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Policy on Prevention of Sexual Harassment at the Workplace (POSH)

1. Purpose

Bigsun Technologies is committed to providing a safe, respectful, inclusive and professional working environment in which every individual is treated with dignity.

The organisation prohibits sexual harassment at the workplace and is committed to preventing such conduct, providing an appropriate complaint mechanism, protecting the confidentiality of proceedings and taking action in accordance with applicable law.

This policy has been prepared with reference to the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“POSH Act”) and the applicable rules, as amended or otherwise in force.

2. Scope and Applicability

This policy applies to the relevant legal entity that formally adopts it and to its covered workplaces in India, including Maharashtra.

It covers, as applicable:

• Permanent, temporary, contractual and probationary employees.
• Trainees, interns and apprentices.
• Consultants and other individuals engaged to provide services.
• Women visiting the workplace, clients, vendors, contractors and other persons interacting with the organisation.
• Work-related travel, client locations, business meetings, conferences, work-related social events and other places or circumstances falling within the statutory meaning of workplace.
• Remote working and work-related electronic communications, including email, messaging applications, telephone calls and video meetings.

The statutory protection under the POSH Act extends to an aggrieved woman irrespective of her age or employment status. The Act also provides a separate complaint mechanism for domestic workers.

The organisation may separately prohibit and address sexual harassment or other inappropriate conduct affecting any employee, irrespective of gender, under its other applicable employment policies. This does not restrict any person's rights or remedies under other applicable laws.

2.1 Applicability to associated companies

The business has identified the following companies and contact persons:

Company	Contact person
Bigsun Technologies	Mamta Pawar
Solarity	Krutika Thakur
Travel Savvy	Rutika Pawar

The legal identity of each entity, its employee strength, workplaces and applicable committee arrangements must be verified before this policy is adopted across the three businesses.

The policy must not be interpreted as automatically constituting one Internal Committee for three separate legal entities. Each employer must ensure compliance with its own applicable statutory obligations and formally adopt the policy as appropriate.

3. Definition of Sexual Harassment

Under the POSH Act, sexual harassment includes one or more of the following unwelcome acts or behaviour, whether directly or by implication:

1. Physical contact and advances.
2. A demand or request for sexual favours.
3. Making sexually coloured remarks.
4. Showing pornography.
5. Any other unwelcome physical, verbal or non-verbal conduct of a sexual nature.

The circumstances specified under the Act may also constitute sexual harassment where they occur in connection with, or in the circumstances of, such conduct. Examples include:

• An implied or explicit promise of preferential treatment in employment.
• An implied or explicit threat of detrimental treatment in employment.
• An implied or explicit threat concerning present or future employment status.
• Interference with work or creation of an intimidating, offensive or hostile work environment.
• Humiliating treatment likely to affect an individual's health or safety.

Examples of conduct prohibited under this policy may include unwelcome sexual advances, inappropriate touching, sexually suggestive messages, repeated unwanted personal invitations, sexually explicit images, inappropriate comments about a person's body or appearance, and misuse of workplace authority to seek sexual favours.

The context and circumstances of each incident must be considered fairly. A complaint must not be dismissed merely because the conduct occurred electronically, outside normal working hours or at a client location, where the statutory workplace connection exists.

4. Zero-Tolerance Principle

The organisation does not tolerate sexual harassment, intimidation, retaliation or abuse of authority.

No employee, manager, director, consultant, vendor or other person acting in a work-related capacity may engage in conduct prohibited by this policy.

All employees are expected to:

• Treat colleagues and other workplace participants with dignity and respect.
• Maintain appropriate professional boundaries.
• Refrain from unwanted conduct of a sexual nature.
• Cooperate honestly with an authorised inquiry.
• Report concerns through appropriate channels.
• Respect the confidentiality of complaints and proceedings.

A person's seniority, position, performance, client relationship or commercial importance does not excuse prohibited conduct.

