POSH Policy

Harvested Labs Private Limited

1. Purpose

Harvested Labs Private Limited is committed to providing a safe, secure, and respectful work environment that is free from sexual harassment and any form of unwelcome conduct of a sexual nature. Harvested Labs Private Limited believes that every individual has the right to work with dignity and without harassment and threat or fear of harassment. This Policy has been framed in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("POSH Act") and the Rules thereunder. Harvested Labs Private Limited adopts a strict, zero-tolerance approach toward sexual harassment and is committed to the prevention, prohibition, and redressal of such conduct, as well as to protecting individuals from retaliation when they raise concerns in good faith. It also adopts an expansive interpretation of the POSH Act to cover all personnel regardless of their gender identity, sex, sexual orientation, romantic orientation, gender expression and performance, and sex characteristics.

2. Scope

This Policy applies to all employees of Harvested Labs Private Limited, including those employed on a permanent, probationary, fixed-term, seasonal, voluntary, freelance, consulting, collaborative, and/or contractual basis. It also extends to interns, trainees, volunteers, contractors, temporary staff, substitute staff, consultants, advisors, gig workers, directors, members of management, and any individual who interacts with employees in connection with work, including vendors, clients, and visitors. The Policy covers conduct occurring at the workplace as well as in any work-related context. This includes business travel, offsite meetings or events, client or vendor locations, virtual meetings, electronic communications such as emails and messaging platforms, and work-from-home or remote working environments. The intent is to ensure that employees are protected from sexual harassment regardless of the medium or location in which work is performed.

For the purposes of this Policy, the term "workplace" shall have the same meaning as assigned under the POSH Act and shall include Harvested Labs Private Limited's premises, branch offices, client locations, transportation provided by Harvested Labs Private Limited, and any place visited by an employee arising out of or during the course of employment. This also includes virtual work environments and remote working arrangements.

3. Expansive Coverage Commitment

While the POSH Act provides statutory protection specifically to women employees, Harvested Labs Private Limited is committed to maintaining a gender-inclusive workplace and does not tolerate sexual harassment against any individual, irrespective of their gender identity, sex, sexual orientation, romantic orientation, gender expression and performance, and sex characteristics. Complaints raised by all persons regardless of their identities as mentioned above will be addressed through Harvested Labs Private Limited's Internal Complaints Committee with the same degree of seriousness, sensitivity, and promptness, in compliance with applicable law.

4. Definition and Understanding of Sexual Harassment

In accordance with Section 2(n) of the POSH Act, sexual harassment includes any unwelcome act or behavior, whether direct or implied, of a sexual nature. Sexual harassment may take place through physical, verbal, non-verbal, written, or electronic means, and may take place in person or through virtual or digital interactions. The determination of whether or not any conduct is unwelcome shall be based on the perception of the aggrieved individual and the surrounding circumstances. Under the POSH Act, sexual harassment includes, but is not limited to:

• Physical contact and advances
• Demand or request for sexual favors
• Making sexually colored remarks
• Showing pornography
• Any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature

Sexual harassment may take the form of _quid pro quo harassment_ or the creation of a _hostile work environment_. The former is said to occur where submission to or rejection of sexual conduct is used explicitly or implicitly as a basis for employment decisions such as hiring, promotion, appraisal, assignment of work, or continuation of employment. The latter is said to occur when unwelcome conduct of a sexual nature creates an intimidating, offensive, humiliating, or hostile work environment, or interferes with an individual's work performance or well-being.

Examples of sexual harassment broadly include unwelcome touching, patting, or physical proximity; sexually suggestive comments, jokes, or remarks; sending of sexually explicit emails, messages, or images; repeated unwelcome invitations or requests for personal meetings; displaying or sharing objectionable or pornographic material; staring, leering, or making gestures of a sexual nature; asking intrusive questions or making comments about a person's body or romantic relationships or sex life; and online harassment during video calls, chats, or collaboration platforms. These examples are illustrative and not exhaustive. Any unwelcome conduct of a sexual nature that violates an individual's dignity or creates an unsafe work environment may constitute sexual harassment under this Policy.

