POLICY FOR PREVENTION OF SEXUAL HARASSMENT OF WOMEN AT WORKPLACE

1. INTRODUCTION
   
   RANKGURU TECHNOLOGY SOLUTIONS PRIVATE LIMITED and or any of its subsidiaries or affiliates under its control, as may be applicable from time to time (hereafter referred to as the “Company”) is committed to provide a work environment that ensures every employee and representative associated with the Company is treated with dignity and respect and afforded equitable treatment. Company is also committed to promote a work environment that is conducive to the professional growth of its employees and representatives, and encourages equality of opportunity. The Company will not tolerate any form of sexual harassment of women and is committed to take all necessary steps to ensure that any woman, whether an employee of company or not, is not subjected to any form of sexual harassment. As part of this commitment, the Company has adopted this Policy for Prevention of Sexual Harassment in accordance with the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 of India and the rules framed thereunder (hereinafter collectively referred to as "PoSH Law"). For the avoidance of doubt, “Company” means and includes Rankguru Technology Solutions Private Limited, or any of its subsidiaries or affiliates under its control, as may be applicable from time to time.
2. SCOPE
   This policy applies to all categories of employees and representatives of the Company, including permanent employees, Company management and workmen, temporary employees, trainees, and employees on contract at its workplace or at client sites, suppliers or any other person associated with Company (hereinafter collectively referred to as “Representatives”). The Company will not tolerate sexual harassment of women in any form or manner, engaged in by any of the Representatives.
   
   The workplace includes:
   1. All offices or other premises where the Company’s business is conducted, including virtual spaces, e.g., remote working and work from home instances.
   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 of any of the Representatives may have an adverse impact on the workplace or workplace relations.
   4. Any place visited by the Representatives arising out of or during the course of their association with the Company, including transportation by the Company for undertaking such journey.
3. DEFINITION OF SEXUAL HARASSMENT
   What is Sexual Harassment?
   Sexual Harassment includes such unwelcome sexually determined behaviour, as physical contacts and advances, sexually coloured remarks, showing pornography and sexual demands whether by words, gestures or actions. Such conduct can be humiliating and may constitute a health and safety problem. It is discriminatory when the woman complainant has reasonable grounds to believe that her objection would disadvantage them in connection with employment, including recruiting or promotion or when it creates a hostile working environment. Sexual harassment includes such unwelcome sexually determined behaviour made towards a woman (whether directly or by implication) as follows:
   
   
   1. Physical contact and advances;
   2. A demand or request for sexual favours;
   3. Sexually colored remarks;
   4. Showing pornography;
   5. Unwelcome sexual advances involving verbal, non-verbal, or physical conduct such as sexually coloured remarks, jokes, letters, phone calls, e-mail, gestures, showing of pornography, lurid stares, physical contact or molestation, stalking, sounds, display of pictures, signs, verbal or non-verbal communication which offends the individuals sensibilities and affect her/his performance.
   6. Eveteasing, innuendos and taunts, physical confinement against one’s will and likely to intrude upon one’s privacy;
   7. Act or conduct by a person in authority which creates the environment at workplace hostile or intimidating to a person belonging to the other sex;
   8. Conduct of such an act at work place or outside in relation to an employee or Representative of Company or vice versa during the course of employment or association with Company; and
   9. any unwelcome gesture by an employee or Representative having sexual overtones.
      Sexual harassment is emotionally abusive and creates an unhealthy, unproductive atmosphere for women at the workplace. Sexual harassment cases can be classified into two categories: - quid pro quo and creation of a hostile working environment.
      1. Under the quid pro quo (meaning - this for that) form of harassment, a person or authority, usually the superior of the aggrieved woman, demands sexual favours for getting or keeping a job benefit and threatens to terminate the aggrieved woman if the conditions are not met.
      2. A hostile work environment arises when a co-worker or supervisor creates a work environment through verbal or physical conduct that interferes with a woman’s job performance or creates the workplace atmosphere which is intimidating, hostile, offensive or humiliating and experienced as an attack on personal dignity. For example: an employee tells offensive jokes. No person shall indulge or cause to be indulged under instructions from his/her superior in sexual harassment of any woman. However, a woman employee or Representative who is sexually harassed can complain about the same even if there is no adverse job consequence as set out below.
4. COMPLAINT PROCEDURE
   Whether or not such conduct constitutes an offence under law and a breach of the employment rules, an appropriate complaint mechanism in the form of Internal Complaints Committee has been created in the Company for time-bound redressal of the complaint made by the complainant. Company will ensure that the complainant will not suffer adverse job consequences as a result of any complaint being made.
   
   Complaints Committee: The Company has formed an Internal Complaints Committee for redressal of harassment complaints and for ensuring time bound treatment and resolution of such complaints. Initially, and till further notice, the Internal Complaints Committee will comprise a minimum of four members as mentioned below, provided that at least half of the members shall be women:
   
   
   1. Chairperson – Woman employee
   2. Member - Employee
   3. Member – Employee
   4. Member – a person from NGO / social worker / person having knowledge of sexual harassment issues, e.g., an advocate. (To be appointed by the person nominated by the Company’s Board of Directors for the purpose).
      
      The Internal Complaints Committee is responsible for investigating every formal written complaint of harassment, taking appropriate remedial measures to respond to any allegations of harassment, and discouraging and preventing any harassment at work place.
      
