SEXUAL HARASSMENT OF WOMAN AT WORKPLACE (P, P,R) POLICY

1. Introduction

Infrastructure Leasing & Financial Services Limited (hereinafter referred to as “Employer”) is committed
to maintaining an environment where all women, enjoy a safe, friendly and supportive working
environment, free of harassment and exploitation. Sexual harassment (as defined below) and abuse
damages both individual and organizational health

In view of the aforesaid, and in light of the provisions of The Sexual Harassment of Women at Workplace
(Prevention, Prohibition and Redressal) Act, 2013 (“Act”), the objective of this Policy is to:

a. provide protection against sexual harassment of women at workplace ; and

b. prevention and redressal of Complaints (as defined below) of sexual harassment

The terms of this Policy should be read in conjunction with the Act and the Rules framed there under. In case
of any inconsistency between this Policy and the Act/Rules, then the Act/Rules (as amended and modified
from time to time) shall prevail. Every employee should be aware that the Employer is strongly opposed to
sexual harassment and such behavior is prohibited. Violation of this Policy will not be permitted and will result
in disciplinary action, including termination of services

2. Applicability

a. This Policy is applicable to (i) persons employed at the workplace by the Employer for any work on
a regular, temporary ad hoc or daily wage basis, either directly or through an agent including a
contractor, with or without the knowledge of the principal employer, whether for remuneration or
not, working on a voluntary basis or otherwise, whether the terms of employment are express or
implied and includes a co-worker, contract worker, probationer, trainee, apprentice or called by
any other such name and; (ii) any aggrieved woman at workplace, who alleges to have been
subjected to any act of sexual harassment (“Complainant”)

b. This Policy shall also be applicable to (i) persons employed at the workplace outside India, by the
Employer for any work on a regular, temporary adhoc or daily wage basis, either directly or
through an agent including a contractor, with or without the knowledge of the principal employer,
whether for remuneration or not, 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 and; (ii) any aggrieved woman at workplace outside India, who
alleges to have been subjected to any sexual harassment (“Complainant”). Provided however, in
case of any inconsistency between this Policy and the applicable laws prevalent in the relevant
jurisdiction, if any, then the relevant applicable laws (as amended and modified from time to time)
shall prevail.

3. Aggrieved Woman : In relation to a workplace an aggrieved woman means a woman, of any age whether
employed or not, who alleges to have been subjected to any act of sexual harassment by the respondent.
Any women employed at a workplace for any work on regular, temporary, adhoc, or daily wage 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, a contract worker, probationer,
trainee, apprentice, or called by any other such name

4. Workplace : Any place visited by the employee arising out of or during the course of employment,
including transportation provided by the employer for undertaking such a journey. A workplace includes

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 private sector organisations, or a private venture, undertaking, enterprise, institution,
establishment, society, trust, non-governmental organisation, unit or service provider carrying on
commercial, vocational, educational, entertainment, industrial, health services or financial activities,
including production, supply, sale, distribution or service. It also includes hospitals and nursing homes,
sports institutes, stadiums, sports complex or competition or games venue, whether residential or not
used for training, sports or other activities

5. What is 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, such as seeking sexual favours or advances in exchange
for work benefits or refusal to comply with a ‘request’ is met with retaliatory action such as
dismissal, demotion, difficult work conditions; or
c. Sexually coloured remarks; or
d. Showing pornography; or
e. Entry into a private place marked for woman, with the intent to commit mischief and harassment;
or
f. Taking photographs of aggrieved woman without permission and converting it into pornographic
material and/or circulating the same by means of electronic media; or
g. Any other unwelcomed physical, verbal or non-verbal conduct of sexual nature; including eve-
teasing, gender based insults or sexist remarks, unwelcome sexual overtone in any manner, like
obnoxious telephone calls, touching or brushing against any part of the body, displaying
pornographic or other offensive or derogatory pictures, cartoons, pamphlets or sayings, forcible
physical touch or molestation.

The following circumstances, among other circumstances, if it occurs or is present in relation to or

connected with any act or behavior of sexual harassment may amount to sexual harassment:-

h. Implied or explicit promise of preferential treatment in her employment, or

i. Implied or explicit threat of detrimental treatment in her employment; or
j. Implied or explicit threat about her present or future employment status; or
k. Interference with her work or creating an intimidating or offensive or hostile work environment
for her; or
l. Humiliating treatment likely to affect her health or safety.

