Prevention Of Sexual Harassment Policy

Zero-Sum Wireless Solutions India Pvt. Ltd. is committed to providing a professional workplace free from sexual harassment, intimidation, exploitation, and discrimination. Any incident of sexual harassment will be addressed promptly, fairly, and effectively to ensure a safe and respectful work environment for all employees.

1. Applicability

This policy applies to:

• Permanent employees
• Temporary employees
• Contract employees
• Probationers
• Apprentices and trainees
• Consultants and contract labor
• Individuals working on a voluntary basis
• Any person engaged by or working with the Company

The policy applies at all workplaces, including:

• Company offices and facilities
• Client locations
• Business travel
• Training programs
• Company-sponsored events
• Employer-provided transportation

2. Definition of Sexual Harassment and Examples

Definition of Sexual Harassment:

Sexual Harassment includes any unwelcome sexually determined behaviour or conduct, whether direct or implied, including:

• Physical contact and advances
• Demand or request for sexual Favors
• Sexually coloured remarks
• Showing pornography through print, electronic, or any other media
• Any unwelcome verbal, non-verbal, or physical conduct of a sexual nature

Sexual harassment may occur when:

• Submission to such conduct affects employment decisions.
• Rejection of such conduct leads to adverse consequences.
• The conduct interferes with work performance.
• The conduct creates an intimidating, hostile, or offensive work environment.

Examples

Examples include, but are not limited to:

Unwelcome Sexual Advances:

• Unwanted touching
• Patting
• Pinching
• Hugging
• Kissing
• Physical advances

Requests for Sexual Favors:

• Direct or indirect requests for sexual Favors
• Promises of benefits in exchange for sexual Favors
• Threats of negative employment consequences

Sexually Coloured Remarks:

• Offensive jokes
• Inappropriate comments about appearance
• Sexually suggestive remarks
• Unwelcome comments or innuendoes

Sexual harassment may occur:

• Between employees of any gender
• Between peers
• Between supervisors and subordinates
• Through a single serious incident or repeated behaviour

3. Prohibition of Sexual Harassment

Sexual harassment is strictly prohibited.

Any employee found guilty of sexual harassment may be subject to disciplinary action, including termination of employment.

Knowingly making false or malicious complaints or providing false evidence may also result in disciplinary action.

Sexual harassment shall be treated as misconduct under applicable service rules.

4. Authorities Dealing with Allegations of Sexual Harassment

Internal Committee (IC)

The Company has constituted an Internal Committee to address complaints of sexual harassment.

The Internal Committee consists of:

• A woman Presiding Officer
• Employee Members
• An External Member familiar with issues relating to sexual harassment

Responsibilities of the Internal Committee:

• Implement this policy
• Conduct inquiries
• Maintain records of complaints
• Organize awareness programs
• Recommend corrective actions

Term of Membership:

Members are appointed for a period of three years unless otherwise revised by the Company.

5. Redressal Procedures

Basic Procedures:

Complaints may be addressed through:

• Informal Procedures
• Formal Procedures

Informal Procedures:

Consultation:

Employees may consult designated counsellors or Human Resources regarding concerns related to sexual harassment.

Direct Communication:

An employee may communicate directly with the concerned individual, verbally or in writing, requesting that the unwelcome behaviour cease.

Retaliation against any person making such communication in good faith is prohibited.

Formal Procedures

Initiation of Complaint

Complaints may be submitted to the Internal Committee via:

Email: [email protected]

Complaints should generally be filed within three months of the incident or the last occurrence in a series of incidents.

The Internal Committee may accept delayed complaints where justified.

Processing of Complaint

Upon receipt:

• The complaint will be reviewed confidentially.
• The Internal Committee will determine whether a prima facie case exists.
• If warranted, a formal inquiry will be initiated.

Inquiry Procedure:

The Internal Committee shall:

• Follow principles of natural justice
• Hear both parties
• Review evidence and witness statements
• Maintain confidentiality
• Conduct proceedings fairly and impartially

All employees are required to cooperate fully with the inquiry.

Report

Upon completion of the inquiry, the Internal Committee shall:

• Prepare a written report
• Record findings and recommendations
• Share the outcome with relevant parties as required

Disciplinary Action:

Where misconduct is established, disciplinary action may include:

• Written warning
• Suspension
• Transfer
• Loss of privileges
• Termination of employment
• Any other action deemed appropriate

Implementation:

The Company shall implement recommendations of the Internal Committee within the prescribed timelines.

Termination:

Where serious or repeated misconduct is established, employment may be terminated.

Where a third party is responsible, the Company may terminate the business relationship and take additional appropriate action.

6. Third-Party Harassment

The Company will provide assistance and support to any employee subjected to sexual harassment by:

• Customers
• Vendors
• Contractors
• Visitors
• Any other third party

7. Confidentiality and Protection Against Victimization

The Company shall maintain confidentiality regarding:

• Complaints
• Investigation proceedings
• Findings
• Recommendations

Retaliation, victimization, intimidation, or adverse treatment against any complainant, witness, or participant in an inquiry is strictly prohibited.

8. Settlement Through Conciliation

At the request of the aggrieved woman, the Internal Committee may facilitate conciliation before initiating an inquiry.

Monetary settlement shall not form the basis of conciliation.

Where settlement is reached, no further inquiry shall be conducted unless settlement terms are violated.

9. Action During Pendency of Inquiry

During an inquiry, the Internal Committee may recommend interim measures, including:

• Temporary transfer
• Reassignment of duties
• Additional leave for the aggrieved employee
• Other appropriate relief measures

10. Outcome of Inquiry / Deduction of Wages

Where appropriate and permissible by law, the Internal Committee may recommend deduction from the salary or wages of the respondent and payment to the aggrieved woman employee.

11. Determination of Compensation

Compensation may be determined considering:

• Mental trauma and emotional distress
• Loss of career opportunities
• Medical expenses incurred
• Financial status of the respondent
• Feasibility of payment in lump sum or instalments.

12. Consensual Sexual or Romantic Relationships

Relationships involving unequal authority positions may create actual or perceived conflicts of interest.

Employees in positions of authority must:

• Avoid supervisory influence over individuals with whom they have a relationship
• Disclose potential conflicts where required
• Comply with Company policies governing workplace conduct

Failure to comply may result in disciplinary action.

13. Miscellaneous

The Company shall:

• Periodically review this policy
• Conduct awareness and training programs
• Ensure compliance with applicable laws
• Support employees seeking legal remedies where applicable

The Company reserves the right to amend this policy at any time.

For questions regarding this policy, employees may contact the Corporate Management Department.

14. Internal Committee Constitution

Reporting Email

[email protected]