Anti–Harassment Policy of STRATEGIC-BRAIN

All individuals within the nation must have the opportunity to lead a life of honor and esteem. Any behavior that has the potential to disrupt an individual's productivity or establish an unwelcoming atmosphere within the workplace is strictly prohibited. Such actions are acknowledged as forms of workplace harassment.

Any form of mistreatment, whether it is psychological, emotional, or physical, is considered a violation of the law and should not be tolerated. It is important to note that even if the employee responsible for the misconduct did not intend to offend; all employees must demonstrate empathy and consider the emotions of their colleagues.

International conventions and instruments, such as the Convention on the Elimination of All Forms of Discrimination against Women, ratified by the Government of India on June 25, 1993, universally acknowledge the human rights of protection against sexual harassment and the right to work with dignity. If you have experienced any of these injustices, it is essential that you promptly notify the relevant authorities.

The fundamental rights of a woman are violated when subjected to sexual harassment in the workplace:

• The Constitution of India guarantees equal treatment under Articles 14 and 15, which should be taken into consideration.

• Under Article 21 of the Constitution, individuals have the right to lead a life with dignity.

• To engage in any profession or pursue any occupation, trade, or business, individuals are entitled to a secure and conducive working environment that is devoid of any form of sexual harassment.

The STRATEGIC-BRAIN is dedicated to fostering a fair and inclusive workplace where all people can thrive without facing discrimination, gender inequality, or harassment. We are committed to treating all individuals in our workforce and associates with respect and dignity, regardless of their race, caste, religion, colour, ancestry, marital status, gender, age, nationality, ethnic origin, or disability. We firmly believe that every member of our organization has the right to be treated fairly. Any form of sexual harassment, whether it occurs within or outside the workplace and involves a staff member or employee, is considered a serious offense and will be subject to appropriate disciplinary action.

This Policy applies to all personnel of STRATEGIC-BRAIN and all affiliated individuals or entities, whether directly or indirectly associated with us, as well as any future incorporation subject to the applicability of STRATEGIC-BRAIN's anti-harassment policy. It is considered to be integrated into the terms of service for all individuals connected to STRATEGIC-BRAIN, whether directly or indirectly. In regions beyond our local jurisdiction, the policy will conform to the prevailing laws of the respective state, if applicable.

This revised policy supersedes all prior policies and communications regarding this subject, effective November 1st, 2023.

Anti–Sexual Harassment Policy

(The Anti-Sexual Harassment Policy (ASH Policy), enforced by the STRATEGIC-BRAIN, is a comprehensive policy that guarantees equal treatment for all genders. This policy applies to all personnel affiliated with the organization, regardless of their employment or engagement status, whether contractual or otherwise, and is also applicable to every individual, regardless of their gender identity, including women, men, and transgender. This policy is implemented in an unbiased manner, ensuring that the sexual orientation or socio-cultural background of any staff member does not impact the decision-making process.)

1. Preamble

2. Applicability

3. Definitions

4. Objective

5. Committee for Redressing Complaints.

6. Submission of Grievance

7. Resolution Procedure through Conciliation

8. Enquiry Process

9. Deliberate, Malicious False Allegations

10. The Final Decision and Course of Action to be Pursued

11. Implications of Sexual Harassment in the Criminal Justice 

     System

12. Petition for Review

13. Prevention Action

14. Implementation and Review of Policies

15. Interpretation of the Code

16. Revise and Amend the Code

17. The Violation of the Code

18. The Code's Publication

19. Instructions for General Use

20. Annexure I of this Policy Outlines the Required Format for Submitting a Complaint

1. Preamble

1.1.The Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act 2013, enacted by the Government of India, came into effect on December 9th, 2013. This legislation aims to address and prevent sexual harassment against female employees in the workplace. Any individual, who engages in unwelcome physical contact, makes explicit sexual advances, demands or solicits sexual favors, makes sexually suggestive remarks, or exposes pornography without the consent of a woman will be held accountable for the offense of Sexual Harassment. Section 354A of the Indian Penal Code 1860 outlines the penalties for this offense, which range from simple to rigorous imprisonment for one to three years, along with fines or both.

