LEGAL
POSH Policy
Policy for the Prevention, Prohibition and Redressal of Sexual Harassment at the Workplace
DOCUMENT OWNER
Human Resources
EFFECTIVE DATE
1 October 2026
VERSION
2.0
APPLICABLE TO
ShopSe / Newbazaar Technologies Private Limited
APPROVED
1 October 2026
Contents
1
Purpose & Statement of the Policy
2
Scope & Applicability
3
Definition
4
Role of Bystander / Aggrieved Person / FIFs
5
Internal Committee
6
Appeals
7
Third Party Harassment
8
Savings
9
Duties of the Company
10
Complainant(s) or witnesses
11
Confidentiality
12
Annual Meeting with the Committee
13
Responsibilities for implementation
14
Control Change Records
15
Annexure 1
16
Annexure 2
1
This Newbazaar Technologies Private Limited (ShopSe Digital Finance) (hereinafter referred to as the “Company”) is committed to maintaining a safe, equitable, and respectful working environment, founded on the principles of dignity, mutual respect, and zero tolerance for coercion, harassment, and inequity.
In compliance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the rules made thereunder, this Policy establishes:
A framework to prevent and prohibit sexual harassment at the workplace.
Formal mechanisms for the fair, timely, and confidential redressal of complaints.
Disciplinary actions for non-compliance and violation of this Policy.
Sexual harassment constitutes severe misconduct under the Company’s code of conduct and service rules. Any employee found to have engaged in sexual harassment will be subject to strict disciplinary action up to and including immediate termination of employment.
2
This Policy applies to all full-time, part-time, temporary, probationers, trainees, apprentices, retainers, consultants, agency/contract labour, ad hoc, daily-wage or voluntary workers, Interns or job applicants and visitors, regardless of rank or department.
Territorial & Structural Scope (“Extended Workplace”): “Workplace” extends beyond physical office premises to encompass:
All physical offices, branches, and administrative units of the Company.
Work-related travel, off-site client meetings, corporate retreats, training programs, and company-sponsored social events.
Virtual and digital environments, including company email, instant messaging platforms, social media, video conferencing, and telephone communications.
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i) Sexual Harassment
“Sexual Harassment” includes any one or more of the following unwelcome acts or behaviour. (whether directly or by implication) namely:-
a) Physical contact and advances; or
b) A demand or request for sexual favours; or
c) Making sexually coloured remarks; or
d) Showing pornography; or
e) Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.
ii) Certain circumstances that may to harassment
The following circumstances among other circumstances, if it occurs or is present in relation to or connected with any act or behaviour of Sexual Harassment may amount to Sexual Harassment:-
(a) Implied or explicit promise of preferential treatment in their employment, or
(b) Implied or explicit threat of detrimental treatment in their employment, or
(c) Implied or explicit threat about their present or future employments, or
(d) Humiliating treatment likely to affect their health or safety, or
(e) Interference with the person’s work or creating an intimidating or offensive or hostile work environment for the person
iii) Workplace
Workplace includes:
a) Any office, branch or unit, which is established, owned or controlled by the Company.
b) Any place visited by the Employee arising out of or during the course of employment including transportation provided by the Company for undertaking such journey.
iv) Employee
“Employee” means a person employed at the workplace for any work on permanent/ regular, temporary, ad hoc or daily wages basis, either directly or through an agent, including a contractor, with or, without the knowledge of the principal employer, whether for remuneration or not, or working on a voluntary basis or otherwise, whether the terms of employment are express or implied and includes a co-worker, probationer, trainee, apprentice or called by any other such name.
v) Aggrieved Person
“Aggrieved Person” means in relation to a workplace, a woman, of any age whether employed or not, who alleges to have been subjected to any act of sexual harassment by the respondent.
vi) Respondent
“Respondent” means a person against whom the Aggrieved Person has made a written Complaint.
vii) Bystander
“Bystander” means any person who observes Sexual Harassment taking place at the workplace and is not the aggrieved person.
viii) Employer
An Employer refers to the head or governing entity of an organization, establishment, or workplace.
ix) Presiding Officer
The Presiding Officer is the designated head of the Internal Committee (IC).
x) Internal Complaint Committee (ICC)
ICC is an independent redressal body that every employer is legally mandated to constitute.