5. Internal Complaints Committee

In compliance with Section 4 of the POSH Act, Harvested Labs Private Limited has constituted an Internal Complaints Committee ("ICC") to receive and redress complaints of sexual harassment. The ICC is chaired by a Presiding Officer (a woman) and comprises members with appropriate seniority and sensitivity to handle such matters. The Committee also includes an external member with relevant legal or social expertise, and at all times, at least half of the total members are women. Members of the ICC are appointed for a tenure of three (3) years. Employees may reach the ICC through the designated email ID: founders@harvestedlabs.com

Details of the ICC members are included within Annexure 1 attached to this document.

6. Filing a Complaint before the ICC

(a) Any aggrieved person who believes that they have been subjected to sexual harassment at the workplace may submit a written complaint to the Internal Complaints Committee ("ICC") in accordance with the POSH Act. While the statutory mechanism under the POSH Act applies specifically to women, Harvested Labs Private Limited maintains a zero-tolerance approach toward sexual harassment against any individual. Accordingly, complaints of sexual harassment raised by any person will be addressed through the ICC with the same degree of seriousness, sensitivity, and promptness, to the extent permissible under applicable law.

(b) Where the aggrieved person is unable to file the complaint due to physical or mental incapacity or death, the complaint may be filed on their behalf by their legal heir, relative, friend, co-worker, or any person who has knowledge of the incident, in accordance with the POSH Act.

(c) A complaint under the POSH Act should ordinarily be submitted within three (3) months from the date of the incident. In cases involving a series of incidents, the limitation period shall be calculated from the date of the last incident. The ICC may extend the time limit by a further period not exceeding three (3) months if it is satisfied that circumstances prevented the complainant from filing the complaint within the prescribed period. The reasons for such extension shall be recorded in writing.

A complaint shall be made in writing and may be submitted either by email to the designated ICC email ID or by submitting a signed hard copy to any ICC member. Where the complainant is unable to submit the complaint in writing, the ICC shall provide reasonable assistance to the complainant in documenting the complaint. The written record so prepared shall be read over to the complainant and confirmed by her.

7. Optional Conciliation

Before initiating a formal inquiry, the ICC may, at the written request of the complainant, attempt a conciliation process between the parties. It is expressly clarified that monetary settlement shall not be made the basis of conciliation. Furthermore, the complainant will not be coerced to participate in conciliation proceedings. Where a settlement is arrived at, the ICC shall record the terms of settlement and forward the same to Harvested Labs Private Limited for implementation. Upon such settlement, no further inquiry shall be conducted unless the terms of settlement are breached.

8. Inquiry Process

Where conciliation is not requested or is unsuccessful, the ICC shall initiate a formal inquiry into the complaint in accordance with the principles of natural justice and the provisions of the POSH Act. The inquiry shall ordinarily be completed within ninety (90) days from the date of receipt of the complaint. Both the complainant and respondent shall be provided a fair and reasonable opportunity to present their respective cases, submit evidence, and produce witnesses. The ICC may conduct proceedings in person or through secure virtual means where circumstances so require.

9. Interim Relief

During the pendency of the inquiry, and upon a written request by the complainant, the ICC may recommend to Harvested Labs Private Limited appropriate interim measures to safeguard the interests of the complainant. Such measures may include transfer of either party, grant of leave to the complainant for a period up to three (3) months in addition to her regular leave entitlement, temporary change in reporting structure, work-from-home arrangements, or issuance of a no-contact directive. Harvested Labs Private Limited shall implement the recommendations of the ICC in a timely manner.

10. Inquiry Report & Action

Upon completion of the inquiry, the ICC shall prepare a reasoned report of its findings and submit it to Harvested Labs Private Limited within ten (10) days. Harvested Labs Private Limited shall act upon the recommendations of the ICC within sixty (60) days of receipt of the report. Where allegations of sexual harassment are substantiated, Harvested Labs Private Limited may take appropriate disciplinary action against the respondent in accordance with the applicable service rules. Such action may include a written apology, warning, reprimand, salary deduction, suspension, termination of employment, mandatory counselling, or withholding of promotion or increment, depending on the severity of the misconduct.

11. False and Malicious Complaints

If the ICC concludes, after due inquiry, that the complaint was made with malicious intent or that the complainant knowingly produced false or misleading evidence, Harvested Labs Private Limited may take appropriate disciplinary action in accordance with the applicable service rules. However, mere inability to substantiate a complaint or provide adequate proof shall not by itself attract action under this clause. Harvested Labs Private Limited recognizes that complaints made in good faith must not be discouraged.

