ATOMY ENTERPRISE INDIA PRIVATE LIMITED

Anti-Sexual Harassment Policy Atomy India is committed to creating and maintaining a secure work environment where it’s Employees, Agents, Vendors and stake holders can work and pursue business together in an atmosphere free of harassment, exploitation and intimidation caused by acts of Sexual Harassment within but not limited to the office premises and other locations directly related to the Company’s business.
The objective of this policy is to provide protection against sexual harassment of women at workplace and for the prevention and redressal of complaints of sexual harassment and for matters connected therewith.
All concerned should take cognizance of the fact that Company strongly opposes sexual harassment, and that such behaviour against women is prohibited by the law as set down in The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and Rules framed thereunder being The Sexual Harassment of Women at Workplace (hereinafter referred to as “Act”) as well as the terms of employment. Commission of any act of sexual harassment as defined in the Act and in this Policy shall result in strict disciplinary action.
At Company, we have zero-tolerance for sexual harassment. We value each and every employee working with us and wish to protect their dignity and self-respect. In doing so, we are determined to promote a working environment in which persons of both genders complement each other as equals in an environment that encourages maximum productivity and to keep the personal dignity.

1) Scope: Company’s Policy with regard to Prevention, Prohibition and Redressal of Sexual Harassment covers every “employee” of the Company. Company encourages every employee who believes they are sexually harassed to use the redressal mechanism as provided in this policy.
The Policy is with respect to Prevention, Prohibition & Redressal of Sexual Harassment which may arise in places not limited to geographical location viz. Company’s offices / branches but includes all such places or locations where acts are conducted in context of working relationships or whilst fulfilling professional duties or which may be visited by an employee during the course of employment.
Company’s Policy against sexual harassment includes sexual harassment by fellow employees, supervisors, managers as well as agents, contractors, customers,
vendors, partners and visitors.This Policy comes into force with immediate effect.

2) Defining Sexual Harassment: “Sexual Harassment” includes any unwelcome acts or behavior such as physical contact and advances, demand or request for sexual favors, sexually colored remarks, showing pornography or any other unwelcome physical verbal or nonverbal conduct having sexual overtones whether directly or by implication.

Sexual Harassment is a form of discrimination related to sexual orientation and can be manifested in several ways, including:

1. • Verbal or written harassment such as jokes, e-mails, derogatory comments, slurs, threats, accusations or negative stereotyping.
2. • Physical harassment such as assault, inappropriate touching, impeding or blocking movement or any physical interference with normal work or movement, which is directed at an individual.
3. • Sexually colored remarks.
4. • Visual forms of harassment such as graphic, offensive, or inappropriate materials, posters, cartoons, or drawings.
5. • Unwelcome sexual advances, requests for sexual favors, or creating a hostile work environment through other verbal or physical conduct of a sexual nature such as e-mails, name calling, gestures, suggestive comments, leering, or lewd talk and/or jokes.
6. • Physical contact and advances involving unwelcome and explicit sexual overture:
7. • Showing pornography
8. • Any other unwelcome and physical, verbal or non-verbal conduct of sexual nature.
9. • Stalking
10. • Voyeurism etc.

3) Internal Complaints Committee: Every complaint received shall be forwarded to the internal complaint committee formed under the policy for redressal. The investigation shall be carried out by the Internal Complaints Committee (‘’ICC’’) constituted for this purpose.

Internal Complaints Committee has been constituted of the following members as nominated by the Company:

1. a. A woman employee employed at a senior level amongst the employees shall act as Presiding officer of the committee.
2. b. Not less than 2 members from amongst employees preferably committed to the cause of women OR who have had experience in social work OR have legal knowledge.
3. c. One member shall be from amongst non-governmental organizations OR associations committed to the cause of women OR a person familiar with the issues relating to sexual harassment.

The Name of the Members of the Internal Complaints Committee is as per Annexure A of this Policy and any change in such composition shall be effected in the policy. At least half the total members of the Committee must be women.

4) Procedure for lodging a complaint: An employee making a complaint (“the Complainant”) has to submit a written complaint to ICC within three months from date of incident or last incident in case of series of incidents. However, time limit can be extended if there are satisfactory circumstances which prevented the Complainant from filing complaint within said period. The Complainant shall provide supporting documents, names and addresses of witnesses and will be afforded strictest confidentiality by the ICC at all times. Within seven (7) working days of the receipt of the complaint, the ICC has to send a copy of the complaint to the alleged accused ("Counter Party") who will have ten (10) working days to file reply along with list of documents, names and addresses of witnesses.

5) Conciliation Process:

1. • Before initiating inquiry, at the request of the Complainant, ICC may take steps to settle the matter through conciliation between the Complainant and the Counter Party. Any conciliation carried out by the ICC will be completed within a period of one month from the date of the receipt of the complaint. Such settlement should be recorded in writing by ICC. However, no monetary settlement shall be made as a basis of conciliation.
2. • Where no settlement can be reached because of the conciliation process by the ICC, or the Complainant informs the ICC that settlement arrived at as a result of such conciliation has not been complied with by the Counter Party, the ICC shall proceed to conduct the enquiry as per the procedure prescribed below.

