Ethika Insurance Broking Private Limited

Policy on Prevention of Sexual Harassment at the Workplace

(PoSH Policy)

In compliance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the Rules thereunder

1. Objective and Policy Statement

Ethika Insurance Broking Private Limited (the “Company” or the “Organization”) is committed to maintaining ethical and professional standards in its workplace and business dealings and to offering equal employment opportunity to all. The Company is committed to a healthy working environment in which every person can work without fear of prejudice, gender bias or sexual harassment and is treated with dignity and respect.

Sexual harassment is unlawful conduct that undermines the integrity of the employment relationship. It is unacceptable, and the Company will not tolerate any form of such conduct. Sexual harassment is a grave offence. The Company treats it as misconduct that is punishable under this Policy and under applicable law. The Company shall take all necessary steps to ensure that no person at its workplace is subjected to sexual harassment, and any violation of this Policy may result in disciplinary and legal action.

2. Legal Framework

This Policy is framed under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the Rules made thereunder (“the Act”), and gives effect to the Company’s obligations under the Act and to the directions of the Supreme Court of India on the subject, including in Aureliano Fernandes v. State of Goa & Ors. It also reflects the Company’s constitutional commitment to equality and dignity under Articles 14, 15 and 21 of the Constitution of India.

The Internal Committee shall also be governed by such directions as may be issued by the Supreme Court or by any legislation enacted on the subject. In the event of any inconsistency between this Policy and the Act, the provisions of the Act shall prevail.

3. Coverage, Applicability and Gender

This Policy applies to all categories of persons at the Company’s workplace, irrespective of gender, gender identity or sexual orientation, including any person employed on a regular, temporary, ad hoc or daily-wage basis, whether directly or through an agent or contractor, whether for remuneration or not, and including co-workers, contract workers, probationers, trainees, apprentices, consultants and volunteers, at the workplace or at client sites.

Gender-neutral application. The Company adopts a gender-neutral standard of conduct: no person at the workplace shall subject any other person to sexual harassment, and every person is entitled to a workplace free from it. A complaint of sexual harassment made by a woman shall be inquired into under the Act. A complaint made by a person of any other gender shall be dealt with under the Company’s Code of Conduct and service rules, which shall have jurisdiction over such complaints, as the Act does not presently extend statutory rights to persons other than women. The Internal Committee shall handle such non-statutory complaints, applying the same principles of fairness, natural justice, confidentiality and protection from retaliation set out in this Policy.

4. Definitions

For the purpose of this Policy:

• “Workplace” includes all offices and premises where the Company’s business is conducted, all Company-related activities performed at any other site, client sites, any place visited by a person arising out of or during the course of employment, transport provided by the Company, off-site events, and all virtual or digital spaces such as email, telephone and video calls, messaging applications and social media used for or in connection with work.
• “Aggrieved person” means a person who alleges to have been subjected to any act of sexual harassment.
• “Complainant” means the aggrieved person, or a person filing a complaint on their behalf as permitted under this Policy.
• “Respondent” means the person against whom a complaint of sexual harassment is made.
• “Employee” means any person on the rolls of the Company, including those on deputation, contract, temporary or part-time engagement, probationers, trainees, apprentices and consultants.
• “Third party” or “visitor” means any person at the workplace who is not an employee, such as a client, vendor or guest.
• “Internal Committee” or “IC” means the committee constituted by the Company under Section 4 of the Act to receive, inquire into and redress complaints of sexual harassment at the workplace.

5. What Constitutes Sexual Harassment

Sexual harassment includes any one or more of the following unwelcome acts or behaviour, whether committed directly or by implication:

• unwelcome physical contact and advances;
• a demand or request for sexual favours;
• sexually coloured remarks;
• showing pornography; and
• any other unwelcome physical, verbal, non-verbal or digital conduct of a sexual nature, including through email, messaging applications, calls, video conferencing, social media, memes, GIFs or cyberstalking.

Sexual harassment also arises where any such conduct is linked to:

• an implied or explicit promise of preferential treatment in employment;
• an implied or explicit threat of detrimental treatment in employment, or about present or future employment status; or
• interference with work, or the creation of an intimidating, hostile, offensive or humiliating work environment, or humiliating treatment likely to affect health or safety.

