing to approach the LC in such circumstances.

3. DEFINITIONS.

Unless the context otherwise requires, the following terms shall have the meanings set out below, drawn from the Act with inclusive language added for policy clarity:

▪ Act: The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, together with the Rules made thereunder.

▪ “Aggrieved person”: Anyone associated with the company in any capacity (as defined within the purview of the Policy as per Section 2.1) who alleges to have
been subjected to sexual harassment in the workplace.

▪ Complainant: The Aggrieved Person who has filed a complaint of sexual harassment, or any other person authorised to file a complaint on their behalf as
permitted under Section 9(1) and (2) of the Act and Section 9 of this Policy.

▪ Respondent: Any person against whom a complaint of sexual harassment has been made.

▪ Employee: A person employed at the workplace for any work, on a regular, temporary, ad hoc, or daily-wage basis, directly or through an agent (including a
contractor), with or without the knowledge of the principal employer, whether for remuneration or otherwise, whether the terms of employment are express or
implied, and includes a co-worker, contract worker, probationer, trainee, apprentice, or a person called by any other such name.

▪ Employer / Management: The person(s), body, or committee responsible for the management, supervision, control, formulation, and administration of policies of
the Company.

▪ Internal Committee (IC): The committee constituted under Section 4 of the Act to receive and inquire into complaints of sexual harassment.

▪ Local Committee (LC): The committee constituted by the District Officer under Section 5 and 6 of the Act, applicable to establishments with fewer than 10
employees, or where the complaint is against the employer.

▪ Member / Presiding Officer: A member of the IC; "Presiding Officer" means the senior-level woman employee designated to preside over the IC under Section
4(2)(a).

▪ Appropriate Authority / District Officer: The authority notified under Section 5 of the Act having jurisdiction over appeals, Local Committees, and statutory filings, as applicable.

3.1 Definition of Sexual Harassment.

In accordance with Section 2(n) and Section 3 of the Act, "sexual harassment" includes any one or more of the following unwelcome acts or behaviour (whether directly or by implication), including (but not limited to):

1. Unwanted physical contact: Such as touching, hugging, kissing, deliberately brushing up against someone, blocking their path, standing too close for no valid reason, or any act that invades privacy or physically confides someone against their will.

2. Sexual comments or jokes: Remarks, comments, questions, jokes or teasing about someone’s body, appearance, personal life, gender, sexuality or sexual orientation; sexual innuendoes, offensive nicknames; inappropriate gossip or suggestive pranks.

3. Offensive looks or gestures: Staring, leering, ogling, making sexual gestures, or looking someone up and down in a way that causes discomfort; exposing one’s private parts.

4. Sexually explicit material: Showing, sending, or displaying pornography, sexual images, videos, cartoons, posters, graffiti or messages, including through social media, messaging apps or office channels; using Company property or systems (including email, instant messenger, social media, computers, servers or its IT system generally) to display or transmit sexually suggestive content

5. Inappropriate conduct in virtual spaces: Dressing in a sexualised manner in work video calls, insisting on unnecessary video calls, or sending sexually suggestive messages or images.

6. Creation or misuse of digital content: Creating fake accounts, morphing images to make them sexually suggestive or explicit, bullying, trolling, causing online
reputational damage, or sending sexual images without consent (cyber-flashing).

7. Unwelcome invitations: Asking someone out repeatedly despite refusals, professing romantic feelings after being told “no”, or giving sexually suggestive gifts.

8. Quid Pro Quo: Asking for sexual favours in exchange for job benefits, promotions, or special treatment, or threatening someone’s job for refusing such requests (also called “quid pro quo”, which literally means something in return or exchange for another). The request can be verbal, implied, physical, or non-verbal.

9. Hostile work environment: When conduct of a sexual nature makes someone feel excluded, unsafe, or unwelcome, affects their ability to work, or creates an
intimidating, offensive, humiliating, or hostile atmosphere or is an attack on their personal dignity.

