CLAIMPOWER INDIA PVT LTD PREVENTION AGASINST SEXUAL HARRASMENT POLICY

Prevention Against Sexual Harassment Policy

Ref No: CIPL/HR/POSH/2021

Version No: 1.0

Date of Issue: November 1, 2021

Document Owner: HR Head, Claimpower India Pvt. Ltd.

Approved By: CEO, Claimpower India Pvt. Ltd.

Objective
The objective of this policy is the protection of women at the work place from any
form of overt or covert sexual harassment by providing a redressal mechanism for
complaints of this nature.

The company has zero tolerance towards any kind of verbal, psychological conduct
of a sexual nature by any employee or partner/ vendor or any other stakeholder
that directly or indirectly creates an intimidating, offensive, or hostile environment
and will take all steps necessary to deal with complaints effectively and quickly.

Scope & Application:

This policy applies to Complaints of Sexual Harassment by an employee or third

party who is associated with the company in any form at its Workplace, regardless
of whether the alleged incident (s) or offence (s) has/have occurred in or outside
the office premises.

Office Premises shall include:

• All offices or other premises where the Company’s business is conducted.
• Any place visited by the employee arising out of or during the course of
employment including transportation provided by the Company.
• Any social, business or other functions organized by the Company The
policy is applicable to all employees in Claimpower India Pvt. Ltd. or in any
of its group companies (hereinafter collectively referred to as “the
Company”).
CLAIMPOWER INDIA PVT LTD PREVENTION AGASINST SEXUAL HARRASMENT POLICY

Definitions

“Sexual Harassment” – includes but is not limited to any of the following acts or
behavior, whether direct or indirect that is unwelcome to the intended recipient. i.
Sending or displaying text or visual messages of a sexual nature from any device.
• Inappropriate comments, jokes etc., threats, gender specific abusive
language
• Physical contact against a persons’ wishes
• Call, stalk, intimidate or pursue anyone against such person’s wishes
• Invite or interact with by compelling any person in the social media
• demanding favors for professional advancement vi. Using threats or
creating a hostile and unpleasant work environment that may impact a
person’s ability to work in a hassle-free Workplace

“Complaint” means a voiced objection or the allegation by the Complainant or

any other person (whether in writing or oral) of sexual harassment by the
Respondent that forms the basis of an investigation under this policy

“Complainant” means the person (s) against whom an incident (s) of sexual
harassment has been allegedly committed.

“Respondent” means a person against whom a complaint of sexual harassment

has been made/filed.

Internal Complaints Committee (ICC)

The Company will constitute Internal Complaints Committees that will investigate
all complaints of sexual harassment. The name of the members of such committee
shall be listed and communicated with the intent of every person knowing whom to
approach to in case an act of sexual harassment occurs.

The members of the ICC shall hold office for a period of three years and the
company will nominate another person to replace a member who vacates office for
any reason including resignation from the company’s service and such changes
will also be communicated to employees from time to time.

Procedure for making and handling of complaints and enquiry

Register Complaint

Any aggrieved employee may make a complaint in person or in writing to either of

the following
a. Immediate Supervisor who in turn will promptly inform the ICC and the HR
department
CLAIMPOWER INDIA PVT LTD PREVENTION AGASINST SEXUAL HARRASMENT POLICY

b. The HR department who shall record the complaint and bring it to the notice
of ICC
c. Any member of the ICC who post receiving the complaint shall initiate
proceedings

Committee Procedure
The committee shall enquire into the complaint of the sexual harassment following
procedures in conformity with the principles of natural justice and gender
sensitivity.

The ICC while proceeding with the inquiry would allow both the parties to explain
their case as well as submit any evidence in support of their statements.

The ICC shall have the power to

a. summon and enforce the attendance of any person and examining on oath;
b. require the discovery and production of documents/records; and any other
matter which may be prescribed

The ICC is expected to conclude the inquiry process within a maximum period of
90 days from the date of the complaint.

On completion of the inquiry the ICC shall provide a written report of its
proceedings and findings to the disciplinary authority/ employer within ten days of
the completion of the enquiry and such report should be made available to the
concerned parties.

If the allegations are not proven, no action will be recommended by the ICC unless
the complaint is found to be malicious.

In case such allegations are proven and ICC concludes that there is some basis
for the complaint, it will recommend: –

• Action for Sexual Harassment that may include transfer, termination or

resignation of the respondent

If the conduct amounts to an offence under the Indian Penal Code or other law,
the company will initiate a complaint with the authorities for redressal.

Punishment for false or malicious complaint and false evidence

If the ICC concludes that the allegations were malicious or frivolous, it may after
due enquiry, recommend action against the Complainant. Mere inability to
CLAIMPOWER INDIA PVT LTD PREVENTION AGASINST SEXUAL HARRASMENT POLICY

substantiate a complaint or lack of adequate proof will not be held against

complainant.

Confidentiality

All matters and proceedings relating to the Complaint including the identity of the
Complainant and Respondent shall remain strictly confidential and will not be
disclosed except to a competent court or a governmental agency that has the right
under the law and regulation to obtain such information. However, the
recommendation of the ICC and its implementation may be intimated on a need-
to-know basis for cause. Any person who breaches the confidentiality requirement
shall be penalized.

Third Party involvement

Where Sexual Harassment occurs as a result of an act or omission by any third
party or outsider, the company will take all steps necessary and reasonable to
assist the affected person in terms of support and preventive action.

Assurance against Retaliation

Employees are encouraged to express freely, responsibly, and in an orderly way
opinions and feelings about any problem or complaint of sexual harassment.
Retaliation against persons who report or provide information about Sexual
Harassment or behavior that might constitute Sexual Harassment is also strictly
prohibited. Any act of reprisal, including internal interference, coercion, and
restraint, by an employee, violates this policy and will result in appropriate
disciplinary actions.

Deviations / Exceptions
There are no exceptions to this policy. No person should be subjected to any form
of unwanted and unwelcome behavior or conduct with sexual overtures or
overtones, directly or indirectly and either physically, verbally or in writing. We
reserve the right to modify or terminate this policy without prior notice. It also shall
make all efforts to update this policy from time to time as required or recommended
by the law of the land. The company might make changes from time to time as and
when it feels necessary for the protection and safety of its employees.

Policy Owner & Status

The HR Head, Claimpower India Pvt Ltd, is responsible for maintaining this policy.

Current version: 1.0

Date of issue: November 1, 2021