Company Policies

Corporate Social Responsibility Policy

Riot Labz Private Limited has vision to do business with a smile for customer delight and a commitment to society. Company has built strong value of trust and earned due respect from its clients, business associates, customers and society at large. Company is committed to implement Corporate Social Responsibility (CSR) Policy through Investments in various areas as defined below. It is the intent of the Company to make a positive difference to society by continuous efforts to make the life of poor and needy persons better.

Policy

This Policy is called as "Corporate Social Responsibility Policy". The policy has been approved by the Board of Directors of the Company. Company shall invest such amount as decided by the Board on any of the following projects or programs.

Area of CSR Projects or Programs

Company plans to undertake CSR projects or programs under following area as approved by the Board either directly or through some registered trust or a registered society or a section 8 company established by Company or its subsidiary or associate company:

(i) eradicating hunger, poverty and malnutrition, promoting preventive health care and sanitation, including contribution to the Swach Bharat Kosh set up by the Central Government for the promotion of sanitation, and making available safe drinking water;

(ii) promoting education, including special education and employment enhancing vocational skills especially among children, women, elderly and the differently abled and livelihood enhancement projects;

(iii) promoting gender equality, empowering women, setting up homes and hostels for women and orphans; setting up old age homes, day care centers and such other facilities for senior citizen and measures for reducing inequalities faced by socially and economically backward groups;

(iv) ensuring environmental sustainability, ecological balance, protection of flora and fauna, animal welfare, agroforestry, conservation of natural resources and maintaining quality of soil, air and water; including contribution to the Clean Ganga Fund set-up by the Central Government for rejuvenation of river Ganga;

(v) protection of national heritage, art and culture including restoration of buildings and sites of historical importance and works of art; setting up public libraries; promotion and development of traditional arts and handicrafts;

(vi) measures for the benefit of armed forces ventures, war widows and their dependents;

(vii) training to promote rural sports, nationally recognized sports, para-olympics sports and Olympic sports;

(viii) contribution to the prime Minister's National Relief Fund or any other fund set up by the Central Government for socio-economic development and relief and welfare of the Scheduled Castes, the Scheduled Tribes, other backward castes, minorities and women;

(ix) contributions or funds provided to technology incubators located within academic institutions which are approved by the Central Government;

(x) rural development projects.

(xi) slum area development.

Provided that if the expenditure is incurred through trust/society/other company, Riot Labz Private Limited shall specify the project or program to be undertaken through these entities, the modalities of utilization of funds on such projects and programs and the monitoring and reporting mechanism.

RIOT LABZ PRIVATE LIMITED

POLICY ON PREVENTION, PROHIBITION AND REDRESSAL OF SEXUAL HARASSMENT AT WORKPLACE (PoSH Policy)

Safe Workplace and Zero Tolerance Policy

Amended and Effective from 30th May, 2026

Content:

1. Introduction and objective: 1
2. Scope and Applicability: 1-2
3. Definitions: 2-3
4. Internal Committee: 3-4
5. Complaint Mechanism: 4
6. Complaint through Local Committee: 4
7. Nodal Officer and SHe-Box: 4
8. Complaints by persons acting on behalf of aggrieved woman: 5
9. Conciliation, inquiry procedure, interim relief, inquiry report: 5
10. Disciplinary Action: 5-6
11. Compensation, False or Malicious complaint: 6
12. Record retention, confidentiality: 6
13. Protection against retaliation, responsibility of employer: 7
14. Duties of employees, Annual Report and Appeal: 7
15. Review of Policy and Amendments: 8
16. Annexure-I Details of Committee Members: 9
17. Annexure-II Complaint Form: 10-14
18. Annexure-III Investigation Procedure Flowchart: 15-16
19. Statutory timelines under POSH Act 17
20. Provisions of Bharatiya Nyaya Sanhita, 2023 relating to Sexual Harassment: 17-18

POLICY ON PREVENTION, PROHIBITION AND REDRESSAL OF SEXUAL HARASSMENT AT WORKPLACE

1. PRELIMINARY

The policy to Prevent sexual harassment at workplace (“Policy”) is approved by the board of directors of Riot Labz Private Limited (“Oakter/Company”) on 30 October, 2019 and effective from 01 November 2019 and revised by the Board on 30th May, 2026 in the meeting of Board of Directors.

Oakter reserves the right to amend, abrogate, modify, rescind / reinstate the entire Policy or any part of it as and when required as per the notification, circulars, master circulars, rules issued by the Government of India time to time.

