Prevention of Sexual Harassment (POSH) Policy

1. Purpose

Everyone who works with us has the right to dignity at work. This policy explains how Unolabs Technologies Private Limited ("we", "us") prevents sexual harassment, and how to complain.

2. Scope

People. This policy covers:

• employees, whether permanent, temporary or on probation;
• interns, trainees, consultants and contractors, including agency staff;
• visitors, candidates and anyone else who deals with us at work.

A complaint can be made about anyone, of any gender, including a client's staff or a visitor.

Places. The workplace includes:

• our office, client sites and any place you visit for work;
• travel for work, including transport we arrange;
• your home or anywhere else you work remotely;
• calls, meetings, chat, email and social media used for work.

Everyone, of any gender. The Act protects women. We go further: we do not tolerate the sexual harassment of anyone, of any gender. Where the Act does not apply, the Internal Committee uses the same process under this policy and our disciplinary rules.

3. Legal framework

• The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013 (the "Act"), and its Rules of 2013 (the "Rules").
• The Companies (Accounts) Rules 2014, rule 8(5)(x), for our Directors' Report.

3.1 What sexual harassment means

Under section 2(n) of the Act, sexual harassment is unwelcome behaviour, direct or implied, such as:

• physical contact and advances;
• a demand or request for sexual favours;
• sexually coloured remarks;
• showing pornography;
• any other unwelcome physical, verbal or non-verbal conduct of a sexual nature.

3.2 Circumstances that also count

Under section 3(2), these may also count when linked to such behaviour:

• an implied or explicit promise of better treatment, or threat of worse treatment, at work;
• a threat about your present or future job;
• interfering with your work, or creating an intimidating, offensive or hostile environment;
• humiliating treatment likely to affect your health or safety.

Intent does not decide the matter. The question is whether the behaviour was unwelcome.

4. Roles and responsibilities

• Internal Committee (IC): receives complaints, holds inquiries, recommends interim relief and outcomes, and prepares the annual report.
• Director, Unolabs Technologies Private Limited: owns this policy, gives the IC what it needs, and acts on its recommendations.
• Managers and everyone else: treat others with respect, take concerns seriously and cooperate with any inquiry.

5. Our commitments

5.1 Internal Committee

Section 4 of the Act requires an IC at each office with 10 or more employees. We have constituted an Internal Committee. Its members are:

• Presiding Officer: a woman employed at a senior level;
• Employee members: at least two employees;
• External member: one person from an organisation committed to women's causes, or familiar with sexual harassment issues.

At least half the members are women. Each serves for up to three years. The external member is paid a fee, as the Rules require.

Internal Committee: contact via posh-policy@unolabs.com.

5.2 Notices

At our office, we display the order constituting the IC, the members' contact details and the penalties for sexual harassment. Remote workers receive the same notice.

5.3 Confidentiality

Under section 16, we keep confidential the identities of everyone involved, the complaint, the proceedings, the recommendations and the action taken. None of it is shared with the public or media. A breach of confidentiality leads to disciplinary action and a penalty under the Rules.

5.4 No retaliation

We do not tolerate retaliation against anyone who complains in good faith, or who helps an inquiry. Retaliation is itself misconduct.

5.5 Data protection

We handle complaint records under our Privacy Policy for India (Digital Personal Data Protection Act 2023). Only the IC, and the people who must act on its report, can see them. We keep them only as long as we need them for their purpose, or as long as the law requires.

5.6 Annual reporting

Under section 21 and Rule 14, the IC will prepare a report for each calendar year. It goes to us and to the District Officer for Pune. It counts complaints received, resolved and pending over 90 days, awareness sessions held, and action taken. The 2026 report will be filed by 31 March 2027.

From financial year 2026-27, our Directors' Report will include the IC statement and complaint numbers that rule 8(5)(x) requires.

6. Making a complaint

6.1 When and how

If you are a woman who has faced sexual harassment at our workplace, email the IC at posh-policy@unolabs.com. Do not use info@unolabs.com, because a wider team reads it.

Complain in writing within 3 months of the incident, or of the last incident in a series. For good reason, the IC can allow 3 more months. If you need help writing it down, any IC member will help.

6.2 If you cannot complain yourself

Under Rule 6, someone else may complain for you:

• Physical incapacity: a relative, friend, co-worker, Commission for Women officer, or anyone who knows of the incident, with your written consent.
• Mental incapacity: a relative, friend, special educator, psychiatrist, psychologist or guardian, or anyone who knows of the incident jointly with one of them.
• Death: anyone who knows of the incident, with your legal heir's written consent.
• Any other reason: anyone who knows of the incident, with your written consent.

6.3 Conciliation

Before an inquiry, the IC can try conciliation, but only if you ask (section 10). No settlement can be based on money. If its terms are not kept, the IC holds an inquiry.

6.4 Inquiry

The IC sends the respondent a copy of the complaint within 7 days. The respondent replies within 10 working days. Both sides are heard and may bring evidence and witnesses, but not lawyers. At least three members, including the Presiding Officer, attend each hearing. The IC completes the inquiry within 90 days (section 11). If you wish to go to the police, we will help you.

6.5 Interim relief

During the inquiry, you can ask the IC in writing for interim relief (section 12). The IC may recommend that we:

• transfer you or the respondent to another workplace;
• give you up to 3 months' leave, on top of your normal leave;
• stop the respondent from reporting on your work or assessing your performance.

We carry out these recommendations.

6.6 Outcomes

The IC sends its report to us and to both sides within 10 days of finishing the inquiry (section 13). If the complaint is not proved, it recommends no action.

If it is proved, the IC may recommend disciplinary action. This ranges from a written apology, warning or withheld promotion to counselling, community service or dismissal. Sexual harassment by an employee is gross misconduct. The IC may also recommend compensation, deducted from the respondent's pay (section 15). We act on the report within 60 days.

6.7 False or malicious complaints

The IC may recommend action against anyone who makes a complaint with malice or knowing it is false, or who gives false evidence (section 14). Not being able to prove a complaint does not make it malicious. Malice must be shown through an inquiry first.

6.8 Appeal

Either side can appeal within 90 days against the IC's recommendations, or our failure to carry them out (section 18). The appeal goes to the authority set by Rule 11.

6.9 Local Committee and other routes

The District Officer for Pune has a Local Committee (section 6). If your complaint is against the employer, such as a director of the company, complain to the Local Committee instead. You can also send a complaint through the Nodal Officer for your area.

If a client's staff harassed you at a client site, you can complain to our IC or to the client's Internal Committee. We will support you either way.

7. Raising a concern

If you see or hear about sexual harassment, tell the IC, or support the person affected to complain. We will not act against you for raising a concern in good faith.

8. Training and awareness

We will run awareness sessions on this policy for all staff at least once a year, starting by 31 March 2027. We will give IC members orientation training by the same date, and to each new member when they join.

9. Monitoring, review and changes

The Director reviews this policy every 12 months, using the IC's annual report, or sooner if the law changes. We publish each new version here with its date.

10. Contact

Complaints: Internal Committee, posh-policy@unolabs.com. Do not send complaints to info@unolabs.com.