5. Responsibilities of the Organisation

The employer shall, as applicable under law:

1. Provide a safe working environment, including protection from persons who come into contact with employees at the workplace.
2. Adopt and communicate a policy prohibiting sexual harassment.
3. Constitute the required Internal Committee by a written order wherever the statutory conditions require it.
4. Display the consequences of sexual harassment and the order constituting the Internal Committee at conspicuous places in the workplace, as required.
5. Organise awareness and sensitisation programmes at appropriate intervals.
6. Provide orientation and support to Internal Committee members.
7. Provide the facilities and assistance necessary for complaint handling and inquiry.
8. Assist in securing the attendance of the respondent and witnesses, where required.
9. Monitor the timely implementation of the Committee's recommendations.
10. Treat sexual harassment as misconduct under applicable service rules and initiate appropriate action where warranted.
11. Maintain confidentiality and comply with statutory reporting obligations.
12. Provide assistance to a complainant who chooses to pursue a criminal complaint, where required by law.

Management shall not interfere improperly with the independence of the Internal Committee.

6. Internal Committee (IC)

Where required by Section 4 of the POSH Act, the employer shall constitute an Internal Committee through a written order.

The committee must have the statutory composition, including:

• Presiding Officer: A senior-level woman employee, subject to the statutory requirements. Where the prescribed condition applies and a suitable senior woman employee is unavailable at the workplace, the appointment must follow the alternative permitted under the Act.
• Employee members: At least two employees nominated in accordance with the Act, preferably committed to the cause of women or having relevant social work or legal knowledge.
• External member: One member from a non-governmental organisation or association committed to the cause of women, or a person familiar with issues relating to sexual harassment, as permitted by the Act.

At least half of the nominated members must be women.

The Presiding Officer and members shall hold office for the period specified in the appointment, not exceeding three years from the date of nomination, in accordance with the Act.

The employer must ensure that the Committee is constituted at the relevant offices or administrative units as required by law.

6.1 Internal Committee details — to be completed before publication

The following details must be formally confirmed and inserted into the final approved policy or the applicable appointment notice.

Required detail	Information
Legal name of employer	Company confirmation required
Presiding Officer	Company confirmation required
Employee Member 1	Company confirmation required
Employee Member 2	Company confirmation required
External Member and organisation	Company confirmation required
Committee appointment date	Company confirmation required
Official complaint email	Company confirmation required
Official postal address	Company confirmation required
Relevant workplace / office	Company confirmation required

These fields must not be replaced with invented names or contact details.

6.2 Workplaces with fewer than ten employees

Where an Internal Committee is not required because the workplace has fewer than ten employees, or where a complaint is against the employer, the complainant may approach the appropriate Local Committee constituted by the District Officer, in accordance with the Act.

The organisation must identify the appropriate District Officer and Local Committee for the relevant workplace in Maharashtra and provide the applicable contact information to employees.

7. How to Make a Complaint

An aggrieved woman may submit a written complaint to the applicable Internal Committee or Local Committee.

The complaint should describe, as clearly as possible:

• The incident or incidents complained of.
• The date, approximate time and place of each incident.
• The identity of the person complained against, if known.
• The names of witnesses, if any.
• Relevant supporting material, such as emails, messages, documents or other available evidence.
• The relief sought, where applicable.

A complainant may request assistance from the Presiding Officer or a Committee member to put the complaint in writing if she is unable to do so herself.

Where the complainant is unable to make a complaint due to physical or mental incapacity, death or another reason recognised by law, a complaint may be made by a person permitted under the applicable rules, subject to the relevant conditions.

7.1 Time limit for filing

Under the POSH Act, a complaint should ordinarily be made within three months from the date of the incident or, in the case of a series of incidents, within three months from the date of the last incident.

The Internal Committee or Local Committee may extend the time by a further period not exceeding three months if it is satisfied that circumstances prevented the woman from filing the complaint within the original period and records its reasons in writing.

The complainant should not be discouraged from raising a concern merely because she is uncertain about the applicable time limit. The appropriate Committee should assess the circumstances under the law.

8. Conciliation

Before initiating an inquiry, the Internal Committee or Local Committee may, at the request of the aggrieved woman, attempt conciliation in accordance with Section 10 of the POSH Act.

