Child Safeguarding & Protection Policy

1. Purpose and Scope

• i.This Child Safeguarding & Protection Policy ("Policy") sets out the mandatory standards, controls, and procedures governing all interaction between Personnel and Minors enrolled in or participating in any Services operated, managed, or facilitated by the Company.
• ii.The purpose of this Policy is to:

• –ensure the safety, dignity, and well-being of all Minors;
• –prevent abuse, misconduct, exploitation, and negligence in any form; and
• –establish a clear, enforceable framework for accountability, reporting, and response in relation to any safeguarding concern or incident.

• iii.This Policy shall apply to all Personnel and any Partner engaged by the Company.
• iv.This Policy shall apply across all locations, facilities, and activities conducted under or in connection with the Services, whether physical or digital, and irrespective of whether such interaction is on or off designated premises.
• v.Compliance with this Policy is mandatory and non-negotiable. This Policy shall have overriding effect over all internal practices, operational arrangements, and third-party engagements to the extent of matters relating to child safeguarding.
• vi.This Policy shall be deemed to form an integral and binding part of all employment arrangements, engagement contracts, and third-party agreements entered into by the Company in relation to the Services, and any breach of this Policy shall constitute a material breach of such arrangements.
• vii.This Policy shall be implemented without discrimination on the basis of a Minor's age, gender, disability, race, religion, language, socio-economic status, or any other status. The Company recognises that Minors with disabilities, or those on elite or performance-focused pathways, may face heightened safeguarding risks and shall receive additional attention accordingly.

1A. Rights of Minors

Every Minor engaged in any Service has the right to:

• (a)be safe from all forms of Abuse, harm, and exploitation;
• (b)be treated with dignity and respect;
• (c)be heard, and to have their views considered in matters affecting them;
• (d)consent to, or refuse, physical contact in the course of coaching, as set out in Clause 5(iv);
• (e)raise a concern or complaint without fear of retaliation, and to have it taken seriously; and
• (f)confidentiality in respect of any concern raised, subject to Clause 9(viii).

This Policy, and all obligations of Personnel hereunder, exist to give effect to these rights.

2. Definitions

For the purposes of this Policy, unless the context otherwise requires:

“Minor”

means any individual below the age of eighteen (18) years.

“Personnel”

means and includes: employees of the Company; coaches, trainers, and staff engaged directly or indirectly through any partner; interns, volunteers, and support staff; and any third party or individual authorised to interact with or having access to Minors in connection with the Services, and shall include such persons irrespective of the nature or terms of their engagement.

“Services”

means the sports-related services made available through the Platform, including training sessions, academy programmes, tournaments, workshops, events, and turf or facility bookings, whether provided by the Company or by a Partner.

“Safeguarding Officer”

means the individual designated by the Company under this Policy to oversee implementation, compliance, reporting, and response mechanisms relating to child safeguarding.

“Incident”

means any act, omission, allegation, suspicion, or circumstance involving a Minor which: constitutes or may constitute abuse, misconduct, harassment, or exploitation; involves breach of this Policy; results in or creates a risk of physical or psychological harm; or requires reporting or escalation under Applicable Law, including the Protection of Children from Sexual Offences Act, 2012.

“Guardian”

means the parent or legal guardian of a Minor, as provided at the time of enrolment or otherwise notified to the Company.

“Platform”

means the website, mobile application, and related services operated by the Company.

“Company”

means Maidan Play Private Limited, a company incorporated under the Companies Act, 2013, having its registered office at H No-39, Block No-23, F/F, Old Rajendra Nagar, New Delhi – 110060, India (CIN: U93110DC2026PTC469981).

“Partner”

means any third-party academy, coach, turf, or facility provider offering services through the Platform.

“Abuse”

means any act or omission that harms or is likely to harm a Minor, and includes: (a) Physical Abuse — deliberate infliction of physical pain or injury, including forcing a Minor to train or play through injury; (b) Emotional or Psychological Abuse — persistent belittling, humiliation, favouritism, or exclusion; (c) Sexual Abuse or Harassment — as defined under the POCSO Act, 2012; (d) Neglect — failure to meet a Minor's basic safety, supervision, or welfare needs; and (e) Bullying, including cyberbullying.

