Child and Student Welfare and Protection Policy

1. preamble and statement of commitment

PSOM Studios Private Limited (hereinafter referred to as the "Company", "School", "PSOM" or "Institution"), a company incorporated under the Companies Act, 2013 and engaged in imparting music education and allied training to students of varying age groups including minors and adults, recognises that the safety, dignity, and well-being of every child and student in its care, custody, or association is a matter of paramount and non-negotiable importance.

The Company is committed to providing an environment that is safe, inclusive, respectful, and free from all forms of abuse, exploitation, harassment, neglect, and discrimination. This Child and Student Welfare & Protection Policy ("Policy") reflects that commitment and has been framed in strict conformity with the Protection of Children from Sexual Offences Act, 2012 ("POCSO Act"), as amended by the POCSO (Amendment) Act, 2019, the POCSO Rules, 2020, the Juvenile Justice (Care and Protection of Children) Act, 2015 as amended in 2021 ("JJ Act"), the Bharatiya Nyaya Sanhita, 2023 ("BNS"), the Bharatiya Nagarik Suraksha Sanhita, 2023 ("BNSS"), the Bharatiya Sakshya Adhiniyam, 2023 ("BSA"), the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("POSH Act"), the Information Technology Act, 2000 as amended, the Digital Personal Data Protection Act, 2023 ("DPDP Act"), the Right of Children to Free and Compulsory Education Act, 2009, the National Commission for Protection of Child Rights Act, 2005, the applicable provisions of the Constitution of India, and the guidelines, model policies, and directions issued from time to time by the National Commission for Protection of Child Rights ("NCPCR"), State Commissions for Protection of Child Rights, the Ministry of Women and Child Development, and Indian and international best-practice frameworks including the UNCRC (United Nations Convention on the Rights of the Child, 1989, ratified by India in 1992), Keeping Children Safe (KCS) International Child Safeguarding Standards, and safeguarding frameworks adopted by leading Indian and international educational institutions.

This Policy shall be read as a composite, living document forming part of the internal governance framework of the Company and shall bind every Director, KMP, employee, faculty member, visiting artist, contractor, vendor, intern, volunteer, and any other individual who interacts with children or students on behalf of, or within the premises or programmes of, the Company.

2. objectives

The objectives of this Policy are to:

1. Create and maintain a safe, secure, and nurturing environment for every child and student associated with the Company, whether as a regular enrolled student, a short-term workshop participant, an examinee, or a visitor.

2. Ensure full compliance with the POCSO Act, the JJ Act, the BNS/BNSS/BSA, the POSH Act (in respect of adult/major students and employees), the IT Act, the DPDP Act, and all other applicable child-protection and student-safety legislation, rules, notifications, and judicial pronouncements in force in India, as amended from time to time.

3. Establish a clear, victim-centric, and time-bound mechanism for the prevention, reporting, investigation, and redressal of any instance of sexual offence, abuse, harassment, bullying, corporal punishment, neglect, or exploitation involving a child or student.

4. Fix unambiguous roles, responsibilities, and accountability for the Board of Directors, management, the Child Protection Committee, staff, faculty, and parents/guardians in matters of child and student safety.

5. Lay down a mandatory Code of Conduct governing all interactions between adults (staff, faculty, visiting artists, volunteers, vendors) and children/students, both on and off the Company's premises, including in digital and online spaces.

6. Institute robust recruitment, screening, background-verification, and training safeguards to prevent persons with a known history of, or propensity for, child sexual abuse or misconduct from gaining access to children.

7. Recognise the differentiated needs, autonomy, and legal status of major (adult, 18 years and above) students as distinct from minor students, while ensuring that both categories receive full protection, dignity, and access to grievance redressal appropriate to their status.

8. Promote age-appropriate awareness, life-skills, and personal-safety education among students, and sensitise parents/guardians and staff on the early recognition of signs of abuse.

9. Ensure mandatory and time-bound reporting of offences to statutory authorities as required under Section 19 of the POCSO Act and other applicable law, and protect persons who report concerns in good faith from retaliation.

10. Safeguard the privacy, dignity, and personal data of children and students, including in relation to photography, videography, social media, and digital records, in conformity with the DPDP Act, 2023 and POCSO confidentiality mandates (Section 23).

3. legal and regulatory framework

This Policy derives its authority from, operates subject to, and shall be interpreted harmoniously with the following statutes, rules, and instruments, as amended, re-enacted, or replaced from time to time:

3.1 Central Legislation

1. Protection of Children from Sexual Offences (POCSO) Act, 2012 and POCSO (Amendment) Act,

2019. The primary gender-neutral, special legislation criminalising penetrative and non-penetrative sexual assault, sexual harassment, and use of children for pornographic/CSAM purposes, and prescribing mandatory reporting, child-friendly investigation and trial procedures, and enhanced/aggravated penalties (including for persons in a position of trust or authority such as teachers, staff of an educational institution).

