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I. OBJECTIVES

1. BROKER NETWORK (refers to all member companies in India and is collectively referred to as “The
Company” in this policy document), is committed to providing all its employees an environment
free from gender-based discrimination and harassment. In furtherance of this commitment, the
Company strives to provide all its employees an equal opportunity condition of employment, free
from gender-based coercion, intimidation, or exploitation and to create a work environment where
everyone has an opportunity to fully participate in achieving business success and is valued for the
distinctive skills, experiences and perspectives she or he brings to the workplace. The Company has
zero tolerance for harassment, intimidation or humiliation of a sexual or gender-based nature in its
workplace and is dedicated to ensure enactment, observance and adherence of guidelines and best
practices that prevent and prosecute acts of sexual harassment.

2. Sexual harassment including discrimination or intimidation of a sexual or gender-based nature by

or towards any employee in the workplace will not be condoned. The Company will not tolerate
retaliation in any form against personnel for raising sexual harassment complaints or concerns.
3. This Policy applies to all allegations of sexual harassment made by any employee of the Company
against another employee irrespective of whether sexual harassment is alleged to have taken place
within the Company premises or in any other place visited by such employee for work. All actions
prohibited for an employee of the Company by this Policy are also prohibited for all individuals who
are on the Company premises or on any other property where the Company conducts its business.
If an individual commits an act in violation of this Policy, whether an employee of the Company or
a third party interacting with the Company, the Company will take appropriate remedial measures
under the circumstances, including measures to mitigate the potential for repetition, and to
discipline any of its employees who may have participated in such conduct, or may have failed to stop
such conduct when he or she had actual knowledge of such conduct and the authority to do so.

II. DEFINITIONS AND EXAMPLES OF SEXUAL HARASSMENT

Sexual harassment is defined under this Policy as any conduct that is unwelcome and sexual in
nature, whether direct or indirect, including physical contact and advances, a demand or request
for sexual favors, making sexually colored remarks, circulating obscene content by email, sms or
mms, showing pornography, or any other unwelcome physical, verbal or non-verbal conduct of a
sexual nature. When any such act or acts are committed in circumstances where such conduct is
humiliating and is likely to constitute a health and safety problem, it will amount to sexual
harassment that violates this Policy.

Sexual harassment may occur as a single incident or a series of incidents and may include, but will
not be limited to the following which may interfere with an individual's performance by contributing
to the creation of an intimidating, hostile or offensive environment:
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(a) Implied or explicit promise of preferential treatment in employment, or

(b) Implied or explicit threat of detrimental treatment in employment, or
(c) Implied or explicit threat of detrimental treatment about present or future employment
status.

Sexual harassment may be of two kinds: (1) indirect, also referred to as a “hostile work
environment” and (2) direct, also referred to as a “quid pro quo”. ("a favor for a favor"),
(a) The indirect form of sexual harassment is one or more instances of unwelcome conduct that,
taken individually or together, have the purpose or effect of (i) creating an intimidating, hostile,
or offensive work environment, and (ii) unreasonably interfering with another’s work
performance. Examples of this type of sexual harassment include pornography in public places,
foul language or joking of a sexual nature. This form of sexual harassment does not need to be
directed at any employee in particular.
(b) Sexual harassment by one in a position of power or influence constitutes direct, or quid pro
quo("a favor for a favor"), sexual harassment when (i) submission by an individual is made
either an explicit or implicit term or condition of employment, or (ii) submission to or rejection
of such conduct is used as the basis for employment decisions affecting that employee such as
promotions, demotions, salary raises, hiring or termination.

III. B. COMPLAINTS COMMITTEE

A Complaints Committee set up by the Company in accordance with the provisions of law, will deal
with all cases of alleged sexual harassment whether escalated to it by any Company employee or
taken up “Suo Moto” by the Company, to prevent and deal with sexual harassment and to otherwise
implement the Policy.

I. CONSTITUTION AND PROCEDURE

1. Composition: The Complaints Committee shall consist of

(a) a four (4)-member committee under the Chairpersonship of a senior woman employee and
will include two (2) members from amongst the employees preferably committed to the
cause of women or having experience in social work, HR matters or legal knowledge; (A
minimum quorum of 3 members is required for the inquiry into complainants)
(b) one (1) member from outside the Company (an NGO representative or outside counsel
familiar or dealing with cases of sexual harassment at workplace);
Subject always to at least half the members of the Complaints Committee being women and
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the Complaints Committee being headed by a woman member to be appointed by the Complaints
Committee from amongst its members.
A person shall cease to hold office as a member of the Complaints Committee if he/she ceases to
be an employee on account of resignation, termination, or death or for any other reason
whatsoever, and in such case the vacancy shall be filled immediately by the Company.

