Prevention of Sexual Harassment at the Workplace Policy

Eternal General Service Foundation (hereby referred to as Eternal Foundation or the Company) has zero tolerance for sexual harassment at the workplace. We aim to create a comfortable environment that encourages growth and development of all people, and we believe that a secure and fearless workplace is pivotal to organizational success.

We encourage harmonious work relations based on mutual trust and respect between all employees. Discrimination and harassment of any type are strictly prohibited.

Eternal Foundation strictly prohibits Sexual Harassment in any form at its workplaces and will take necessary actions to address any violations of this policy. This Policy aligns with the Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013 (the SHW Act) and applicable rules.

This global Policy applies to Employees of Eternal Foundation, affiliates, group companies, and contractual staff. It also applies to visitors, suppliers, customers, and business associates (Third Parties) who interact with Employees during or arising out of work.

Employees include all permanent and temporary employees, probationers, trainees, interns, consultants, volunteers, secondees, and persons engaged through contractors, vendors, service providers, digital platforms, intermediaries, or gig arrangements where interaction arises out of or in connection with Company work or workplace.

This Policy covers misconduct on Company premises and all work-related interactions, including travel, off-sites, third-party locations, public venues, work from home, cyberspace, social media, and electronic communication where there are work-related consequences.

For this Policy, Workplace includes:

Sexual Harassment includes one or more unwelcome acts or behavior (directly or by implication):

The following circumstances in relation to an act of Sexual Harassment may also amount to Sexual Harassment:

Important note: The impact on the recipient, and not the intent of the offender, is critical in assessment of these issues.

Illustrative examples include:

Consensual, welcome, appreciated, and reciprocated interactions within professional norms and the Company Code of Conduct may not amount to Sexual Harassment. However, once discomfort or unwelcomeness is expressed, continuation of such behavior may amount to Sexual Harassment.

Any romantic relationship between co-workers with a senior/subordinate reporting dynamic must be disclosed at the first possible instance to the relevant People Team representative. In the absence of disclosure, such relationships may be considered conflict of interest.

Any grievance of Sexual Harassment against any Employee or Third Party may be submitted in writing by Employees or Third Parties by emailing speakup@eternalfoundation.com.

Complaints by Aggrieved Women (women or trans women) are addressed under the SHW Act by the Internal Committee (IC). Complaints by persons not covered by the SHW Act (including men, trans men, or non-binary persons) are also addressed under this Policy by the IC acting as disciplinary committee.

The IC acts promptly, maintains confidentiality to the extent practicable, and employees are expected to cooperate fully in investigations.

An Aggrieved Person may file a complaint in writing to speakup@eternalfoundation.com within 3 months of occurrence, or in case of a series of incidents, within 3 months of the latest incident.

The IC may extend the period by a further 3 months where reasonable circumstances prevented timely filing.

The complaint should identify the Respondent, circumstances, dates, locations, witness names, and any available evidence.

In cases of physical or mental incapacity, complaint may be filed by a relative, friend, co-worker, psychiatrist/psychologist, or person with knowledge, with appropriate consent.

Anonymous complaints are generally discouraged; however, where risk is indicated, the IC may conduct preliminary assessment and direct referral to relevant company channels.

Retaliation is strictly prohibited. False testimony or forged or misleading documents may invite disciplinary action.

Complainants are advised to maintain a record of incidents. While not mandatory, it may strengthen the case.

On receiving a complaint, the IC may prepare a detailed statement, explore conciliation at the complainant request (without monetary settlement), or proceed with inquiry where required.

Where inquiry proceeds, complaint details are shared with the Respondent for response. Hearings may be held online, on call, or in person.

During inquiry, the IC may adopt interim measures to protect complainant and witnesses, including transfer, reporting changes, leave, and other safeguards.

As far as practicable, inquiry under the SHW Act is completed within 90 days. No party may be represented by an external legal practitioner in IC proceedings.

Upon completion, findings are communicated to parties, and final report is shared with designated stakeholders. Parties may be required to provide non-disclosure undertakings before accessing report details.

No parallel fact-finding or disciplinary process will run for the same complaint once IC inquiry has commenced and until valid conclusion.

After inquiry, the IC may conclude that complaint is substantiated, partially substantiated, or not substantiated. Proportionate action is recommended based on findings and severity.

Where complaint is not substantiated, non-disciplinary preventive measures may still be recommended to prevent future discomfort.

Where Sexual Harassment is substantiated, disciplinary actions may include:

Disciplinary action is implemented by the People Team, ordinarily within 60 days of receiving IC report.

If a complaint is found malicious after separate inquiry, action may be taken against complainant. Mere lack of evidence is not treated as malice.

Information related to complaints, parties, witnesses, inquiry proceedings, recommendations, and actions is treated as confidential except where disclosure is legally required or required by statutory reporting obligations.

Retaliation against complainants or witnesses is serious misconduct and may lead to severe disciplinary action up to termination, even where original complaint is not substantiated.

Where a witness is found to have testified falsely on oath or submitted forged or misleading documents, disciplinary action may be recommended.

Any change in this Policy shall be approved by the Board. The Board may withdraw or amend any part or whole of this Policy from time to time. Subsequent legal and regulatory amendments will apply automatically, where applicable.

The Internal Committee (IC) is responsible for supervision of this Policy. All employees are required to comply with this Policy. Any queries may be referred to the IC.

The Company shall maintain disclosures, filings, and records relating to Sexual Harassment complaints in accordance with applicable labor laws and compliance systems.

Where this Policy conflicts with any existing or newly enacted law, rule, regulation, or standard, the law will prevail. Internal Committee details and membership composition are available through Company internal communication channels and updated from time to time.

The Company reserves the right to amend, supplement, or rescind provisions of this Policy at its discretion. This is a confidential internal document of the Company. For clarification, write to speakup@eternalfoundation.com.