The following are illustrative examples of conduct that, depending on the circumstances, may amount to sexual harassment or contribute to a hostile work environment: sexual pranks or repeated sexual teasing, jokes or innuendo; verbal abuse of a sexual nature; touching or grabbing of a sexual nature; repeatedly standing too close to or brushing against a person; repeatedly asking a person to socialise after they have declined; giving gifts or leaving objects that are sexually suggestive; repeatedly making sexually suggestive gestures; posting sexually demeaning or offensive material in the workplace; and off-duty conduct of a sexual nature that affects the work environment.

6. Internal Committee – Constitution, Tenure and Removal

The Company has constituted an Internal Committee (IC) to consider and redress complaints of sexual harassment. The Committee comprises:

• a Presiding Officer, who shall be a woman employed at a senior level at the workplace;
• not less than two Members from amongst the employees, preferably committed to the cause of women or having experience in social work or legal knowledge; and
• one external Member from a non-governmental organisation or association committed to the cause of women, or a person familiar with issues relating to sexual harassment.

At least one-half of the total Members of the Committee shall be women. The presence of the external Member is mandatory for the valid constitution of the Internal Committee; however, for the conduct of an inquiry the quorum shall be a minimum of three Members, including the Presiding Officer. Members shall hold office for a term not exceeding three years from the date of their nomination.

A Member shall be removed from the Committee where they breach confidentiality; are convicted of, or have an inquiry pending against them for, any offence under any law in force; are found guilty in any disciplinary proceeding, or have such a proceeding pending; or have so abused their position as to render their continuance prejudicial to the public interest. Any manager or supervisor who becomes aware of a complaint, or of conduct that may amount to sexual harassment, shall promptly inform the Internal Committee.

The current composition of the Internal Committee is as follows:

In addition to handling complaints, the Committee shall carry out preventive activities to create a harassment-free workplace, including circulating this Policy, organising campaigns and workshops for all employees, including new joiners, and conducting training at regular intervals at all business locations.

7. Complaint

7.1 Time limit for making a complaint

A complaint of sexual harassment must be made to the Internal Committee within three months from the date of the incident and, where it relates to a series of incidents, within three months from the date of the last incident. The Committee may, for reasons to be recorded in writing, extend this period by a further period of up to three months where it is satisfied that circumstances prevented the complainant from filing within time.

7.2 Manner of making a complaint

A complaint may be submitted to any Member of the Internal Committee in writing, in physical form or by email to posh@ethika.co.in. Where the complainant is unable to make the complaint in writing on account of physical or mental incapacity or otherwise, the Presiding Officer or any Member of the Committee shall render all reasonable assistance to put the complaint in writing.

7.3 Complaint on behalf of the aggrieved person

Where the aggrieved person is unable to make a complaint on account of physical incapacity, mental incapacity, death or for any other reason, the complaint may be made on their behalf by a person specified under Rule 6 of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013, including:

• a relative, friend or co-worker;
• an officer of the National Commission for Women or the State Women’s Commission;
• a special educator, or a qualified psychiatrist or psychologist;
• the guardian or authority under whose care the aggrieved person is receiving treatment or care;
• any person who has knowledge of the incident, with the consent required under Rule 6; or
• in the event of the death of the aggrieved person, the legal heir, in accordance with Rule 6.

8. Conciliation

Before initiating an inquiry, the Internal Committee may, at the written request of the complainant, take steps to settle the matter between the complainant and the respondent through conciliation, provided that no monetary settlement shall be made the basis of such conciliation. Where a settlement is reached, the Committee shall record the settlement, forward copies to the complainant and the respondent, and conduct no further inquiry. Where no conciliation is requested, no settlement is reached, or the complainant informs the Committee that a term of the settlement has not been complied with, the Committee shall proceed to inquire into the complaint.

9. Inquiry into the Complaint

9.1 Procedure and timelines

Where conciliation is not requested, or a settlement is not reached, the Internal Committee shall proceed to inquire into the complaint in accordance with the principles of natural justice. The Committee shall investigate all complaints promptly and objectively, without pre-judgment. In the course of the inquiry, the Committee shall:

• forward a copy of the complaint to the respondent within seven working days;
• require the respondent to file a reply, together with any supporting documents and the names of witnesses, within ten working days of receiving the complaint;
• provide the complainant and the respondent a reasonable opportunity of being heard and of presenting and defending their case, and call the witnesses named by both parties;
• complete the inquiry within ninety days; and
• submit its report of findings and recommendations to the employer within ten days of completion of the inquiry, and make it available to both parties.

