ANTI-SEXUAL

HARASSMENT POLICY
 Anti-Sexual Harassment Policy | Confidential | No part of this document may be circulated or reproduced in part or in full without the explicit,
written permission of the top management representative of Vedantu Innovations Pvt. Ltd.

Anti-Sexual Harassment Policy – Version 1.1

Version Proposed By Reviewed By Approved By Effective Date Modifications

Abishek Chiripal S Naga Siddharth S Vamsi Krishna

1.0 1st May 2019 New Policy
DGM-HR CHRO CEO

Vamsi Krishna
1.1 Legal Counsel Human Resource 1st October 2020 Updated/Revised
CEO

Surya Omar Vamsi Krishna

1.2 Legal Counsel 30th March 2022 Updated/Revised
Human Resource CEO
Ritika Singh Vamsi Krishna
1.3 Legal Counsel Human Resource CEO 27th Feb 2023 Updated/Revised
 Anti-Sexual Harassment Policy | Confidential | No part of this document may be circulated or reproduced in part or in full without the explicit,
written permission of the top management representative of Vedantu Innovations Pvt. Ltd.

I. INTRODUCTION
Vedantu Innovations Private Limited (“the Company”) seeks to uphold the highest ethical and professional
standards in its workplace conduct and business dealings. The Company is committed towards creating a
healthy working environment that enables its employees to work without fear, prejudice, or sexual
harassment.
In accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal)
Act, 2013 (hereinafter referred to as the “Act”) & the Sexual Harassment of Women at Workplace
(Prevention, Prohibition and Redressal) Rules, 2013 (hereinafter referred to as the “Rules”), the Company
has framed the following policy (the “Policy”) for prevention of sexual harassment at workplace. This policy
is intended to be gender neutral and will apply uniformly in case of sexual harassment of any person,
irrespective of the gender of the parties.

II. COMMITMENT

The Company is committed towards providing a work environment that ensures every employee is treated
with dignity and respect and afforded equitable treatment. The Company is also committed towards
promoting a work environment that is conducive to the professional growth of its employees and encourages
equality of opportunity.
The Company will not tolerate any form of sexual harassment and is committed to take all necessary steps
to ensure that its employees are not subjected to any form of harassment. This Policy seeks to provide
awareness to all employees of the Company on what acts constitute sexual harassment, the redressal
mechanism in place and the penal consequences (both interim and final) imposed on perpetrators of sexual
harassment.

III. SCOPE

This Policy is applicable to all 'employees' of the Company, which for the purpose of this Policy shall include
all permanent and temporary management, employees, probationers, trainees, apprentices and also
contract workers or vendors/consultants working on the Company’s premises or in any of the extended
workplace. The Policy is applicable to all categories of employees as stated above, irrespective of whether
such persons have been engaged directly or through an agency or a contractor, and whether such employees
are working for remuneration or on a voluntary basis. The Policy shall also be applicable to all third parties
such as visitors, clients, customers, contractors, service providers, and any other person authorized to be
present within the premises/ workplace of Vedantu.
This policy is applicable not only on the Company’s premises, but also in instances where individuals covered
by this policy have occasion to interact on a work-related basis (e.g., in vehicles, third party premises, off site
meetings and public venues). Company will not tolerate any form of sexual harassment, if engaged in by its
employees, clients or suppliers or any other business associates, if such conduct occurs on the Company’s
premises or during the course of the employee's work for the Company.
 Anti-Sexual Harassment Policy | Confidential | No part of this document may be circulated or reproduced in part or in full without the explicit,
written permission of the top management representative of Vedantu Innovations Pvt. Ltd.

The policy applies to any allegations of sexual harassment made by an employee, client (including students
and or their parents) or visitor against an employee, if the conduct occurred on the premises of the Company,
or during the course of the employee's work for the Company. In the case of an allegation of sexual
harassment made against a contract worker, the Company will work with the direct employer of the alleged
offender to decide how the matter should be dealt with.