6) Procedure for Inquiry:

1. • Where no conciliation process referred above has been requested by the Complainant or if requested and carried out, has not been successful; the ICC, shall within a period of one month of its receipt of the complaint or conclusion of the conciliation process, proceed to conduct an inquiry into the allegation of sexual harassment, in accordance with the procedure prescribed.
2. • The ICC is intended to be an independent, objective and unbiased fact-finding body established to investigate any complaints of sexual harassment in a fair, reasonable and time-bound manner in a neutral environment. The ICC shall conduct the enquiry in accordance with principles of natural justice. It will broadly be governed by the following principles in conducting its proceedings:
3. • The ICC shall give every reasonable opportunity to the Complainant and the Counter Party for putting forward and defending their respective cases and to ensure that the Complainant and the Counter Party have full opportunity to present their claims, witnesses and evidence which may establish or substantiate their claims;
4. • Both the Complainant and the Counter Party shall have the right to submit supporting evidence and shall have the right to bring their respective witnesses, if any, to be examined by the ICC;
5. • If the Complainant or the Counter Party fails, without sufficient cause, to be present before the ICC for three (3) consecutive hearings, the ICC will give a notice of fifteen (15) days to the concerned party before terminating the enquiry proceedings or giving an ex-parte decision on the complaint;
6. • The Complainant, the Counter Party or any other person that the Complaints Committee meets with, interacts with, or has a teleconference or video conference with, for the purpose of enquiry into any complaint of sexual harassment shall be bound by strict confidentiality and each such party shall not be permitted to discuss the Complaints Committee proceedings with any third person;
7. • All the proceedings of the ICC will be summarized by the ICC. In the event either the Complainant or the Counter Party is desirous of submitting a statement in writing or reviewing the summary of discussion prepared by the ICC, such statement shall be endorsed by such Party in token of authenticity thereof and submitted to the ICC;
8. • Inquiry shall be completed, including the submission of the report, within a period of 90 days from the date of the complaint.
9. • The ICC shall complete the enquiry and make a report of its findings on the Complaint and its recommendations to the senior management of the Company ("Management") within a period of ten (10) days from the conclusion of the enquiry procedure set out above. The report of the ICC shall also include recommendations for the imposition of any penalty and the reasons for such recommendations to the Management.
10. • The Management shall consider the recommendations and findings of the ICC and take a decision in relation to action to be taken. The Management may issue such order or directions as it deems fit and shall inform the Complainant and the Counter Party of its decision. The Management shall provide all necessary assistance to the ICC for the purpose of ensuring full, effective and speedy implementation of this procedure for investigating any complaint of sexual harassment at work place in accordance with the Policy.

7) Protection against victimization: The Company shall take appropriate steps to prevent victimization of the Complainant during the pendency of the Enquiry and shall ensure that the Complainant and the witnesses are protected from reprisal.

8) Findings & Directions: If the ICC arrives at the conclusion that the allegation against the Counter Party is proved and it recommends action against the Counter Party, the Management shall take such action as may be appropriate action for misconduct by the employee under the Company’s policy within no later than sixty (60) days of receipt of ICC’s report. Such actions may include any of the following:

1. • Written apology;
2. • Warning;
3. • Reprimand or censure;
4. • Withholding of promotion;
5. • Withholding of pay rise or increments;
6. • Termination of employment;
7. • Or any penalty applicable as per the law

In the event, the ICC after investigation of a Complaint in accordance with the procedure prescribed herein, concludes that the Complaint was false, frivolous or made with malaise intention by the Complainant including due to personal issues with the Counter Party, then the ICC shall make such appropriate recommendations to the Management to take action against the Complainant, as may be necessary. However mere inability to substantiate a complaint or provide adequate proof will not attract action and further inquiry will be made before any action is recommended against such a Complainant.
In the event the Complainant decides to pursue personal action against the Counter Party, the Company will provide all assistance and cooperation in any investigation by the relevant law enforcement agencies.

ANNEXURE – A Composition of Internal Complaints Committee

Sno	Name	Designation	Membership	Email	Contact No.
1.	Ms. Shruti Agarwal	Company Secretary	Presiding officer	shruti@atomypark.com	0124 6472857
2.	Mr. Rahul Kokadwar	COO	Internal Member	rahul@atomypark.com	0124 6472871
3.	Mr. Jacob Boban Abraham	Manager – Marketing	Internal Member	jacob01@atomypark.com	0124 6472867
4.	Mr. Rajeev Kumar Rattawa	Manager – Finance & Accounts	Internal Member	rajeev@atomypark.com	0124 6472856
5.	Ms. Nasharah	Manager – Product Development	Internal Member	nasharah@atomypark.com	0124 6472885
6.	Advocate Ms. Akshiptika Verma	Advocate/NGO Member	External Member	akshiverma30@gmail.com	+91 84473 86680