WORKPLACE HARASSMENT POLICY DRAFT BrightTech Solutions Mumbai Maharashtra India Effective Date: June 1 2026 Version 1.0 Prepared by: HR Department 1. POLICY STATEMENT BrightTech Solutions is absolutely committed to maintaining a workplace where every person is treated with dignity, respect, and fairness. Harassment, discrimination, and bullying of any kind will not be tolerated under any circumstances. We take every complaint seriously, investigate it promptly and impartially, and hold all individuals fully accountable for their conduct regardless of their seniority, role, or tenure with this organization. 2. PURPOSE OF THIS POLICY 2.1 This policy defines conduct that is unacceptable in our workplace. 2.2 It provides a clear and accessible reporting process for all affected employees. 2.3 It sets out the Company's investigation and disciplinary procedures. 2.4 It fulfills the Company's legal obligations under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act 2013 (POSH Act) and all other applicable Maharashtra India employment and anti-discrimination laws. 3. SCOPE OF THIS POLICY 3.1 This policy applies to all employees of BrightTech Solutions regardless of employment type, including full-time, part-time, contract, and intern staff. 3.2 It also applies to visitors, clients, and any other individuals who interact with our workplace. 3.3 This policy applies in all Company environments including our Mumbai office, remote working settings, Company events, business travel, and all digital communications platforms used for work. 4. DEFINITIONS 4.1 Harassment: Unwanted conduct related to a protected characteristic that violates a person's dignity or creates an intimidating, hostile, or offensive environment. Example 1: Making repeated derogatory comments about a colleague's disability. Example 2: Excluding a team member from meetings because of their religion. 4.2 Sexual Harassment: Any unwanted conduct of a sexual nature that violates a person's dignity or creates an intimidating or offensive environment. Example 1: Sending sexually explicit messages to a colleague without their consent. Example 2: Making inappropriate comments about a colleague's physical appearance in a sexual context. 4.3 Bullying: Persistent negative behavior directed at one or more individuals that undermines their confidence or dignity. Example 1: Repeatedly shouting at an employee in front of colleagues. Example 2: Consistently undermining a team member's contributions in meetings. 4.4 Cyber Harassment: Harassment carried out through digital platforms including email, messaging apps, or social media. Example 1: Sending hostile or threatening messages through a work messaging platform. Example 2: Posting embarrassing images of a colleague on social media without consent. 4.5 Retaliation: Any adverse action taken against an employee for making a complaint or participating in an investigation. Example 1: Excluding an employee from projects after they filed a complaint. Example 2: Reducing an employee's responsibilities or salary following their participation in an investigation. 5. HOW TO REPORT HARASSMENT 5.1 Employees may report harassment to: (a) The HR Department at BrightTech Solutions; or (b) The Internal Complaints Committee (ICC) as constituted under the POSH Act 2013 where the complaint involves sexual harassment. 5.2 If the alleged harasser is in the employee's reporting line, the complaint may be directed to the ICC or directly to a senior HR leader. 5.3 Verbal reports are accepted but a written record will be made by HR. 5.4 Employees who report a complaint will be provided with the name of a designated HR contact who will support them throughout the process. 6. WHAT HAPPENS AFTER A REPORT IS MADE 6.1 The Company will acknowledge receipt of every complaint within 7 calendar days. 6.2 An impartial investigator or the ICC will be appointed within 7 days of acknowledgment. 6.3 The alleged harasser will be notified that a complaint has been made against them. 6.4 Interim protective measures such as temporary reassignment or remote work arrangements may be implemented during the investigation. 6.5 The investigation will be completed within 60 calendar days. 7. THE INVESTIGATION PROCESS 7.1 An impartial investigator or ICC panel will be appointed for each complaint. 7.2 Both the complainant and respondent will have the right to present their account and submit evidence. 7.3 Relevant witnesses will be interviewed by the investigator. 7.4 All investigation proceedings will be conducted and documented confidentially. 8. DISCIPLINARY CONSEQUENCES 8.1 Substantiated findings of harassment may result in the following disciplinary actions depending on severity: (a) Formal written warning and mandatory training for less severe incidents. (b) Demotion or suspension for repeated or more serious harassment. (c) Immediate termination of employment for serious harassment including sexual harassment as defined under the POSH Act. 8.2 The Company reserves the right to escalate directly to termination in cases of serious misconduct without following prior warning steps. 9. SUPPORT FOR AFFECTED EMPLOYEES 9.1 Employees who have experienced harassment will have access to the Company's Employee Assistance Programme (EAP) for confidential counseling support. 9.2 Temporary reassignment away from the alleged harasser may be arranged pending the outcome of the investigation. 9.3 A named HR contact will provide the affected employee with regular updates throughout the investigation process. 10. PROTECTION AGAINST RETALIATION 10.1 Retaliation against any employee who has made a complaint in good faith, participated in an investigation, or supported a complainant is strictly prohibited. 10.2 Any employee found to have retaliated will face disciplinary action up to and including immediate termination. 11. HARASSMENT TRAINING 11.1 All employees at BrightTech Solutions are required to complete mandatory anti-harassment training annually. 11.2 Managers and HR personnel will receive additional training covering their legal obligations under the POSH Act 2013. 11.3 Completion of training will be documented in each employee's personnel record. 12. LEGAL COMPLIANCE 12.1 This policy is designed to comply with the POSH Act 2013 and all other applicable Maharashtra India employment and anti-discrimination legislation. 12.2 This policy will be reviewed and updated annually and whenever there is a material change in applicable law. EMPLOYEE ACKNOWLEDGMENT I confirm that I have received, read, and understood the contents of this Workplace Harassment Policy. Employee: ________________ Date: ____________________ DISCLAIMER: This Workplace Harassment Policy was generated by an AI drafting tool for reference and preparation purposes only. It does not constitute legal advice. Anti-harassment laws, mandatory reporting obligations, and workplace conduct requirements vary significantly by jurisdiction and industry. Always have this reviewed by a qualified employment attorney before distributing it to employees.