IV. DEFINITIONS:
(a) “Complainant” means, in relation to a Workplace (as hereinafter defined), a man or a woman, of any
age whether employed or not, who alleges to have been subjected to any act of sexual harassment by
the Respondent (as hereinafter defined);
(b) “Employees” means all employees of the Company as set out in Clause 4 of this Policy and includes
all categories of employees of the Company either working part-time or full time and including but not
limited to:
● Permanent employees.
● Temporary employees;
● Trainees;
● Contract employees;
● Consultants; and
● Advisers.
(c) “Employer” means the Company and includes –
● Board of Directors of the Company; and
● any person(s) or board or committee responsible for the formulation and administration of
policies that enables management, supervision, and control of the Workplace.
(d) “Internal Committee (IC)” means a committee constituted by the Employer for the purpose of
dealing with all matters in relation to sexual harassment;
(e) “Member/s” means a Member/s of the IC;

(f) “Respondent” means a person (Employee) against whom the Complainant has made a complaint of
Sexual Harassment;

(g) “Sexual harassment” includes anyone, more or/and series of the following unsolicited and
unwelcome acts or behaviour (whether directly or by implication) namely:

I. Physical contact and advances; or

II. A demand or request for sexual favours; or
III. Sexually coloured remarks; or
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written permission of the top management representative of Vedantu Innovations Pvt. Ltd.

IV. Display of pornography; or

V. Any other unwelcome physical, verbal or non-verbal conduct of sexual nature.
VI. 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
at the workplace:
(i) Implied or explicit promise of preferential treatment in the Complainant’s employment; or
(ii) Implied or explicit threat of detrimental treatment in the Complainant’s employment; or
(iii) Implied or explicit threat about the Complainant’s present or future employment status; or
(iv) Interference with the Complainant’s work or creating an intimidating or offensive or hostile
work environment for the Complainant; or
(v) Humiliating treatment likely to affect the Complainant’s health or safety.
VII. It is unlawful for males to sexually harass females or other males, and for females to sexually
harass males or other females. Sexual harassment in the workplace is prohibited whether it
involves co-worker harassment, harassment by a manager, applicants for employment,
temporary agency personnel and contractors, customers or vendors, or harassment by or of
persons doing business with or for the Company.

(h) “Workplace” means and includes the offices of the Company as well as the premises of other third
parties, vendors and associates of the Company where the Employees of the Company are required
to perform work or that are visited by the Employees of the Company, arising out of or during the
course of employment and includes transportation provided by the Company for undertaking any
journey, stay in connection with the business of the Company.

V. EXCLUSIONS
It is to be noted that this Policy does not apply when the Complainant is performing work of their own accord
and for personal reasons.

VI. THIRD PARTY HARASSMENT

● Third party harassment means Sexual Harassment perpetrated by visitors, patients, patrons,
vendors, independent contractors, auditors, consultants, and others with whom the Employees have
come in contact, directly or indirectly, because of the Company having a relationship/business
relationship with them.
Where the Sexual Harassment at the Workplace occurs as a result of an act or omission by any third party,
the Company shall take all steps necessary and reasonable to assist the affected Employee in terms of
support and preventive action.
 Anti-Sexual Harassment Policy | Confidential | No part of this document may be circulated or reproduced in part or in full without the explicit,
written permission of the top management representative of Vedantu Innovations Pvt. Ltd.

VII. PREVENTION OF SEXUAL HARASSMENT

The Company will maintain a zero-tolerance policy as far as Sexual Harassment is concerned and as such the
same is unacceptable and the Company will strive through education and deterrence to create an
environment that is free from Sexual Harassment. All Employees are expected to:
I. Treat others with respect and dignity.
II. Refrain from actions that may offend, embarrass, or humiliate others (whether deliberate or
unintentional).
III. Let others know they do not approve of disrespectful or harassing behavior.
IV. Apologize if someone tells them they are offended by their words or actions; and
V. Familiarize themselves with this Policy.
To prevent sexual harassment at the workplace and for redressal of sexual harassment complaints made by
the victims in a time bound manner, an IC has been constituted at each office.