1.2.The Organization, known as STRATEGIC-BRAIN, is dedicated to ensuring a secure workplace and strictly prohibits any type of sexual harassment. Our commitment is to establish a healthy and safe work environment that allows our workforce and associates to work without any fear of discrimination, gender inequality, or sexual harassment. We firmly believe that every member of staff has the right to be treated with respect and dignity. Any occurrence of sexual harassment within the workplace or during official duties involving our employees will be considered a serious offense and will be punishable under the relevant laws.

1.3.The Organization has developed a Policy known as "The Anti-Sexual Harassment Policy" to establish and uphold a secure work environment where workforce and associates treat one another with politeness, integrity, and equality, regardless of their gender, race, caste, creed, religion, place of origin, sexual orientation, disability, economic status, or hierarchical position. This policy aims to prevent any instances of sexual harassment and provides guidelines for the workforce to follow in the event of a policy violation, by all relevant regulations about sexual harassment.

1.4.Submitting a fraudulent claim of sexual misconduct or furnishing inaccurate details about a complaint shall also be considered a breach of policy. Non-compliance with this policy will result in severe disciplinary measures, which may include the termination of all affiliations with our organization.

1.5.This policy has been formulated in strict adherence to the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013.

1.6. This Policy aims to provide necessary assistance and remedial measures to individuals who perceive themselves as victims of such conduct.

2. Applicability

This policy applies to all personnel affiliated with the organization, regardless of their employment or engagement status, whether contractual or otherwise. Moreover, it extends its coverage to individuals who are not workforce and associates of the organization or entities, whether directly or indirectly associated with us, as well as any future incorporation but are associated with us directly or indirectly, such as channel partners, business associates, etc.

Additionally, this policy also encompasses customers, visitors, suppliers, and other parties who may encounter incidents of sexual harassment at the organization's premises or through offline or online means, as defined in the following sections.

3. Definitions

3.1 In the context of a workplace, the term "Aggrieved Individual" refers to any person, regardless of employment status or age, who claims to have experienced sexual harassment at the hands of the respondent.

3.2. An individual who files a complaint alleging sexual harassment under this policy is referred to as the "complainant".

3.3. An "employee" or "workforce" denotes an individual or organization who is involved or connected with this organization to carry out diverse responsibilities on a regular, temporary, sporadic, or daily wage basis. This affiliation can be established either directly or through a representative, such as a contractor or business associate, irrespective of whether the primary employer is cognizant of it. The involvement may entail remuneration or be voluntary, and the terms of employment can be explicitly stated or implied. Furthermore, this definition encompasses individuals who collaborate within the same workplace, contract workers, individuals on probation, trainees, apprentices, or those referred to by any other comparable designation.

3.4. When a complaint is filed, the term "Respondent" is used to identify the person who is the subject of the allegations made by the Complainant.

3.5. The term "Sexual Harassment" encompasses any unwelcome acts or behaviors (whether direct or implied) that may include, but are not limited to:

a) Any sexually inappropriate conduct, including but not limited to physical contact, advances, or solicitation for sexual favors, whether explicitly or implicitly, in exchange for employment, promotion, examination, or evaluation within the scope of any company-related activities;

b) Any inappropriate behavior of a sexual nature that includes verbal, non-verbal, or physical actions such as making sexually suggestive comments, jokes, written or electronic communication (such as letters, phone calls, SMS or emails), gestures, sharing pornography, staring suggestively, physical contact or harassment, following someone persistently, creating disturbing sounds, displaying explicit images, showing offensive signs, or engaging in any form of communication that offends an individual's sensibilities and hampers their performance in the professional environment;

c) Any exhibition of explicit content or any other type of unwelcome sexual conduct, whether it is manifested through physical actions, spoken language, or non-verbal signals;

d) Instances of harassment such as verbal abuse, suggestive remarks, and unwarranted confinement that can potentially violate an individual's personal space; and

e) Any conduct displayed by a person in a position of authority cultivates an unwelcoming or intimidating environment in the professional setting for an individual of a different gender. This encompasses scenarios where there is an insinuated or explicit assurance of favorable treatment in terms of employment, the possibility of adverse treatment in employment, apprehension concerning present or future employment, disruption of work, or the establishment of an objectionable work atmosphere. Furthermore, any behavior of a sexual nature that could reasonably be expected or interpreted as causing offense, embarrassment, or actions that undermine the individual's well-being or safety.

