Policy on Prevention of Sexual Harassment at Workplace

1. Purpose and Scope

Maidan Play Private Limited ("Company") is committed to providing a safe, secure, and dignified environment for all persons engaged with the Company, free from sexual harassment of any kind. The Company has zero tolerance for sexual harassment and believes that a fearless and respectful environment is essential to its functioning as an organisation and to its mission of building a safe sporting ecosystem for children and adults alike.

This Policy on Prevention of Sexual Harassment at Workplace ("Policy") has been framed in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, and the rules made thereunder (together, the "Act"). This Policy sets out the Company's mechanism to prevent, prohibit, and redress complaints of sexual harassment. In the event of any inconsistency between this Policy and the Act, the Act shall prevail.

This Policy operates alongside, and does not replace, the Company's Child Safeguarding & Protection Policy.

2. Definitions

“Act”

means the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, and the rules made thereunder, as amended from time to time.

“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.

“Aggrieved Woman”

means, in relation to a workplace, a woman of any age, whether employed or not, who alleges to have been subjected to any act of sexual harassment, and includes a woman engaged on a contractual, temporary, or voluntary basis, an intern, and a visitor.

“Committee”

or "IC" means the Internal Committee constituted under Clause 6 of this Policy.

“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).

“Complainant”

means an Aggrieved Woman who has filed a complaint under this Policy, and includes any person who has filed a complaint on her behalf in accordance with Clause 7(iv).

“Guardian”

means the parent or legal guardian of a Minor.

“Minor”

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

“Partner”

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

“Personnel”

means and includes: (a) employees of the Company; (b) coaches, trainers, and staff engaged directly or indirectly through any Partner; (c) interns, volunteers, and support staff; and (d) 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.

“Platform”

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

“Respondent”

means a person against whom the Complainant has made a complaint under this Policy.

“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.

“Sexual Harassment”

has the meaning given to it in Clause 4.

“Workplace”

means: (a) all business locations, offices, academies, and turfs operated or contracted by the Company; (b) all Company-held or Company-sponsored events, tournaments, workshops, and gatherings; (c) any Partner facility or other external location visited by Personnel in connection with the Services; (d) the notional extended workplace, including remote work, cyberspace, social media, and electronic communication between persons covered by this Policy which may have work-related consequences.

3. Applicability and Scope

• i.This Policy applies to all Personnel of the Company.
• ii.Where the Respondent is not Personnel, the Company shall take all necessary and reasonable steps to support the Aggrieved Woman, including facilitating a complaint to the appropriate authorities.
• iii.Where a Partner's Personnel are alleged to have committed an act of sexual harassment, the Partner shall be required to cooperate fully with the Company and the Committee in relation to any investigation under this Policy, and any breach of this Policy by such Personnel shall be treated as a breach by the Partner itself. The Partner shall further: (a) notify the Committee of any complaint, allegation, or concern of sexual harassment received by it involving its personnel, without any undue delay, whether or not it is considered substantiated, and whether or not it concerns Company-facilitated Services; and (b) ensure continuous supervision of, and compliance with this Policy by, its personnel.
• iv.Where the Aggrieved Woman chooses to file a complaint under the Bharatiya Nyaya Sanhita, 2023, or any other Applicable Law, the Company shall render all necessary assistance to her in this regard, and shall, where the Respondent is not Personnel, initiate such action against the Respondent as may be available to the Company at the workplace where the incident occurred.
• v.Where the Respondent is the employer, or a person in ultimate control of the affairs of the Company, the Aggrieved Woman may file her complaint directly with the Local Committee constituted by the District Officer for the relevant district, in accordance with Section 6 of the Act. The Company shall render all necessary assistance to her in making such a filing, and no person who is the subject of such a complaint shall participate in any manner in its handling.

4. What Constitutes Sexual Harassment

Sexual harassment includes any one or more of the following unwelcome acts or behaviour, whether committed directly or by implication:

• (a)physical contact and advances;
• (b)a demand or request for sexual favours;
• (c)making sexually coloured remarks;
• (d)showing pornography; or
• (e)any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature.

Without limiting the generality of the above, sexual harassment includes the following, whether occurring once or repeatedly:

• (f)sexual pranks, jokes, or repeated sexual messages, whether in person, by email, SMS, or any messaging platform;
• (g)giving gifts or leaving objects that are sexually suggestive;
• (h)repeatedly standing too close to, or brushing up against, a person;
• (i)persistent watching, following, or contacting of a person; and
• (j)repeatedly asking a person to socialise during or after duty hours after that person has declined or indicated disinterest.