2. Protection of Children from Sexual Offences Rules, 2020. Prescribe procedures for reporting, emergency medical care, interim compensation, care and protection of the child during investigation and trial, and the constitution of Child Welfare Committees and Special Juvenile Police Units ("SJPU").

3. Juvenile Justice (Care and Protection of Children) Act, 2015 (as amended in 2021) and the JJ Model Rules, 2016. Governs children in need of care and protection and children in conflict with law; establishes Child Welfare Committees ("CWC") and Juvenile Justice Boards; imposes obligations on institutions in contact with children.

4. Bharatiya Nyaya Sanhita, 2023 (BNS). Replaces the Indian Penal Code, 1860 with effect from 1 July 2024; contains general offences (e.g., outraging modesty, criminal intimidation, wrongful confinement, causing hurt, criminal force, stalking, voyeurism) applicable to major students, staff, and residuary situations not covered by POCSO.

5. Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS). Replaces the Code of Criminal Procedure, 1973 with effect from 1 July 2024; governs procedure for recording of information, arrest, investigation, and recording of statements, including of child witnesses/victims.

6. Bharatiya Sakshya Adhiniyam, 2023 (BSA). Replaces the Indian Evidence Act, 1872 with effect from 1 July 2024; governs admissibility of evidence, including the special evidentiary protections available to child witnesses.

7. Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act). Applicable to the Company as an employer and, by extension of best practice under this Policy, to complaints of sexual harassment made by major (adult) female students, interns, and visiting participants against employees/faculty/other students, redressed through the Company's Internal Committee ("IC").

8. Information Technology Act, 2000 (as amended) — Sections 66E, 67, 67A, 67B. Criminalise violation of privacy, publication/transmission of obscene material, sexually explicit material, and material depicting children in sexually explicit acts (Child Sexual Abuse Material/CSAM); Section 67B applies irrespective of the age of the child up to 18 years and covers browsing, downloading, and possession.

9. Digital Personal Data Protection Act, 2023 (DPDP Act). Requires verifiable parental/guardian consent prior to processing the personal data of a child (defined as a person below 18 years) under Section 9, prohibits tracking, behavioural monitoring, and targeted advertising directed at children, and mandates data-minimisation and purpose-limitation safeguards. 10.Right of Children to Free and Compulsory Education Act, 2009 (RTE Act). Section 17 prohibits physical punishment and mental harassment of a child; relevant to the Company's music education programmes for school-going children.

11.National Commission for Protection of Child Rights Act, 2005. Establishes NCPCR/SCPCRs empowering them to inquire into violations of child rights and recommend safeguards, including model Child Protection Policies for schools and institutions.

12.Prohibition of Child Marriage Act, 2006; Immoral Traffic (Prevention) Act, 1956. Residuary protective statutes relevant where facts so warrant.

13.Companies Act, 2013 and rules thereunder. Governs corporate governance, Board oversight, and (where applicable) CSR obligations that may extend to child-safety initiatives.

14.Persons with Disabilities (Equal Opportunities, Protection of Rights and Full Participation) Act, 1995 / Rights of Persons with Disabilities Act, 2016. Requires additional safeguards, accessible reporting, and non-discrimination for children and students with disabilities.

3.2 Constitutional Foundation

This Policy also gives effect to Articles 14, 15(3), 21, 21A, 23, 24, and 39(e) and (f) of the Constitution of India, which respectively guarantee equality, permit special provisions for children, protect life and personal liberty and dignity, guarantee free and compulsory education, prohibit trafficking and forced labour, prohibit employment of children in hazardous occupations, and direct the State (and, through judicial extension, institutions performing public functions such as education) to ensure that children are given opportunities to develop in a healthy manner and in conditions of freedom and dignity.

3.3 Judicial Guidance

The Company shall remain cognizant of, and this Policy shall be read subject to, evolving Supreme Court and High Court jurisprudence on child protection, age of consent, mandatory reporting, and the balancing of child safety with the rights of adolescents and the accused, and shall be updated to reflect binding precedent and any legislative amendment (including any future amendment to the POCSO Act) as and when notified.

3.4 State-Specific and Sectoral Guidelines

Where the Company operates schools or conducts programmes in multiple States/Union Territories, it shall additionally comply with applicable State Government/Education Department circulars on child safety in coaching institutes and private training schools, and with any guidelines issued by bodies regulating music/performing-arts examinations or affiliations that the Company may hold or seek.

4. definitions

"Child" — A person who has not completed eighteen (18) years of age, as defined under Section 2(d) of the POCSO Act and Section 2(12) of the JJ Act.

"Minor Student" — Any student, participant, or child enrolled in or attending any course, class, workshop, examination, concert, tour, or activity conducted by the Company who is below 18 years of age.

"Major Student / Adult Student" — Any student, participant, intern, or trainee associated with the Company who has attained 18 years of age. References in this Policy to "protection" and "welfare" extend to major students save where a provision is expressly stated to apply only to minors (e.g., mandatory POCSO reporting, which is triggered specifically in respect of children).