Sexual harassment shall also include such unwelcome sexually determined behavior by any person either
individually or in association with other persons or by any person in authority whether directly or by
implication which amounts to offence defined in the Indian Penal Code.

6. If You are being harassed:

a. Keep a record of incidents (dates, times, locations, possible witness, what happened, your
response). It is not mandatory to have a record of events to file a Complaint, but a record can
strengthen your case and helps you remember the details over time, in case the Complaint is not
filed immediately.

b. May try telling the harasser that his behaviour is unwelcome and ask him to stop

c. File a Complaint as soon as possible and, report the abuse to the Internal Complaints Committee
formed for this purpose.

7. Constitution of Internal Complaints Committee :

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 a. A Committee known as the "Internal Complaints Committee" (ICC) for Infrastructure Leasing &
Financial Services Limited has been constituted at Mumbai with following members:

Name Company

Ms. Lubna Usman Presiding Officer IFIN

Ms. Shaivali Parekh Member IL&FS
Ms. Sudakshina Bhattacharya Member IFIN
Ms. Meghana Singh Member IFIN
Mr. Gaurav Khungar Member IFIN
Mr. Neerav Kapasi Member IL&FS
Mr. Amit Shah Member IFIN
Ms. Shobha Sachdev NGO Member -

b. The term of the members of the ICC will not exceed three years from the date of their nomination

c. An exclusive email id being ICCChairperson@ilfsindia.com is created with access only to the ICC

d. All employees shall address any sexual harassment complaints only to the ICC and not to talk or
disclose information on the case to anybody else except to persons permitted to make a complaint
on behalf of the Complainant as set out in this policy

e. Meetings of the ICC to be held :

i. Every quarter
ii. Within 7 (seven) days from receipt of Complaint
iii. Such other special meetings to address the Complaints pertaining to sexual harassment of the
female employees

f. It shall prepare an annual report in each calendar year and submit the same to the Employer and
the District Officer which shall have the following details:

 Number of complaints of sexual harassment received in the year

 Number of complaints disposed off during the year
 Number of cases pending for more than ninety days
 Number of workshops or awareness programmes against sexual harassment carried out
 Nature of actions taken by the Employer
g. In conducting the inquiry, a minimum of three members of the ICC including the Presiding Member
shall be present

8. Filing Complaint with ICC

a. The procedure for filing the Complaint is contained in Annexure A subject to such
amendments/modifications as per applicable laws

b. Indicative formats of the Complaint, reply of Respondent and statement of witnesses are annexed
hereto as Annexures B, C and D respectively (which formats may be modified by the ICC members
as may be necessary from time to time). The formats may be followed by the Complainant and
Respondent as required.

9. Settlement of Complaint

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 a. Before initiating an inquiry on the Complaint, ICC may at the request of the Complainant take steps
to settle the matter between her and the Respondent through conciliation, provided that monetary
settlement shall not be made a basis of conciliation

b. If a settlement has been arrived at, the ICC shall:

i. Record the settlement and forward the same to the Employer to take action as specified in the
recommendation; and

ii. Provide copies of the settlement as recorded to the Complainant and the Respondent and no
further inquiry shall be conducted.

c. The indicative format of the settlement is annexed as Annexure E, which may be modified by the
ICC members as may be necessary from time to time

10. Termination Of Inquiry /Ex-Parte Order

The ICC shall, after giving prior fifteen days’ notice in writing to the concerned party, have the right to
terminate the inquiry proceedings or pass an ex-parte decision on the Complaint, if the Complainant or
Respondent fails, without sufficient cause, to present herself or himself for three consecutive meetings
of the convened by the Presiding Officer.

11. Inquiry Of Complaint By ICC

a. In case no conciliation has been arrived at or the terms of conciliation are not complied with, then
at the request of the Complainant (where the Respondent is an employee), the ICC shall proceed
to make an inquiry into the Complaint in accordance with the provisions of the service rules
applicable to the Respondent or in accordance with the Rules formulated under the Act.

b. During the course of inquiry:

i. Where both the Complainant and the Respondent are employees, both the parties shall be given
an opportunity of being heard;

ii. A copy of the findings shall be made available to both the parties enabling them to make
representation against the findings before ICC;

iii. Both the Complainant and the Respondent will be interviewed, and also such individuals who
may be able to provide relevant information;

iv. ICC shall have the same powers as are vested in a Civil Court under the Code of Civil Procedure,
1908 namely summoning and enforcing attendance of any person and examining him on oath
and requiring the discovery and production of documents

v. ICC shall make inquiry into the complaint in accordance with the principles of natural justice.