Conciliation must not be initiated at the request of the respondent alone.

No monetary settlement shall be made the basis of conciliation.

Where a settlement is reached, the Committee must record it and follow the statutory process for forwarding the settlement and ensuring that appropriate action is taken. A further inquiry into the same complaint is not required where the Act so provides, unless the terms of settlement are not complied with.

If conciliation is not requested, is unsuccessful or is not completed in accordance with law, the Committee shall proceed as applicable.

9. Inquiry Procedure

The Internal Committee or Local Committee shall handle complaints impartially, fairly and in accordance with the POSH Act, applicable rules and the relevant service rules.

The process shall include:

1. Reviewing the complaint and determining the appropriate procedure.
2. Providing the respondent with the complaint and a fair opportunity to respond, in accordance with the prescribed procedure.
3. Allowing both parties to present relevant information and evidence.
4. Giving both parties a fair opportunity to be heard.
5. Examining relevant witnesses and records, where appropriate.
6. Maintaining proper records of the proceedings.
7. Avoiding bias, intimidation, unnecessary delay or interference.
8. Reaching findings based on the material available and the applicable standard of proof.

The parties shall not be permitted to bring legal practitioners to represent them before the Committee during the inquiry where the POSH Act prohibits such representation.

The Committee shall have the powers and follow the procedures provided under the Act and Rules. It shall not act as a substitute for a criminal court or exceed its statutory authority.

9.1 Statutory timelines

The following timelines must be observed, subject to the applicable provisions of the Act:

• Complaint filing: Ordinarily within three months of the incident or last incident in a series; a permitted extension of up to a further three months may be granted for recorded reasons.
• Completion of inquiry: Within 90 days.
• Submission of inquiry report: Within 10 days of completion of the inquiry.
• Action on recommendations: The employer or District Officer, as applicable, must act on the recommendations within 60 days.
• Appeal: An appeal may be made within 90 days in accordance with Section 18 and the applicable rules.

These statutory periods must not be confused with internal administrative targets.

10. Interim Relief

During a pending inquiry, the Internal Committee may recommend appropriate interim relief to the employer on the written request of the aggrieved woman, as permitted under Section 12 of the POSH Act.

Depending on the circumstances and statutory requirements, recommendations may include:

• Transfer of the aggrieved woman or the respondent.
• Grant of leave to the aggrieved woman for a period permitted under the Act, in addition to her other leave entitlement.
• Other relief expressly permitted under the Act or applicable rules.

The employer shall consider and implement lawful recommendations within the applicable requirements.

Interim measures should not be imposed in a manner that unfairly penalises the complainant or prejudges the final outcome.

11. Inquiry Findings and Action

On completion of the inquiry, the Committee shall submit its findings and recommendations in accordance with the POSH Act.

Where the Committee concludes that the allegation has not been proved, it shall recommend that no action is required against the respondent on that complaint.

Where the allegation is proved, the Committee may recommend appropriate action permitted by law, which may include:

• Disciplinary action under applicable service rules.
• Written apology, warning, reprimand or censure, where appropriate.
• Withholding of a promotion or pay increment, where legally permissible and appropriate.
• Termination of employment or other disciplinary measures, where warranted under applicable rules.
• Deduction from the respondent's salary or wages towards compensation payable to the aggrieved woman, where recommended and permitted under Section 15 of the Act.

Any action must be proportionate, based on the findings and compliant with applicable law and service rules.

The employer shall implement the Committee's recommendations within the statutory period and communicate the outcome to the parties as required.

12. Compensation

Where the Committee recommends compensation, it shall apply the factors prescribed under Section 15 of the POSH Act, as applicable. These include:

• The mental trauma, pain, suffering and emotional distress caused.
• Loss of career opportunity.
• Medical expenses incurred for physical or psychiatric treatment.
• The income and financial status of the respondent.
• The feasibility of payment in a lump sum or instalments.

Any deduction from salary or wages and the recovery of compensation must be handled in accordance with the Act.

13. Protection Against Retaliation

No person shall be threatened, intimidated, disadvantaged or subjected to retaliation for making a complaint in good faith, participating as a witness, providing information or cooperating with an authorised inquiry.