4.1. Quid Pro Quo Harassment

Sexual harassment includes any of the following circumstances, occurring in connection with any act or behaviour of a sexual nature:

• (a)an implied or explicit promise of preferential treatment in employment or engagement;
• (b)an implied or explicit threat of detrimental treatment in employment or engagement;
• (c)an implied or explicit threat about a person's present or future employment or engagement status;
• (d)interference with a person's work, or the creation of an intimidating, offensive, or hostile work environment for that person; or
• (e)humiliating treatment likely to affect a person's health or safety.

4.2. Hostile Work Environment

A hostile work environment arises where a co-worker, supervisor, or other person creates, through verbal or physical conduct of a sexual nature, a workplace atmosphere that is intimidating, hostile, offensive, or humiliating, and that interferes with another person's dignity or ability to work.

4.3. The Reasonable Person and Impact Standard

Whether conduct amounts to sexual harassment is assessed from the perspective of the impact on the Aggrieved Woman, and not the intention of the Respondent. A reasonable person standard is used to determine whether the conduct in question was offensive.

4.4. What Does Not Amount to Sexual Harassment

Interactions between individuals that are consensual, welcome, and within professional norms and the Company's code of conduct and internal policy do not amount to sexual harassment. However, where previously welcome behaviour becomes unwelcome and this is communicated, continuation of that behaviour may amount to sexual harassment.

5. Interplay with Child Safeguarding Policy

This Policy applies to Aggrieved Women of any age, including a Minor, consistent with the Act. Where the Aggrieved Woman or any person involved in a complaint under this Policy is a Minor, the Company's Child Safeguarding & Protection Policy, and the reporting obligations under the Protection of Children from Sexual Offences Act, 2012, shall apply in addition to, and shall take precedence over, the procedure set out in this Policy to the extent of any conflict. Where the Aggrieved Woman is a Minor, the matter shall be handled under the Child Safeguarding & Protection Policy with mandatory reporting under the Protection of Children from Sexual Offences Act, 2012, and the Committee shall not conduct a parallel inquiry that may delay, duplicate, or interfere with any statutory proceedings.

5A. Complaints by Persons Not Covered by the Act

The Act applies to an Aggrieved Woman. The Company recognises, however, that any person may be subjected to sexual harassment, and that no person engaged with the Company should be left without recourse. Accordingly, where a complaint of sexual harassment is made by any Personnel who is not an Aggrieved Woman within the meaning of the Act, including a man, a transgender person, or a person of any other gender identity, such complaint shall be received and dealt with by the Committee in accordance with the same procedure, timelines, and standards of confidentiality and non-retaliation as are set out in this Policy.

Complaints under this Clause are dealt with as a matter of Company policy and not under the Act. Nothing in this Clause shall be construed as extending the statutory jurisdiction of the Committee under the Act, or as diminishing any right, protection, or remedy available to an Aggrieved Woman under the Act.

6. Internal Committee

• i.The Company has constituted an Internal Committee under Section 4 of the Act for the timely and impartial resolution of complaints of sexual harassment.
• ii.The Committee shall comprise:

• (a)a Presiding Officer, being a woman employed at a senior level at the Company;
• (b)not less than 2 (two) members from amongst Personnel, committed to the cause of women or having legal knowledge or experience in social work;
• (c)1 (one) external member from a non-governmental organisation or association committed to the cause of women, or otherwise familiar with issues relating to sexual harassment; and
• (d)such that not less than one-half of the total members of the Committee are women.

• iii.Each member of the Committee shall hold office for a term not exceeding 3 (three) years from the date of nomination, as may be specified by the Company.
• iv.The current constitution of the Committee is set out in Annexure A.
• v.The Committee shall be responsible for: (a) receiving and processing complaints of sexual harassment; (b) conducting inquiries in accordance with this Policy and the Act; (c) recommending interim relief and final action to the Company; (d) maintaining confidentiality throughout the process; and (e) submitting an annual report for each calendar year in the format prescribed under the Act.
• vi.The external member of the Committee shall be entitled to fees or allowances for attending the proceedings of the Committee, and to reimbursement of travel costs reasonably incurred. Such fees shall be determined by the Company at its discretion, and shall in no event be less than Rs. 200 (Rupees Two Hundred) per day of attendance, being the minimum prescribed under the rules framed under the Act.