“Peer Abuse”

means physical, psychological, or sexual abuse — including bullying and cyberbullying — inflicted by one Minor upon another. Personnel shall be responsible for identifying, preventing, and promptly reporting instances of Peer Abuse in accordance with this Policy, and shall not treat such conduct as less serious merely because it occurs between Minors.

“Poor Practice”

means conduct that falls below the standards expected under this Policy but does not meet the threshold of Abuse, including inadequate supervision, minor lapses in record-keeping, or failure to follow a procedural requirement of this Policy.

“Applicable Law”

means all applicable laws, statutes, regulations, rules, notifications, guidelines, and orders of any governmental or regulatory authority in India, as amended or re-enacted from time to time.

“Personal Data”

has the meaning given to it in the Privacy Policy.

“Sensitive Personal Data”

has the meaning given to it in the Privacy Policy.

3. Governance & Accountability

i. Overall Responsibility

The Company shall have overall responsibility for the implementation, enforcement, and monitoring of this Policy across all Services and locations. The Company shall retain full supervisory and disciplinary control in relation to matters concerning child safeguarding.

The Company's directors and senior management are aware that under Section 21(2) of the POCSO Act, 2012, the head of an institution may be held personally criminally liable where an offence committed by a subordinate is not reported. Accordingly, the Safeguarding Officer shall provide mandatory escalation to the Company's management in the event of any Incident falling within the scope of POCSO.

ii. Designation of Safeguarding Officer

The Company shall designate a Safeguarding Officer for the purposes of this Policy. The Safeguarding Officer shall act as the central point of responsibility for:

• –receiving and reviewing reports of any Incident;
• –ensuring timely action and escalation in accordance with this Policy, including, but not limited to escalation to the Company's management in the event of any Incident falling within the scope of POCSO;
• –maintaining records of all safeguarding-related matters; and
• –overseeing compliance with preventive and reporting obligations.

The Safeguarding Officer shall have the authority to:

• –seek information from any Personnel;
• –direct interim measures, including suspension of Personnel from duties involving Minors;
• –recommend disciplinary or legal action as may be required; and
• –conduct periodic, proactive risk assessments of Services, facilities, and activities — independent of any reported Incident — to identify and mitigate safeguarding risks before they materialise.

iii. Designation of Safeguarding Committee

The Company shall constitute a Committee, comprising Personnel nominated by the Company, which shall:

• –receive and act on any report implicating the Safeguarding Officer, with the Safeguarding Officer recused from such matters;
• –constitute an independent investigation team for cases of this nature;
• –hear appeals under Clause 9(x)(d); and
• –provide ongoing oversight, guidance, and periodic review of this Policy's implementation.

iv. Obligations of Personnel

• –All Personnel shall comply strictly with this Policy at all times.
• –No Personnel shall engage in any activity involving Minors unless such Personnel has: (1) been duly onboarded in accordance with the Company's requirements; and (2) completed all verification and training requirements prescribed under this Policy.
• –Each Personnel shall be individually responsible for adhering to the standards set out herein.

v. Obligations of Partner(s)

The Partner and its representatives shall ensure that all coaching and support personnel engaged by or through it comply fully with this Policy. The Partner(s) shall:

• –not deploy or permit any individual to interact with Minors unless such individual has satisfied all verification, onboarding, and training requirements;
• –notify the Safeguarding Officer of any safeguarding complaint, allegation or concern received by them without any undue delays, whether or not it is considered substantiated, and whether or not it concerns Company-facilitated Services;
• –ensure continuous supervision and compliance by its personnel; and
• –cooperate fully with the Company in relation to any safeguarding matter.