10. Stalking or harassment: Following someone physically or online, sending repeated unwanted messages, or tracking someone without consent.

11. Intimidation, threats or retaliation: Punishing someone for refusing advances or for reporting unwanted behaviour.

The following circumstances, among others, if they occur or are present in connection with any act or behaviour of sexual harassment, may amount to sexual harassment under Section 3(2) of the Act:

▪ Implied or explicit promise of preferential treatment in employment;
▪ Implied or explicit threat of detrimental treatment in employment;
▪ Implied or explicit threat about present or future employment status;
▪ Interference with work, or creation of an intimidating, offensive, or hostile work
environment; or
▪ Humiliating treatment likely to affect health or safety.

Sexual harassment, for the purposes of this Policy, may be a single incident or a pattern of persistent behaviour; physical, verbal, or non-verbal; directed at one individual or more than one individual; and may occur irrespective of whether it was intentional.

What this Policy does not cover.

Mutually welcome, respectful interactions consistent with professional conduct, and consensual relationships between colleagues, do not amount to sexual harassment.

However, consent or participation obtained through threat, intimidation, coercion, or abuse of authority does not constitute real consent, and will be treated as harassment.

Where an employee is in a consensual relationship with a colleague — particularly one over whom they hold direct or indirect authority — they are strongly encouraged, though not legally required, to voluntarily and confidentially disclose this to HR or the IC, to help manage potential conflicts of interest. Such disclosures will be handled sensitively and shared with the IC only if strictly necessary for an inquiry.

4. THE INTERNAL COMMITTEE (IC).

The Company has constituted an Internal Committee to ensure the timely, impartial, and confidential redressal of complaints of sexual harassment, and to lead measures for its prevention and prohibition. In accordance with Section 4(2) of the Act, the IC shall consist of:

1. A Presiding Officer — a woman employed at a senior level at the workplace. Where no such senior-level woman employee is available at a particular office or branch, the Presiding Officer may be nominated from any other office or administrative unit of the Company;

2. At least two Members from amongst employees, preferably committed to the cause of women or having experience in social work, or having legal knowledge;

3. One external Member from a non-governmental organisation or association committed to the cause of women, or a person familiar with issues relating to sexual harassment.

At least one-half (50%) of the total Members of the IC shall be women, as required under the proviso to Section 4(2).

4.1 Tenure and reconstitution.

Members of the IC, including the Presiding Officer, shall hold office for a period not exceeding three (3) years from the date of their nomination, in accordance with Section 4(3) of the Act. If a Member demits office, resigns, or ceases to be associated with the Company during their tenure, the resulting vacancy shall be filled through a fresh nomination for the remainder of that term, as soon as reasonably practicable.

4.2 Removal or disqualification of IC Members.

In accordance with Section 4(4) of the Act, an IC Member may be removed from the Committee on the following grounds:

▪ Breach of confidentiality by disclosing any information related to complaints, identities of complainants, respondents, or witnesses, inquiry proceedings, or
findings.
▪ Conviction for an offence or an inquiry into an offence under any law for the being is in force is pending against the member.
▪ Found guilty in disciplinary proceedings or disciplinary proceeding is pending against the member.
▪ Misuse or abuse of position within the IC that renders continued membership prejudicial to the interests of justice or the Company.
▪ Any conduct that renders the member incapable of performing the duties of the IC impartially and effectively.

Any vacancy so created shall be filled through fresh nomination in accordance with the Act.

4.3 Conflict of interest, and complaints against a Member, the Presiding Officer, or the Employer.

Before commencing any inquiry, the IC shall conduct an internal conflict-of-interest check; any Member with a real or perceived conflict in relation to the specific complaint shall recuse themselves from that matter, and, where required to maintain quorum, an alternate/ad hoc arrangement permitted under the Act shall be used.

Where a complaint is made against the Presiding Officer, or a member of the Company's senior management/Employer in a manner that creates a genuine conflict for the IC as constituted, the Company shall refer the matter to the Local Committee constituted by the District Officer, or reconstitute an ad hoc committee excluding the conflicted individual(s), so that the integrity of the inquiry is preserved.