7. Filing of a Complaint

• i.An Aggrieved Woman may file a written complaint with any member of the Committee, or by writing to posh@maidanplay.com as soon as possible after the incident, and in any event within 3 (three) months of the date of the incident, or, in case of a series of incidents, within 3 (three) months of the date of the last incident.
• ii.The Committee may, for reasons recorded in writing, extend the time limit under Clause 7(i) by a further period not exceeding 3 (three) months, where it is satisfied that circumstances prevented the Complainant from filing the complaint within the original period.
• iii.The complaint should set out the circumstances giving rise to the complaint, the date(s) of the alleged incident(s), and the names of any witnesses, and should be accompanied by any supporting documents available to the Complainant.
• iv.Where the Aggrieved Woman is unable to make the complaint in writing owing to physical or mental incapacity or otherwise, any of the following may make the complaint on her behalf, with her written consent: (a) a legal heir, relative, or friend; (b) a co-worker; or (c) any person with knowledge of the incident. Any member of the Committee shall render reasonable assistance to the Aggrieved Woman in reducing a verbal complaint to writing.
• v.Where a complaint is received by a person who is not a Committee member, that person shall report it to the Committee promptly, and shall not disclose it to any other person.
• vi.A complaint should be accompanied by supporting documents and the names and addresses of witnesses, where available. Where a complaint is filed physically, it shall be submitted in six copies in accordance with the rules under the Act; where filed electronically, a single copy suffices and the Committee shall make the copies required.

8. Process of Dealing with Complaints

8.1. Conciliation

Before initiating an inquiry, and only at the request of the Complainant, the Committee may take steps to settle the matter between the Complainant and the Respondent through conciliation, provided that no monetary settlement shall form the basis of such conciliation. Where a settlement is reached, the Committee shall record the settlement and provide copies to the Complainant and the Respondent, and no further inquiry shall be conducted. Conciliation, where requested, shall ordinarily be attempted within 2 (two) weeks of receipt of the complaint. For the avoidance of doubt, conciliation does not, by itself, amount to an acceptance of the complaint by the Respondent, nor does it constitute a waiver of the Complainant's right to pursue a formal inquiry where a settlement is not reached or is not complied with.

8.2. Inquiry

• (a)Where conciliation is not requested, has not resulted in a settlement, or where the terms of a settlement have not been complied with, the Committee shall proceed to inquire into the complaint.
• (b)The Committee shall share a copy of the complaint with the Respondent within 7 (seven) working days of receipt.
• (c)The Respondent shall submit a written reply, together with any supporting documents and a list of witnesses, within 10 (ten) working days of receiving the complaint.
• (d)The Committee shall conduct the inquiry in accordance with the principles of natural justice. No party shall be permitted to be represented by a legal practitioner at any stage of the inquiry.
• (e)The inquiry shall be conducted in accordance with this Policy and the rules made under the Act, which together constitute the Company's service rules for the purposes of Section 11(1) of the Act.
• (f)A minimum of 3 (three) Committee members, including the Presiding Officer, shall be present for the conduct of the inquiry.
• (g)Both parties shall be given a reasonable opportunity to be heard, to present witnesses, and to produce relevant documents. Where either party wishes to cross-examine a witness, the Committee shall facilitate this and record the statements taken.
• (h)The inquiry, including submission of the inquiry report, shall be completed within 90 (ninety) days from the date on which the complaint is received.
• (i)The Committee may terminate the inquiry, or render an ex-parte decision, where the Complainant or the Respondent, as applicable, is absent for 3 (three) consecutive hearings without sufficient reason, provided that not less than 15 (fifteen) days' written notice of such intended action is given to the concerned party.
• (j)The Committee shall provide its inquiry report to the Company within 10 (ten) days of the completion of the inquiry, and shall make the findings available to both the Complainant and the Respondent.

8.3. Interim Relief

During the pendency of an inquiry, the Committee may, on a written request from the Complainant, recommend that the Company:

• (a)transfer the Complainant or the Respondent to another location or role;
• (b)grant leave to the Complainant, of up to 3 (three) months, in addition to leave otherwise available to her;
• (c)restrain the Respondent from reporting on the Complainant's work performance or writing her confidential report; or
• (d)grant such other relief as the Committee considers appropriate.

9. Decisions and Actions

i. Where the Committee concludes that the allegation has not been substantiated, it shall recommend that no action be taken, and shall ensure both parties understand that the matter is concluded and that neither shall be disadvantaged as a result.

ii. Where the Committee concludes that the allegation has been substantiated, it shall recommend appropriate action to the Company, which may include:

• (a)counselling;
• (b)a written warning or censure;
• (c)withholding of promotion or increment;
• (d)suspension;
• (e)termination of employment or engagement;
• (f)removal from association with the Company, in the case of a Partner's Personnel;
• (g)deduction from the Respondent's salary or wages of such sum as the Committee may determine, to be paid to the Complainant as compensation; or
• (h)such other action as the Company considers appropriate, including reporting the matter to the appropriate authorities where the conduct may constitute a criminal offence.

For the purposes of Clause 9(ii)(g), the Committee shall determine the sum payable having regard to the factors set out in Section 15 of the Act, namely: (a) the mental trauma, pain, suffering, and emotional distress caused to the Complainant; (b) the loss in career opportunity suffered by her; (c) medical expenses incurred by her for physical or psychiatric treatment; (d) the income and financial status of the Respondent; and (e) the feasibility of payment as a lump sum or in instalments. Where the Respondent fails to pay such sum, the Committee may forward the order for recovery in accordance with the Act.

