Policy On Posh at Workplace:

This policy has been framed in accordance with the provisions of “The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013” and rules framed thereunder (hereinafter “the Act”). Accordingly, while the policy covers all the key aspects of the Act, for any further clarification reference shall always be made to the Act and the provisions of the Act shall prevail.

1. COMMITMENT:

a. Pinnacle is committed to providing work environment that ensures every employee is treated with dignity and respect and afforded equitable treatment.

b. Pinnacle is also committed to promoting a work environment that is conducive to the professional growth of its employees and encourages equality of opportunity.

c. Pinnacle will not tolerate any form of sexual harassment and is committed to take all necessary steps to ensure that its employees are not subjected to any form of harassment.

d. In case a case is reported, Pinnacle vows to investigate the case thoroughly & ensure fair outcomes.

2. SCOPE:

a. This policy applies to all categories of employees of Pinnacle, including permanent management and workmen, temporaries, trainees and employees on contract at their workplace or at client sites. Pinnacle will not tolerate sexual harassment, if engaged in by clients or by suppliers or any other business associates.

b. The workplace includes:

• All offices or other premises where the Pinnacle’s business is conducted.

• All Pinnacle-related activities performed at any other site away from Pinnacle’s premises.

• Any social, business or other functions where the conduct or comments may have an

• adverse impact on the workplace or workplace relations.

3. DEFINITION OF SEXUAL HARASSMENT:

a. Sexual harassment may be one or a series of incidents involving unsolicited and unwelcome sexual advances, requests for sexual favors, or any other verbal or physical conduct of sexual nature.

b. Sexual Harassment at the workplace includes:

i. Unwelcome sexual advances (verbal, written or physical),

ii. Demand or request for sexual favours.

iii. Any other type of sexually-oriented conduct-sexually coloured remarks, including but not limited to vulgar/indecent jokes, letters, phone calls, text messages, emails, gestures.

c. Any conduct that has the purpose or the effect of interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment and/or submission to such conduct is either an explicit or implicit term or condition of employment and /or submission or rejection of the conduct is used as a basis for making employment decisions.

4. RESPONSIBILITIES REGARDING SEXUAL HARASSMENT:

a. All employees of Pinnacle have a personal responsibility to ensure that their behaviour is not contrary to this policy.

b. All employees are encouraged to reinforce the maintenance of a work environment free from sexual harassment.

5. COMPLAINT MECHANISM:

A mail ID has particularly been created where complaints of such nature can be registered without the fear of disclosing the Identity. This mail ID is accessible only to the members of the ICC.

1. For Jaipur Employees: ASHI@jpr.pinnaclecad.com

2. For West Bengal Employees: ASHI@dgp.pinnaclecad.com

3. For Madurai Employees: ASHI@mdu.pinnacleinfotech.com

Only electronic complaints will be entertained. A complaint can be registered with minimum details & can be left open for further investigation.

An appropriate complaint mechanism in the form of “Complaints Committee” has been created in the Pinnacle for time-bound redressal of the complaint made by the victim. Once the initial complaint is received on the above email id, the committee will call the person and gather relevant information in a comfortable and safe environment in a structured format. Initial relief will be provided in the same meeting about ensuring all steps being taken to address the same including project change/manager change etc. as the case may be.

In case where the compliant is of a very grave nature & continuous work-related interaction between the complainant & the accused could aggravate the harassment, one the following action will be taken:

1. The complainant’s reporting & team will be changed till the time the enquiry is in progress

2. If the above is not possible, then either the complainant or the accused (based on criticality of work) will be sent on leave up to a period of 3 months till the time the enquiry is in progress.

6. COMPLAINTS COMMITTEE:

a. Pinnacle has instituted a Complaints Committee for redressal of sexual harassment complaint (made by the victim) and for ensuring time bound treatment of such complaints.

b. Initially, and till further notice, the Complaints Committee will comprise of the following four members out of which at least two members will be of the same gender as that of the complainant:

i. Woman Employee (Presiding Officer)

ii. Head HR (Member)

iii. Employee at the level of Functional Head (Member)

iv. Employee from HR / Administration Department (Member)

v. Employee as Dept. Head from BSD/BED Division (Member)

vi. Member from an NGO or Lawyer (External Member)

c. The Complaints Committee is responsible for:

i. Investigating every formal written complaint of sexual harassment.

ii. Taking appropriate remedial measures to respond to any substantiated allegations of sexual harassment.

iii. Discouraging and preventing employment-related sexual harassment.