2. Disqualifications: A person shall be disqualified for being appointed, elected, nominated or

designated, or for continuing, as a member of the Complaints Committee, for any period of time
during which there is any complaint concerning sexual harassment pending against him/her or if
he/she is found guilty of sexual harassment

3. Confidentiality: To the fullest extent practicable and consistent with the Complaints Committee's
need to investigate and ensure that corrective action is taken, all complaints of sexual harassment
by employees will be processed with strict confidentiality.

4. Filing a Complaint: Any aggrieved employee may approach the Complaints Committee with a
complaint of sexual harassment under this Policy. Employees who face harassment may also file a
written complaint with the Internal Complaints Committee at grievances@brokernetwork.app.

Additionally, such instances can be brought to the attention of the Committee Members or any
member of the Human Resources team. The following steps will be followed in this regard:

(a) A complaint of sexual harassment is to be filed within a time limit of three (3) months. This
may be extended to another three (3) months if the Complainant can prove that grave
circumstances prevented them from doing the same within the stipulated time of three
months.
(b) An employee making a complaint ("Complainant") has to give the complaint to the
Complaints Committee in writing along with supporting documents, names and addresses of
witnesses and the said complaint will be afforded confidentiality as described in Section B.I.3.

(c) No person against whom a complaint is made shall be part of the Complaints Committee.
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(d) Within seven (7) working days of the receipt of the complaint, the Complaints Committee
has to send a copy of the complaint to the alleged accused ("Counter Party") who will have
ten (10) working days to file reply along with list of documents, names and addresses of
witnesses.

(e) At the first meeting of the Complaints Committee, the Complainant shall be heard and the
Complaints Committee may, before initiating an enquiry and at the request of the
Complainant, take steps to settle the matter between the Complainant and the Counter
Party through conciliation; provided there can be no monetary settlement as the basis of
conciliation.

(f) In case there is no request for conciliation or conciliation attempt fails, the Complaints
Committee shall proceed with the complaint and, if not already informed, approach the
Counter Party to inform him of the allegation in order to start the investigation.

5. Proceedings of the Complaints Committee: The Complaints Committee is intended to be an

independent, objective and unbiased fact-finding body established to investigate any complaints of
sexual harassment in a fair, reasonable and time-bound manner in a neutral environment. The
Committee shall conduct the enquiry in accordance with principles of natural justice. It will broadly
be governed by the following principles in conducting its proceedings:

(a) The Complaints Committee shall give every reasonable opportunity to the Complainant and
the Counter Party for putting forward and defending their respective cases and to ensure that
the Complainant and the Counter Party have full opportunity to present their claims,
witnesses and evidence which may establish or substantiate their claims.

(b) Both the Complainant and the Counter Party shall have the right to submit supporting
evidence and shall have the right to bring their respective witnesses, if any, to be examined
by the Complaints Committee.

(c) If the Complainant or the Counter Party fails, without sufficient cause, to be present before
the Complaints Committee for three (3) consecutive hearings, the Complaints Committee will
give a notice of fifteen (15) days to the concerned party before terminating the enquiry
proceedings or giving an ex-parte decision on the complaint.

(d) If considered appropriate by the Complaints Committee, all meetings of the Complaints
Committee including with the Complainant, the Counter Party or any witnesses shall be held
outside the relevant office and at a neutral venue to ensure comfort of parties.
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(e) The Complainant, the Counter Party or any other person that the Complaints Committee
meets with, interacts with, or has a teleconference or video conference with, for the purpose
of enquiry into any complaint of sexual harassment shall be bound by strict confidentiality as
described in Section B.I.3 above and each such party shall not be permitted to discuss the
Complaints Committee proceedings with any third person.

(f) All the proceedings of the Complaints Committee will be summarized by the Committee. In
the event either the Complainant or the Counter Party is desirous of submitting a statement
in writing or reviewing the summary of discussion prepared by the Complaints Committee,
such statement shall be endorsed by such Party in token of authenticity thereof and
submitted to the Committee.

(g) The Committee is required to complete the inquiry within a time period of ninety (90)
days from the date on which the Complaint is filed by the Complainant.

