Policy against Sexual Harassment

1. Purpose

UGC Supply Chain Solutions Pvt. Ltd. is committed to providing a safe, respectful and inclusive work environment where all individuals are treated with dignity. This policy outlines UGC’s zero-tolerance approach towards sexual harassment in the workplace and provides a framework for preventing, reporting and addressing incidents of such misconduct.

2. Scope

This policy applies to all employees, contract workers, consultants, interns, apprentices, vendors, clients and visitors, across all locations and premises under the operational control of UGC, including offsite locations, digital communications and work-related events.

3. Policy Statement

Sexual harassment is strictly prohibited and will not be tolerated under any circumstances. UGC is committed to:

• Preventing any form of sexual harassment in the workplace.
• Promoting awareness and providing training to all employees.
• Establishing a clear mechanism for reporting and resolving complaints.
• Ensuring confidentiality, impartiality and non-retaliation throughout the process.

4. Definition of Sexual Harassment

Sexual harassment includes, but is not limited to, the following unwelcome acts or behavior:

• Physical contact and advances;
• Demand or request for sexual favors;
• Sexually colored remarks or jokes;
• Display or circulation of sexually explicit or suggestive material;
• Inappropriate or offensive gestures, comments or innuendos;
• Repeated and unwelcome social invitations;
• Any verbal, non-verbal, written, physical or visual conduct of a sexual nature that interferes with an individual’s work performance or creates a hostile, intimidating or offensive work environment.

5. Preventive Measures

To uphold a harassment-free workplace, the Company will:

• Sensitize all personnel through induction, periodic training and awareness campaigns;
• Promote respectful behavior and inclusivity through organizational values;
• Incorporate this policy into all employment agreements and codes of conduct.

6. Complaints Committee

UGC has established a duly constituted Internal Complaints Committee (ICC), also known as the POSH Committee, in accordance with its commitment to ensure a harassment-free workplace. The POSH Committee shall:

• Include a Presiding Officer (senior woman employee), two or more employees committed to women’s cause or with legal/ social expertise and an external member with experience in social work or legal matters;
• Be empowered to receive, investigate and resolve complaints in a time-bound and confidential manner;
• Submit annual reports to management on the number of complaints received, resolved and actions taken;
• Ensure all inquiries are conducted fairly, impartially and with respect for the rights of all parties involved.

7. Reporting and Redressal Mechanism

• How to Report: Complaints can be submitted in writing to the POSH Committee or through a secure digital channel designated for this purpose.
• Time Frame: Complaints should ideally be lodged within 3 months of the alleged incident.
• Process: The POSH Committee will conduct a fair and impartial inquiry within a stipulated time frame, ensuring both the complainant and respondent are heard.
• Interim Relief: UGC may provide interim measures (e.g., temporary transfer, leave) to ensure the safety and comfort of the complainant.
• Outcome: Disciplinary action may include warning, reprimand, transfer, reduction of grade or termination of employment, depending on the severity of misconduct.

8. Confidentiality and Protection from Retaliation

• All proceedings, records and identities will be kept strictly confidential.
• The Company will ensure that no retaliatory action is taken against any person for reporting a complaint in good faith or participating in an inquiry.

9. Malicious Complaints

False complaints made with malicious intent are subject to disciplinary action. However, the inability to prove an allegation does not imply a malicious complaint.

10. Roles and Responsibilities

Stakeholder	Responsibilities
Management	Provide resources, oversight and leadership commitment
POSH Committee	Conduct inquiries and recommend appropriate actions
HR Department	Facilitate awareness, training, documentation and process support
All Employees	Uphold a respectful workplace and report violations without fear

11. Monitoring and Review

The implementation of this policy will be reviewed annually. Improvements will be made based on feedback, changing needs or any organizational, legal or ethical developments.