Any breach of this Policy by personnel engaged through the Partner(s) shall be deemed to be a breach by the Partner itself, without prejudice to the Company's rights under applicable agreements.

vi. Non-Delegation of Responsibility

No delegation of operational functions to any Partner or third party shall absolve the Company of its responsibility to ensure implementation of this Policy, and all such delegation shall remain subject to oversight and control by the Company.

4. Mandatory Safeguards & Preventive Measures

i. Pre-Engagement Verification

No Personnel shall be permitted to interact with Minors unless such Personnel has undergone mandatory verification in accordance with this Clause. Such verification shall include:

• –identity verification; and
• –qualification and certification verification, where applicable.

In addition to the above, the Company shall require police verification of all Personnel who are engaged in roles involving direct or regular interaction with Minors. No exception or provisional engagement shall be permitted in respect of police verification requirements, unless expressly approved in writing by the Company subject to such conditions as it may impose.

ii. Periodic Re-Verification

Verification of Personnel, including police verification, shall be conducted on a periodic basis as may be determined by the Company. The Company shall have the right to require re-verification at any time, including upon:

• (1)renewal or continuation of engagement;
• (2)change in role or responsibilities; or
• (3)any safeguarding concern or Incident.

All personnel engaged by the Company have a continuing duty to disclose if they are charged, investigated or made subject to any safeguarding proceeding during their engagement with the Company.

iii. Mandatory Training and Sensitisation

All Personnel shall undergo mandatory training on child safeguarding prior to commencement of any engagement involving Minors. Such training shall include, at a minimum:

• –awareness of appropriate and inappropriate conduct;
• –identification of safeguarding risks and warning signs;
• –reporting obligations and escalation procedures; and
• –applicable legal framework, including the Protection of Children from Sexual Offences Act, 2012.

The Company shall ensure that periodic refresher training and sensitisation programmes are conducted for all Personnel at such intervals as it may determine. Completion of such training shall be a pre-condition for continued engagement, and failure to complete or participate shall result in suspension from duties involving Minors.

iv. Onboarding Controls

No Personnel shall be deployed for any Service unless:

• –all verification requirements have been completed;
• –mandatory training has been completed; and
• –such Personnel has acknowledged and agreed to comply with this Policy.

The Partner shall be responsible for ensuring that all personnel engaged through it comply with the above requirements prior to deployment.

v. Supervision and Visibility Requirements

• –All interactions with Minors shall be conducted in open, observable, and accessible environments.
• –Personnel shall not engage with Minors in any setting that is isolated, concealed, or not capable of supervision.
• –The Company may prescribe supervision ratios, monitoring requirements, or additional safeguards from time to time, which shall be binding on all Personnel.

vi. Access Control

• –Access to Minors shall be restricted only to authorised Personnel who have complied with the requirements of this Policy.
• –No unauthorised individual shall be permitted to interact with or remain in proximity to Minors during any Service.

vii. Preventive Responsibility

• –All Personnel shall be responsible not only for their own conduct but also for maintaining a safe environment and preventing situations that may give rise to safeguarding risks.
• –Any unsafe condition, practice, or environment identified by Personnel shall be promptly reported and addressed in accordance with this Policy.

4A. Medical Emergency Response

• (a)Every Service shall have access to basic first-aid provisions.
• (b)In the event of an injury or medical emergency, Personnel shall immediately administer or arrange first aid, and where necessary, arrange transport to the nearest hospital.
• (c)The Guardian shall be notified immediately upon any injury requiring medical attention beyond basic first aid.

5. Code of Conduct with Minors

i. Standard of Conduct

All Personnel shall, at all times, maintain a professional, appropriate, and respectful standard of conduct in their interaction with Minors. Such interaction shall be strictly limited to the scope of the Service and shall not extend into any personal or informal engagement.

ii. Permitted Conduct

Personnel may engage with Minors only in a manner that:

• –is directly related to the Services;
• –takes place in an open, observable, and supervised environment; and
• –is capable of being explained, justified, and reviewed at any time.

iii. Prohibited Conduct

Without prejudice to the generality of the foregoing, Personnel shall not, under any circumstances:

