DEFINITION

A complaint shall be submitted in writing to hr@xeamventures.com or to any member of the Internal Committee mentioned herein within 01 month of occurrence of an act of Sexual Harassment. If the respondent is direct supervisor of the complainant, or person influencing the career growth of the complainant, the reporting structure will be changed till the time the enquiry is completed.

1. Each complaint of Sexual Harassment shall be dealt with utmost confidentiality and urgency by an Internal committee consisting of the members mentioned members table.
2. Within 3 working days, the Internal committee shall commence Official Internal Enquiry by:
   • By informing the said complaint to the respondent.
   • By instructing to stop the alleged act of Sexual Harassment immediately.
   • By informing not to reach out to the complainant directly or indirectly.
   • By asking an immediate explanation from him/her to the same.
3. Within 5 working days from the receipt of original complaint, the designated person among Internal Committee shall respond in writing to the complainant informing him/her about the initial steps taken by XEAM Ventures in order to stop the alleged act(s).
4. Within 15 days from receipt of the original complaint, the Internal committee shall record and accordingly communicate in writing to the complainant and the respondent, its prima facie findings, upon giving the concerned parties a fair and due opportunity to represent themselves and upon conducting fact finding, truth verification and counseling sessions with persons involved in alleged act(s).
5. A complaint will be closed no later than one month from receipt of original complaint by recording the decisions of the internal committee, accordingly informing to the complainant and the respondent of the same.
6. Employees are duty bound to assist in investigative steps, employees' wholehearted participation shall be mandatory in this regard. Whistleblowers shall be protected from exposure, retaliation or hostility.
7. Within 2 working days from receipt of prima facie findings or the charges, if the complainant or the respondent is dissatisfied with the decision of internal committee, she or he may appeal specifying the reasons in writing to Managing Director. Within 5 working days from the receipt, the appeal shall be finally disposed of by written communication to the said party. The decision of Managing Director shall be final and cannot be appealed.

1. An amicable resolution of the complaint is possible only with the written consent of the complainant.
2. Within 24 hours of closing the case file, the internal committee shall present the same to and inform its decision to the Managing Director.
3. In case of decision establishing the offence of Sexual Harassment of the complainant, within 3 working days, the internal committee shall recommend Disciplinary action against the offender considering the nature and extent of injury caused to the complainant, prior complaints or repetition of offence etc and the impact of the offence on the company profile as a whole.
4. The position of the offender and the criticality of the position occupied by the offender shall not be any hindrance to the disciplinary action taken against the offender.
5. The disciplinary action that shall be commensurate with the nature of the gravity of the offence, shall include but not limited to,
   • Warning
   • Written apology from offender
   • Bond of good behavior
   • Transfer
   • Debarring from supervisory duties
   • Denial of employee benefits like increments/ promotion/ salary correction etc.
   • Cancellation of specific work assignment
   • Suspension
   • Dismissal
6. Annual report summarizing complaints and Redressal of Sexual harassment shall be prepared by designated person of Internal Committee. The said report as well as all documents regarding Sexual Harassment complaints shall be in the custody of respective designated person and will be termed as 'Strictly Confidential'.