No party shall be allowed to bring in a legal practitioner to represent them before the Committee. The inquiry shall be conducted in English or the local language, as requested by the respondent. Where the complainant or the respondent fails, without sufficient cause, to attend three consecutive hearings, the Committee may, after giving fifteen days’ written notice, terminate the inquiry or proceed to give an ex-parte decision; no such decision shall be taken without giving that notice.

9.2 Powers of the Committee

For the purpose of an inquiry, the Internal Committee shall have the same powers as are vested in a civil court under the Code of Civil Procedure, 1908 in respect of summoning and enforcing the attendance of any person and examining them on oath, requiring the discovery and production of documents, and recording statements, which shall be signed by the person making them. All documents tendered to the Committee shall be taken on record.

10. Interim Relief during Pendency of the Inquiry

During the pendency of an inquiry, the Internal Committee may, on the written request of the complainant, recommend to the employer to:

• transfer the complainant or the respondent to another workplace;
• grant the complainant leave of up to three months, in addition to their normal leave entitlement;
• restrain the respondent from reporting on the work performance of the complainant or writing their confidential report, and assign that responsibility to another person; or
• direct the respondent not to contact the complainant.

Wherever possible during the inquiry, the Company will try to ensure that the complainant and the respondent are not required to work together. The final decision on any interim relief rests with the Committee and the Company.

11. Findings, Outcomes and Action

On completion of the inquiry, the Internal Committee shall record one of the following findings: that the allegation is upheld; that it is not upheld; that the complaint was malicious or false; or that the evidence is inconclusive. The report shall specify the charges, the evidence, and the reasons for the Committee’s decision.

Where the Committee concludes that the respondent has engaged in sexual harassment, it shall recommend appropriate action to the employer, irrespective of the respondent’s status in the Organization. Disciplinary action shall be initiated by Human Resources within sixty days of receiving the recommendations, and may include a written warning, withholding of increment or promotion, transfer, suspension, or termination of service, together with, where the conduct amounts to an offence, a complaint to the appropriate authority under the Bharatiya Nyaya Sanhita, 2023 or any other applicable law. Where the Committee concludes that the conduct does not constitute sexual harassment under this Policy, it shall record its reasons and recommend closure, and the employer may, where appropriate, take action under the applicable Code of Conduct or service rules.

12. Compensation to the Complainant

Where a complaint is upheld, the Committee may recommend that the employer deduct from the salary or wages of the respondent such sum as it considers appropriate to be paid to the complainant, or that it be recovered as an arrear of land revenue where the respondent cannot pay. In determining the amount, the Committee shall have regard to the mental trauma, pain, suffering and emotional distress caused to the complainant; the loss of career opportunity; medical expenses incurred; the income and financial status of the respondent; and the feasibility of payment as a lump sum or in instalments.

13. False or Malicious Complaint and False Evidence

Where the Committee concludes that a complaint is malicious or false, or that any witness has given false evidence or produced a forged or misleading document, it may recommend action against the person concerned in accordance with the applicable service rules, which may include a written warning, suspension or termination of service. A mere inability to substantiate a complaint, or to provide adequate proof, shall not by itself attract action against the complainant; malicious intent must be established through an inquiry conducted in accordance with the prescribed procedure before any such action is recommended.

14. Confidentiality

The Company recognises the complainant’s interest in keeping the matter confidential. This Policy and the law prohibit any person, including Committee Members, from publishing or making known to the public or the media the contents of the complaint; the identity and addresses of the aggrieved person, the respondent or witnesses; any information relating to conciliation or inquiry proceedings; or the recommendations of the Committee. All records of complaints, meetings, investigations and related material shall be kept confidential, except where disclosure is required under disciplinary or other remedial processes. Any person violating this clause shall be subject to disciplinary action and a fine of INR 5,000 (Rupees Five Thousand only). All Committee Members and witnesses shall sign a confidentiality declaration.