5. RIGHTS OF THE PARTIES.

5.1 Rights of the Aggrieved Person / Complainant.

1. To a safe and respectful work environment, free from sexual harassment;

2. To file a complaint without fear of retaliation, victimisation, or any adverse consequence;

3. To be heard empathetically by the IC, and to have their account recorded in a safe environment, free from shame, blame, or judgement;

4. To be clearly informed of the process, expected timelines, and the option of conciliation;

5. To present evidence and witnesses;

6. To receive a copy of the Respondent's reply, along with the evidence and list of witnesses submitted by the Respondent;

7. To a fair, effective, and time-bound inquiry conducted in a manner that respects their dignity;

8. To confidentiality of their identity and of all related information, subject to the exceptions set out in Section 9.9 (including the POCSO exception described in

Section 6 of this Policy);

9. To interim relief during the pendency of the inquiry;

10. To be supported in lodging an FIR or pursuing other legal remedies, should they choose to;

11. To be protected from intimidation during and after the process; and

12. To appeal against the findings/recommendations of the IC - available, as a matter of statutory right under Section 18 of the Act, to aggrieved women; extended as a matter of policy to other Aggrieved Persons.

5.2 Rights of the Respondent.

1. To be heard patiently and without bias;

2. To be clearly informed of the process and what to expect;

3. To present evidence and witnesses;

4. To receive, within a reasonable time, a copy of the complaint along with the evidence and list of witnesses relied upon;

5. To a fair and impartial inquiry conducted in accordance with the principles of natural justice;

6. To receive a copy of the inquiry findings and to make written representations before the final report is submitted, in accordance with Section 13(1) of the Act;

7. To confidentiality of their identity throughout the process, subject to the outcome and any legal disclosure obligations;

8. To be protected from victimisation during and after the process, unless and until the complaint is substantiated and appropriate action is recommended; and

9. To appeal against the findings/recommendations of the IC, in accordance with Section 18 of the Act and Section 9.10 of this Policy.

6. THIRD-PARTY HARASSMENT & COMPLAINTS INVOLVING MINORS.

6.1 Third-party harassment

If any Employee of Company experiences sexual harassment by a third party or outsider while on official duty, whether inside or outside Company premises, Company will take all reasonable steps to support and protect the aggrieved person.

This may include assisting with the complaint, providing interim protective measures, working with the third-party organisation or authorities to address the incident, and taking steps to prevent recurrence. The matter may also be referred to the Internal Committee (IC) for necessary action.

All complaints will be handled with strict confidentiality, and Employees will be protected from retaliation, as much as within the control of the Company.

This Policy is in addition to, and does not limit, any other legal rights or remedies available to the affected person.

7. REDRESSAL MECHANISM.

7.1 Filing a complaint.

Any Aggrieved Person who believes they have been, or are being, subjected to sexual harassment is encouraged to come forward. The Company is committed to addressing every complaint sensitively, confidentially, and in accordance with law.

Who may complain.

1. A complaint should ordinarily be made by the Aggrieved Person directly to the IC.

2. Anonymous complaints are discouraged, as accurate detail from both sides is essential to a fair inquiry; however, every report, even if incomplete, will be treated
seriously and assessed sensitively.

3. If a complaint is first shared with someone other than an IC Member (e.g., a manager, HR representative, or colleague), that person must encourage the Aggrieved Person to approach the IC directly, and may, with the Aggrieved Person's consent, forward the matter to the IC. That person must not conduct any inquiry, investigation, or fact-finding themselves. Such a manager-relayed report is not, by itself, a formal complaint under Section 9(1) of the Act; it becomes a formal complaint only once it is lodged with, or consented to be forwarded to, the IC in writing. Breach of confidentiality by such a person will be treated as misconduct.