c. The inquiry shall be completed within a period of ninety days

d. The parties shall not be permitted to bring any legal practitioner to represent them in their case at
any stage of the proceedings before the ICC

12. Action Pending Inquiry By ICC :

During the pendency of an inquiry, on a written request made by the Complainant, ICC may recommend
to the Employer to:

a. Transfer the Complainant or the Respondent to any other workplace; or

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 b. Grant leave to the Complainant upto a period of three months (this leave shall be in addition to
the leave she would be otherwise entitled); or

c. Restrain the Respondent from reporting on the work performance of the Complainant or writing
her confidential report and assign the same to another officer

On the receipt of recommendation from ICC, the Employer shall promptly implement the
recommendations made and send the report of such implementation to ICC.

13. Completion Of Inquiry By ICC:

On completion of the inquiry proceedings:

a. ICC shall provide a report of its findings to the Employer, within a period of ten days from the date of
completion of the inquiry and such report shall be made available to the concerned parties. An
indicative format of the said Report is annexed as Annexure F which may be modified by the ICC
members as may be necessary from time to time;

b. Where ICC arrives at a conclusion that the allegation against the Respondent has not been proved,
it shall recommend the Employer that no action is required to be taken in the matter;

c. Where ICC arrives at a conclusion that the allegation against the Respondent has been proved, it
shall recommend to the Employer :

i. To take action for sexual harassment as a misconduct in accordance with the provisions of
the service rules applicable to the Respondent or, in the following manner including:

 Written apology
 Warning
 Reprimand or censure
 Withholding of promotion
 Postponement or withholding or stoppage of increment, performance related pay or
promotion or pay rise
 Demotion to a lower post or grade or to a lower stage in his incremental scale
 Suspension
 Termination of services
 Undergoing a counseling session
 Carrying out community service

ii. To deduct, notwithstanding anything in the service rules applicable to the Respondent, from
the salary or the wages of the Respondent such sum as it may consider appropriate to be
paid to the Complainant or to her legal heirs. For the purpose of determining the sums to
be paid to the Complainant, ICC shall have regard to

 The mental trauma, pain, suffering and emotional distress caused to the Complainant
 The loss in the career opportunity due to the incident of sexual harassment
 Medical expenses incurred by the Complainant for physical or psychiatric treatment
 The income and financial status of the Respondent
 Feasibility of such payment in lump sum or in installments

iii. In case Employer is unable to make such deduction from the salary of the Respondent due
to his being absent from duty or cessation of employment, it may direct the Respondent to
pay such sums to the Complainant. Further, in case Respondent fails to pay such sums, ICC
may forward the order for recovery of the sum as arrears of land revenue to the concerned
District Officer

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 iv. To take disciplinary action for sexual harassment as a misconduct in accordance with the
provisions of the service rules applicable to the Respondent

d. Where ICC arrives at a conclusion that during an inquiry, any witness has given false evidence or
produced any forged or misleading document, it may recommend to the Employer of the witness,
to take action in accordance with Clause 11(c)(i) above

14. Appeal

(a) Any person aggrieved on account of recommendations made by ICC or due to non-implementation
of such recommendations by the Employer, may prefer an appeal to the court or tribunal in
accordance with the Rules framed under the Act, where applicable. Provided However, if the person
aggrieved, does not fall within the ambit of the Act and Rules framed thereunder, then in such a
person may prefer an appeal to the Chairman of the Employer/IL&FS Group HR Head/such person
as may be nominated by ICC

(b) The appeal shall be made within a period of ninety days of the recommendations of ICC

15. Action By Employer On Recommendation Made By ICC On Conclusion Of Inquiry

The Employer shall act on the recommendation made by ICC within sixty days of its receipt

16. Protection Against Retaliation

Regardless of the outcome of the Complaint made in good faith, the Complainant and any person
providing information or any witness, will be protected from any form of retaliation. While dealing with
Complaints of sexual harassment, ICC shall ensure that the Complainant or the witness(es) are not
victimized or discriminated against by the Respondent. Any unwarranted pressures, retaliatory or any
other type of unethical behaviour from the Respondent against the Complainant while the inquiry is in
progress should be reported by the Complainant to ICC as soon as possible. Disciplinary action will be
taken by ICC against any such complaints which are found genuine