Oakter’s fundamental Policy is that we treat all the employees of Oakter with dignity and respect. Any act constituting a grievance or harassment of any employee, trainee, contractor, vendor, customer, contract employee on the basis of religion, caste, community, physical disability or any other reason is strictly prohibited. Avoidance of acts of harassment is a precondition of employment. This Policy is applicable to all those covered under Clause-3 of this Policy, irrespective of their religion, caste, creed, community, marital status, age, sexual orientation, gender identity, physical disability, or any other protected characteristic.

2. OBJECTIVE

Oakter is committed to providing a safe, secure and dignified workplace free from sexual harassment and discrimination to all women.

This Policy is framed in accordance with(a) The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013;

(b) Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013;(c) The Repealing and Amending Act, 2016 and amendments thereto.

The Company adopts a zero-tolerance approach towards sexual harassment.

3. SCOPE AND APPLICABILITY

This Policy has been drafted keeping in view the provisions under “The Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013 (“Act”) and this Policy applies to:

1) All employees, regardless of seniority or contractual status, that is permanent, short-term contract, casual employees and trainees;

2) All board members, executive and non-executive directors, owners, shareholders etc.;

3) All contractors and sub-contractors;

4) All persons dealing with Oakter, clients, customers, suppliers, vendors, applicants for employment and anyone with whom employees interact personally or by telephone, or by electronic communication, including written communication, website and emails;

5) All business locations of Oakter including subsidiaries, associate companies etc;

6) Any external location including all foreign countries visited by employee due to or during the course of their employment with Oakter such as business locations of other Companies/entities, guest houses, foreign trips, office parties etc. organized by Oakter.;

7) Any mode of transport provided by Oakter (or a representative of Oakter) for undertaking a journey to and from the aforementioned locations.

4. MEANING OF WORKPLACE

For the purposes of this Policy, “Workplace” shall have the meaning assigned to it under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“POSH Act”) and shall include, without limitation, any place or location where an employee is present or required to be present in connection with or arising out of his/her employment with the Company.

For the purposes of this Policy, the Workplace shall include:

(i) the registered office, corporate office, branch office, factory, warehouse, plant, unit or any other premises of the Company;

(ii) any premises of a client, customer, vendor, contractor, consultant, business associate or other third party visited by an employee in connection with or during the course of employment;

(iii) any place visited by an employee arising out of or during the course of employment, including business trips, official travel, conferences, seminars, meetings, training programmes, workshops, Company-sponsored events, off-site meetings and other official activities;

(iv) transportation provided, arranged or authorised by the Company for undertaking any journey in connection with employment;

(v) Company-provided accommodation, hotels, guest houses or other places of stay during official travel or assignments; and

(vi) any other place or location, including a remote working location or work-from-home arrangement, where an employee performs duties or participates in activities connected with or arising out of employment, to the extent applicable under the POSH Act.

4. DEFINITION OF SEXUAL HARASSMENT

Sexual harassment is emotionally abusive and creates an unhealthy, unproductive atmosphere at the workplace. Sexual harassment includes such unwelcome sexually determined behavior, as physical contacts and advances, sexually colored remarks, showing pornography and sexual demands whether by words, gestures or actions. Such conduct can be humiliating and may constitute a health and safety problem. Sexual harassment includes such unwelcome sexually determined behavior (whether directly or by implication) as:

(a) Physical contact and advances;

(b) Demand or request for sexual favours;

(c) Making sexually colored remarks;

(d) Showing pornography;

(e) Unwelcome sexual advances involving verbal, non-verbal, or physical conduct such as sexually colored remarks, jokes, letters, phone calls, e-mail, gestures, showing of pornography, lurid stares, physical contact or molestation, stalking, sounds, display of pictures, signs, verbal or non-verbal communication which offends the individuals sensibilities and affect her/his performance.

(f) Eve teasing, innuendos and taunts, physical confinement against one’s will and likely to intrude upon one’s privacy;

(g) Act or conduct by a person in authority which creates the environment at workplace hostile or intimidating to a person belonging to the other sex;

(h) Conduct of such an act at workplace or outside in relation to an employee of Company or vice versa during the course of employment; and

(i) any unwelcome gesture by an employee having sexual overtones.

Illustrative examples include:

• Inappropriate touching;
• Unwanted messages or emails;
• Lewd comments or jokes;
• Displaying offensive material;
• Repeated requests for dates;
• Stalking;
• Online harassment;
• Sharing obscene content electronically;
• Retaliation after refusal of sexual advances.

5. INTERNAL COMMITTEE

The Company shall constitute an Internal Committee ("IC") as required to take up the cases of sexual harassment and constituted under Section 4 of the Act and rules thereof.