VIII. INTERNAL COMMITTEE

I. The IC shall consist of the following Members namely:
(a) a Presiding Officer who shall be a woman Employee at a senior level;
(b) not less than two Members from amongst Employees who have had experience in social work
or have legal knowledge;
(c) one member from amongst non-governmental organizations or associations committed to the
cause of women or a person familiar with the issues relating to sexual harassment. One half of the
total Members so nominated shall be women. This Policy details the names and contact details of
the members of the IC under Clause 20 herein.
II. The Presiding Officer and every Member of the IC shall hold office for a period not exceeding (3)
three years from the date of nomination. The Member appointed from amongst the non-
governmental organizations or association shall be paid such fees or allowance as prescribed under
the Rules. IC shall send periodical reports to the Employer constituted under this Policy.
III. The procedure as regards the IC shall be as contemplated under the provisions of the Act.

IX. DUTIES OF EMPLOYEES WHILE FACING HARASSMENT

If an Employee feels that he/she is experiencing any kind of retaliation, victimization, or discrimination in the
nature of intimidation, pressure to withdraw the complaint or threats for reporting, testifying or otherwise
participating in the proceedings, he/she should immediately report the matter by sending an email to the
dedicated email id [email protected]. All members of the IC are mapped to/ included in this email id. The
Company prohibits retaliation against anyone for raising a complaint or helping in addressing the complaint.
Any retaliation or reprisals are subject to immediate corrective action, up to and including termination of
services. Alleged retaliation or reprisals are subject to the same complaint procedures and disciplinary action
as complaints of Sexual Harassment.
 Anti-Sexual Harassment Policy | Confidential | No part of this document may be circulated or reproduced in part or in full without the explicit,
written permission of the top management representative of Vedantu Innovations Pvt. Ltd.

X. COMPLAINT OF SEXUAL HARASSMENT

1. A Complainant may make the written complaint to the IC. No particular form is required but the
complaint must be in writing and signed by the Complainant.
2. Any Employee may make a complaint of Sexual Harassment at Workplace to the IC of the particular
location within a period of three months from the date of the incident and in case of series of
incidents, with in a period of three months from the date of last incident.
3. The IC is empowered to extend the time limit beyond three months from the date of incident, but
not exceeding three months thereafter, for reasons to be recorded in writing if the IC is satisfied that
the circumstances were such which prevented the person from filing the complaint within the said
period.
4. The Presiding Officer or any Member of IC may also render reasonable assistance to the Employee
for making any complaint in writing, if he/she cannot make the complaint in writing themselves. Legal
heirs or such other persons may also make the complaint if the Complainant is unable to make the
complaint on account of his/her trauma, physical or mental incapacity or death or otherwise.
5. In the event the Complainant is unable to make a complaint on account of the Complainant’s physical
or mental incapacity or death or any other reason which prevents the Complainant from making a
complaint, then the Complainant’s legal heir or any other person as mentioned below may make the
complaint on the Complainant’s behalf under the Policy:
a) In the event the Complainant is unable to make the complaint on account of the
Complainant’s physical or mental incapacity, the complaint may be filed by:
● the Complainant’s relative or friend;
●
the Complainant’s co-worker;
●
any person who has knowledge of the incident, with the written consent of the
Complainant.
b) In the event the Complainant is unable to make the complaint for any other reason, the
complaint may be filed by any person who has knowledge of the incident, with the
Complainant’s written consent.
c) In the event of the death of the Complainant, the complaint may be filed by any person who
has knowledge of the incident, with the written consent of the Complainant’s legal heir.
6. A withdrawal of the complaint made or filed at any stage of the proceedings shall not preclude the
IC from proceeding with the investigation of the complaint.
7. The Employer shall implement such recommendations and send a report of such implementation
to the IC.

