Approval Date: August 07, 2025

Approval Date: August 07, 2025

Document Owner: Presiding Officer - ICC and CHRO - Airtel Payments Bank

Approved By: Board of Directors, Airtel Payments Bank

1.     Objective

This policy is in compliance with and incorporates provisions of the recently enacted The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“Act”). The objective of the Act is the protection of women at the work place from any form of overt or covert sexual harassment by providing a redressal mechanism. 

The Company has zero tolerance towards any kind of verbal, psychological conduct, physical act/conduct of a sexual nature by any employee or partner/ vendor or any other stakeholder that directly or indirectly creates an intimidating, offensive, or hostile environment and will take all steps necessary to deal with complaints effectively and quickly. 

2.     Scope and Application

This policy applies to Complaints of Sexual Harassment by an employee or third party who is associated with Airtel Payments Bank Limited (the “Company”) in any form at its Workplace, regardless of whether the alleged incident (s) or offence (s) has/have occurred in or outside the Workplace.

2.1  Policy and Exception

No person should be subjected to any form of unwanted and unwelcome behavior or conduct with sexual overtures or overtones, directly or indirectly either physically, verbally or in writing. There are no exceptions to this Policy.

3. Definitions

3.1  “Complaint” means an objection or the allegation by the Complainant or any other person in writing of sexual harassment by the Respondent that forms the basis of an investigation under this Policy.

3.2 “Complainant” means the person (s) against whom an incident (s) of sexual harassment has been allegedly committed.

3.3 “Respondent” mean a person against whom a complaint of sexual harassment has been made/filed.

3.4 “Rules” means the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013

3.5 “Sexual Harassment” – includes but is not limited to any of the following acts or behavior, whether direct or indirect that is unwelcome to the intended recipient and includes

i     Sending or displaying text or visual messages of sexual nature from any device;

ii    Inappropriate comments, jokes, threats, gender specific abusive language;

iii. Physical contact against a persons’ wishes;

iv. Call, stalk including cyberstalking, intimidate or pursue anyone against such person’s wishes;

v. Invite or interact with/by compelling any person on the social media, internet, cyber space, via electronic communication;

vi. Demanding favours for professional advancement

v. Using threats or creating a hostile and unpleasant work environment that may impact a person’s ability to work in a hassle free Workplace; and

vi. following circumstances, among other circumstances, if it occurs, or is present in relation to or connected with any act or behaviour of sexual harassment may amount to sexual harassment: -   a) Implied or explicit promise of preferential treatment in employment; or

b) Implied or explicit threat of detrimental treatment in employment; or

c) Implied or explicit threat regarding present or future employment status; or

d) Interference with work or creating an intimidating or offensive or hostile work environment for an employee; or

e) Humiliating treatment likely to affect employee’s health or safety

“Workplace” shall include:

i     All offices or other premises where the Company’s business is conducted including during the course of performing duties while working from home.

ii    Any place visited by the employee arising out of or during the course of employment including transportation provided by the Company.

iii  Any social, business or other functions organized by the Company

4. Internal Complaints Committee (ICC)

As required under the Act, the Company has constituted Internal Complaints Committees that will investigate all Complaints of Sexual Harassment. The name of the members of the committee, along with the contact details are listed in the Appendix to this Policy. 

The members of the ICC shall hold office for a period of three years from the date of nomination and the Company can re-nominate the existing members or nominate another person to replace a member who vacates office for any reason including resignation from the Company’s service. The Company has also appointed an external member who is from a recognized non-governmental organization or association committed to the cause of women or a person familiar with the issues relating to sexual harassment.

5. Procedure for making and handling of complaints and enquiry

The Procedure for dealing with complaints shall be as follows:

a)     A complaint may be made orally but preferably in writing by the Complainant within 3 months of the alleged incident or the last of such incidents, as applicable and may be extended by the ICC for just cause. Where an aggrieved person is unable to make a complaint on account of physical incapacity or mental incapacity or for any other reason, a complaint may be filed in accordance with the provisions of the Rules, with the written consent of the aggrieved person and where the an aggrieved person is dead, a complaint may be filed by any person who has knowledge of the incident, with the written consent of the legal heir.

b)     The ICC may before initiating an inquiry, on a request from the Complainant, take steps to settle the matter between the Complainant and the Respondent through conciliation. Conciliation may include Complainant seeking a written apology from the Respondent. No monetary settlement shall be made on this basis. When the parties have agreed on a settlement/conciliation, the relevant ICC shall record the same, copies of which shall be provided to both parties and take suitable action in terms of the settlement. The matter will then be treated as closed and no further enquiry shall be conducted.

c)     If the settlement is not complied with for any reason, or a settlement is not reached between the parties, the ICC shall proceed with an inquiry, allowing both the parties to explain their case as well as submit any evidence in support of their statements.

