Policy on Prevention of Sexual Harassment.

1) INTRODUCTION

As a Company, we are committed to conducting and governing ourselves with ethics, transparency and accountability and to this, we have developed governance structures, practices and processes to ensure that conduct at all levels is promoted across our value chain. We are committed to ensure that the work environment at all our locations is conducive to growth and development, where every employee is treated with dignity and respect. Nanta Tech promotes a culture of transparency and accountability among its associates and encourages an environment where all feel safe to raise concerns. We promote and maintain this culture to ensure that associates of the Company do not engage in practices that are abusive in any form or manner, whatsoever.

In pursuit of this commitment, this policy envisions, intends to prohibit such occurrences and also details procedures to follow when an associate believes that a violation of the policy has occurred within the Company.

2) POLICY

Nanta Tech Limited (herein after referred as "the Company") is an equal employment opportunity company and is committed to creating a healthy working environment that enables employees to work without fear, harassment, discrimination, gender bias and sexual harassment. The Company strives to ensure that all employees of the Company have the right to a respectful workplace.

Sexual harassment at the work place of other than work place is a grave offense and is, therefore, punishable.

All employees of the Company are covered under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (SH Act) with the ensued protection under this policy. This policy provides for the redressal of complaints of sexual harassment. This policy is in compliance with the provisions of the Act. It is also in keeping with our commitment to the adoption of best practices.

3) SCOPE AND EFFECTIVE DATE

This Policy applies to all categories of employees of the Company. The expression "employees" used in the policy include all those who are contracted, trainees, apprentices, consultants, trainees and employees on contract at the Company. The Policy applies to the conduct of such persons at the workplace and also away of the following in addition to the meaning provided under Section 2 of the Act:

• Any conduct, whether verbal, non-verbal, physical, emotional or behavioural such as sexually coloured remarks, jokes, taunts, phone calls, e-mail, gestures, showing of pornographic material, unwelcome physical contact, a demand or request for sexual favour either explicitly or implicitly, remarks on the individual's sex-related characteristics and effects bodily performance;
• Any act or conduct of such an act or workplace or outside in relation to stakeholders of the Company, in viva voce during the course of employment; and
• An aggressive gesture having sexual connotations.

The policy covers the following types of work places:

• All offices or other premises where the Company's business is conducted.
• All work places where work is performed at any other site away from the Company's premises.
• Any social, business or other functions where the conduct or comments may have an adverse impact on the workplace or workplace relations.

4) INTERNAL COMPLAINTS COMMITTEE

A Complaints Committee has been constituted by the Management to consider and redress complaints of Sexual Harassment. The Managing Director may constitute such other committees and may reconstitute the committee for the redressal of complaints of Sexual Harassment. The composition of the Internal Complaints Committee shall be as under:

• At least two members from amongst employees preferably committed to the cause of women or who have had experience in social work or have large knowledge;
• One Member, preferably an NGO or associations committed to cause of women or any professional with the issue relating to sexual harassment.

Out of the aforesaid members at least two members will be of the same gender as that of the Complainant, subject to at least one half of the total members so nominated being women.

In case, if a member is required to be present for the proceedings to take place. The quorum shall include the Presiding Officer and at least two other members, one of whom is a woman.

You may reach the Committee and report the matter to the below committee members.

5) REMEDIAL PROCESS

6) OTHER POINTS TO BE CONSIDERED

• The Committee may recommend to the General Manager / HR action which may include transfer of any of the other appropriate disciplinary actions.
• At the end, the Committee will provide a copy to the person ensuring full efficacy of this policy.
• The Management shall subject to the provisions of the policy and as per the law, shall possess appropriate action shall be initiated by the Management, for making a Police Complaint.

7) CONFIDENTIALITY

All persons involved in the enquiry are bound to come forward with a complaint of sexual harassment and allegations the victim's interest in keeping the matter confidential to protect the interests of the victim, the accused person and others who may report incidents of sexual harassment, confidentiality will be maintained throughout the investigative process to the extent practicable and appropriate under the circumstances.

8) 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.