Composition:

(a) Presiding Officer – Senior woman employee;(b) Minimum two employee members committed to women's causes or possessing legal/social work knowledge;(c) One external member from NGO, association or person familiar with issues relating to sexual harassment.

At least one-half of the members shall be women.

Members shall hold office for a term not exceeding three (3) years form their nomination and appointment.

Present composition of IC having complete name and details of the members is annexed herewith as Annexure-I

6. COMPLAINT MECHANISM

Any aggrieved woman who feels and is being sexually harassed directly or indirectly may submit a complaint of the alleged incident to any member of the Committee in writing/verbal with her signature within 3 months from the date of incident and/or in case of series of incidents within 3 months from the date of last incident.

The Internal Committee may extend the period by another three months for sufficient cause.

Assistance shall be provided where the complainant is unable to make a written complaint.

7A. COMPLAINT THROUGH LOCAL COMMITTEE, NODAL OFFICER AND SHe-Box

(a) Where the complaint is against the Employer, Managing Director, Occupier, Director, or any person responsible for the management and control of the workplace, or where an Internal Committee has not been constituted, the aggrieved woman may file a complaint before the Local Committee constituted by the District Officer under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

(b) Employees may also approach the Nodal Officer designated by the District Administration for receipt and forwarding of complaints to the Local Committee in accordance with the Act and Rules.

(c) An aggrieved woman may also lodge a complaint through the Sexual Harassment Electronic Box (SHe-Box) portal of the Ministry of Women and Child Development, Government of India. Complaints received through the SHe-Box portal shall be processed in accordance with the provisions of the Act, Rules and Government notifications issued from time to time.

(d) The availability of SHe-Box shall not restrict the right of an aggrieved woman to directly approach the Internal Committee or Local Committee.

7B. COMPLAINTS BY PERSONS ACTING ON BEHALF OF AGGRIEVED WOMAN

Where the aggrieved woman is unable to make a complaint on account of physical incapacity, mental incapacity or death, a complaint may be filed by such persons as permitted under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 including a relative, friend, co-worker, special educator, qualified psychologist, guardian, legal heir or any other person having knowledge of the incident and authorised under the applicable provisions of law.

8. CONCILIATION

The Company shall ensure before initiating inquiry, the Internal Committee may, at the request of the aggrieved woman, attempt conciliation. No monetary settlement shall be made the basis of conciliation.

Settlement terms shall be recorded and implemented by the Company.

9. INQUIRY PROCEDURE

The Company shall comply the following process of inquiry:

• Copy of complaint shall be served on respondent within seven working days.
• Respondent shall submit reply within ten working days.
• Principles of natural justice shall be followed.
• Parties may produce evidence and witnesses.
• Inquiry shall be completed within ninety days.

10. INTERIM RELIEF

During inquiry, the Internal Committee may recommend:

• Transfer of complainant or respondent;
• Grant of leave up to three months to complainant;
• Restriction on reporting relationship;
• Any other suitable relief.

11. INQUIRY REPORT

The Internal Committee shall submit its report within ten days of completion of inquiry.

The employer shall act on recommendations within sixty days.

12. DISCIPLINARY ACTION

Where allegations are proved, disciplinary action may include:

• Written apology;
• Warning;
• Reprimand;
• Counselling;
• Withholding promotion;
• Withholding increment;
• Suspension;
• Transfer;
• Termination;
• Any other action permissible under law.

13. COMPENSATION

While determining compensation, the Internal Committee shall consider:

• Mental trauma and emotional distress;
• Medical expenses;
• Loss of career opportunities;
• Income and financial status of respondent;
• Feasibility of lump sum or instalment payment.

14. FALSE OR MALICIOUS COMPLAINTS

Action may be recommended only where malicious intent is established after inquiry.

Mere inability to substantiate a complaint or provide adequate proof shall not attract action.

14A. RECORD RETENTION

The Company shall maintain records relating to complaints, inquiry proceedings, evidence, inquiry reports, recommendations, action taken reports, awareness programmes and annual reports in a secure and confidential manner.

Such records shall be preserved for a minimum period of seven (7) years from the date of closure of the complaint or for such longer period as may be required under applicable law, litigation requirements or directions of any authority.

15. CONFIDENTIALITY

The following shall remain confidential:

• Identity of complainant;
• Identity of respondent;
• Witnesses;
• Inquiry proceedings;
• Recommendations;
• Action taken report.

Any breach may invite disciplinary action.