Retaliation may include threats, harassment, unjustified adverse treatment, deliberate isolation, intimidation or improper interference with employment.

Any such concern should be reported to the Internal Committee or another appropriate authority. The Committee or employer shall address the concern in accordance with applicable law and the circumstances.

This provision does not prevent lawful action based on independently established performance, conduct or business reasons. Such action must not be used as a pretext to punish a complainant or witness.

14. Confidentiality and Records

The organisation and all persons involved in complaint handling shall preserve confidentiality as required under Section 16 of the POSH Act.

The following must not be published, communicated or made known to the public, press or media in a manner prohibited by law:

• The contents of the complaint.
• The identity and address of the aggrieved woman, respondent and witnesses.
• Information relating to conciliation and inquiry proceedings.
• Recommendations of the Committee.
• Action taken by the employer.

Information concerning the justice secured to an aggrieved woman may be disseminated without disclosing the identity or particulars that could lead to identification, as permitted by law.

Complaint records shall be restricted to authorised persons, stored securely and retained in accordance with applicable legal requirements and the organisation's approved retention procedures.

No employee shall circulate complaint details through informal email groups, messaging applications, social media or other unauthorised channels.

15. Malicious Complaints and False Evidence

A complaint that cannot be substantiated does not, by itself, establish that it was malicious or false.

Action against a complainant for a malicious complaint, knowingly false allegations or forged or misleading evidence may be considered only where the Committee reaches the findings required under Section 14 of the POSH Act and follows the applicable procedure.

A mere inability to substantiate a complaint or provide adequate proof shall not attract action on that basis alone.

The same principles of fairness, evidence and applicable service rules shall govern any resulting disciplinary action.

16. Awareness and Training

The organisation shall take appropriate steps to prevent workplace sexual harassment, including:

• Communicating this policy to employees.
• Conducting awareness and sensitisation programmes at regular intervals.
• Providing orientation for Internal Committee members.
• Displaying required notices and Committee details at the workplace.
• Including relevant policy information in employee induction.
• Making the complaint mechanism accessible to employees and other relevant workplace participants.

Training and awareness activities should be documented, including the date, subject, audience and attendance, as appropriate.

17. Employer Reporting Obligations

The Internal Committee shall prepare and submit its annual report to the employer and the appropriate District Officer in accordance with the POSH Act and applicable rules.

The report must include the information required by law, including the number of complaints received, disposed of and pending at the end of the reporting period, as applicable.

The employer shall include the required information in its annual report or intimate the number of cases to the District Officer where no annual report is required, in accordance with Section 22 of the Act.

The organisation shall verify the applicable reporting format, submission deadline and District Officer requirements for each relevant workplace in Maharashtra.

18. External Complaints and Other Legal Remedies

Nothing in this policy prevents a person from approaching the police, the appropriate Local Committee, a competent court or another authority where permitted by law.

Where the alleged conduct may constitute a criminal offence, the organisation shall provide assistance required by law. The internal process shall not be used to obstruct lawful reporting or investigation.

The organisation shall also comply with any applicable directions of competent authorities.

19. Responsibilities of Employees and Managers

Employees must maintain professional conduct, respect the rights and dignity of colleagues, cooperate with lawful inquiries and refrain from retaliation or unauthorised disclosure.

Managers must act promptly when concerns are brought to their attention, avoid suppressing complaints, protect confidentiality and refer matters to the appropriate channel.

Human Resources / Management must support the implementation of this policy, maintain relevant records, coordinate required training and ensure that statutory responsibilities are fulfilled.

Internal Committee members must act independently, impartially and confidentially, declare and address conflicts of interest, and follow the statutory process.

20. Policy Review and Amendments

This policy is issued as a draft for management approval for 2026.

It shall be reviewed periodically and whenever required due to changes in applicable law, organisational structure, workplace arrangements or the statutory requirements governing the relevant legal entity.

Any amendment shall be approved by the authorised management representative and communicated to employees.

The policy year does not replace statutory annual reporting periods or extend any legal deadline.