Anywr India Prevention of Sexual Harassment Policy

Policy Statement

Anywr India is committed to a work environment in which all individuals are treated with respect and dignity. This Prevention of Sexual Harassment Policy (“POSH Policy”) is formulated as per the guidelines prescribed in the “Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013” (the “POSH Act”).

While the POSH Policy sets forth Anywr India’s goals of promoting a workplace that is free of Sexual Harassment, the POSH Policy is not designed or intended to limit the company’s authority to discipline or take remedial action for workplace conduct that the company deems unacceptable, regardless of whether such conduct satisfies the definition of Sexual Harassment.

The POSH Policy applies to every person engaged with Anywr India for any work whatsoever, on a regular, temporary, ad hoc basis, either directly or through an agent, including contractors, consultants, trainees, apprentices, and even a visitor, whether working from home or remote working. These are also considered in an extended workplace.

“Sexual Harassment” - shall include one or more of the following unwelcome acts or behaviour’s namely:

· Physical contact and advances.

· A demand or request for sexual favours.

· Making sexually coloured remarks.

· Showing pornography.

· Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.

· Physical contact and sexual advances such as pinching, patting, rubbing, or purposefully brushing up against another person.

· Staring in a sexually suggestive or offensive manner or whistling.

· Sending suggestive or obscene letters, notes, electronic mail messages, or invitations.

· Making or using derogatory comments, slurs, or jokes of a sexual nature, verbal sexual advances or propositions, graphic commentaries about an individual’s body, sexually degrading words used to describe an individual.

· Making sexual gestures or displaying sexually suggestive objects, pictures, cartoons, posters, calendars or computer screens, or pornography.

· Inquiries about someone's sexual history or sexual orientation.

· Any other unwelcome physical, verbal, or non-verbal conduct of sexual nature.

In addition to the above, any of the following circumstances, if it occurs concerning any act or behaviour of Sexual Harassment, may amount to Sexual Harassment:

1. Implied or explicit promise of preferential treatment in her/his employment; or

2. The implied or explicit threat of detrimental treatment in her/his employment; or

3. The implied or explicit threat about her/his present or future employment status; or

4. Interference with her/his work or creating an intimidating or offensive or hostile work environment for her/his; or

5. Humiliating treatment which is likely to affect her/his health or safety.

Any actions or words with a sexual connotation that interfere with an individual’s ability to work or create an uncomfortable atmosphere are considered Sexual Harassment.

Internal Committee

As per the guidelines of the POSH Act, an Internal Complaints Committee (“IC”) for Anywr India has been constituted for all the administrative units/offices of Anywr India.

The IC consists of 4 members:

· Presiding Officer – Daisy Cardoz (daisy.cardoz@anywr-group.com)

· Member – Atish Nair (atish.nair@anywr-group.com)

· Member – Lalitha Shree (lalitha.shree @anywr-group.com)

· Member – Vineetha Wahane (vineetha.v-wahane @anywr-group.com)

· External Committee Member – Srishti John (srishti@sashaindia.com)

Reporting an Incident of Sexual Harassment

•• The Complainant who believes that she/he has experienced or subjected to or observed Sexual Harassment, directly or indirectly, may submit a complaint of the alleged incident to the IC in writing. Such a complaint must be filed within three (3) months from the incident and, in case of a series of incidents, within a period of three (3) months from the date of the last incident.

If any complaint is filed after these given timelines, the IC may refuse to entertain the same.

The IC, upon a written application made to it and if it is satisfied that the circumstances were such which prevented the Complainant from filing a

complaint within the prescribed period, may extend the time limit for making the complaint for further three (3) months from the expiry of the initial timelines.

Inquiry into the Complaint

Anywr India promises to investigate all reports of Sexual Harassment as discreetly, promptly, thoroughly, and confidentially as possible. However, the investigation of such complaints will generally require disclosure to the respondent.

The objective of the POSH Policy is to conduct a thorough investigation, to determine whether Sexual Harassment has occurred and to eliminate any hostile or offensive working conditions and decide actions to take against the respondent.

The IC shall make an inquiry into the complaint in accordance with the principles of natural justice.

A complaint will be resolved within 90 days from receipt of the complaint by the IC.

The IC will record its decisions and recommendations and, accordingly, inform the same to the Complainant and the respondent.

For making an inquiry under this POSH Act, the IC shall have the same powers as are vested in a Civil Court under the Code of Civil Procedure, 1908, namely:

1. Summoning and enforcing the attendance of any person and examining him on oath.

2. Requiring the discovery and production of documents; and

3. Any other matter which may be necessary.

The management of Anywr India shall act upon the recommendations of the IC immediately but not later than sixty (60) days of the receipt of the recommendations of the IC.

The HR will direct appropriate action in accordance with the recommendation proposed by the IC.

Conciliation

Upon a request made by the Complainant, before initiating an inquiry into any alleged complaint, the IC may take steps to resolve the matter between the Complainant and Respondent through conciliation.

In case the Respondent agrees to actions such as apologies without going through the formal disciplinary procedures, then based on such actions, the Complainant and the Respondent may arrive at a resolution of the complaint informally.

Where the parties have arrived at a conciliation, no further inquiry shall be conducted by IC. IC shall record the details of the conciliation and forward the same to the Head – Human Resources (HR) for necessary action within ten (10) days of the conciliation.

Subject to point “In case the Respondent agrees to actions such as apologies, without going through the formal disciplinary procedures” above, if the complaint has not been resolved through conciliation, IC may proceed to initiate a formal inquiry into the complaint.

Disciplinary Action

Based on the conclusions of the investigation, the IC will suggest (as a part of the written report in case of formal resolution) appropriate disciplinary action to the management of Anywr India, which can include a written apology, counselling, carrying out community service, warning, reprimand or censure, suspension, transfer from project/location (of the Complainant or the Respondent), withholding of promotion, deducting the salary or any such sum as it may deem necessary, withholding of pay rise or increment, direct the Respondent to pay to the Complainant such sum considering the trauma suffered, loss in career, medical expenses incurred, income or financial status of the Complainant or any action up to and including termination of employment. Anywr India will implement the actions with the support of the Human Resources Head of Anywr India.

Confidentiality

Cases that involve allegations of Sexual Harassment are especially sensitive, and special attention will be given to the issue of privacy for all individuals.

Retaliation

This POSH Policy strictly prohibits any kind of intimidation or harassment of individuals who have filed complaints, instituted proceedings, assisted in investigations, or formally or informally objected to discriminatory practices, irrespective of the outcome. Anywr India will take strict action against those employees who would indulge in such retaliatory actions. Anywr India will ensure that the Complainant or witnesses are not victimized or discriminated against while dealing with any complaint of Sexual Harassment.