d)     During an inquiry, the ICC may recommend any interim relief to the Complainant if a written request is received including:

i.      transfer of the Complainant or the Respondent to any other location; or

ii.     grant leave to the Complainant up to a period of three months that will be in addition to any other entitled leave

iii.   grant such other relief to the Complainant, as deemed fit.

e)     For the purpose of making an inquiry, the ICC shall have the same powers as are vested in a civil court under the Code of Civil Procedure, 1908 when trying a suit in respect of the following matters, namely:

i.    summoning and enforcing the attendance of any person and examining on oath;

ii.   requiring the discovery and production of documents/records; and any other matter which may be prescribed

f)      On completion of the inquiry (which is to be completed within a period of 90 days), the ICC shall send a report on the findings to the business head and CHRO within 10 days and the relevant extract or a summary of the findings shall be given to the Complainant and the Respondent. An opportunity will also be provided to the concerned parties to make representations to the committee if either or both do not agree with the findings.

g)     If the allegations are established after due process and investigation, depending on the nature and seriousness of the offence,  ICC will make a recommendation to Human Resources Department of the Company for implementation in terms of the Consequence Management Policy applicable and may include without limitation, the following :-

i.       A warning letter to be issued in writing to the accused; or a counselling session for an accused

ii.     Deferment of increment or promotion

iii.    Transfer, termination or separation.

iv.    Deduction of a sum, from the salary of the Respondent as deemed appropriate by the ICC depending on the facts of each case, such sum shall be paid to the Complainant. For the purpose of determining the sums to be paid to the Complainant, ICC shall have regard to

a)    Mental trauma, pain, suffering, and emotional distress caused to the Complainant;

b)     Loss of career opportunity due to the incident of Sexual Harassment;

c)     Medical expenses for physical or psychiatric treatment;

d)     Income and financial status of the respondent;

e)     Feasibility of payment in lump sum or instalments.

v.     If the Company is unable to make such deduction from the salary of the Respondent due to absenteeism, cessation of employment, etc., the ICC may direct to the Respondent to pay such sum to the Complainant. 

vi. Any other action as it may deem fit in accordance with Consequence Management Policy

h) The Company shall act upon the recommendation within sixty days of its receipt. If the Complaint is not established, a report of the same will also be sent by the ICC to Human Resources Department for records.

6.   Punishment for false or malicious complaint and false evidence

If the ICC concludes that the allegations were malicious or frivolous, it may after due enquiry, recommend action against the Complainant that may include deferment of annual increment, promotion, warning letter, transfer or separation. Mere inability to substantiate a complaint or lack of adequate proof will not be held against Complainant.

7.   Confidentiality

Notwithstanding anything contained in the Right to Information Act, 2005 (as may be applicable to the Company), subject to the provisions hereinafter, the contents of the Complaint, identity and address of the Complainant, respondent and witnesses, any information relating to conciliation and inquiry proceedings, recommendations of the ICC, as the case may be, and the action taken by the Company will not be published, communicated or made known to public, press, media in any manner. All matters and proceedings relating to the Complaint including the identity of the Complainant and Respondent shall remain strictly confidential and will not be disclosed except to a competent court or a governmental agency that has the right under the law and regulation to obtain such information. However, the recommendation of the ICC and its implementation may be intimated on a need to know basis for cause. Any person who breaches the confidentiality requirement shall be penalized.

8.  Revision of recommendations or Filing of Appeal

Any person who does not agree with the recommendations made or non-implementation of such recommendations may prefer an appeal before the Court of competent jurisdiction, as per Rules.

9. Assurance against Retaliation

Employees are encouraged to express freely, responsibly, and in an orderly way opinions and feelings about any problem or complaint of sexual harassment. Retaliation against persons who report or provide information about Sexual Harassment or behavior that might constitute Sexual Harassment is also strictly prohibited. Any act of reprisal, including internal interference, coercion, and restraint, by an employee, violates this policy and will result in appropriate disciplinary actions.

10.  Third Party involvement

Where Sexual Harassment occurs as a result of an act or omission by any third party or outsider, the Company will take all steps necessary and reasonable to assist the affected person in terms of support and preventive action.

11.  Penal Consequences under the Indian Penal Code (IPC)

Conduct that may be construed as sexual harassment not only violates the Prevention of Workplace Sexual Harassment Act, but also could constitute an offence under the IPC/Bhartiya Nyaya Sanhita (“BNS”). Listed out below are the key offenses under the IPC/BNS that could be triggered in a case of sexual harassment.

 12. Modifications 

Management reserves the right to modify or terminate this Policy without prior notice.

13. Policy Owner

This policy is owned by the Head of ICC, Airtel Payments Bank and CHRO, Airtel payments Bank Ltd. Contact details – POSH@airtelbank.com