3.6. The term "Workplace" encompasses the physical location where business activities take place and refers to the following:

• a) Premises, locations, establishments, enterprises, institutions, offices, branches, or units that have been established, owned, and controlled by the Company;

• b) During employment, the employee may have visited various locations for official events, utilizing transportation and accommodation provided by the employer to undertake such journeys.

4. Objective

4.1. To ensure a secure working environment at the workplace, encompassing protection from individuals who come into contact with the premises;

4.2. To ensure the safeguarding of women's rights to protection against sexual harassment and their right to livelihood, to prevent and address instances of sexual harassment against women;

4.3. To establish a proficient system for addressing, prohibiting, and rectifying instances of sexual harassment experienced by employees within the workplace or during the performance of official duties within the Organization;

4.4. To foster an atmosphere that cultivates consciousness and discourages instances of sexual harassment among the Organization’s workforce and associates;

4.5. To guarantee the full execution of the Policy in both its literal and intended sense, it is imperative to undertake all essential and rational measures. These measures encompass, among others, the establishment of suitable Committees dedicated to fostering gender sensitization and conducting thorough investigations into allegations of sexual harassment;

4.6. The Organization’s dedication to ensuring a workplace that is devoid of any form of discrimination and violence towards women is unwavering.Anti–Sexual

4.7. To foster a widespread understanding regarding the issue of sexual harassment of women in professional settings.

5. Committee for Redressing Complaints.

5.1. An Internal Complaints Committee (hereinafter referred to as 'the Committee') has been established by the Board of Directors of the Company to address and resolve complaints of Sexual Harassment under The Sexual Harassment of Women in the Workplace (Prevention, Prohibition, and Redressal) Act, 2013 (hereinafter referred to as 'the Act') and any other applicable legislation currently in effect in India, as well as the Rules outlined in the notification issued by the Ministry of Women and Child Development on December 9, 2013 (hereinafter referred to as 'the Rule').

The Human Resource Department of the Organization will establish the aforementioned Committee by the provisions outlined in the Act and its corresponding Rule.

The individuals comprising the Chairman and Members of the Committee are as stated below:

Mrs. Mina Baksi, Chairperson;

Mr. Jayanta Baksi, Member;

Mr. Soumen Chowdhury; Member;

Mrs. Chitralekha Baksi, Member.

5.2. The Committee's proceedings necessitate the presence of a minimum of three members. The Quorum, to be established, requires the Chairperson and a minimum of two members, with the inclusion of a female member;

5.3. If the defendant's representative on the Committee holds a lower rank within the Company compared to the defendant, a higher-ranking individual will take their place for that particular investigation;

5.4. Members of the Committee shall not include any individual who is a complainant, witness, or defendant in the sexual harassment complaint;

5.5. Any Committee member who is accused of sexual harassment in a written complaint is required to resign from their position as a member while the investigation into the complaint is being conducted;

5.6. In the Committee, a minimum of fifty percent of the members shall be women;

5.7. The Committee shall additionally include a third-party Member who is a nominee from a Non-Governmental Organization or an individual well-versed in the subject of Sexual Harassment;

5.8. The Board shall promptly effectuate any required alterations in the composition of the Committee, ensuring utmost efficiency;

5.9. The Rule will determine the length of time for which the Chairperson and Committee members will serve, with a maximum term of three years, commencing from the date of their appointment;

5.10. If the Chairperson or any member of the Committee:

• a) Violates any provision of the Act in conjunction with the stated Rule; or

• b) Has been found guilty of a crime or is currently under investigation for a violation of any current laws, this must be taken into consideration; or

• c) Has been determined culpable in any disciplinary proceedings or has a disciplinary proceeding pending against them; or

• d) Misuse of his authority has reached such an extent that it is detrimental to the welfare of the general public, thereby making it unsuitable for him to remain in his current position.

Then any violation of the Act, in conjunction with the stated Rule, by either the Chairperson or any other member of the Committee shall result in the dismissal of said member. Subsequently, a new nomination process, by the regulations outlined in the Act, shall be initiated to fill the resulting vacancy, be it casual or otherwise.