15. Protection from Retaliation

The Company shall ensure that the complainant, the witnesses and the Members of the Internal Committee are not victimised, disadvantaged or discriminated against on account of their involvement in a complaint or inquiry. Any retaliation, pressure, intimidation or unfair treatment directed at any such person shall itself be treated as misconduct attracting disciplinary action and, where necessary, legal action. Any person who abuses the procedure shall be subject to disciplinary action.

16. Appeal

Any person aggrieved by the recommendations of the Internal Committee, or by the non-implementation of such recommendations, may prefer an appeal to the court or tribunal in accordance with the provisions of the Act within ninety days of the recommendations being communicated. Where a complaint falls outside the scope of the Act, the matter, and any appeal, shall be dealt with in accordance with the Company’s Code of Conduct, service rules or other applicable internal policies.

17. Duties of the Employer and Prevention

The Company shall:

• provide a safe working environment, including safety from persons coming into contact at the workplace, and foster a culture in which harassment is known to be unacceptable and in which individuals are confident to bring complaints without fear of ridicule or reprisal;
• display, at conspicuous places in the workplace, the penal consequences of sexual harassment and the order constituting the Internal Committee;
• organise regular workshops and awareness programmes to sensitise employees to this Policy, and orientation and skill-building programmes for the Members of the Committee;
• provide the Committee with the facilities and assistance necessary to conduct the inquiry, and assist in securing the attendance of the respondent and witnesses;
• assist any person who wishes to file a complaint in relation to an offence under the Bharatiya Nyaya Sanhita, 2023 or any other law, and treat sexual harassment as misconduct under the service rules;
• encourage bystander intervention, so that a person who witnesses harassment supports the affected person and may bring the matter to the attention of the Committee where the aggrieved person is unwilling to do so;
• communicate this Policy to all employees, contractors and consultants, and monitor the timely submission of reports by the Committee; and
• maintain records of complaints and inquiries and, where it deems fit, provide affected persons with access to counselling.

17.1 SHe-Box and Nodal Officer

The Company shall register its Internal Committee on the Government’s SHe-Box portal (shebox.wcd.gov.in), appoint a Nodal Officer to receive and route complaints and to coordinate reporting on the portal, and publish the composition of the Internal Committee and the complaint procedure on the Company’s internal channels. A complaint filed on SHe-Box is routed to the Internal Committee and does not replace the statutory inquiry, which the Committee must complete within ninety days.

18. Duties of Employees

Every person at the workplace has a personal responsibility to ensure that their behaviour is not contrary to this Policy, to comply with it, and to reinforce the maintenance of a work environment free from sexual harassment. Managers and supervisors are responsible for being alert to harassment and for promptly bringing any complaint or relevant conduct to the attention of the Internal Committee.

19. Annual Report and Board’s Report Disclosure

The Internal Committee shall prepare, in each calendar year, an annual report and submit it to the employer and to the District Officer, stating the number of complaints of sexual harassment received during the year, the number disposed of, the number of cases pending for more than ninety days, the number of workshops and awareness programmes conducted, and the nature of the action taken by the employer.

The Company shall also include in its Board’s Report, in accordance with Section 134 of the Companies Act, 2013 and the Companies (Accounts) Rules, 2014 as amended by the Companies (Accounts) Second Amendment Rules, 2025 (effective 14 July 2025) – except where the Company qualifies as a One Person Company or a small company – a statement confirming that it has constituted an Internal Committee under the Act, together with the number of complaints of sexual harassment received, disposed of and pending for more than ninety days during the year, the gender composition of the workforce, and an affirmation of compliance with the applicable provisions of the Maternity Benefit Act, 1961.

20. Policy Implementation and Review

This Policy shall be implemented and reviewed by the Internal Committee, in coordination with Human Resources, at least once every year and earlier upon any change in the applicable law, so as to keep it current and compliant. The Company reserves the right to amend, modify, rescind or reinstate the whole or any part of this Policy at any time. In conclusion, the Company reiterates its commitment to providing all persons at its workplace with a safe environment free from harassment and discrimination, in which every person is treated with dignity and respect.

Annexure A – Complaint Format

(To be submitted to any Member of the Internal Committee, in physical form or by email to posh@ethika.co.in. All information provided will be kept strictly confidential. Where the complainant is unable to put the complaint in writing, a Member of the Committee will assist in doing so.)

Declaration: I confirm that the information given above is true and correct to the best of my knowledge and belief.