• –be alone with a Minor in a closed, isolated, or non-visible setting;
• –engage in or permit any unnecessary, inappropriate, or excessive physical contact;
• –use language, gestures, or behaviour that is abusive, suggestive, intimidating, or otherwise inappropriate;
• –develop or attempt to develop personal, social, or non-professional relationships with Minors;
• –engage in personal communication with Minors through text, WhatsApp, social media, or any other digital communication channels;
• –solicit or accept any personal information, photographs, or content from Minors outside authorised channels;
• –transport or accompany Minors outside designated Services without prior written authorisation and the Guardian's consent; or
• –engage in any act or omission that may constitute or give rise to an Incident under this Policy or under Applicable Law, including the Protection of Children from Sexual Offences Act, 2012.

Personnel shall not, under any circumstances, administer or threaten corporal punishment of any kind, including slapping, hitting, or forcing a Minor to continue training or play while injured as a form of discipline.

iv. Physical Interaction

Any physical interaction with a Minor shall be strictly limited to what is necessary for the legitimate delivery of Services. Such interaction shall be:

• –appropriate in nature;
• –minimal in duration; and
• –conducted in full public view.

Before any physical contact necessary for the delivery of Services, the Personnel concerned shall explain the reason for such contact to the Minor and obtain the Minor's assent. Where a Minor expresses discomfort or withholds assent, Personnel shall immediately cease such contact and shall not repeat it without addressing the Minor's concern. In case of uncertainty, Personnel shall refrain from physical contact.

v. Boundary Obligation

Personnel shall, at all times, maintain clear professional boundaries with Minors and shall avoid any conduct that may:

• –be perceived as favouritism, familiarity, or undue influence; or
• –create a situation of dependency, vulnerability, or discomfort for the Minor.

vi. Strict Liability for Breach

Any deviation from the standards set out in this Clause shall be treated as a serious breach of this Policy, irrespective of intent, and shall attract immediate action in accordance with this Policy subject to Clause 9(x)(e).

vii. Substance Abuse

• –No Personnel shall consume, distribute, or be under the influence of alcohol, tobacco, or any psychoactive substance while engaged in any Service activity.
• –Where Personnel reasonably suspect that a Minor is using or has used any such substance, they shall report the matter to the Safeguarding Officer, who shall facilitate an appropriate response, including notification of the Guardian and, where warranted, referral for counselling or medical support.
• –This Clause is without prejudice to any obligations under the Narcotic Drugs and Psychotropic Substances Act, 1985, or other Applicable Law.

6. Operational Controls

i. Conduct and Environment during Services

• –All Services involving Minors shall be conducted only at approved locations and within designated time slots.
• –Services shall be conducted in open, visible, and accessible environments capable of supervision at all times.
• –No Personnel shall conduct or permit any Service in a closed, isolated, or non-monitored setting.

ii. Restriction on Isolated Interaction

• –Personnel shall not engage in one-on-one interaction with a Minor in circumstances where such interaction is not visible or capable of supervision.
• –Any necessary individual instruction shall be conducted only within the general training environment and in the presence of other Personnel or participants.

iii. Access and Attendance Control

• –Only authorised Personnel who have complied with the requirements of this Policy shall be permitted to conduct or assist in Services involving Minors.
• –Attendance of Minors shall be recorded for each Service in such manner as may be prescribed by the Company.
• –No unauthorised individual shall be permitted to remain present in the premises during Services involving Minors.

iv. Communication Controls

• –All communication with Minors shall be conducted exclusively through authorised channels or through Guardians.
• –No Personnel shall engage in personal communication with Minors through text, WhatsApp, social media, or any other digital communication channels.
• –Any communication relating to scheduling, training, or programme matters shall be routed through authorised channels only.

v. Pick-up, Drop and Movement of Minors

Responsibility for pick-up and drop of Minors shall remain with the Guardian unless expressly agreed otherwise in writing.