5.11. The Committee responsible for maintaining good governance within the Organization shall create a report on a quarterly or annual basis. This report will be presented to the Chief Executive Officer, Company Secretary, and Compliance Officer after each year.

6. Submission of Grievance

Any employee, who has experienced sexual harassment, whether directly or indirectly, can choose to submit a written complaint about the incident. This complaint must be presented to the Committee members within three (03) months of the occurrence, along with supporting evidence and pertinent details. The evidence provided should be safeguarded and impervious to tampering, encompassing physical copies of emails, recordings, and specific information about dates, locations, and witnesses involved.

In cases where it is not feasible to submit a written complaint, the Chairperson or any Member of the Internal Complaints Committee will extend their utmost support to the concerned individual to facilitate the conversion of the complaint into a written format.

If the employee who has suffered harm is unable to complain due to physical or mental incapacity, demise, or any other reason, it is permissible for their legal heir or any other individual designated by law to file a complaint within three (03) months from the occurrence of the incident. The classifications of individuals designated by law to file a complaint will differ in the following manner:

1. In cases where the Aggrieved Woman cannot file a complaint due to “Physical limitations”, it is acceptable for individuals falling under these categories to file a complaint on her behalf:

• a) Her relative or friend; or

• b) Her co-worker; or

• c) An officer of the National Commission for Women or State Women’s Commission; or

• d) Any person who knows about the incident, with the written consent of the Aggrieved Woman.

2. If the Aggrieved Woman is unable to file a complaint due to “Mental constraints”, it is permissible for individuals falling into these categories to file a complaint on her behalf:

• a) Her relative or friend; or

• b) A special educator; or

• c) A qualified psychiatrist or psychologist; or

• d) The guardian or authority responsible for overseeing her treatment or care; or

• e) Any individual who possesses information regarding the incident in conjunction with a relative or friend of the Aggrieved Woman, a specialized educator, a certified psychiatrist or psychologist, a guardian, or an authority responsible for her treatment or care.

Annexure I of this Policy outlines the required format for submitting a complaint. This form can be obtained from the Committee or the Human Resource Department of the Organization, as well as from the Organization’s website. Nevertheless, the Committee will also accept written complaints submitted in any other format. Complaints can be submitted electronically to stratbrain@gmail.com or physically to any Committee member. While the Committee may consider oral complaints, it is not obligated to do so under this Policy.

During the investigation and until the resolution of a sexual harassment complaint under this Policy, the Complainant's status, job position, nature of job, compensation, promotion prospects, academic grades, and other relevant factors shall generally remain unaffected. Furthermore, the Organization is obligated not to make any detrimental changes to the terms and conditions of service for the Complainant, Witnesses, or Supporters involved in the complaint process. Such changes should not be imposed as a result of the filing, participation, or conduct of an investigation under this Policy, to safeguard their rights and interests.

The Organization strongly encourages and emphasizes the timely reporting of incidents of Sexual Harassment to ensure that swift and suitable action can be taken. Nevertheless, the Committee recognizes the sensitivity of this issue and the potential emotional consequences it may entail. Hence, if the Complainant presents valid reasons for a delay in reporting, favorable consideration may be granted.

If an employee has encountered Sexual Harassment while working for the Organization but has already resigned, the Committee will consider a written Complaint within three months from the date of employment termination.

If an employee suspects they are facing retaliation in the form of intimidation, coercion to withdraw the case, or threats for reporting, testifying or engaging in the proceedings before the Committee, they should promptly notify the Committee. These occurrences will be handled with the same level of seriousness as a reported case of Sexual Harassment, regardless of whether the initial complaint was filed.

Any attempt, whether direct or indirect, to exert undue influence on the proceedings by any party will be considered as 'Misconduct' and will result in disciplinary measures being taken.

The Committee is responsible for maintaining a register to validate the received complaint and securely store it under the custody of the Human Resource Department of the Organization. The confidentiality of the endorsed complaint in the register shall be strictly upheld unless discreet investigation necessitates its use. The detailed information shall not be shared with anyone except the Legal Team of the Organization.