17. Malicious Complaint

If ICC 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 has produced forged or misleading documents, it may
recommend to the Employer, to take action against the Complainant in accordance with the provisions
of the service rules as applicable or as in accordance with Clause 11(c)(i) above. However, failure/ inability
to substantiate /prove a claim of sexual harassment does not constitute proof of a false and / or malicious
accusation. Malicious intent on the part of the Complainant shall be established after an inquiry in
accordance with the procedure prescribed under the service rules, before any action is recommended

18. Confidentiality

1. It shall be the duty of all the persons including members of ICC involved to ensure that the
Complaint, identity and addresses of the Complainant, Respondent, witnesses, any information
relating to conciliation and inquiry proceedings, recommendations of ICC and/or action taken by
the Employer shall not be published, communicated or made known to public, press and media in
any manner and shall be strictly confidential

2. The members of the ICC and the Employer shall use best endeavours to ensure to keep the
investigation and disseminate information on a strict "need to know" basis. The ICC shall emphasize
to all persons involved in the investigation, including the Complainant, the Respondent and
witnesses, that the policy is to keep discussions strictly confidential and that disciplinary
consequences may result from a breach of this confidence

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 3. In any event, the ICC shall make best efforts to

a. Limit the number of persons who have access to the aforesaid information
b. Avoid needless disclosure of information to witnesses

4. However, information may be disseminated regarding the justice secured to any victim of sexual
harassment without disclosing the name, address, identity or any other particulars calculated to
lead to the identification of the Complainant and witnesses

5. If any person who is entrusted with the duty to handle or deal with the Complaint, inquiry or any
recommendations or actions to be taken under the provisions of the Act) contravenes the aforesaid,
then he/she shall be liable for penalty in accordance with the service rules or the Employer shall
recover a sum of five thousand rupees as penalty from such person.

19. Invitees

If the ICC considers it is necessary for achieving the objectives of the Act, the ICC may call upon persons:

i. To appear as witnesses during the inquiry proceedings to provide factual information/details

regarding the Complainant, the Respondent or any other similar matter; or

ii. To provide general guidance and training to the members of the ICC; or

iii. To assist and advise the ICC members in conducting the investigations to the complaint, without
being a part of the inquiry proceedings However, it is pertinent to note that the inputs provided
by these invitees shall not:

a. Be binding on the members of ICC;

b. Directly or indirectly or in any other manner, dilute and/or transfer the powers/obligations
and rights of the members of the ICC as provided under the Act and/or the Rules framed
thereunder

20. Duties of The Employer

Subject to the provisions of the Act and Rules/applicable laws prevalent in the relevant jurisdiction, the
duties of the Employer is shall be as contained in Annexure G of the policy

21. Modifications To The Policy:

The provisions of this Policy can be altered, added to, varied or substituted from time to time at the
discretion of a competent authority as maybe designated by the Employer

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 Annexure A

Procedure for filing complaint

1. The Complaint should be made by the Complainant in writing. In case where the Complaint cannot be
made in writing, the Presiding Officer or any member of the ICC shall render all reasonable assistance to
the Complainant to make the Complaint in writing

2. Where the Complainant is unable to make a complaint on account of her physical incapacity, Complaint
may be filed by:
i. Her relative or friend;
ii. Her co-worker;
iii. An officer of the National Commission for Women or State Women’s Commission;
iv. Any person who has knowledge of the incident with the written consent of the Complainant

3. Where the Complainant is unable to make a complaint on account of her mental incapacity, Complaint
may be filed by:
i. Her relative or friend;
ii. A special educator
iii. A qualified psychiatrist or psychologist
iv. The guardian or authority under whose care she is receiving treatment or care; or
v. Any person who has knowledge of the incident jointly with her relative or friend or a special educator
or a a qualified psychiatrist or psychologist or a guardian or authority under whose care she is
receiving treatment or care;

4. Where the Complainant for any other reason is unable to make a complaint, a Complaint may be filed by
any person who has knowledge of the incident, with the Complainant’s written consent

5. Where the Complainant is dead, a complaint may be filed by any person who has knowledge of the
incident, with the written consent of the legal heir