      Procedures for Resolution, Settlement of Acts of Harassment: The Company is committed to providing a supportive environment in which to resolve concerns of harassment as under:
      
      Conciliation: Upon receipt of a written request from the aggrieved woman, the Internal Complaints Committee may, before initiating an inquiry pursuant to a complaint received from the aggrieved woman, take reasonably necessary steps to settle the matter between the aggrieved woman and the accused through conciliation, provided that no monetary settlement shall be made as a basis of conciliation.
      
      Procedure for complaints in occurrence of sexual harassment:
      
      1. An aggrieved woman employee or Representative with a harassment concern, may make a formal complaint to the Chairperson or any member of the Internal Complaints Committee. The aggrieved woman should make a complaint within three months from the date of occurrence of the event or in a case of series of incidents, within a period of three months from the date of the last occurrence. The Internal Complaints Committee may, for reasons to be recorded in writing, extend the time limit not exceeding three months, if it is satisfied that the circumstances were such which prevented the aggrieved woman from filing a complaint within the said period.
      2. The complaint should be submitted in writing for it to be considered as formal and for the committee to probe and take the necessary actions. The aggrieved woman may submit the complaint in the form of an email to posh@infinitylearn.com, or a written letter duly signed by the aggrieved woman and submitted in a sealed envelope to the Chairperson/Member of Internal Complaints Committee. Alternatively, the aggrieved woman may also send in a written communication through email to the Chairperson/Member of Internal Complaints Committee. The aggrieved woman should disclose their name, department, date of occurrence, place of occurrence in the complaint letter. The composition of the Internal Complaints Committee as on the date of last update of this policy is set forth in Annexure 1 hereto, and is subject to change from time to time.
      3. If any complaints are received by any of the members of the Internal Complaints Committee, such member is obliged to bring it to the notice of the Chairperson within three (3) working days from the receipt of the complaint.
      4. The Internal Complaints Committee should meet within seven (7) working days from the date of receipt of the complaint by the Chairperson to decide on the proceedings and the course of investigation.
      5. A quorum of three (3) members is required to be present for the proceedings to take place. The quorum shall include the Chairperson and at least two members, one of whom shall be a woman.
      6. Once the complaint is received by the Internal Complaints Committee, the alleged accused should be informed regarding the complaint. It should also be made clear that no act of retaliation or unethical action by the accused shall be tolerated and that the accused should extend full support and co-operation during the investigation of the complaint.
      7. The Internal Complaints Committee shall ensure that a fair and just investigation is undertaken immediately.
      8. Both the aggrieved woman and the alleged accused will be questioned separately by the Internal Complaints Committee with a view to ascertain the authenticity of their contentions.
      9. Witnesses named, if any, shall also be questioned separately.
      10. The aggrieved woman and the accused shall be informed of the outcome of the investigation. The investigation shall be completed within ninety (90) days of the receipt of the complaint by the Internal Complaints Committee. If the investigation reveals that the aggrieved woman has been sexually harassed as claimed, necessary action shall be taken against the accused, which may include termination of employment and appropriate legal action against the accused.
      11. In case the complaint is found to be false, the complainant shall be liable for appropriate action by the Internal Complaints Committee, which may include termination of employment. The final decision shall be communicated to the aggrieved woman and the accused.
5. CONFIDENTIALITY
   The Company understands that it is difficult for the aggrieved woman to come forward with a complaint of sexual harassment and recognizes the aggrieved woman’s interest in keeping the matter confidential. To protect the interests of the aggrieved woman, the accused person and others who may report incidents of sexual harassment, confidentiality will be maintained throughout any investigatory process to the extent practicable and appropriate under the circumstances, including the identity of the aggrieved woman.
6. 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 applicable laws, disciplinary or other remedial processes.
7. PROTECTION TO COMPLAINANT / VICTIM
   The Company is committed to ensuring that no employee or Representative who brings forward a harassment concern is subject to any form of reprisal. Any reprisal will be subject to necessary action, which may include termination of employment. The Company will ensure that aggrieved woman or witnesses are not victimized or discriminated against while dealing with complaints of sexual harassment.
   In addition to the rights vested in the Company and the Internal Complaints Committee as set forth in this policy, Company and the Internal Complaints Committee reserve the right to pursue such other steps and remedies as may be available under contract, law, or equity.
8. COMPLAINTS MADE WITH A MALICIOUS INTENT
   This policy has been issued to ensure that in the interest of justice, aggrieved woman employees and Representatives have a forum to approach in the event of instances of sexual harassment. However, if upon investigation it is revealed that the complaint was made with a malicious intent and with the motive of maligning the accused, tarnishing the reputation or goodwill of the accused, settling personal/professional scores, or any other reason, strict action will be taken against the complainant, which may include termination of employment. The Internal Complaints Committee may also take suo moto action, if any incident of harassment is brought to its attention, without any formal complaint being made in this regard.
9. RESPONSIBILITY OF EMPLOYEES AND REPRESENTATIVES TO COMPLY WITH THIS POLICY
   All employees and Representatives of the Company have a personal responsibility to ensure that their behaviour is strictly in accordance with this policy, and not contrary to this policy in any form or manner. This policy is deemed to be a part of the terms of employment of every Company employee, and the terms of association of every Representative with the Company. All employees and Representatives are under an obligation to maintain a work environment free from sexual harassment.
10. DISSEMINATION OF THE POLICY:
    This Policy shall be made available to all employees, Representatives and to all new recruits and they shall acknowledge that they have received, read, understood and will abide by the Policy at all times. Additionally, the Company shall conduct training sessions from time to time to increase the awareness of this policy and its objectives throughout the organization. This Policy is as per the applicable laws of India including The Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013 as well as any other applicable law governing sexual harassment, for the time being in force in India.

ANNEXURE 1