Note: In the event that the Complainant is granted leave in accordance with this Policy, such leaves shall be
in addition to the leave the Complainant is otherwise entitled to.
 Anti-Sexual Harassment Policy | Confidential | No part of this document may be circulated or reproduced in part or in full without the explicit,
written permission of the top management representative of Vedantu Innovations Pvt. Ltd.

XI. ENQUIRY PROCEDURE

I. The IC will normally hold a meeting with the complainant, as soon as practicable, but not later than
a week in any case. At this meeting, the Committee shall hear the complainant, record her/his
allegations, and encourage her/him to submit any corroborative material with a documentary proof,
oral or written material etc. to substantiate the complaint.
II. The IC shall normally forward a copy of complaint to the respondent, within seven working days from
the initial meeting, or within such time-period as it may deem reasonable and give her/him an
opportunity to submit a written explanation if she/he so desires.
III. The respondent shall file her/his reply to the complaint along with her/his list of documents and
names and addresses of witnesses within a period of ten working days from the date of receipt of
the complaint from the IC or such other period that the IC may specify.
IV. In the event the IC concludes that prima facie the complaint does not fall within the purview of Sexual
Harassment, the IC will forward the complaint to the relevant adjudicating body that can look into
the complaint.

XII. FURTHER ACTION INTO THE COMPLAINTS

I. The Committee may, before initiating an inquiry and at the request of the victim, take steps to settle
the matter between the victim and the respondent through conciliation, provided that no monetary
settlement shall be made as a basis of conciliation.
II. Where a settlement has been arrived at under sub-clause (i) of this clause (a), the Committee shall
record the settlement so arrived at, and forward the same to the Company to implement the terms
of the settlement where required.
III. Where a settlement is arrived at, no further inquiry shall be conducted by the Committee.
IV. Where the victim informs the Committee that any term or condition of the settlement arrived at as
part of the conciliatory proceedings has not been complied with by the respondent, or if the victim
does not request for conciliation, or if the conciliation process fails, and where the respondent is an
employee, the Committee would proceed to make an inquiry into the complaint in accordance with
the provisions of this policy.
V. The quorum for meetings of the Committee will require 2 members to be present, including one lady
member.
VI. Both the respondent and the complainant (unless specifically exempted by the Committee in writing)
shall be required to attend every hearing that they have been called for. If either party fails to attend
[three] consecutive hearings without sufficient cause, the Committee may terminate the inquiry or
pass an ex parte order with [fifteen days'] notice.
VII. The enquiry shall abide by the established procedures and principles of natural justice. The enquiry
shall be conducted in English or the local language, whichever is requested by the defendant. While
conducting the inquiry, the Committee shall call upon such witnesses as it may deem appropriate.
VIII. The Committee shall see that every reasonable opportunity is extended to the complainant and the
defendant, for putting forward and defending their respective cases.
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written permission of the top management representative of Vedantu Innovations Pvt. Ltd.

IX. On completion of the inquiry, the Committee shall prepare a report of its findings and
recommendation for action to be taken by the Company and submit the same to the [Head of Human
Resources Department]. Appropriate action will also be taken in a manner that is deemed
appropriate by the Company based on the recommendations made by the Committee.

XIII. INTERIM RELIEF

I. During the pendency of the inquiry, on a written request being made by the victim, the IC may
recommend to the Company to: (a) transfer the victim to another office/department/division as
deemed appropriate, or (b) transfer the respondent to another office/department/division as
deemed appropriate, or (c) grant leave to the victim up to a period of three months, or (d) restrain
the respondent from reporting on the work performance of the victim or writing the victim's
appraisal/ confidential report(s).
II. The Committee may also recommend to the Company to suspend the respondent with full pay during
the pendency of the inquiry if the circumstances so merit.