4. Where the Aggrieved Person is unable to file the complaint themselves, it may be filed, with their consent, as permitted under Rule 6 of the PoSH Rules, by:

i. where physically incapacitated - a relative, friend, co-worker, any person with knowledge of the incident (with written consent), or an officer of the National
Commission for Women/State Women's Commission (for aggrieved women only);

ii. where mentally incapacitated - a relative, friend, special educator, qualified psychologist/psychiatrist, the guardian/caregiving authority, or a person with
knowledge of the incident jointly with any of the above; or

iii. where the Aggrieved Person is deceased - any person with knowledge of the incident, with the written consent of their legal heir.

What to include, and when to file.

5. The complaint should be made in writing (physical or electronic), and should include, as far as possible: a description of the incident(s) with date(s), time(s), and
location(s); the surrounding circumstances; details of the Respondent; names/contact details of witnesses; and any supporting evidence. If the Aggrieved
Person is unable to reduce the complaint to writing, an IC Member will provide reasonable assistance, based on their verbal account.

6. The complaint must be filed within three (3) months of the incident, or of the last incident in a series of incidents (Section 9(1)). The IC may, for reasons recorded in writing, extend this period by a further three (3) months where it is satisfied that circumstances prevented the Aggrieved Person from filing in time.

7. Where an individual does not wish to lodge a formal complaint, they are still encouraged to speak up informally with the person concerned, a manager, HR, or an
IC Member, who may assist with informal resolution. No formal disciplinary action can be taken on the basis of an informal report alone.

Where and how to submit.

8. The written complaint may be submitted to the IC by email or in hard copy, delivered in person or by post; where submitted physically, six (6) copies should be provided for official records, in line with common IC administrative practice.

9. If the Aggrieved Person is not comfortable raising this at the office, they may request to meet an IC Member at a mutually convenient, safe, and neutral location.
10. Where the Respondent is not a Company employee, the IC may assist the Complainant in filing the complaint with the Respondent's employer or the police,
and will extend all reasonable cooperation.

11. Aggrieved women may also lodge a complaint through the SHe-Box Portal (https://shebox.wcd.gov.in/), a facility of the Ministry of Women and Child
Development, Government of India. Complaints filed through SHe-Box are routed to the authority having jurisdiction, as determined by the relevant Nodal Officer; the IC will extend full support to this process where initiated.

7.2 Conciliation.

Before commencing a formal inquiry, and only at the specific request of the Complainant, the IC may facilitate conciliation between the parties, in accordance with Section 10 of the Act. Conciliation is voluntary and is never imposed.

▪ Monetary settlement shall not form the basis of conciliation (Section 10(1) proviso).
▪ A conciliated settlement may include an apology, a warning, a commitment to undergo counselling/sensitisation, or other mutually agreed terms; it shall be
recorded in writing, with copies to both parties, and the matter will thereafter be treated as closed, with no further inquiry.
▪ If the Respondent does not honour the settlement, the Complainant may report this to the IC, which shall reopen the matter and proceed to a formal inquiry.
▪ If no settlement is reached, the IC shall proceed to inquiry. Conciliation does not imply acceptance of the complaint, or an admission of guilt by the Respondent.

7.3 Interim relief.

During the pendency of an inquiry, the IC may, at the Complainant's request or on its own initiative, recommend interim measures under Section 12 of the Act, including:

▪ Transfer of the Complainant or the Respondent to another workplace, team, or reporting line;
▪ Permitting the Complainant to work from home or take leave, where feasible;
▪ Granting the Complainant leave of up to three (3) months, in addition to leave otherwise due;
▪ Restraining the Respondent from supervising, reporting on, or evaluating the Complainant's work performance; or
▪ Any other relief the IC considers appropriate to the circumstances.