4
(a) In the instance, when a Bystander or Aggrieved Person conduct behaviour of Sexual Harassment, the Bystander/Aggrieved Person should bring it to their attention that the behaviour is unwelcome and firmly request it be stopped.
(b) The Aggrieved Person may bring it to the attention of Internal Committee.
(c) The Company may nominate officers in different locations as First Instance Facilitators (FIFs) as an internal support mechanism. The FIF role is in addition to, and does not replace or delay, the right of an Aggrieved Woman to complain directly to the Internal Committee under section 9 of the Act.
(d) If the Bystander/ Aggrieved Person needs any support or clarification they may reach out to the allocated FIF for their respective locations.
(e) An Aggrieved Person may make, in writing, a complaint of Sexual Harassment at Workplace to the Internal Committee within a period of three months from the date of the incident and in case of series of incidents, within a period of three months from the date of last incident or any such period as may be provided by the POSH laws from time to time.
(f) The complaint shall address to the Member(s) of the Internal Committee and shall to be addressed at posh@getshopse.com
(g) The Internal Committee may, for reasons to be recorded in writing, extend the time limit for making a complaint under clause (e) by a period not exceeding three months, if it is satisfied that the circumstances were such that they prevented the Aggrieved Woman from filing the complaint within the period specified in clause (e)
(h) Where such complaint cannot be made in writing, the Presiding Officer of the Internal Committee or any member of the Internal Committee as the case may be, shall render all reasonable assistance to the Aggrieved Person for making the complaint in writing.
(i) Where the Aggrieved Person is unable to make a complaint on account of their physical or mental incapacity or death or otherwise, their legal heir or any other person as per the provisions of POSH Laws may make a complaint in writing to the Internal Committee.
5
As Mandated under POSH Act, the Company has constituted Internal committees across its offices for redressal of sexual harassment complaints and for ensuring time bound treatment of such complaints. Whenever it may be necessary or appropriate, the Company shall have to remove or replace any member of the Internal Committees.
There will be central Internal Committee which will look into complaints from all locations. The minimum composition of the Internal Committee shall be given below
(a) Presiding Officer who shall be a woman employed at the Workplace.
(b) Provided that at least one half of the total members so nominated shall be women. The tenure of the presiding officer/members shall not exceed three years.
The information regarding the Presiding Officer / members of the internal Committee details will be made available on the website of the Company along with the procedure of filing complaints.
A. Content of Complaint
The complaint shall contain all material and relevant details concerning the alleged Sexual Harassment including name(s) of Complainant, Respondent, designation, location of the incident and Respondent, date(s) of incidence(s) time, witness if any etc.
B. Interim Relief
During the pendency of the inquiry, on a written request, if made by the Complainant, the IC may recommend to the Company as to: -
(i) Transfer the Complainant or the Respondent to any other Workplace.
(ii) Granting of leave(s) as appropriate, as per the POSH laws from time to time.
(iii) Restrain the Respondent from assessing/ reporting on Complainant’s work performance and accordingly change in reporting hierarchy if the Complainant is directly reporting to the Respondent.
(iv) Or grant such other relief to the Complainant as may be prescribed by the POSH laws.
C. Conciliation
(i) Before initiating an inquiry under this Policy, the Internal Committee may, at the written request of the Complainant take steps to settle the matter between the Complainant and the Respondent through conciliation. The Internal Committee will attempt to resolve the raised issue through mutual discussion between the Complainant and the Respondent. The conciliation process will also be documented. And shall be the part of the records.
(ii) The Internal Committee will record the terms of the settlement acceptable to the Complainant and the Respondent and file a closure report with the Employer to take further action as recorded in the settlement. Copies of the settlement shall be provided to the Complainant and the Respondent. All persons involved in the conciliation will maintain the dignity and confidentiality of the persons involved. The Aggrieved Woman may withdraw from the conciliation process at any time before a settlement is recorded, by informing the Internal Committee in writing. She is not required to state any reason. On withdrawal, the Internal Committee shall proceed to inquire into the complaint under section 11 of the Act.