The Committee is obligated to arrange a meeting with the Complainant within ten working days of receiving the complaint, with a maximum of fifteen working days allowed. In extraordinary circumstances, the Chairperson may call an emergency meeting as necessary.

During the initial meeting, the Committee will listen to the Complainant and document their allegations. Additionally, the Complainant has the option to provide any supporting evidence, whether it be in the form of written or oral corroborative material, to substantiate their complaint. In cases where the Complainant feels uncomfortable narrating the events in person, a female officer will be available to meet with the lady employee(s), while a male officer will be assigned to the male employee(s) who wish to lodge such a complaint, ensuring a comfortable environment for the deposition.

Afterward, the Committee will call upon the individual against whom the Complaint is filed to appear before the Committee for a deposition, providing them with an opportunity to address the allegations. Subsequently, an 'Inquiry' will be carried out and finalized.

If the Committee chooses not to initiate an investigation into a complaint, it must document the rationale behind this decision in the minutes of the Committee meeting and present it to the Board of the Organization. Additionally, the Committee is obligated to provide the Complainant with a written copy of the same.

During an Inquiry, the Committee has the authority to propose the transfer of the employee who has been aggrieved or the individual against whom the complaint has been lodged. Alternatively, the Committee can grant a leave of absence for up to three months (in addition to their regular entitlement) or offer any other form of relief as prescribed by the Organization periodically.

7. Resolution Procedure through Conciliation

Once the complaint is received, the committee can initiate the investigation after implementing appropriate measures to facilitate a resolution between the complainant and the respondent. However, it is essential to highlight that conciliation can only be pursued if explicitly requested by the aggrieved woman. It is imperative to emphasize that no financial settlement can be achieved through this conciliatory procedure.

Upon settling, the committee will duly document and report the outcome to the employer, who will then proceed with the necessary actions. The resolution process through conciliation is expected to be completed within a maximum of two weeks from the date of receiving the complaint.

The committee is responsible for furnishing copies of the settlement to both the complainant and the respondent. Once a settlement has been reached, the committee is not required to conduct any further investigation.

The committee will initiate an inquiry into the following situations:

• i ) There is no plea for reconciliation from the woman who feels aggrieved.

• ii) No settlement has been achieved through the process of conciliation.

• iii) The complainant has brought to the attention of the committee that the respondent has failed to adhere to any of the terms or conditions agreed upon during the conciliation process.

8. Enquiry Process

The Inquiry Committee will promptly initiate the investigation and notify the Complainant and the accused party. The location of the inquiry will be chosen with the utmost consideration for the Complainant's safety and convenience. The Committee ensures the utmost protection and confidentiality for the Complainant and all witnesses, safeguarding their identities with the utmost care.

The Committee is required to diligently prepare and deliver the Statement of Allegation to the individual (him/her) who is the subject of the complaint. Furthermore, the Committee must afford the said individual (him/her) the chance to provide a written explanation, should they wish to do so, within seven working days from the date of receiving the aforementioned statement.

No legal practitioner can represent any party at any stage of the inquiry procedure. The Complainant shall receive a duplicate of the written explanation submitted by the individual accused in the complaint.

If the Complainant or the person against whom a complaint is made wishes to summon any witnesses, they must submit a written request to the Committee, providing the names of the witnesses they intend to call. The responsibility of coordinating with the witnesses, including determining the meeting's date, time, and location, rests with the Complainant or Defendant.

To present any documents as evidence before the Committee, the Complainant (she/he) must provide original copies. Likewise, if the accused party wishes to present any documents as evidence, they must provide original or certified true copies. Both parties must sign the respective documents to certify their authenticity. The Committee is authorized to request official papers or documents related to the complaint being investigated.

The Committee is required to call upon all witnesses mentioned by both the complainant and the accused party. Furthermore, the Committee retains the authority to summon any crucial documents or witnesses at its discretion, if it deems it necessary in the pursuit of justice.

The Committee has a responsibility to guarantee that both the Complainant and the defendant have sufficient opportunities to present and defend their respective cases. Both the complainant and the defendant are entitled to exercise their right to cross-examine all witnesses. Nevertheless, the Committee retains the power to dismiss any inquiries it considers irrelevant, mischievous, slanderous, derogatory, or insensitive towards gender. Additionally, if the defendant or their representative engages in any conduct, whether verbal or otherwise, with the aim of intimidating or causing emotional and physical distress to the complainant or her witness, the Committee is entitled to suggest disciplinary actions against the defendant.

