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Axelerant Technologies Private Limited (referred to as the "Company") is committed to providing an equal opportunity and harassment-free workplace notwithstanding race, caste, religion, color, ancestry, marital status, gender, sexual orientation, age, nationality, ethnic origin, or disability, as the case may be. Thus, to create such a safe and conducive work environment, this Policy has been framed in line with the provisions of the "Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013" of India (referred to as the "Act" 1) and existing rules framed thereunder namely the "Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 (referred to as the "Rules" 2).

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This policy is a sub-section of the existing Safe Space Policy and does not replace the current policy.   This policy gives a more detailed and descriptive view of the Protection of team members from Sexual Harassment who engaged with our company.

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This policy is intended to protect and thereby prevent sexual harassment of team members (irrespective of gender) at the workplace and redressal of redress complaints and related matters related to it.

This policy extends to all team members, including individuals coming to the workplace for employment or any other purpose whatsoever, including but not limited to visitors, vendors, contractual resources, and secondees, and applies to any alleged act of sexual harassment against persons at the workplace, whether the incident has occurred during or beyond office hours.

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"Aggrieved Individual" means in the workplace, a person of any age, whether employed or not, alleges to have been subject to any act of sexual harassment by the respondent and includes contractual, temporary team members , and visitors.

  1. "Complainant" is any aggrieved individual (including a representative as more fully described under Rule 6 of the said Rules, if the aggrieved individual is unable to make a complaint on account of their physical or mental incapacity or death or otherwise) who makes a complaint alleging Sexual Harassment under this Policy.

  2. "Team Member" as defined under the Act means a person employed with the Company for any work on a permanent, temporary, part-time, ad-hoc, or daily wage basis, either directly or through an agent, including a contractor, who with or without the knowledge of the Principal employer, whether for remuneration or not, or working voluntarily or otherwise, whether the terms of employment are expressed or implied and includes a co-worker, a contract worker, probationer, trainee, apprentice or called by any other such name.

  3. "Employer" means a person who is responsible for management, supervision, and control of the workplace, including appointment/removal/termination of team members, and will include the Chief Executive Officer (CEO) or another executive representative (CXO).

  4. "Internal Committee" means and includes an Internal Complaints Committee (referred to as the "ICC").

  5. "Member" means a member of the ICC.

  6. "Presiding officer" means the ICC's presiding officer and shall be an empathetic person employed at a senior level among the team members.

  7. 'Respondent" means a person against whom a complaint of alleged sexual harassment has been made under this policy.

  8.  "Parties" means the complainant and the respondent collectively.

  9. "Sexual Harassment" includes any one or more of the following unwelcome acts or behavior (whether directly or by implication):

    1. Any unwanted sexually determined action or pattern of conduct that would cause discomfort or humiliate a person

      1. Making sexually colored remarks or remarks of  of a sexual nature about a person's clothing or body;

      2. Showing pornography;

      3. Any other unwelcome physical, visual, verbal, or non-verbal conduct of a sexual nature, including but not limited to cat-callcalls, wolf/finger whistles, vulgar/lewd jokes, letters, phone calls, text messages, e-mails, gestures, etc.

    2. Sexual harassment can involve a series of incidents or be a one-off occurrence.

      1. The following circumstances, among other things, if it occurs or is presently connected with any act or behavior of sexual harassment, may amount to sexual harassment:-

      2. Implied or explicit promise of preferential treatment in employment ; or

      3. The implied or direct threat of detrimental treatment in employment ; or

      4. The implied or immediate threat about the present or future employment status ; or

      5. Interference with work or creating an intimidating or , offensive, or hostile work environment for the person ; or

      6. Humiliating treatment affecting affects any person's health or safety.

  10. "Workplace" means establishments, enterprises, institutions, offices, branches, premises, locations, or units established, owned, and controlled by the Company or places visited by the team members out of or during employment, including accommodation and transportation provided by the employer undertaking such a journey.

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  1. Any aggrieved individual may make in writing an allegation of sexual harassment within three (3) months from the date of the incident and, in case of more than one incident, within three (3) months from the time of the last incident. Whether to consider it or not, the ICC will review complaints arising from more than three (3) months-old incidents.

  2. However, the ICC may, for reasons to be recorded in writing, extend such time limit of filing a complaint up to a further three (3) months if it is satisfied that bonafide circumstances prevented the aggrieved individual from filing a complaint within the time limit mentioned in point (1) hereinabove. The complaint should indicate the name and available details of the aggrieved person and the respondent. Anonymous or pseudonymous complaints will not be investigated.

  3. The People Operations representative will officially forward the complaint to the Presiding Officer of ICC within fourteen (14) days from the date of making a claim.

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a. Their relative or friend; , or

b. a qualified psychiatrist or psychologist; or

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  • Transfer the aggrieved individual or the respondent to any other workplace ; or

  • Grant leave to the aggrieved individual of a maximum of three (3) months, in addition to the leave they would be otherwise entitled; , or

  • Grant such other relief to the aggrieved individual as may be found to be appropriate ; or

  • Restrain the respondent from reporting on the work performance of the complainant.

Once the recommendations of interim relief are implemented, CPO the People Operations representative shall inform the committee regarding the same.

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This policy and the law prohibits any person, including ICC Members, from publishing, communicating, or making known to the public, press, and media in any manner the contents of the complaint, the identity, and addresses of the aggrieved person, respondent, and witnesses, any information relating to conciliation and inquiry proceedings, or recommendations of the ICC during the proceedings under the provisions of the Act. Any violation shall also be subject to applicable Disciplinary Actions outlined in the Safe Space Policy. Further, the CEO/CXO  shall impose monetary sanctions per the Act and Rules provisions.

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However, anyone who abuses the procedure (for example, by maliciously putting making an allegation, knowing it to be untrue, or producing any forged or misleading document) will be subject to appropriate disciplinary action, including possible termination.

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