• iii.The Company shall act on the Committee's recommendations within 60 (sixty) days of receiving its report.
• iv.Where the Committee concludes that a complaint was made with malicious intent, or that the Complainant knowingly made a false complaint or produced forged or misleading evidence, it may recommend action against the Complainant similar to that available against a Respondent under Clause 9(ii). Malicious intent must be separately and clearly established by the Committee; the mere inability to substantiate a complaint shall not, by itself, be treated as malicious intent.
• v.Any person found to have retaliated against a Complainant, witness, or any person who has, in good faith, raised a concern under this Policy, shall be subject to disciplinary action, independent of the outcome of the underlying complaint.

10. Confidentiality

The identity of the Complainant, Respondent, and any witness, together with the contents of the complaint, statements, evidence, and the Committee's recommendations, shall be kept strictly confidential and shall not be published or disclosed to any person not directly concerned with the inquiry, except as required for the conduct of the inquiry itself or as required under Applicable Law. Any person found to have breached this confidentiality obligation shall be subject to disciplinary action.

11. Roles and Responsibilities

11.1. Responsibilities of Personnel

All Personnel are responsible for respecting the dignity of others and for not engaging in, or encouraging, conduct that constitutes sexual harassment. Personnel are encouraged to support a colleague who indicates that behaviour is unwelcome, and to act as a witness where requested, subject to Clause 10.

11.2. Responsibilities of the Company

The Company shall:

• (a)display, at each workplace, the order constituting the Committee and the penal consequences of sexual harassment under the Act;
• (b)organise periodic awareness programmes on this Policy;
• (c)provide the Committee with the facilities necessary to conduct inquiries;
• (d)treat sexual harassment as misconduct under its service rules and initiate action accordingly;
• (e)monitor the timely submission of the Committee's reports;
• (f)file an annual report for each calendar year with the District Officer in the format prescribed under the Act, whether or not any complaint has been received during that year; and
• (g)disclose compliance with the Act in its Board's Report, as required under the Companies Act, 2013.

12. Reporting Channels

A complaint may be made to any member of the Committee, or through the following channels:

• –Email: posh@maidanplay.com
• –Phone: 8796551118

In addition to the above, a complaint or concern may be raised with the Local Committee constituted by the District Officer for the relevant district, or through the Ministry of Women and Child Development's SHeBox portal at https://shebox.wcd.gov.in. These external channels remain available at all times and are not contingent on the outcome of any internal process.

13. Appeal

Any party aggrieved by the Committee's recommendations, or by their implementation or non-implementation, may prefer an appeal in accordance with Section 18 of the Act to the court or tribunal having jurisdiction — being the appellate authority notified under clause (a) of Section 2 of the Industrial Employment (Standing Orders) Act, 1946, presently the Industrial Tribunal or Labour Court having territorial jurisdiction, within 90 (ninety) days of the recommendations being communicated.

14. Amendment

The Company may amend, supplement, or rescind any provision of this Policy at any time, as it deems appropriate. Any subsequent amendment to the Act, or the rules framed thereunder, shall automatically apply to this Policy. No amendment to this Policy shall reduce any protection, right, or procedural safeguard available under the Act, and any provision of this Policy that is inconsistent with the Act shall be read down to the extent necessary to give effect to the Act.

15. Compliance

The Committee is responsible for supervision of this Policy. All Personnel are required to comply with its provisions. Any queries regarding this Policy may be directed to the Committee.

16. Interpretation

Where any term of this Policy is inconsistent with the Act or any other Applicable Law, the Act or such other Applicable Law shall take precedence over this Policy.

Annexure A. Constitution of the Internal Committee

Pursuant to Section 4(1) of the Act, the Company has constituted an Internal Committee, comprising the members set out below, with effect from 23 August 2026.

• –Presiding Officer: Michelle Farah Mishra, engaged by the Company at a senior level in an honorary capacity. A qualified psychologist, she brings professional expertise relevant to the conduct of inquiries under this Policy.
• –Member: Ayush Tripathi, Personnel of the Company, committed to the cause of women.
• –Member: Simran Jha, Personnel of the Company, committed to the cause of women.
• –External Member: Akriti Gaur, an advocate with a background in gender and rights work, and familiar with issues relating to sexual harassment, as contemplated by Section 4(2)(c) of the Act.

Composition: The Committee comprises 4 (four) members, of whom 3 (three) are women, satisfying the requirement under Section 4(2) of the Act and Clause 6(ii)(d) of this Policy that not less than one-half of the total members of the Committee be women.

Term: Each member shall hold office for a term of 3 (three) years from the date of constitution set out above, unless removed earlier in accordance with the Act and this Policy.

Contact: A complaint may be made to any member of the Committee, or at posh@maidanplay.com or 8796551118.