7.4 Formal inquiry procedure.

▪ Upon receipt of a complaint, the IC shall send a copy to the Respondent within seven (7) days (Rule 6(3)).
▪ The Respondent shall file a written reply, with supporting documents and a list of witnesses, within ten (10) days of receiving the complaint.
▪ A minimum of three (3) Committee Members, including the Presiding Officer, shall be present to constitute quorum for any hearing; as good governance
practice, the Company shall make all reasonable efforts to ensure the external Member is present for substantive hearings, given their statutory role in reducing
institutional bias.
▪ No advocate/legal practitioner may represent either party at any stage of the inquiry (Rule 7(6)).
▪ The inquiry shall be completed within ninety (90) days from the date it is commenced (Section 11(4)).
▪ Where either party fails to appear, without sufficient cause, for three (3) consecutive hearings, the IC may, after giving fifteen (15) days' prior written notice, terminate the inquiry or record an ex parte decision.

On the IC's powers.

For the process of conducting the inquiry, the IC has been granted the powers of the Civil Court as per the Code of Procedure, 1908. This grants the IC the power to summon and enforce the attendance of any relevant person and examine them under oath, call for all relevant documents and evidence, and any other such matters in order to conduct a thorough and fair investigation. (Please note that as these powers are granted by the PoSH Act, and thus apply only for complaints made by aggrieved women).

What to expect during the inquiry.

▪ The IC will hear both parties with patience and fairness, and may cross-examine them where necessary; it will record testimony of listed witnesses and other
relevant individuals. Testimony must relate to the specific incident under review, and "character witnesses" will not be entertained.
▪ The inquiry will be conducted in English or the local language, as requested by the Complainant.
▪ Hearings are ordinarily conducted face-to-face, but the IC may permit video conference or telephonic hearings in appropriate cases, subject to: consent of
the parties/witnesses; at least twenty-four (24) hours' notice; the same confidentiality standards as in-person proceedings, with no unauthorised person
present; no recording without the consent of all parties; and circulation of minutes/relevant documentation by email. All communication in such cases
(consent, confirmations, questions, responses, statements) shall be through email and/or digital signature.
▪ All parties are expected to cooperate fully and in good faith, maintain strict confidentiality, and refrain from any retaliation, victimisation, or adverse action. Retaliation will be treated with the utmost seriousness.

7.5 Completion of the inquiry, findings, and outcomes.

On completion of the inquiry, the IC shall prepare a written report with findings and recommendations, and submit it to the Employer within ten (10) days of the conclusion of the inquiry (Section 13(1)). A copy will be shared with both parties, who may make representations against the findings. The Employer is required to act on the IC's recommendations within sixty (60) days of receipt (Section 13(3)/(4)).

Unsubstantiated complaint.

Where the IC concludes that sexual harassment has not occurred, or that the evidence is insufficient to establish it, it will recommend that no adverse action be taken, and both parties will be informed accordingly. An unsubstantiated complaint does not mean the complaint was false or malicious - it means only that the available evidence did not meet the required standard of proof.

Substantiated complaint.

Where the IC determines that sexual harassment has occurred, it will recommend prompt and proportionate remedial action, which may include:

▪ A written apology;
▪ Formal warning, reprimand, or censure;
▪ Withholding of promotion or pay increment;
▪ Demotion, suspension, or termination of employment;
▪ Mandatory counselling or gender-sensitisation training;
▪ Community service; or
▪ Any other corrective action appropriate under the Company's service rules.

Where financial compensation is considered appropriate, the IC shall, in accordance with Section 15 of the Act, take into account: the mental trauma, pain, suffering, and emotional distress caused; loss of career opportunity; medical expenses incurred; the income and financial status of the Respondent; and feasibility of payment in a lump sum or instalments.

Where the conduct also amounts to an offence under the Bharatiya Nyaya Sanhita, 2023 (or any other applicable law), the IC will recommend that a complaint be filed with the appropriate authority, including the police. This is without prejudice to the Complainant's independent right to approach the police at any stage; the Respondent will remain bound by any lawful findings of such authorities or a court of law.

7.6 Protections against retaliation, and safeguards against misuse.

Retaliation.