6. The Complaint of sexual harassment at workplace to the ICC should be filed within a period of three months
from the date of incident and in case of a series of incidents, within a period of three months from the date
of last incident
7. However, the ICC may for reasons recorded in writing extend the said period for a further period 8 not
exceeding three months, if it is satisfied that circumstances prevented the Complainant from filing the
Complaint within the said period
9. A Non -Disclosure Undertaking shall be signed by all individuals concerned with the Complaint;
including the Complainant, the Respondent, witnesses (if any) prior to commencing an inquiry. The
indicative format of the Non- Disclosure Undertaking is annexed as Annexure H, which may be modified
by the ICC members as may be necessary from time to time

10. One of the copies of the Complaint shall be sent to the Respondent within seven working days of the
receipt of the Complaint

11. The Respondent shall file his reply to the Complaint along with his list of documents and names and
addresses of witnesses within a period not exceeding ten working days from the date of receipt of the
Complaint.

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 Annexure B

Format of the Complaint

Sr. No. Query Particulars

1) Name of Complainant
2) Address and contact number of the Complainant
3) Name, address and contact of next of kin of the
Complainant
4) Designation of the Complainant
5) Immediate supervisor of the Complainant
6) Employer of the Complainant
7) Name of Respondent
8) Address and contact number of the Respondent, if
available
9) Name, address and contact of next of kin of the
Respondent, if known
10) Designation of the Respondent, if known
11) Immediate supervisor of the Respondent, if known
12) Employer of the Respondent, if known
13) Details of the incident
14) Date and time of incident
(If more than one, kindly mention all the dates and times)
15) Place of incident
(If more than one, kindly mention all the places)
16) Details of the incident
17) Witnesses to the incident, if any
(If more than one, kindly mention all the witnesses)
18) Any oral or written evidence of the incident
(attach copies of the documents, if any)
19) Names and addresses of person(s) who the Complainant
confided in about the incident, if applicable
20) Any further relevant details
I state that the information as stated above is true and accurate
Date:

Signature of Complainant

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 Annexure C

Format of the Reply of the Respondent

Sr. No. Query Particulars

1) Name of Respondent

2) Address and contact number

3) Name, address and contact of next of kin

4) Designation

5) Immediate supervisor

6) Employer

7) Details of the incident

8) Defenses of the Respondent

Any oral or written evidence supporting the
9) Respondent’s defense
(attach copies of the documents, if any)
Witnesses to support the Respondent’s defense, if
10) any
(If more than one, kindly mention all the witnesses)
11) Any further details
1. I state that the information as stated above is true and accurate

Date:

Signature of Respondent

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 Annexure D

Format of Witness statement

Sr. No. Query Particulars

I. Name of witness

II. Address and contact number

III. Designation

IV. Immediate supervisor

V. Employer

VI. Witness for Complainant or Respondent

VII. Details of the incident

VIII. Date and time of incident(s)

IX. Place of incident(s)

X. Circumstances

XI. Number of occurrences witnessed

Reaction to the incident by Complainant/
XII.
Respondent
XIII. Any oral or written evidence of the incident

XIV. Any further details

I state that the information as stated above is true and accurate. I hereby confirm that I shall at all times maintain
the confidentiality of all information that I am privy to and that may be shared with during the course of the inquiry
proceedings. I will not, either directly or indirectly, make any disclosure of any confidential information to any
third party.

Date:

Signature of Witness

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 Annexure E
Format for Settlement through the conciliation mechanism

[On the letterhead of the ICC]

[Date]

[____] .. Complainant

[______] .. Respondent

ICC Members present:

[_]
[_]
[_]

The Complainant had filed a Complaint dated [_] with the ICC in relation to certain allegations against the Respondent. The
Complaint had been duly taken on record by the ICC and had sent a copy of the Complaint to the Respondent within [] days.

The ICC has not yet initiated an inquiry into this matter.

The Complainant had 1through her letter dated [__] requested the ICC to settle the matter between the Complainant and the
Respondent.

The parties have thus reached a settlement and the terms of which are as under:

[]

The Respondent shall comply with the aforesaid terms and conditions within [] days of the date hereof.

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 Annexure F

Format of the Report of the ICC

Sr. No. Broad Heads Particulars

I. Name and other details of the Complainant
II. Name and other details of the Respondent
III. Date of complaint
Whether the inquiry has been concluded within 90
IV.
days of receipt of Complaint
Documentation/ oral evidence relied upon by the
V.
Complainant
Documentation/ oral evidence relied upon by the
VI.
Respondent
Whether the Complainant requested conciliation
VII. and settlement of the matter and if yes, the reason
why the complaint was not settled
Any recommendation for interim action pending
VIII.
completion of inquiry
IX. Reasons for the recommendation
X. Detailed facts of the incident
Whether the incident can be termed as sexual
XI.
harassment under the Act
XII. Detailed reasons for the decision in XI above
XIII. Action recommended against the Respondent
XIV. Reasons for recommending the said action
Whether the Complainant has filed a criminal action
XV.
against the Respondent and status of the same
Date:

Signature of the ICC Members

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 Annexure G

Duties of Employer

The Employer shall:

(a) Provide a safe working environment at the workplace which shall include safety from the
persons coming into contact at the workplace;

(b) Display at any conspicuous place in the workplace, the penal consequences of sexual
harassments and the order constituting the ICC;

(c) Formulate and widely disseminate an internal policy for prohibition, prevention and redressal
of sexual harassment at the workplace intended to promote a gender sensitive safe space
and remove underlying factors that contribute towards a hostile work environment against
women;

(d) Carry out employees awareness programmes and create forums for dialogues which may
involve any other body as may be considered necessary

(e) Use modules developed by the State Government to organise and conduct workshops and
awareness programmes at regular intervals for sensitizing the employees with the provisions
of the Act

(f) Carry out orientation programmes and seminars for the members of ICC;

(g) Conduct capacity building and skill building programmes for the Members of the ICC.

(h) Declare the names and contact details of all the Members of the ICC.

(i) Provide necessary facilities to ICC for dealing with the Complaint and conducting an inquiry;

(j) Assist in securing the attendance of Respondent and witnesses before the ICC

(k) Make available such information to the ICC from time to time as it may require having regard
to the Complaint;

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(l) Provide assistance to the Complainant if she chooses to file a complaint in relation to the
offence under the Indian Penal Code or any other law for the time being in force

(m) Cause to initiate action, under the Indian Penal Code or any other law for the time being in
force, against the perpetrator, or if the Complainant so desires, where the perpetrator is not
an employee, in the workplace at which the incident of sexual harassment took place;

(n) Treat sexual harassment as a misconduct under the service rules and initiate action for such
misconduct;

(o) Monitor the timely submission of reports by the ICC ;

(p) Take all steps necessary and reasonable to assist the Complainant in terms of support and
preventive action, where sexual harassment occurs at a workplace as a result of an act or
omission by any third party or outsider;

(q) Include in its annual report number of cases filed, if any, and their disposal under this Policy;

(r) Shall remove any member/s of ICC, if the member :

i. Contravenes confidentiality provisions stated in the Policy; or

ii. Has been convicted for an offence or an inquiry into an offence under any law for the
time being in force is pending against him; or

iii. Has been found guilty in any disciplinary proceedings or a disciplinary proceeding is
pending against him; or

iv. Has so abused his position as to render his continuance in office prejudicial to the public
interest.

(s) On occurrence of vacancy / removal of any member of ICC, fill in such vacancy by fresh
nomination.

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 Annexure H

NON DISCLOSURE UNDERTAKING

Date: [________]

I, [_______________________] [s/o][d/o] Mr. [__________________], having his/her permanent residing

address at [___________________] (hereinafter referred to as “Recipient”) , working with
[__________________________] as [_________________________] hereby execute this undertaking in
relation to the complaint filed/to be filed or Inquiry proceedings initiated/to be initiated before the Internal
Complaints Committee (“ICC”) constituted under the Sexual Harassment of Women at Workplace
(Prevention, Prohibition and Redressal) Act (“Act”), 2013 by [________________] (“Complainant”) against
[_____________] (“Respondent”).

I hereby agree and irrevocably undertake that I shall keep the Complaint, identity and addresses of the
Complainant, Respondent, witnesses, any information relating to conciliation and inquiry proceedings,
recommendations of ICC and action taken by the Employer under the Act or any other information related
thereto (“Confidential Information”) strictly confidential and shall not either wilfully or through any other
act, omission or negligence, share, distribute, disclose or howsoever cause or induce any other person to
share, distribute or disclose either verbally, electronically or in writing any such Confidential Information to
any person, other than as required under applicable laws.

I further undertake not to publish, communicate or make known to public, press or media the Confidential
Information in any manner whatsoever.

I am aware and acknowledge that in case of breach of this Undertaking, I shall be liable for penal
consequences and other consequences in accordance with the services rules and/ or as per applicable laws

Signed by

[____________]

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