Personnel shall not take custody of, transport, or accompany a Minor outside the designated premises or Service without:

• –prior written authorisation from the Company; and
• –documented consent from the Guardian.

vi. Digital Interaction Restrictions

• –Personnel shall not share, request, or exchange photographs, videos, or personal content with Minors through any personal or unauthorised medium.
• –Any authorised recording, photography, or digital interaction shall be carried out strictly in accordance with the Company's policies and with appropriate consent.

vii. Boundary of Engagement

• –Interaction between Personnel and Minors shall be strictly limited to the duration, location, and scope of the Service.
• –Personnel shall not interact with Minors outside scheduled Services, including private coaching, informal meetings, or off-platform interaction, unless expressly authorised by the Company.

viii. Control over External Interaction

• –Personnel shall not independently organise, promote, or conduct any activity involving enrolled Minors outside the Service.
• –Any such unauthorised engagement shall constitute a serious breach of this Policy.

7. Whistleblower Protection & Non-Retaliation

i. Right to Report

All Personnel, enrolees and Guardians shall have the right and obligation to report any Incident, suspected Incident, unsafe condition, or breach of this Policy in good faith, without fear of retaliation.

ii. Protection Against Retaliation

No Personnel, enrolee or Guardian shall be subject to any form of retaliation, victimisation, harassment, adverse action, or disadvantage, whether direct or indirect, for:

• (a)making a report in good faith;
• (b)participating in any safeguarding inquiry or process; or
• (c)providing information or assistance in relation to an Incident.

iii. Prohibition on Retaliatory Conduct

Any act of retaliation, including but not limited to:

• –intimidation, threats, or coercion;
• –reduction of responsibilities or removal from duties;
• –denial of opportunities or adverse treatment; or
• –termination or disengagement on account of reporting,

shall constitute a serious breach of this Policy.

iv. Confidentiality of Reporter

The Company shall take all reasonable steps to ensure that the identity of any individual making a report is kept confidential, subject to:

• –requirements under Applicable Law; and
• –the need to conduct a fair and effective inquiry.

v. Reporting Channels

Reports may be made to:

• –the Safeguarding Officer; or
• –such other designated reporting channels as may be notified by the Company from time to time.

vi. Good Faith Requirement

Protection under this Clause shall apply to reports made in good faith. Any Personnel who reports an Incident in good faith is protected from civil and criminal liability under Section 19(7) of the POCSO Act, 2012, irrespective of whether the report is subsequently found to be unsubstantiated. Any knowingly false or malicious report shall constitute a breach of this Policy and may attract disciplinary action.

vii. Independent Action

The protections under this Clause shall apply irrespective of the outcome of any investigation, provided that the report was made in good faith.

8. Data Protection & Media Handling

i. Use of Data Relating to Minors

All Personal Data relating to Minors, including any Sensitive Personal Data, collected in connection with the Services, shall be used strictly for purposes relating to the Services. All such data shall be collected, used, and processed in accordance with the Digital Personal Data Protection Act, 2023, and the Company's Privacy Policy, in addition to the restrictions set out in this Clause. No Personnel shall access, use, or process such data except to the extent necessary for discharge of their authorised duties.

ii. Restriction on Storage and Use

• –Personnel shall not copy, download, store, or retain any data relating to Minors on personal devices, systems, or unauthorised platforms.
• –No Personnel shall use such data for any personal, commercial, or unauthorised purpose, including independent coaching, solicitation, or communication.
• –All data shall be accessed and managed exclusively through authorised systems and the Platform.

iii. Confidentiality Obligation

All information relating to Minors shall be treated as confidential. Personnel shall not disclose, share, or circulate such information except:

• –as required for the Services; or
• –as required under Applicable Law.

iv. Photography, Video and Media

No Personnel shall capture, record, or create any photograph, video, or other media involving Minors using personal devices or for personal use. Any authorised photography, videography, or recording shall be undertaken only:

• –for legitimate purposes relating to the Services, or promotional purposes;
• –through authorised Personnel; and
• –subject to prior consent of the Guardian.