XIV. DECISION OF THE COMMITTEE

I. If the Committee forms the opinion that the defendant has indulged in Sexual Harassment in the
Workplace, depending upon the gravity of the offence and without prejudice to any legal right(s), an
appropriate disciplinary action would be taken against him/her by the Company irrespective of
his/her status in the Company. Disciplinary action will be initiated by Human Resources Department
and may include any of the following:
a) The services of the employee would be terminated, or such action would be initiated as
recommended by the Committee;
b) Transfer of the complainant or the perpetrator, if the Company deems fit to do so based on the
recommendations of the Committee;
c) To deduct from the salary of the defendant such sum as it may consider appropriate to be paid to
the complainant;
d) Direct the respondent to undergo training or counselling to address any specific issues.
e) Give a verbal or written warning which will also be noted in the respondent's record.
f) Withhold increment or bonus (whether in full or part).
g) Withhold promotion.
II. If the victim desires to take criminal action against the respondent, there shall be no objection by the
Committee and the Company. In such an event, the Company will attempt to provide all reasonable
assistance to the victim. Company may also choose to initiate criminal proceedings against the
respondent.

III. If an employee is found to have lodged a false complaint, then action will be taken against the
employee for such action. These actions taken by the Company will be similar to the disciplinary
action to be taken against the respondent if she/he is found guilty of sexual harassment, as discussed
above.
 Anti-Sexual Harassment Policy | Confidential | No part of this document may be circulated or reproduced in part or in full without the explicit,
written permission of the top management representative of Vedantu Innovations Pvt. Ltd.

IV. The Company prohibits any form of retaliation against anyone who has raised a complaint of sexual
harassment or has cooperated in any inquiry involving a complaint of sexual harassment. The
Company will ensure that victims and witnesses will not be victimized or discriminated against
because of their complaint.
V. Any individual who believes that she/he is experiencing retaliation, by way of intimidation, pressure
to withdraw the case or threats for reporting, testifying or otherwise participating in the proceedings,
should report this to the Committee or HR, and the Company will then address the concerns raised.
Any person who is found to be guilty of retaliation may be subject to appropriate disciplinary action
including dismissal from service. Anyone who abuses this procedure (for example, by maliciously
putting an allegation knowing it to be untrue) would also be subject to disciplinary action including
dismissal from service.
VI. The Company will take proactive measures to sensitize its employees about the need for appropriate
workplace conduct in a gender-neutral manner.
VII. The Company understands that it is difficult for the victim/complainant to come forward with a
complaint of sexual harassment and recognizes the victim/complainant's interest in keeping the
matter confidential. To protect the interests of the victim/complainant, the respondent, witnesses,
and others who may assist with the inquiry into a complaint of sexual harassment, confidentiality of
the complaint’s procedure would be maintained throughout any investigatory process to the extent
practicable and appropriate under the circumstances.
VIII. The Committee, the Company, the victim/complainant, the respondent, and the witnesses would be
bound to keep information relating to the inquiry process confidential. All records of sexual
harassment complaints, including contents of meetings, results of investigations and other relevant
material will be kept confidential by the Company, except where disclosure is required under
disciplinary or other remedial processes.
IX. The victim/complainant, respondent, witnesses, and members of the Committee who are employees
of the Company who breach the confidentiality of the inquiry process would be liable for disciplinary
action up to and including termination. x. The Company shall assist the persons affected by cases of
sexual harassment, through counselling by independent professionals / specialists / bodies, as
deemed fit.

XV. APPEALS
The Complainant and the Respondent shall have the right to appeal to the Court of appropriate jurisdiction
within ninety days of the decision of the IC if they are not satisfied with the decision of the IC.

XVI. SAVINGS
The proceedings under this Policy shall be conducted in parallel with the other remedies of law, if such a case
arises. The provisions of this Policy shall not restrict the power of Employer or Complainant to proceed
against the Respondent for any other misconduct or to pursue the criminal or civil remedies.
 Anti-Sexual Harassment Policy | Confidential | No part of this document may be circulated or reproduced in part or in full without the explicit,
written permission of the top management representative of Vedantu Innovations Pvt. Ltd.