If the Committee determines that the Complainant, Defendant, or their respective witnesses are unable to attend the dispute hearing for valid reasons, the Committee will postpone that specific meeting for a maximum of fifteen working days. Subsequently, the adjourned meeting will proceed, regardless of the absence of the individual in question, provided there was no prior notification or valid justification for their non-appearance.

The Committee may request the defendant, complainant, or any witnesses to provide additional testimony or clarifications as required, without any limitations on the number of times they may be called upon.

The Committee possesses the authority to conclude the proceedings and issue an 'ex-parte' ruling on the complaint if, without justifiable cause, the defendant neglects to appear for three consecutive hearings organized by the Committee.

The Inquiry Committee is required to finalize its investigation within a reasonable timeframe, not exceeding three months from the start date, and submit its findings and recommendations to the Company's Board. If there is any delay in submitting the Inquiry Report, the Committee must provide written reasons for the delay. The Committee's Report will serve as the basis for imposing appropriate disciplinary action on the erring employee by the Board. The Board will adhere to the Organization's Rules while acting on the Committee's Report.

The Committee will ensure that evidence or examination of the aggrieved individual's character, personal life, conduct, and personal and sexual history is not allowed.

The Committee is expected to acknowledge the distinct socio-economic standings of the involved parties, as well as their respective roles within the Organization’s structure.

The rules and guidelines governing the Committee shall align with the prevailing law or regulation, subject to any amendments or enactments made from time to time.

9. Deliberate, Malicious False Allegations

Where the committee determines that the accusation against the respondent is malicious, or if the aggrieved woman or any other individual making the complaint knowingly presents false information or fabricated or misleading documents, it will be considered severe misconduct, and then the Committee may advise the Employer to initiate appropriate actions against the woman or the complainant. The Complainant may face disciplinary action, including permanent termination of services, or as deemed appropriate by the Organization’s Management.

While deciding malicious intent, the committee should consider that mere inability to substantiate a complaint need not mean malicious intent. Malicious intent must be established through a separate inquiry.

10. The Final Decision and Course of Action to be Pursued

If the Committee determines that the defendant has not been proven guilty of the allegation, it shall advise the Board that no further action is necessary. In cases where the Committee establishes an incident of Sexual Harassment, the severity of the offense will be taken into account when recommending appropriate corrective or disciplinary measures to the Organization /Board's Management. The execution of this Policy shall greatly rely on the significant contribution of the Human Resources Department within the Organization.

The Board may consider implementing a diverse range of appropriate measures and actions, including but not limited to disciplinary actions and other corrective measures:

• a) A formal cautionary letter may be dispatched to the employee, with a duplicate meticulously archived in the personal dossier of said individual within the Human Resource Department for future consultation;

• b) Immediate relocation or any other suitable measures to address the situation;

• c) The cessation of increment, whether with or without cumulative impact, should be duly considered;

• d) Implementing various methods can lead to a reduction in rank and responsibility;

• e) Permanent termination, dismissal, or mandatory disconnection in all respects from the Organization's services and association;

• f) The Board may take any other appropriate action as it sees fit;

• g) Submit a complaint to the appropriate statutory, police, or legal authorities.

The Organization’s Board shall extend its utmost support to facilitate the seamless execution of this Policy, ensuring its complete, efficient, and expeditious implementation.

After each fiscal year, the Committee is responsible for examining and presenting regular investigation findings on any grievances received to the Organization’s Board.

Upon receipt of the Inquiry Report, the Board will promptly proceed with appropriate measures by its findings. If the Board holds a different viewpoint or intends to make adjustments to the recommendations put forth by the Committee on Sexual Harassment, it will diligently document the underlying rationale in written form.

The Board will provide the Complainant and the Defendant with a Copy of the Inquiry Report. However, disciplinary action will only be taken by the Board after granting the defendant an opportunity to respond to the Committee's findings.

If the conduct of sexual harassment constitutes a specific offense as defined by the Indian Penal Code, 1860, or any other applicable legislation, it is incumbent upon the Committee to promptly notify the complainant of her entitlement to pursue legal action by the law, with the appropriate authority, and to provide counsel and guidance in this regard. Any such action or proceedings initiated shall be in addition to any proceedings or actions undertaken under this Policy. Furthermore, this Policy shall not impede the Complainant or the individual against whom the complaint was lodged from seeking formal legal remedies or seeking resolution through competent authorities empowered by law or regulation, or through the courts of law in India.

Suitable actions will be implemented based on the gravity and impact of the sexual harassment. Furthermore, alternative methods that do not involve confrontation may be considered to handle and settle such incidents. These may include verbal warnings, apologies, a pledge to better behavior, or counseling, among other options.

The Committee has the authority to propose a heightened penalty for any violation that is repeated or occurs subsequently. The Board's decision shall be deemed conclusive and irrevocable.

The Board of the Organization is empowered to make recommendations for modifying this Policy by its Preamble and Objectives. The Human Resources Department will effectively communicate any changes to all workforces and associates.

11. Implications of Sexual Harassment in the Criminal Justice System

If the Committee concludes that the offense is covered by the Indian Penal Code, it will state this in its report, and the employer will take appropriate measures to file a Police Complaint. The Indian Penal Code (IPC) has recently introduced Section 354A, which pertains to Sexual Harassment, and designates it as a 'cognizable offense', allowing for arrest without a warrant.

12. Petition for Review

In case any party is dissatisfied or feels further aggrieved due to the implementation or non-implementation of the recommendations, they have the right to appeal to the appellate authority as per the Act. This appeal must be made within 90 days from the date of communication of the recommendations.

13. Awareness & Prevention Action

The Organization will implement necessary measures to safeguard against incidents of sexual harassment in the workplace, such as disseminating relevant policies and pertinent information to all workforces and associates, including newly hired individuals.

Facilitate the organization of awareness sessions with the purpose of:

• Develop and extensively circulate an internal policy, charter, resolution, or declaration that prohibits, prevents, and addresses sexual harassment in the workplace. This initiative aims to foster gender-sensitive safe spaces and eliminate the root causes of a hostile work environment that negatively impacts women.

• Arrange orientation programs and seminars to ensure the Internal Committee members are well-informed and equipped to carry out their duties effectively.

• Organize training sessions to enhance the capabilities and expertise of the Internal Committee Members.

• The names and contact details of all the members of the Internal Committee will be officially announced.

• Employ modules formulated by State Governments to organize workshops and awareness campaigns targeted at familiarizing employees with the provisions of the Act.

14. Implementation and Review of Policies

The implementation and review of the Policy will be carried out by the Human Resources Department of the Organization. The Board retains the authority to alter, revoke, adjust, or reinstate the entire policy or any portion of it at any given moment.

15. Interpretation of the Code

For any questions or clarifications regarding this Code of Ethics and Business Conduct, the Organization’s Human Resources Department will assume the responsibility of addressing them.

16. Revise and Amendment of the Code

Any changes made to the provisions of the Act will be included in this Policy after obtaining the necessary approval from the Board periodically. Once approved by the Board, the revised Policy will be communicated to all workforce and associates of the Organization.

17. The Violation of the Code

In the event of any possible violations of this Policy, it is imperative to notify either the Board Chairman or the Organization's management. All reported violations must undergo a comprehensive investigation. It is crucial to obtain prior authorization for any exemption from this Policy.

18. The Code's Publication

The newly adopted Policy and any subsequent amendments shall be published/posted on the Organization's website of the Organization.

19. Instructions for General Use

Any information about conciliation and inquiry proceedings, recommendations of the Committee, and subsequent actions shall remain confidential, and must not be disclosed, shared, or disseminated to the general public or the press in any form.

Disciplinary measures will be implemented as per the company's policy if the individual responsible for managing complaints, inquiries, or proposed actions fails to comply.

20. Annexure I of this Policy Outlines the Required Format for Submitting a Complaint.

Complaint Sheet (Attached herewith)

[Under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013 & Anti – Sexual Harassment Policy of STRATEGIC-BRAIN]

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