No media involving Minors shall be shared, published, or circulated except through authorised channels and in accordance with the Company's policies.

Any Personnel engaged in photography or videography of Minors who comes across any material that may be sexually exploitative of a child is obligated to report the same to the Safeguarding Officer and, where required, to the appropriate authorities under Section 20 of the POCSO Act, 2012.

v. Digital Interaction and Content Sharing

• –Personnel shall not request, solicit, or accept photographs, videos, or personal content directly from Minors through any medium.
• –No media involving Minors shall be exchanged through personal messaging applications, social media platforms, or any unauthorised channel.

vi. Data Breach and Misuse

• –Any actual or suspected misuse, loss, unauthorised access, or breach of data relating to Minors shall be reported immediately in accordance with Clause 9 of this Policy.
• –Such incidents shall be treated as serious breaches and may attract disciplinary and legal action.

vii. Media and Public Communication

In the event of an Incident that attracts or may attract media attention, the Company shall designate a single authorised spokesperson to respond to media inquiries. No other Personnel shall provide comment, confirmation, or information to any media outlet. Any communication shall protect the identity and privacy of the Minor involved and shall not disclose identifying information, including name, age, or images, without the Guardian's consent.

9. Response & Escalation Framework

i. Immediate Protective Measures

Upon receipt of any report of an Incident from a enrolee, Guardian or Personnel, the Company, acting through the Safeguarding Officer, shall take immediate steps to ensure the safety and well-being of the Minor. Without prejudice to the generality of the above, such measures may include:

• –immediate removal or suspension of the concerned Personnel from any interaction with Minors;
• –securing the premises and preventing further contact; and
• –such interim actions as may be necessary to mitigate risk.

Such measures shall be taken on a precautionary basis and shall not be contingent upon completion of any inquiry.

ii. Incident Reporting Procedure

Any Personnel, enrolee or Guardian who becomes aware of, or has reasonable grounds to suspect, an Incident shall:

• –report immediately to the Safeguarding Officer through the designated reporting channel;
• –not investigate independently, interview the Minor, or take any action that may compromise a subsequent inquiry; and
• –maintain confidentiality about the report, disclosing it only on a need-to-know basis as directed by the Safeguarding Officer.

Guardians and enrolled students are also individually entitled — and under Section 19 of the POCSO Act, 2012, where applicable, may be legally obligated — to report directly to the Special Juvenile Police Unit (SJPU) or local police, irrespective of any internal process under this Policy. The Company shall not discourage, delay, or condition any such direct report to statutory authorities.

iii. Preliminary Assessment

The Safeguarding Officer shall conduct a preliminary assessment of the reported Incident solely for the purpose of determining:

• –the nature and severity of the concern; and
• –the requirement for escalation under Applicable Law.

No Personnel shall undertake any independent investigation or fact-finding outside the process led by the Safeguarding Officer.

iv. Mandatory Escalation under Law

Where an Incident involves or reasonably indicates sexual abuse, harassment, or exploitation of a Minor, or any conduct falling within the scope of the Protection of Children from Sexual Offences Act, 2012, the Company shall ensure that such matter is reported to the appropriate authorities in accordance with Applicable Law. No internal process or assessment shall delay or override such statutory reporting obligation.