7. PROCEDURES FOR RESOLUTION, SETTLEMENT OR PROSECUTION OF ACTS OF SEXUAL HARASSMENT:

Pinnacle is committed to providing a supportive environment to resolve concerns of sexual harassment as under:

A. Informal Resolution Options:

When an incident of sexual harassment occurs, the victim of such conduct can communicate their disapproval and objections immediately to the harasser and request the harasser to behave decently.

If the harassment does not stop or if victim is not comfortable with addressing the harasser directly, the victim can bring their concern to the attention of the Complaints Committee for redressal of their grievances.

The Complaints Committee will thereafter provide advice or extend support as requested and will undertake prompt investigation to resolve the matter.

B. Complaints:

a. An employee with a harassment concern, who is not comfortable with the informal resolution options or has exhausted such options, may make a formal complaint to the Presiding Officer of the Complaints Committee constituted by the Management. The complaint shall have to be in writing and acceptable in electronic format only via email, preferably within 15 days from the date of occurrence of the alleged incident. The employee is required to disclose their name, department, division and location they are working in, to enable the Presiding Officer to contact them and take the matter forward.

b. The Presiding Officer of the Complaints Committee will proceed to determine whether the allegations (assuming them to be true only for the purpose of this determination) made in the complaint fall under the purview of Sexual Harassment, preferably within 30 days from receipt of the complaint.

c. In the event, the allegation does not fall under the purview of Sexual Harassment, or the allegation does not constitute an offence of Sexual Harassment, the Presiding Officer will record this finding with reasons and communicate the same to the complainant.

d. If the Presiding Officer of the Complaints Committee determines that the allegations constitute an act of sexual harassment, he/ she will proceed to investigate the allegation with the assistance of the Complaints Committee.

e. Where such conduct, on the part of the accused, amounts to a specific offence under the law, Pinnacle shall initiate appropriate action in accordance with law by making a complaint with the appropriate authority.

f. The Complaints Committee shall conduct such investigations in a timely manner and shall submit a written report containing the findings and recommendations to the Chairperson as soon as practically possible and in any case, not later than 90 days from the date of receipt of the complaint. The Head HR will ensure corrective action on the recommendations of the Chairperson of the Complaints Committee and keep the complainant informed of the same.

g. Corrective action may include any of the following:

(i) Formal apology

(ii) Counselling

(iii) Written warning to the perpetrator and a copy maintained in the employee’s file.

(iv) Change of work assignment / transfer for either the perpetrator or the victim.

(v) Suspension or termination of services of the employee found guilty of the offence.

(vi)In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for appropriate disciplinary action by the Management which could lead to the termination of the employment as well.

8. CONFIDENTIALITY:

a. Pinnacle understands that it is difficult for the victim to come forward with a complaint of sexual harassment and recognizes the victim’s interest in keeping the matter confidential.

b. 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 investigatory process to the extent practicable and appropriate under the circumstances.

9. 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 Pinnacle except where disclosure is required under disciplinary or other remedial processes.

10. PROTECTION TO COMPLAINANT / VICTIM:

a. Pinnacle is committed to ensuring that no employee who brings forward a harassment concern is subject to any form of reprisal. Any reprisal will be subject to disciplinary action.

b. Pinnacle will ensure that the victim or witnesses are not victimized or discriminated against while dealing with complaints of sexual harassment.

c. However, anyone who abuses the procedure (for example, by maliciously putting an allegation knowing it to be untrue) will be subject to strict disciplinary action which could lead to termination of the employment.

d. In case the IC arrives at a conclusion that the allegation against the Respondent is malicious or the Complainant has made the complaint knowing it to be false or has produced any forged or misleading document, it may recommend to the Company to

take suitable action against the Complainant who has made the complaint, in accordance with the provisions of the applicable service rules or as prescribed under applicable law.

11. CONCLUSION:

In conclusion, Pinnacle reiterates its commitment to providing its employees, a workplace free from harassment/ discrimination and where every employee is treated with dignity and respect.

12. INTERNAL COMMITTEE (IC):

The Pinnacle Internal Committee (ICC) is constituted for a period of 3(three) years from the date of their nomination. The Chairperson is from Management - Mrs. Sapna Patwari.

Members of ICC Durgapur

Members of ICC Kolkata

Members of ICC Jaipur

Members of ICC Madurai