Workplace POSH Policy

Effective date and version: September 27, 2026 (Version 1.0). This document is available in English only and forms part of, and shall be read together with, the Terms of Service and the Privacy Policy.

1. Policy Statement and Core Objective

1.1 Khypri AI (the “Company”) is committed to providing a safe, respectful, and inclusive working environment free from sexual harassment, intimidation, exploitation, or discrimination. The Company maintains a zero-tolerance policy against sexual harassment in any form in accordance with The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (the “POSH Act”) and applicable statutory rules.

1.2 Every individual associated with the Company has the right to be treated with dignity and respect. This Policy sets out the framework for the prevention, prohibition, and prompt redressal of sexual harassment complaints, ensuring fair inquiries, strict confidentiality, and complete protection against victimisation.

2. Comprehensive Workforce Scope

2.1 This Policy applies universally across all organizational tiers and operational roles. It governs all personnel engaged with or performing work for the Company, regardless of location, designation, or employment classification, including:

• Full-Time Employees: Regular permanent managerial, technical, administrative, and executive staff.
• Part-Time Employees: Staff engaged on part-time schedules or reduced hours.
• Contractual Staff and Retainers: Personnel hired through third-party agencies, fixed-term contractors, and retainers.
• Interns, Apprentices, and Trainees: Paid or unpaid interns, research associates, and educational apprentices.
• Independent Freelancers and Consultants: Gig workers, freelance developers, content creators, legal experts, advisory consultants, and external service providers engaged under contracts for services.

3. Definition of Workplace

3.1 Extended Physical and Remote Workplace: For the purposes of this Policy, the term “Workplace” extends beyond traditional office premises to include:

• Physical offices, branch locations, conference centers, and registered premises of the Company.
• Remote working locations, Work From Home (WFH) environments, co-working spaces, and temporary field sites.
• Offsite client premises, business travel destinations, field visits, industry conferences, and company-sponsored social events or meals.
• Digital and Virtual Workspaces: All digital communication channels used for work, including email, instant messaging apps (Slack, Microsoft Teams, WhatsApp), video conferencing platforms (Zoom, Google Meet), shared code repositories, and collaborative development tools.

4. Prohibited Conduct and Definition of Sexual Harassment

4.1 Sexual Harassment includes any one or more of the following unwelcome acts, behaviors, or gestures (whether directly, indirectly, or digitally):

• Physical contact and advances, or unwelcome physical closeness.
• A demand or request for sexual favors.
• Making sexually colored remarks, jokes, or offensive comments regarding gender or appearance.
• Showing pornography or sexually explicit visual/digital content.
• Any other unwelcome physical, verbal, non-verbal, or electronic conduct of a sexual nature.

4.2 Quid Pro Quo and Hostile Work Environment: The following circumstances, if connected with any act of sexual harassment, shall also constitute prohibited conduct under this Policy:

• Implied or explicit promise of preferential treatment in employment, contract renewal, or assignment allocation.
• Implied or explicit threat of detrimental treatment or termination of engagement.
• Interference with work performance or creating an intimidating, hostile, or offensive working environment.
• Humiliating treatment likely to affect health, safety, or professional standing.

5. Internal Complaints Committee (ICC)

5.1 Constitution: The Company has constituted an Internal Complaints Committee (ICC) to handle and inquire into all complaints of sexual harassment. The ICC is headed by a senior female Presiding Officer and includes employee members as well as an independent external member experienced in social work, law, or POSH compliance.

5.2 Contacting the ICC: Complaints may be submitted in writing or via secure electronic communication directly to the ICC at posh@khypri.com.

6. Complaint and Inquiry Procedure

6.1 Filing a Complaint: Any aggrieved person (or their legal heir/representative if incapacitated) may file a written complaint with the ICC within three (3) months from the date of the incident (or last incident in a series).

6.2 Conciliation Option: Prior to initiating a formal inquiry, the ICC may, at the explicit request of the complainant, take steps to settle the matter through informal conciliation, provided no monetary settlement forms the basis of conciliation.

6.3 Formal Inquiry Process: Where conciliation is not requested or fails, the ICC shall initiate a formal inquiry adhering to principles of natural justice:

• The inquiry shall be completed within a statutory timeframe of ninety (90) days.
• Both parties shall be provided full opportunity to present evidence and witness testimony.
• The ICC shall submit its final Inquiry Report within ten (10) days of inquiry completion to the Executive Management.

6.4 Interim Relief: During the pendency of an inquiry, the ICC may recommend interim measures—including temporary re-assignment, digital interaction isolation, or paid leave up to three (3) months—to protect the complainant.

7. Strict Confidentiality and Non-Retaliation

7.1 Mandatory Confidentiality: In accordance with Section 16 of the POSH Act, the identity of the complainant, respondent, witnesses, and ICC proceedings shall remain strictly confidential and shall not be published or communicated to unauthorized persons.

7.2 Protection Against Victimisation: The Company strictly prohibits victimisation, retaliation, or adverse personnel action against any individual for filing a complaint in good faith or assisting in an inquiry. Any act of retaliation shall be treated as a severe disciplinary breach leading to immediate termination of employment or contract.

8. Preventive Awareness and Statutory Compliance

8.1 Sensitization and Onboarding: The Company conducts regular POSH awareness workshops and incorporates mandatory POSH orientation into onboarding for all full-time employees, contractors, and freelancers.

8.2 Annual Reporting: The ICC prepares and submits an Annual POSH Compliance Report to the management and relevant District Officer pursuant to Section 21 of the POSH Act.

9. Alignment with Indian Labour Codes (2019/2020)

9.1 Comprehensive Labour Standards: In addition to the POSH Act 2013, the Company aligns its workforce policy with the Code on Wages, 2019, the Social Security Code, 2020, and the Industrial Relations Code, 2020. All full-time employees, part-time staff, contractual workers, retainers, and remote freelancers are guaranteed equal opportunity, fair contractual terms, timely compensation, non-discriminatory treatment, and complete statutory protection against workplace harassment or exploitation.