• (a)The Company shall ensure that any report required under Section 19 of the POCSO Act, 2012 is made to the Special Juvenile Police Unit (SJPU) or local police without any undue delays.
• (b)Under Section 19 of the POCSO Act, 2012, every person — irrespective of role or designation — who has knowledge or reasonable apprehension that an offence under POCSO has been, is being, or is likely to be committed against a child, is legally obligated to report the same to the Special Juvenile Police Unit (SJPU) or the local police. Failure to report constitutes an offence under Section 21 of the POCSO Act, punishable with imprisonment of up to six months, a fine, or both. This obligation exists independently of, and is not satisfied by, internal reporting to the Safeguarding Officer alone.
• (c)In addition to internal reporting under this Policy, any Incident may also be reported directly to: (i) the local police or the nearest Special Juvenile Police Unit; (ii) Childline, on 1098; (iii) the District Child Protection Unit; or (iv) the National Commission for Protection of Child Rights (NCPCR), including via the POCSO e-Box. These external channels remain available at all times and are not contingent on the outcome of any internal process.
• (d)Where a matter is escalated to police or falls within the scope of the Juvenile Justice (Care and Protection of Children) Act, 2015, the Company shall cooperate fully with, and defer to, any directions of the jurisdictional Child Welfare Committee (CWC) or Special Court, and shall not conduct any internal process in a manner that delays, duplicates, or interferes with statutory proceedings.
• (e)Independently of any POCSO obligation, where the Safeguarding Officer has reasonable grounds to believe that a Minor is a "child in need of care and protection" within the meaning of the Juvenile Justice (Care and Protection of Children) Act, 2015 — including on account of neglect, emotional abuse, or circumstances placing the Minor at risk of harm — the Company shall ensure that the matter is reported to the jurisdictional Child Welfare Committee (CWC) without undue delay. Personnel who observe indicators suggesting that a Minor may be in need of care and protection shall report the same to the Safeguarding Officer, who shall assess and escalate as appropriate.

v. Guardian Notification

The Guardian of the concerned Minor shall be informed promptly of any Incident involving the Minor, subject to:

• –legal requirements;
• –considerations relating to the safety and best interests of the Minor.

Such communication shall be made in a responsible and controlled manner by authorised representatives of the Company.

vi. Internal Action and Disciplinary Measures

Based on the findings of the preliminary assessment and/or any subsequent review, the Company may initiate disciplinary action against the concerned Personnel, in accordance with Clause 11. Such action may include suspension, termination, blacklisting, or such other measures as deemed appropriate. The Partner(s) shall fully cooperate in implementing such action, including removal of Personnel engaged through them.

vii. Documentation of Incident

All Incidents shall be documented in writing, including:

• –details of the report received;
• –actions taken;
• –escalation steps; and
• –outcome or status.

Such records shall be maintained securely and shall form part of the Company's safeguarding records.

viii. Confidentiality and Information Control

• –All information relating to an Incident shall be treated as confidential and shall be disclosed only on a need-to-know basis.
• –No Personnel shall disclose, discuss, or circulate information relating to an Incident except as authorised.

ix. No Waiver of Rights

Any action taken by the Company under this Clause shall be without prejudice to its rights to take further action under applicable agreements or law.

x. Protection of the Wrongly Accused and Right of Appeal

• (a)The identity of any Personnel accused of an Incident shall remain confidential during the preliminary assessment, and no disciplinary or reputational action shall be taken until findings are made, save for precautionary measures under Clause 9(i).
• (b)Any Personnel found to have been wrongly accused shall be entitled to reinstatement and, where appropriate, a formal communication clearing their position.
• (c)A knowingly false report — made with the intent to defame or harm — constitutes a breach of this Policy and may constitute an offence under Section 22 of the POCSO Act. This does not apply to reports made in genuine but mistaken belief, which are protected under Section 19(7) of the POCSO Act, 2012.
• (d)Any Personnel subject to disciplinary action under Clause 11 shall have the right to appeal the finding to the Safeguarding Committee within 14 (fourteen) days, whose decision on appeal shall be final. No person involved in the original assessment or decision may sit on the appeal.
• (e)Where an Incident is assessed to constitute Poor Practice rather than Abuse, it shall be addressed through corrective guidance or coaching in the first instance, and shall only escalate to disciplinary action under Clause 11 upon repeated or wilful non-compliance.

xi. Emotional and Behavioural Wellbeing

• (a)Personnel shall be trained to recognise signs of emotional distress, anxiety, or behavioural change in Minors, independent of any reported Incident.
• (b)Where such signs are observed, Personnel shall report the same to the Safeguarding Officer, who shall, where appropriate, facilitate a referral to a qualified counsellor or mental health professional and notify the Guardian.
• (c)Following a confirmed Incident, the Company shall facilitate access to counselling or psychological support for the affected Minor.

10. Record Keeping & Documentation

i. Maintenance of Records

The Company shall maintain accurate and complete records in relation to safeguarding, including:

• –verification and onboarding of Personnel;
• –training and sensitisation conducted;
• –attendance of Minors in Services;
• –Guardians' consents and authorisations; and
• –all reported Incidents and actions taken.

All such records shall be maintained in a secure manner and shall be accessible only to authorised Personnel.

ii. Retention of Records

• –Records relating to safeguarding, including Incident reports and verification documents, shall be retained for such period as may be prescribed by the Company or required under Applicable Law.
• –No record relating to an Incident shall be destroyed, altered, or concealed without authorisation.

iii. Audit and Inspection

• –The Company shall have the right to review, inspect, and audit compliance with this Policy at any time.
• –The Partner and all Personnel shall provide full cooperation and access to records, information, and systems as may be required for such audit.

11. Consequences of Breach

• i.Any breach of this Policy shall be treated as a serious violation.
• ii.Without prejudice to any other rights, the Company may take one or more of the following actions:

• –immediate suspension from duties involving Minors;
• –termination of employment or engagement;
• –removal from all Services;
• –blacklisting from future association with the Company; and
• –initiation of legal proceedings, where applicable.

• iii.Any breach by Personnel engaged through a Partner shall be deemed to be a breach by the Partner.
• iv.The consequences under this Clause shall apply irrespective of intent and may be invoked on a precautionary basis where required.

12. Contractual Binding Effect

i. This Policy shall be binding on all Personnel and shall be deemed to form an integral part of:

• –all employment agreements;
• –all engagement contracts; and
• –all third-party arrangements relating to the Services.

• ii.Compliance with this Policy shall be a condition of engagement, and any breach shall constitute a material breach of the relevant agreement.
• iii.The obligations under this Policy shall survive termination or expiry of any engagement to the extent they relate to confidentiality, reporting, or any ongoing Incident.

13. Training, Awareness & Periodic Review

• i.The Company shall ensure that all Personnel are provided with periodic training and sensitisation on child safeguarding and protection.
• ii.Such training shall be conducted at such intervals as may be determined by the Company and shall be mandatory for continued engagement.
• iii.The Company shall review this Policy and its implementation on an annual basis to ensure:

• –continued effectiveness;
• –alignment with Applicable Law; and
• –incorporation of best practices relating to child safety.

13B. Emergency Contacts

Emergency: 112 | Police: 100 | Ambulance: 102 | Cybercrime: 1930 | Childline: 1098 | NCPCR POCSO e-Box | Delhi DCPU (DCPCR).

14. Amendment

• i.The Company reserves the right to amend, modify, or update this Policy at any time.
• ii.Any such amendment shall be effective upon communication or publication and shall be binding on all Personnel.

Schedule 1. Designated Safeguarding Officer

This Schedule is issued pursuant to Clause 3(ii) of this Policy and sets out the current details of the Designated Safeguarding Officer. It shall be updated within 30 days of any change in the individual holding this role.

Email: support@maidanplay.com

All reports of Incidents, suspected Incidents, or safeguarding concerns under this Policy should be directed to the Safeguarding Officer at the contact details above. Where a concern implicates the Safeguarding Officer directly, reports should be made to the Company's directors at captain@maidanplay.com, and the Safeguarding Committee shall be convened in accordance with Clause 3(iii).

Schedule 2. Designated Safeguarding Committee

This Schedule is issued pursuant to Clause 3(iii) of this Policy and sets out the current membership of the Designated Safeguarding Committee. It shall be updated within 30 days of any change in the composition of the Committee.

The Committee may be convened by any director of the Company, as recorded in the Ministry of Corporate Affairs register from time to time. All safeguarding matters escalated to the Committee shall be directed to captain@maidanplay.com. The Committee shall convene Shiwangi Jha as an External Independent Member upon being constituted for any matter.

Email: captain@maidanplay.com