XVII. EXAMPLES OF INSTANCES CONSTRUED AS SEXUAL HARASSMENT

Sexual harassment is classified as below, which includes but is not limited to the following:
I. surreptitiously looking or prolonged staring at a person, giving rise to gross discomfort to the person;
II. telling smutty jokes or sending these through text, electronic mail or other similar means, causing
embarrassment or offense, and the same being carried out after the offender has been advised that
they are offensive or embarrassing or, even without such advice, when they are by their nature
clearly embarrassing, offensive or vulgar;
III. malicious leering or ogling;
IV. the display of sexually offensive pictures, materials or graffiti;
V. unwelcome inquiries or comments about a person’s sex life;
VI. unwelcome sexual flirtation, advances, propositions;
VII. making offensive hand or body gestures;
VIII. persistent unwanted attention with sexual overtones;
IX. unwelcome phone calls with sexual overtones causing discomfort, embarrassment, offense or
insult to the receiver;
X. unsavory remarks about a person’s physical characteristics, dressing, attitude, etc. ;
XI. sexual assault;
XII. malicious and/or unwanted touching or brushing against a victim’s body;
XIII. requesting for sexual favors in exchange for employment, promotion, local or foreign travels,
favorable working conditions or assignments, a passing grade, the granting of honors or scholarship,
or the grant of benefits or payment of a stipend or allowance;
XIV. verbal abuse with sexual overtones; and
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written permission of the top management representative of Vedantu Innovations Pvt. Ltd.

XVIII. NAMES AND CONTACT DETAILS OF THE MEMBERS OF THE IC

The names and contact details of the Members of the IC shall be as communicated by REV to the
Employees from time to time.
The members of the Internal Committee at Vedantu, Bangalore are:

Employee Name of the committee Job Title Email ID Contact

ID members Number

VD00028 Pooja Bheemaiah - Chairperson Associate Director [email protected] 9986799995

- Care

VD08422 Sudhanshu Jain Associate Vice [email protected] 9001532881

President -
Academics
VD00010 Sridhar Rotnadigikar Associate Vice [email protected] 9886576953
President -
Academic
Operations
VD20762 Ritika Singh Director - HRBP [email protected] 8860599674

VD00017 Simriti Goel Chief of Culture Office [email protected] 9620596200

Binu Verma NGO Partner [email protected]

XIX. Annual Report of the IC

The IC shall in each calendar year prepare an annual report in the prescribed form and submit the same to
the Employer. The report shall encompass the following:
I. Number of complaints received that year;
II. Number of complaints disposed off during that year
III. Number of workshops or awareness programs conducted;
IV. Number of cases pending for more than 90 (ninety) days;
V. Nature of action taken by the Employer.
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XX. TIMELINES:

Sl ACTION POINT AUTHORITY/CONCER TIME LIMIT

No NED PERSON

1 Complaint Complaint to be lodged 1) within the period of 3 months from the date of
by Complainant Before the incident, or
IC 2) in case of series of incidents, within the period
of 3 months from the date of last incident.

2 Initiation of Inquiry Proceedings By the IC, by sending the Within the period of 7 working days of receipt
copy of complaint To the of the complaint
Respondent
3 Reply by the Respondent along with To the IC Within 10 working days from the day of
his list of documents, names, and receipt of the copy of complaint forwarded by
addresses of witnesses IC.
4 Completion of Inquiry proceedings By IC Within 3 months from the date of receipt of
complaint

5 Submission of Inquiry Report and To the Employer Within 10 days of completion of Inquiry
Findings along with Recommendations Proceedings by IC
by IC
6 Implementation of Recommendations By the Employer Within 60 days of the receipt of the
made in the Enquiry Report of IC Recommendations made in the Enquiry
Report by IC
7 Appeal under the policy. By the aggrieved person Within a period of 90 days of
Recommendations by IC.