(h) The Complaints Committee shall complete the enquiry and make a report of its findings on
the Complaint and its recommendations to the senior management of the Company
("Management") within a period of ten (10) days from the conclusion of the enquiry
procedure set out above. The report of the Complaints Committee shall also include
recommendations for the imposition of any penalty and the reasons for such
recommendations to the Management.

II. IMPLEMENTATION OF RECOMMENDATIONS OF THE COMPLAINTS COMMITTEE

The Management shall consider the recommendations and findings of the Complaints Committee
and take a decision in relation to action to be taken as soon as possible and within thirty (30) days
of the submission of the report by the Complaints Committee. The Management may issue such
order or directions as it deems fit and shall inform the Complainant and the Counter Party of its
decision. The Management of the Company shall provide all necessary assistance to the Complaints
Committee for the purpose of ensuring full, effective and speedy implementation of this procedure
for investigating any complaint of sexual harassment at work place in accordance with the Policy.

III. PUNISHMENT FOR SEXUAL HARASSMENT

1. Penalties: If an employee is found to have violated this Policy, the Management shall take such
action as may be appropriate action for misconduct by the employee under the Company policy.
Such actions may include any of the following, or a combination of the below mentioned statutory
actions
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(a) Written apology;

(b) Warning;
(c) Reprimand or censure;
(d) Withholding of promotion;
(e) Withholding of pay rise or increments;
(f) Termination of employment;
(g) Counselling session; or
(h) Carrying out community service.

2. Compensation: The Committee can also recommend monetary compensation in favour of the
Complainant by way of deduction from the salary or wages of the Counter Party, in an amount that
it may consider appropriate to be paid to the Complainant and in accordance with applicable law.

IV. PROTECTION AGAINST VICTIMISATION

(a) In the event the Counter Party is the Complainant’s supervisor/superior, the Company shall,
during the pendency of the Complaint, ensure that the reporting relationship is suspended
and that the Complainant is not subject to appraisal by the Counter Party.

(b) The Company shall strictly prohibit any sort of retaliation against the Complainant or any
witnesses. Any act of reprisal, including internal interference, coercion and restraint, by the
Counter Party, whether directly or indirectly, will result in appropriate action against the
Counter Party by the Management in consultation with the Complaints Committee.

(c) Where the Counter Party is an outsider, during the pendency of the investigation of the
Complaint and even thereafter, if found guilty, the Counter Party shall not be allowed to
enter the Company premises except for the purpose of attending the Complaints Committee
proceedings.

(d) In the event of the Counter Party and the Complainant both being employees of the
Company, and the Counter Party is found to be guilty, irrespective of the penalty
imposed, the Company shall ensure that the Counter Party shall not write the appraisal
reports of the Complainant, if he is otherwise so authorized.

(e) In the event, the Complaints Committee after investigation of a Complaint in accordance
with the procedure prescribed herein, concludes that the Complaint was false, frivolous or
made with malafide intention by the Complainant including due to personal issues with the
Counter Party, then the Complaints Committee shall make such appropriate
recommendations to the Management to take action against the Complainant, as may be
necessary. Such actions may include those referred to in Paragraph III (1) above.

V. MODIFICATION AND REVIEW OF THE POLICY

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The Company reserves the right to modify and, or, review the provisions of this Policy, so as to
comply with applicable legal requirements, internal policies, or otherwise with a view to revise the
provisions of this Policy to the extent deemed necessary by the Company from time to time. Any
such changes or modifications may be notified by the Company to its employees in due course.

VI. List of Committee Members

Employee
Employee Name Designation Position Department Gender
Code
Sangeeta
4B0036 Senior Manager Chairperson Admin Female
Paryani
4B0564 Priyanka Sarkar Assistant Manager Member Human Resources Female
Avanti Anil
4B0536 Assistant Manager Member Legal Female
Poredi
4B0484 Niti Niraj Patel Market Head Member Broker Acquisition Female
Finance &
4B0552 Ankur Somani AVP- Finance Member Male
Accounts
Murtuza
Ebrahim Member Male
4B0122 Vapiwala Maketing Head Marketing
4B1384 Swati Adhikary VP - HR Member Human Resources Female
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VII. CERTIFICATION

BROKER NETWORK Prevention of Sexual Harassment at Workplace Policy

The undersigned certifies that he/she has read (or will read) Anti-Harassment Policy along with India
Annexure for Anti-Harassment Policy & Procedure, a copy of which was distributed with this
certification.

Signature: Date:

Printed Name:

Office Address: