COMMITMENT:

This Policy is applicable to all AegisCovenant employees, irrespective of their designation and role.

AegisCovenant expressly prohibits any form of unlawful employee harassment based on race, color, religion, gender,

sexual orientation, gender identity, national origin, age, disability, genetic information, marital status, amnesty or

status as a covered veteran or any other classification in accordance with law. Improper interference with the ability

of AegisCovenant employees to perform their expected job duties is strictly prohibited and not tolerated.

AegisCovenant is committed to a work environment in which all individuals are treated with respect, dignity and

protected from all forms of harassment. Everyone has the right to work in a professional atmosphere that promotes

equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore,

AegisCovenant expects that all relationships among persons in the office will be business-like and free of bias,

prejudice and harassment.

AegisCovenant encourages reporting of all perceived incidents of discrimination or harassment. It is the policy of

AegisCovenant to promptly and thoroughly investigate such reports. AegisCovenant prohibits retaliation against any

individual who reports discrimination or harassment or who participates in an investigation of such reports.

Management is committed to providing a work environment that ensures every employee is treated with dignity

and respect and afforded equitable treatment. Should a female employee experience harassment, they are to be

encouraged to report this immediately to any member of the Internal Complaints Committee, without fear or

favour, and be provided with protection against repetition, retribution, or victimisation as a consequence.

The Company strictly prohibits, and it will not tolerate any form of sexual harassment and is committed to take al

necessary steps to ensure that its employees are not subjected to any form of harassment.

SCOPE:

The objective of this policy is to provide protection against sexual harassment of employees within but not limited

to the office premises and for prevention and redressal of complaints of sexual harassment and for matters

connected there with or incidental thereto, as per the provisions of The Sexual Harassment of Women at

Workplace (Prevention, Prohibition and Redressal) Act, 2013 (as amended up-to-date).

The policy will ensure that employees are protected against sexual harassment at all the work places, be it in public

or private. This will contribute to realization of their right to gender equality, life and liberty and equality in working

conditions. The sense of security at the workplace will improve employee's participation in work, resulting in their

empowerment and inclusive growth.

This policy applies to all employees of all categories (full-time, part-time, trainees and those engaged on contract) of

the Company including all outstation employees.

The workplace includes:

1. All offices or other premises where the Company's business is conducted.
2. All company related activities performed at any other site away from the company's premises.
3. Any social, business or other functions where the conduct or comments may have an adverse impact on the workplace or workplace relations.

HARASSMENT:

Harassment may be of the following types:

a. Sexual Harassment: Harassment for this purpose includes but is not limited to unwelcome behaviour (whether it is directly or by implication), This includes:

i. Sexual advances (verbal, visual, or physical or online).

i. Inappropriate physical contact, advances or threats.

ii. epithets, derogatory or suggestive comments, slurs or gestures and offensive posters, cartoons, pictures, or

drawings.

iv. Inappropriate verbal comments of an indecent, inappropriate or sexual nature which have the purpose or

effect of unreasonably interfering with an individual's work performance, or result in creating a hostile or

threatening working environment.

b. Physical harassment would include:

i. Inappropriate physical contact, advances or abuse.

ii. Touching another employee's body deliberately or indulging in physical movement that is known in all

probability would entail touching another employee's body in an unwelcome manner.

iii. Threatening reprisals for an employee's refusal to respond to requests for sexual favours or for reporting

a violation of this Policy.

c. Visual harassment / online harassment would include:

i. Showing, or allowing to see pornographic or indecent materials.

ii. A demand made by any employee directed to any other employee for the granting of sexual favours to that

employee, in order to gain or retain certain job benefits or the job itself.

iii. Inappropriate and unwelcome visual actions of indecent and sexual nature that violate another's sense of

dignity, morals, ethics.

d. Verbal harassment would include:

i. Demands, comments or requests for sexual favours.

ii. Sexually coloured remarks or comments.

iii. A suggestion that an employees' or applicants' employment or advancement will be contingent upon a

personal relationship or providing inappropriate favours outside of the scope of their position.

The following circumstances, among other circumstances, if it occurs or is present in relation to or connected with any act or behavior of sexual harassment:

1. Implied or explicit promise of preferential treatment in her employment.
2. Implied or explicit threat of detrimental treatment in her employment; or
3. Implied or explicit threat about her present or future employment status; or
4. Interference with her work or creating an intimidating or offensive or hostile work environment for her.
5. Humiliating treatment is likely to affect her health or safety. An essential feature of sexual harassment is that unwanted by the recipient. It is for individual recipients to determine what behaviour is acceptable to them and what they regard as unwelcome or offensive.

COMPLAINT:

Individuals who believe they have been the victims of conduct prohibited by this policy statement or who believe

they have witnessed such conduct and should discuss their concerns with their internal Committee.

AegisCovenant encourages the prompt reporting of complaints or concerns so that rapid and constructive action

can be taken immediately.

Any reported allegations of harassment, discrimination or retaliation will be investigated promptly. The investigation

may include individual interviews/examination of the parties involved and, where necessary, with individuals who

may have observed the alleged conduct or may have other relevant knowledge.

Confidentiality will be maintained throughout the investigatory process to the extent consistent with adequate

investigation and appropriate corrective action.

Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of

a claim of harassment or discrimination is a serious violation of this policy and, like harassment or discrimination

itself, will be subject to disciplinary action. Acts of retaliation should be reported immediately and will be promptly

investigated and addressed. Misconduct constituting harassment, discrimination or retaliation will be dealt with

appropriately.

RESPONSIBILITIES REGARDING SEXUAL HARASSMENT:

All employees of the Company have a personal responsibility to ensure that their behaviour is not contrary to this

policy. All employees are encouraged to reinforce the maintenance of a work environment free from sexual

harassment.

COMPLAINT MECHANISM:

An appropriate complaint mechanism in the form of "Complaints Committee" has been created in the Company for

time- bound redressal of the complaint made by the victim.

Internal Committee (Internal Committee):

The Company has instituted a Complaints Committee for redressal of sexual harassment complaints (made by the

victim) and for ensuring time bound treatment of such complaints.

Complaints Committee will comprise of the following 6 members.

Following are the name and detail of the Internal Complaint Committee Members of the AegisCovenant Private

Limited:

The Complaints Committee is responsible for:

• Investigating every formal written complaint of sexual harassment.
• Taking/suggesting appropriate remedial measures to respond to any substantiated allegations of sexual harassment.
• Discouraging and preventing employment-related sexual harassment.

PROCEDURES FOR RESOLUTION, SETTLEMENT OR PROSECUTION OF ACTS OF SEXUAL HARASSMENT:

The Company is committed to providing a congenial environment to resolve concerns of sexual harassment as

under:

Complaints:

An employee with a harassment concern, to make a formal complaint to the member or the Internal Committee

and/or Presiding Officer of the Complaints Committee constituted by the Management. The complaint shall be in

writing and can be in form of a letter, and shall also be sent at email ld- posh@aegiscovenant.com submitted

preferably within three months from the date of the incident and in case of a series of incidents, within a period of

three months from the date of the last incident. Further, where such a Complaint cannot be made in writing, the

Presiding Officer or any member of the Internal Complaint Committee shall render all reasonable assistance to the

complainant for making the complaint in writing.

Complaints against any member of the Complaints Committee or employee in Strategic Job should be sent directly

to the presiding officer or to the employer directly if you are not comfortable with the presiding office.

The Internal Committee may, before initiating an inquiry and at the request of the complainant, take steps to settle

the matter between her and the respondent (the individual against whom the complaint is filed) through conciliation.

The Internal Committee will go through the details of the Complaint and determine whether there is a prima facie

case or not. While conducting the inquiry the Internal Committee will keep in mind that the proceedings are

conducted strictly in accordance with the principles of natural justice. Thus, sufficient time will be granted to the

parties to submit their version before the Internal Committee.

In the event the allegation does not fall under the purview of Sexual Harassment or does not constitute an offence

of Sexual Harassment, the Presiding Officer and the two members will record this finding with reasons and

communicate the same to the complainant.

If the Presiding Officer of the Complaints Committee determines that the allegations constitute an act of sexual

harassment, he/ she will proceed to investigate the allegation with the assistance of the Complaints Committee.

Thereafter, the Internal Committee shall send one copy of the complaint (including list of documents, and names

and addresses of witnesses) received from the Complainant to the Respondent, within a period of seven working

days. The Respondent shall file their reply to the complaint along with their list of documents and names and

addresses of witnesses, within a period not exceeding 10 working days from the date of receipt of the documents.

but not exceeding ten working days from the date of receipt of the documents.

Where such conduct, on the part of the accused, amounts to a specific offence under the law, the Company shall

initiate appropriate action in accordance with law by making a complaint with the appropriate authority.
The Complaints Committee shall conduct such investigations in a timely manner and shall submit a written report

containing the findings and recommendations on action to be taken to CEO/ MD &/or coo within 90 days plus 10

days from the date of receipt of the complaint. The CEO/MD/C00, Head-HR of the Company will jointly take decision on the corrective action based on the recommendations of the Complaints Committee and keep the complainant informed of the same.

Corrective action may include any of the following:

1. Formal written apology and counselling
2. Written warning with a copy of it maintained in the employee's file.
3. Change of work assignment /transfer.
4. Suspension or termination of services.
5. Withholding of promotion
6. Demotion
7. Withholding of pay rise or increment
8. Carrying out community service
9. Awarding compensation to the complainant

In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for appropriate disciplinary

action by the Management.

In case the complaint is against the Internal Committee member, the respective member will not take part in the

proceedings.

CONFIDENTIALITY:

The Company understands that it is difficult for the victim to come forward with a complaint of sexual harassment

and recognizes the victim's interest in keeping the matter confidential.

To protect the interests of the victim, the respondent and others who may report incidents of sexual harassment;

confidentiality will be maintained throughout the investigatory process to the extent practicable and appropriate

under the circumstances.

ACCESS TO REPORTS AND DOCUMENTS:

All records of complaints, including contents of meetings, results of investigations and other relevant material will

be kept confidential by the Company except where disclosure is required under disciplinary or other remedial

processes.

PROTECTION TO COMPLAINANT / VICTIM:

The Company is committed to ensuring that no employee who brings forward a harassment concern is subject to

any form of reprisal. Any reprisal will be subject to disciplinary action.

The Company will ensure that the victim or witnesses are not victimized or discriminated against while dealing with

complaints of sexual harassment.

However, anyone who abuses the procedure (for example, by maliciously putting an allegation knowing it to be

untrue) will be subject to disciplinary action.

CONCLUSION:

In conclusion, the Company reiterates its commitment to providing its employees a workplace free from

harassment/ discrimination and where every employee is treated with dignity and respect.