12. Confidentiality

Harvested Labs Private Limited shall maintain strict confidentiality throughout the complaint, inquiry, and resolution process. In accordance with Section 16 of the POSH Act, the identity of the complainant, respondent, witnesses, details of the proceedings, and the recommendations of the ICC shall not be published, communicated, or made known to the public, press, or media in any manner. All persons involved in the process, including ICC members, parties, and witnesses, are required to preserve confidentiality. Any breach of confidentiality, including disclosure through social media or informal channels, may result in disciplinary action in accordance with Company policy and applicable law.

13. Protection against Retaliation

Harvested Labs Private Limited strictly prohibits retaliation against any individual for filing a complaint in good faith, participating in an inquiry, or supporting a complainant. Any act of retaliation, intimidation, or victimization shall be treated as misconduct and may attract disciplinary action under Harvested Labs Private Limited's service rules.

14. Annual Reporting

The ICC shall prepare an annual report in accordance with the POSH Act, containing details of the number of complaints received, disposed of, pending cases, and actions taken during the year. The report shall be submitted to Harvested Labs Private Limited and to the District Officer or other statutory authority as required under applicable law.

15. Harvested Labs Private Limited's Responsibilities

Harvested Labs Private Limited is committed to fulfilling its statutory obligations under the POSH Act and shall take all reasonable steps to prevent and address sexual harassment at the workplace. Harvested Labs Private Limited shall provide a safe working environment, display POSH awareness materials at conspicuous locations, conduct regular training and sensitization programs, and ensure that the ICC is properly constituted and functional at all times. Harvested Labs Private Limited shall also assist the complainant in filing a police complaint where required, monitor timely submission of ICC reports, and include POSH compliance as part of its internal governance and audit processes.

16. Consensual Romantic Relationships at the Workplace

All consensual romantic and sexual relationships between an employee and their subordinate (or) between employees regardless of whether they involve the superior-subordinate dynamic must be disclosed to Harvested Labs Private Limited's HR division. Employees in a relationship should neither use office resources or property to further their relationship nor should they engage in intimate or affectionate behavior during work hours or while on office premises. The end of such a relationship should also be communicated to HR.

In the case of a relationship between a supervisor and supervisee, Harvested Labs Private Limited reserves the right to reassign and rearrange teams in such a way that the employee is no longer directly supervised by the person with whom they are or were in a relationship. Harvested Labs Private Limited is committed to maintaining a fair and equitable workplace and accordingly strives to ensure that no romantic, personal, or vested interests inform access to opportunities, performance-related rewards, and other advantages. An employee in a supervisory capacity shall withdraw from and not participate in activities or decisions involving hiring, evaluations, promotions, appraisals, and disciplines that reward or penalize any person with whom the supervisor has or has had a romantic and/or sexual relationship.

All consensual romantic and sexual relationships between employees not involving supervisors and their subordinates can also impact the office environment and work performance. Thus, Harvested Labs Private Limited reserves the right to reassign and rearrange teams if such relationships affect the office environment and work performance adversely. If an employee is interested in a co-worker, they can respectfully inform the co-worker without causing any discomfort and respect the decision and response of the co-worker. They should refrain from continuously pursuing the second party for this purpose.

If customers, vendors or any non-employee, who has a business relationship with the organization, approaches the employees requesting for dates or behave in sexually inappropriate or offensive ways, it should be reported to the Human Resources Department, regardless of whether the behavior was welcomed or not. The employee can determine whether or not to file a complaint to the ICC if the behavior was unwelcome. Harvested Labs Private Limited shall ensure that the designated HR person will document this information and maintain utmost confidentiality while handling workplace romances.

17. Appeal

Any person aggrieved by the recommendations of the ICC or by non-implementation thereof may prefer an appeal before the High Court for the State of Telangana within ninety (90) days in accordance with Section 18 of the POSH Act and the applicable service rules of Harvested Labs Private Limited.

Annexure 1 — Internal Complaints Committee

Presiding Officer: SAI PHANI RAHUL AREPAKA

Member 1: GEORGE MATHEW

Mode of Contact: Email: founders@harvestedlabs.com