Workplace Anti-Discrimination and Harassment Policy

1. Purpose:

The purpose of this policy is to foster a workplace environment that is free from discrimination and harassment, promoting respect, equality, and inclusion for all employees.

2. Scope:

This policy applies to all employees, contractors, interns, vendors, and visitors at Sunbeam Elastomers Pvt. Ltd., covering all interactions within the workplace and during work-related activities, including online communications.

3. Objectives:

• To prevent and address all forms of discrimination and harassment in the workplace.
• To promote a culture of respect, equality, and inclusivity.
• To establish a transparent mechanism for reporting and resolving incidents.

4. Policy Guidelines:

Prohibited Conduct:

Discrimination: Discrimination on the basis of race, gender, religion, caste, age, marital status, disability, sexual orientation, or any other protected characteristic is strictly prohibited.

Harassment: Includes verbal, physical, or visual conduct that creates an intimidating, hostile, or offensive work environment. Examples:

• (a) Unwelcome jokes, comments, or gestures.
• (b) Displaying offensive materials.
• (c) Physical harassment or threats.

Sexual Harassment: Covered under the Prevention of Sexual Harassment (POSH) Policy and includes unwelcome advances, requests for favours, or other verbal or physical conduct of a sexual nature.

Reporting Mechanism:

• (a) Employees are encouraged to report incidents promptly to their manager, HR, or through the Internal Complaints Committee (ICC).
• (b) Complaints may be submitted in writing or through a designated email or software system.

Investigation Process:

• (a) Acknowledgement: Complaints will be acknowledged within 2 working days.
• (b) Investigation: A thorough and confidential investigation will be conducted within 15 working days of receiving the complaint.
• (c) Resolution: Findings and actions will be communicated to the complainant and respondent within 10 working days after the investigation is completed.

Confidentiality:

• (a) All complaints and investigations will be treated with strict confidentiality.
• (b) Information will only be disclosed to individuals directly involved in the investigation and resolution process.

Protection Against Retaliation:

• (a) Retaliation against individuals reporting discrimination or harassment in good faith is strictly prohibited.
• (b) Retaliation complaints will be treated with the same seriousness as the original incident.

5. Roles and Responsibilities:

Employees:

• (a) Treat colleagues with respect and uphold the principles of this policy.
• (b) Report incidents of discrimination or harassment promptly and honestly.

Managers/Supervisors:

• (a) Ensure team members adhere to the policy and address any violations immediately.
• (b) Create an inclusive and respectful team culture.

HR Department:

• (a) Provide training and awareness programs on discrimination and harassment prevention.
• (b) Facilitate the reporting and investigation process and maintain records of complaints and resolutions.

Internal Complaints Committee (ICC):

• (a) Investigate and resolve complaints related to discrimination and harassment.
• (b) Ensure compliance with the POSH Act and other applicable laws.

6. Key Provisions:

Training and Awareness: Regular workshops and training sessions will be conducted to educate employees on anti-discrimination and harassment policies.

Zero Tolerance: The company maintains a zero-tolerance stance toward discrimination and harassment. Violations will result in disciplinary action, up to and including termination.

Support for Victims: Counseling and support services will be provided to victims of discrimination or harassment, if required.

7. Monitoring and Reporting:

• (a) HR will maintain an annual record of complaints, resolutions, and preventive measures implemented.
• (b) An annual report will be shared with senior management, ensuring transparency and accountability.

8. Review and Amendments:

This policy will be reviewed annually or as required based on employee feedback, legal updates, and organizational needs. Amendments will be approved by the Board of Directors.

Approval:

This Workplace Anti-Discrimination and Harassment Policy has been approved by the Board of Directors of Sunbeam Elastomers Pvt. Ltd. on 1st January 2025.

This policy ensures a safe, inclusive, and respectful work environment at Sunbeam Elastomers Pvt. Ltd.