No person shall face retaliation or disadvantage for raising a complaint, acting as a witness, or otherwise supporting an inquiry. Retaliation includes (but is not limited to) unfair treatment, hostility, intimidation, demotion, loss of opportunity, spreading of rumours, or workplace bullying linked to the complaint, and will attract serious disciplinary action, up to and including termination, against anyone found responsible. This protection operates alongside, and does not replace, protections available under the Company's Whistle-blower Policy, where applicable.

False or malicious complaints.

Where, after a fair and thorough inquiry, the IC concludes that a complaint was made with knowingly false, malicious intent such as to damage the reputation of an individual or the Company, or to settle personal or professional scores, the IC may recommend action against the Complainant, mirroring the process applicable to a substantiated complaint against a Respondent. Critically, the mere fact that a complaint is unsubstantiated for lack of evidence does not, by itself, justify a finding of malicious intent. The IC will make a distinct, reasoned finding that the complaint was knowingly false before recommending any action against the Complainant. Similarly, where a witness is found to have knowingly given false testimony or submitted forged/misleading material, the IC may recommend action against that witness.

Confidentiality.

Confidentiality is central to the integrity of this process and to protecting all parties involved. Company takes confidentiality extremely seriously and breach of the same would entail appropriate penalties/ punishments. All those involved in the process – including the complainant, respondent, witnesses, members of the IC, HR staff, managers, and anyone else who may have been taken into confidence during the course of the process and/or is privy to details – must keep all
information strictly confidential.

The identity and details of the Complainant, Respondent, witnesses, and any evidence obtained in the course of the inquiry process, as well as recommendations of the IC and action taken by the Employer is treated as strictly confidential, and it shall not be published or make known to the colleagues, public, press or media.
Breach of confidentiality in any form will attract disciplinary action, fines, and/or other penalties as appropriate.

Data protection.

Complaint records, inquiry notes, and related documentation constitute sensitive personal data and shall be collected, stored, and processed in accordance with applicable data protection law, including the Digital Personal Data Protection Act, 2023, on a strict need to-know basis, with access restricted to the IC, HR, and persons directly involved in administering the process.

7.7 Appeal.

Any party aggrieved by the recommendations of the IC, or by the Company's implementation (or non-implementation) of those recommendations, may appeal to the appellate authority prescribed under the Act (ordinarily the court or tribunal notified for this purpose), within ninety (90) days of the recommendations being communicated, in accordance with Section 18 of the Act. As noted in Section 2 of this Policy, this statutory right of appeal is, as a matter of law, available to aggrieved women; the Company extends a comparable internal escalation route to other Aggrieved Persons under this Policy.

8 ROLES AND RESPONSIBILITIES.

8.1 The Internal Committee.

▪ Be thoroughly conversant with the Act, the Rules, and this Policy, and attend periodic orientation/training;

▪ Receive complaints with empathy, guide the Complainant on process and support available, and clarify expectations to both parties;

▪ Conduct a fair, impartial, and confidential inquiry, in accordance with the principles of natural justice, within statutory timelines;

▪ Recommend interim relief, attempt conciliation where requested, and issue a reasoned, proportionate report of findings and recommendations;

▪ Maintain strict confidentiality of all proceedings, documents, and identities;

▪ Submit an annual report to the Employer, and, where required, to the District Officer, in accordance with Section 21 and 22 of the Act, containing the number

of complaints received, disposed of, pending beyond ninety (90) days, and the nature of action taken; and

▪ Support the Company in building awareness and training on the prevention of sexual harassment.

8.2 Employees.

▪ Attend mandatory training and e-learning on this Policy and on preventing/addressing sexual harassment;

▪ Treat colleagues, vendors, clients, and visitors with dignity, and never encourage or overlook harassing behaviour; refuse to participate in inappropriate activity, support colleagues in rejecting unwelcome conduct, and act as a witness where willing and able;

▪ If experiencing harassment: recognise there is no shame or blame in coming forward; where possible, make clear that the behaviour is unwelcome; do not assume it will stop on its own; and consider keeping a contemporaneous, dated record of incidents (not mandatory, but often useful later); and

▪ If witnessing harassment: encourage the affected colleague to approach the IC or HR and assure them of support; where comfortable, informally flag repeated concerning behaviour to the IC (this does not itself constitute a formal complaint); and cooperate fully if called upon as a witness.