(iii) No monetary settlement shall be made as a basis of conciliation.
(iv) Post the conciliation process, after the settlement is arrived at, no further inquiry shall be conducted by the Internal Committee.
(v) Where the Complainant informs the IC that any of the terms or conditions mentioned in the conciliation settlement are not complied with the Respondent, then the Internal Committee shall take appropriate next steps.
D. Formal Complaint Resolution Procedure
(i) The Internal Committee while maintaining strict confidentiality, shall, where the Respondent is an employee take immediate necessary action to hold an inquiry in accordance with the provisions of Service rules applicable. The Respondent shall be provided a copy of the Complaint within 7 (seven) working days from receipt of the Complaint. The Respondent shall file his/ her reply to the complaint along with his list of documents, and names and addresses of witnesses, within a period not exceeding 10 (ten) working days from the date of receipt of the complaint.
(ii) The Complainant shall be provided with a copy of the Respondent’s reply. The Internal Committee may also take inputs from the witnesses named by the parties and any other persons whosoever deemed appropriate.
(iii) The IC shall make inquiry into the Complaint in accordance with the principles of natural justice.
(iv) The IC may terminate the inquiry proceedings or give an ex-parte decision on the Complaint, if the Complainant or Respondent fail, without sufficient cause, to present themselves for 3 (three) consecutive hearings convened by the IC. However, such termination or ex-parte order may not be passed without giving a notice in writing, 15 (fifteen) days in advance, to the party concerned.
(v) The Complainant or Respondent shall not be allowed to bring in any legal practitioner to represent them in their case at any stage of the proceedings before the IC.
(vi) In conducting the inquiry, a minimum of 3 (three) members of the IC including the Presiding Officer shall be present.
(vii) Members of the IC shall after examination of the complaint and the response of the Respondent and all evidence placed before it, including witness statements conclude the inquiry. Where both the parties are employees, the parties shall during the course of the inquiry be given an opportunity of being heard and a copy of the findings shall be made available to both the parties enabling them to make representation against the findings before the Internal Committee. On the completion of the inquiry, the IC shall provide a report of its findings to the Company within a period of 10 (ten) days from the date of completion of the inquiry and such report be made available to the concerned parties. The inquiry shall be completed within a period of 90 (ninety) days. The Internal Committee shall keep complete documentation of the complaint, inquiry and its report. The IC/ Officer designated for this purpose or the Presiding Officer shall ensure that all documents shall be kept securely.
(viii) Where the Internal Committee arrives at a conclusion that the allegation against the Respondent has been proved, it shall recommend to the Company to take necessary action as appropriate as per the provisions of the applicable service rules and POSH law. The Company shall act upon the recommendation within 60 (Sixty) days.
(ix) Where the Internal Committee arrives at a conclusion that the allegation against the Respondent has not been proved, it shall recommend the Company in the report as to no action is required to be taken in this matter.
(x) Where the Internal Committee 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 the Complainant or witness has given any false evidence or produced any forged or misleading document it may recommend the Company to take necessary action as appropriate as per the provisions of the applicable service rules and POSH laws. However, mere inability to substantiate a complaint or provide adequate proof need not attract action against the Complainant. Further that the malicious intent on part of the Complainant shall be established after an inquiry in accordance with the procedure prescribed before any action is recommended.
E. Recusal from inquiry
IC member shall inform the IC Committee for any potential conflict of interest while conducting the inquiry. The IC member shall be excused to be part of inquiry wherever there is any conflict of interest. The management is authorized to appoint any member in the IC on ad hoc basis.
F. Annual Report
The Internal Committee shall prepare and submit an annual report to the Company in each calendar year.
6
Any person aggrieved from the recommendations of the IC or non-implementation of such recommendations may, within 90 (ninety) days of recommendations, prefer an appeal to the court or tribunal in accordance with the provisions of the service rule applicable to the said person.