16. PROTECTION AGAINST RETALIATION

Any act of retaliation, victimisation, intimidation or adverse employment action against the complainant, respondent, witness or any person participating in the inquiry process shall be treated as misconduct and may attract disciplinary action.

17. RESPONSIBILITIES OF EMPLOYER

The Company shall:

• Provide a safe workplace;
• Display POSH awareness notices;
• Organise awareness programmes;
• Conduct IC training programmes;
• Assist IC in inquiry;
• Assist complainants in criminal proceedings;
• File statutory disclosures and annual reports.

17A. DUTIES OF EMPLOYEES

In order to maintain and promote Oakter's ethical values, every employee shall adhere to the following duties and responsibilities

• Maintain a respectful and dignified work environment;
• Refrain from engaging in any act constituting sexual harassment;
• Cooperate with the Internal Committee during inquiry proceedings;
• Maintain confidentiality of complaints and inquiry proceedings;
• Participate in awareness and training programmes conducted by the Company.

18. ANNUAL REPORT

The Internal Committee shall prepare and submit annual report containing:

• Number of complaints received;
• Number disposed of;
• Cases pending beyond ninety days;
• Awareness programmes conducted;
• Nature of action taken.

19. APPEAL

Any person aggrieved by the recommendations of the Internal Committee or the implementation thereof may prefer an appeal within ninety (90) days before the authority prescribed under the applicable service rules or any law for the time being in force.

20. REVIEW OF POLICY

The Company reserves the right to amend this Policy to ensure compliance with applicable laws.

21. AMENDMENTS

The Company reserves the right to amend the Policy from time to time in order to comply with any laws / rules / regulations that come into effect from time to time, related to Sexual Harassment.

ANNEXURE-I Details of Internal Committee Members

[updated with current members]

ANNEXURE-II Complaint Form and contact information

ANNEXURE-III Investigation Procedure Flowchart

ANNEXURE-I Details of Internal Committee Members

Riot Labz Private Limited CIN: U29253DL2014PTC273460

Email Id: Posh@@oakter.com

Contact No.: +91 8750388345

ANNEXURE-II Complaint Form

POSH COMPLAINT FORM / यौन उत्पीड़न शिकायत प्रपत्र

(Under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013)(कार्यस्थल पर महिलाओं का यौन उत्पीड़न (निवारण, प्रतिषेध एवं प्रतितोष) अधिनियम, 2013 के अंतर्गत)

Complaint No. / शिकायत संख्या: ______________________

Date of Complaint / शिकायत की तिथि: ______________________

1. Details of the Aggrieved Woman / पीड़ित महिला का विवरण

Name / नाम: ______________________________________

Employee ID / कर्मचारी आईडी: ______________________

Designation / पदनाम: ______________________

Department / विभाग: ______________________

Location / कार्यस्थल/स्थान: ______________________

Contact Number / संपर्क नंबर: ______________________

Email ID / ईमेल आईडी: ______________________

2. Details of the Respondent / प्रतिवादी का विवरण

Name / नाम: ______________________________________

Employee ID (if applicable) / कर्मचारी आईडी (यदि लागू हो): ______________________

Designation / पदनाम: ______________________

Department / विभाग: ______________________

Location / कार्यस्थल/स्थान: ______________________

Relationship with Complainant / शिकायतकर्ता से संबंध:

☐ Colleague / सहकर्मी

☐ Supervisor / प्रबंधक

☐ Reporting Manager / रिपोर्टिंग प्रबंधक

☐ Vendor / विक्रेता

☐ Consultant / सलाहकार

☐ Customer / ग्राहक

☐ Other / अन्य ______________________

3. Details of the Incident / घटना का विवरण

Date(s) of Incident / घटना की तिथि(याँ):

Time(s) of Incident / घटना का समय:

Place(s) of Incident / घटना का स्थान:

4. Nature of Sexual Harassment Alleged / कथित यौन उत्पीड़न का स्वरूप

(Please tick applicable box(es) / कृपया उपयुक्त विकल्प पर ✓ करें)

☐ Physical contact and advancesअनचाहा शारीरिक संपर्क एवं निकटता बनाने का प्रयास

☐ Demand or request for sexual favoursयौन संबंधी अनुग्रह/सुविधा की मांग या अनुरोध

☐ Making sexually coloured remarksयौन संकेतात्मक या अशोभनीय टिप्पणियाँ करना

☐ Showing pornography or sexually explicit materialअश्लील सामग्री या चित्र दिखाना

☐ Unwelcome emails, messages, calls or social media communicationअनचाहे ईमेल, संदेश, कॉल या सोशल मीडिया संचार

☐ Stalking or repeated unwanted attentionपीछा करना या बार-बार अनचाहा ध्यान देना

☐ Verbal harassmentमौखिक उत्पीड़न

☐ Non-verbal harassmentअमौखिक उत्पीड़न

☐ Any other unwelcome conduct of a sexual natureयौन प्रकृति का कोई अन्य अवांछित व्यवहार

Please specify / कृपया विवरण दें:

5. Detailed Description of Incident / घटना का विस्तृत विवरण

Please describe the incident(s) in detail, including the sequence of events, words spoken, actions taken, and any other relevant information.