8.3 Managers and supervisors.

▪ Ensure their teams understand expected standards of behaviour, and that harassment of any kind will not be tolerated;

▪ Provide practical and emotional support - including reasonable adjustment of workload/schedule - to Complainants, Respondents, and witnesses navigating the process;

▪ Ensure no team member faces victimisation, retaliation, or hostility at any stage;

▪ Intervene appropriately on witnessing or becoming aware of inappropriate behaviour, and model professional, respectful conduct; and
▪ Cooperate fully with the IC during inquiries, and ensure their teams do the same.

8.4 The Employer.

In accordance with Section 19 of the Act, the Employer shall:

▪ Provide a safe working environment, including protection from sexual harassment by any person coming into contact with employees at the workplace;
▪ Display, at conspicuous places within the workplace, the constitution of the IC, the penal consequences of sexual harassment, and the order(s) constituting the IC (Section 19(b));
▪ Organise workshops, awareness programmes, and orientation for employees and IC Members at regular intervals (Section 19(a), (h));
▪ Provide necessary facilities, administrative support, and information to the IC to enable timely and confidential inquiries (Section 19(c), (e));
▪ Assist in securing the attendance of the Respondent and witnesses before the IC (Section 19(f));
▪ Treat sexual harassment as misconduct under applicable service rules, and initiate action for such misconduct (Section 19(d));
▪ Monitor timely submission of reports by the IC, and act upon its recommendations (Section 19(i), Section 13);
▪ File the IC's annual report with the District Officer where required, and include details of PoSH cases in the Company's annual report/Board's report, as applicable under the Companies Act, 2013; and
▪ Assist Aggrieved Persons who wish to pursue remedies under the Bharatiya Nyaya Sanhita, 2023 or other applicable law, including where the Respondent is not an employee of the Company (Section 19(g)).

9 MISCELLANEOUS.

9.1 Dissemination, display, and training

A copy of this Policy shall be made easily accessible to all employees and new joiners, including through the Company intranet/HR portal. Details of the IC and applicable penal consequences shall be displayed prominently at conspicuous locations, in accordance with Section 19(b) of the Act. The Company shall organise periodic training and e-learning for all employees, and specialised capacity-building for IC Members, on a recurring basis.

9.2 Interaction with other Company policies

This Policy operates alongside, and does not limit, the Company's Code of Conduct, Whistle-blower Policy, Disciplinary Policy, and Data Privacy Policy. Where a specific provision of any such policy conflicts with this Policy on a matter governed by the Act, this Policy (and the Act) shall prevail.

9.3 Revisions and modifications

The Company may review or modify this Policy periodically, including to reflect changes in law. Any amendment must be recommended by the IC and approved in writing by Management, and will be promptly communicated to all employees and updated wherever the Policy is made available.

9.4 Record retention

Records relating to complaints, inquiries, findings, and action taken shall be retained by the Company for a minimum period of eight (8) years / as advised by counsel, in a secure and access-controlled manner, to meet both statutory limitation considerations and regulatory audit requirements.

10 CONCLUSION.

At UBDS India, we are committed to building and sustaining a workplace that is safe, respectful, inclusive, and free from harassment and where relationships are grounded in trust, dignity, and fairness. Through this Policy, the Company reaffirms its determination to provide every person associated with it a workplace that is not only legally compliant, but genuinely safe, supportive, and empowering.

11 ANNEXURE I – INTERNAL COMMITTEE DETAILS.

The following Members constitute the Internal Committee of UBDS India, effective 17 July 2026.

This Annexure will be updated on every reconstitution of the IC or change in Membership, and the updated version shall be displayed and disseminated as per Section 9.1 of this Policy.

This policy was updated on 17th July 2026.