7
a) This Policy applies where an Aggrieved Woman alleges sexual harassment at a Workplace by any person, whether or not that person is on the Company’s payroll. This includes contract workers and persons engaged through an agent or contractor, as well as vendors, customers and visitors.
b) The Internal Committee shall receive and register such a complaint under clause 4 and shall not decline it only because the Respondent is not an employee of the Company. Where the Respondent is an employee, contract worker or person engaged through an agent or contractor, the complaint shall be inquired into under clause 5. In any other case, the Internal Committee shall examine the complaint, give the Respondent a reasonable opportunity to be heard where practicable, and make its recommendations to the Company.
c) In accordance with section 19 of the Act, the Company shall:
(i) assist the Aggrieved Woman, if she so chooses, in filing a complaint under the Bharatiya Nyaya Sanhita, 2023 or any other applicable law;
(ii) cause action to be initiated against the perpetrator under such law or, if the Aggrieved Woman so desires, at the workplace where the incident took place; and
(iii) take appropriate action under the applicable contract or terms of engagement, including restricting entry to the Workplace.
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a) Nothing contained in this Policy shall prejudice any right available to the aggrieved person, Complainant, Respondent, Company, IC or prevent any person from seeking any legal remedy under any law for the time being in force.
b) In case of any discrepancy in the Policy, the provisions of relevant POSH laws shall prevail.
c) The Company reserves the right to modify and or review the provisions of this Policy, so as to meet the requirement of the provisions of any applicable law.
d) The Policy is drafted in compliance of the present POSH laws and therefore all the implied procedure, provisions (present or if amended from time to time) shall be followed and applicable mutatis mutandis. Also, the mentioned timelines, limitations etc in the Policy shall be deemed to be replaced and updated with the new enactment(s), amendment (s), legal provision(s), ruling(s) and likewise as and when pronounced and effective.
e) IC shall have all powers as provided under the POSH laws and shall discharge their duties and dispose the complaints accordingly.
f) If any provision of the Policy is held to be illegal or invalid or amended for any reason, the illegality or invalidity shall not affect the remaining provisions hereof, but such provision shall be fully severable and the Policy shall be construed and enforced as if the illegal and invalid provision had never been included herein.
9
The Company shall in accordance with the POSH laws
a) Provide a safe working environment at the Workplace which shall include safety from persons coming into contact at the Workplace.
b) Display at any conspicuous place in the Workplace, the penal consequences of Sexual Harassment, and the order constituting, the Internal Committee.
c) Organise workshops and awareness programmes at regular intervals.
d) Provide necessary facilities to the Internal Committee for dealing with the Complaint and conducting inquires.
e) Assist in securing the attendance of Respondent and witness before the Internal Committee.
f) Make available such information to the Internal Committee.
g) Treat Sexual Harassment as a misconduct under the service rules and initiate action for such misconduct.
h) Monitor timely submission of IC reports.
i) Initiate action under the IPC/ BNS or other law.
10
The Complainant(s) or witnesses shall not be victimized or discriminated against, while dealing with complaints of Sexual Harassment or thereafter. This policy seeks to encourage all employees to express freely, responsibly and in an orderly way opinions and feelings about any problem or complaint of sexual harassment. Retaliation against persons who report or provide information about Sexual Harassment or behaviour that might constitute Sexual Harassment as also strictly prohibited.
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The Company understands that it is difficult for the aggrieved person to come forward with a complaint of Sexual Harassment and recognizes their interest in keeping the matter confidential.
Therefore, to protect the interest of the Complainant who reports incidents of Sexual Harassment and the Respondent who has been accused of Sexual Harassment, confidentiality shall be maintained throughout any inquiry process to extent practical and appropriate under the circumstances.
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The Committee shall meet at least once every financial year and review the efficacy of the implementation of the policy.
13
It will be the responsibility of Head – Human Resources to ensure the implementation of the Policy in the Company.
14
1.00
Prerna Kashyap
To align with the requirement of constitution of Internal Complaint Committee as per the POSH act
30.3.2026
2.00
Soma Gambhir
Changes made in alignment with the POSH Act and Rules, apart from other cosmetic and language modification. Change in the email id and updating of list of IC members and FIFs
9.10.2026
15
Policy on Prevention, Prohibition and Redressal of Sexual Harassment. List of First Instance Facilitators (FIFs)
16
Policy on Prevention, Prohibition and Redressal of Sexual Harassment. Complaints can be addressed to the Member(s) of the Internal Committee or sent to posh@getshopse.com