कृपया घटना/घटनाओं का विस्तृत विवरण दें, जिसमें घटनाक्रम, कही गई बातें, किए गए कार्य तथा अन्य प्रासंगिक जानकारी शामिल हो।

6. Witness Details (if any) / गवाहों का विवरण (यदि कोई हो)

7. Supporting Documents/Evidence Attached / संलग्न दस्तावेज़ एवं साक्ष्य

(Please tick applicable box(es) / कृपया उपयुक्त विकल्प पर ✓ करें)

☐ Emails / ईमेल

☐ WhatsApp Messages / व्हाट्सएप संदेश

☐ SMS / एसएमएस

☐ Screenshots / स्क्रीनशॉट

☐ Audio Recording / ऑडियो रिकॉर्डिंग

☐ Video Recording / वीडियो रिकॉर्डिंग

☐ Photographs / फोटोग्राफ

☐ Medical Records / चिकित्सीय अभिलेख

☐ Other Documents / अन्य दस्तावेज़

Details / विवरण:

8. Relief/Action Requested (if any) / अपेक्षित राहत या कार्रवाई (यदि कोई हो)

9. Declaration / घोषणा

I hereby declare that the information furnished above is true and correct to the best of my knowledge and belief. I understand that this complaint and the proceedings thereof shall be treated confidentially in accordance with the applicable law and the Company’s POSH Policy.

मैं यह घोषणा करती हूँ कि ऊपर दी गई जानकारी मेरी जानकारी एवं विश्वास के अनुसार सत्य एवं सही है। मैं समझती हूँ कि इस शिकायत तथा इससे संबंधित कार्यवाही को लागू कानून एवं कंपनी की POSH नीति के अनुसार गोपनीय रखा जाएगा।

Name of Complainant / शिकायतकर्ता का नाम:

______________________________________

Signature / हस्ताक्षर:______________________________________

Date / दिनांक: ______________________

Place / स्थान: ______________________

For Internal Committee Use Only

केवल आंतरिक समिति (IC) के उपयोग हेतु

Complaint Received On / शिकायत प्राप्ति की तिथि: ______________________

Complaint Number / शिकायत संख्या: ______________________

Received By / प्राप्त करने वाले का नाम: ______________________

Acknowledgement Issued On / प्राप्ति रसीद जारी करने की तिथि: ______________________

Remarks / टिप्पणियाँ: ______________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

___________________________________________________________________________________

Signature of Presiding Officer:

______________________________

ANNEXURE-III Investigation Procedure Flowchart

22. STATUTORY TIMELINES UNDER POSH ACT, 2013

23. PROVISIONS OF BHARATIYA NYAYA SANHITA, 2023 RELATING TO SEXUAL HARASSMENT

Under Bharatiya Nyaya Sanhita, 2023 Section 75 which deals with the Sexual Harassment has made this a “cognizable offense” i.e. a person charged with Sexual Harassment may be arrested without warrant.

Under Section 75 of the BNS, a person committing any of the following acts may be guilty of sexual harassment:

• Physical contact and advances involving unwelcome and explicit sexual overtures;
• Demand or request for sexual favours;
• Showing pornography against the will of a woman;
• Making sexually coloured remarks.

A person committing the above acts shall be liable for punishment as prescribed under the BNS.

In addition to Section 75 of the BNS, acts of sexual harassment may also constitute offences under:

• Section 74 – Assault or criminal force to woman with intent to outrage her modesty;
• Section 77 – Voyeurism;
• Section 78 – Stalking;
• Section 63 – Definition of Rape;
• Section 64 and related provisions – Punishment for Rape and aggravated forms of rape;
• Section 79 – Word, gesture or act intended to insult modesty of a woman.

Where the alleged conduct constitutes a criminal offence under applicable law, the aggrieved woman may, in addition to seeking redressal under this Policy, pursue remedies before the appropriate law enforcement authorities. The Internal Committee shall assist the aggrieved woman in filing a complaint with the police, wherever requested or required under applicable law.