"Student" — Collectively, both Minor Students and Major Students enrolled with, or participating in any programme, class, examination, or event of, the Company.

"Specified Person" — Includes every Director, Key Managerial Personnel, employee, full-time or part-time faculty member, visiting/guest artist, accompanist, examiner, contractor, vendor, driver, security personnel, housekeeping staff, intern, volunteer, and any other individual engaged by or on behalf of the Company who has access to, or comes into contact with, children/students in the course of the Company's activities.

"Sexual Assault / Sexual Harassment / Sexual Offence against a Child" — Shall bear the meanings assigned under Sections 3 to 12 of the POCSO Act, including penetrative sexual assault, aggravated penetrative sexual assault, sexual assault, aggravated sexual assault, and sexual harassment, and shall include use of a child for pornographic purposes under Section 13 (Child Sexual Abuse Material).

"Position of Trust or Authority" — Includes a teacher, faculty member, coach, staff member, or other person who is in a fiduciary, care-giving, or supervisory relationship with a child, whose misconduct against the child amounts to an aggravated offence under Section 5(f)/5(n) etc. of the POCSO Act.

"Abuse" — Includes physical abuse, sexual abuse, emotional/psychological abuse, neglect, corporal punishment, verbal abuse, bullying, cyberbullying, and any act or omission that harms or is likely to harm the safety, health, development, or dignity of a child or student.

"Child Sexual Abuse Material (CSAM)" — Any visual depiction, including photograph, video, digital or computer-generated image indistinguishable from an actual child, of sexually explicit conduct involving a child, punishable under Section 13-15 of the POCSO Act and Section 67B of the IT Act.

"Child Protection Committee (CPC)" — The internal committee constituted under Clause 6 of this Policy, entrusted with implementation, monitoring, prevention, and initial redressal of child-safety concerns.

"Internal Committee (IC)" — The Internal Committee constituted under Section 4 of the POSH Act, 2013, which shall additionally receive and inquire into complaints of sexual harassment made by or against major/adult students to the extent set out in this Policy.

"Reportable Conduct" — Any conduct that constitutes, or reasonably appears to constitute, a sexual offence, physical abuse, grooming behaviour, or serious emotional abuse against a child or student, whether occurring on or off the Company's premises, and whether by a Specified Person, another student, or a third party. "SJPU / Local Police / Special Court" — The Special Juvenile Police Unit, local police, and Special Courts designated under Sections 28 and 32 of the POCSO Act for reporting, investigation, and trial of offences under the Act.

"CWC" — Child Welfare Committee constituted under Section 27 of the JJ Act, before which a child in need of care and protection is to be produced.

"Parent/Guardian" — The biological or adoptive parent, or a person having lawful custody or care of a minor student.

"Grooming" — A pattern of manipulative behaviour by an adult or older individual intended to build trust with a child or their family for the purpose of facilitating sexual abuse or exploitation, including through gifts, special attention, secrecy, or online contact.

5. applicability and scope

5.1 Persons Covered

This Policy applies to all Specified Persons, all Minor Students, and all Major Students of the Company, without exception, across all locations, schools, studios, and branches operated by the Company, and extends to:

• All on-campus/on-premises activities, including regular classes, group rehearsals, individual (one-onone) music lessons, examinations, auditions, recording sessions, and internal recitals;
• All off-premises and outstation activities organised, sponsored, or endorsed by the Company, including concerts, competitions, tours, workshops, and residential camps;
• All online and digital interactions between Specified Persons and students, including virtual classes, learning-management platforms, messaging applications, and social media pages maintained by or on behalf of the Company;
• All transportation arranged or facilitated by the Company for students; and
• Any interaction, on or off Company premises, between a Specified Person and a student that arises out of or is connected with the student's association with the Company.

5.2 Differentiated Application — Minor Students and Major Students

The Company recognises that Minor Students and Major Students stand on a different legal footing. In respect of Minor Students, this Policy operates on a zero-tolerance, mandatory-reporting basis strictly in accordance with the POCSO Act, under which consent of a child under 18 years is not a defence and is legally irrelevant to any sexual act, and every Specified Person is under a positive, non-derogable legal duty under Section 19 of the POCSO Act to report any knowledge or apprehension of an offence against a child, failing which the person may themselves be liable to prosecution under Section 21.

In respect of Major Students (18 years and above), this Policy affirms their capacity for informed consent and autonomous decision-making, and channels complaints of sexual harassment, misconduct, or abuse through the Internal Committee constituted under the POSH Act (where the respondent is an employee/faculty member) and/or through ordinary criminal law (BNS/BNSS) and the Company's general Grievance Redressal Mechanism (Clause 10), while ensuring the same standards of confidentiality, non-retaliation, safety, and dignity applicable to minors, adapted to respect adult autonomy and privacy.

6. guiding principles

1. Best Interest of the Child — Every decision, action, and interpretation under this Policy shall be guided primarily by the best interest, safety, and well-being of the child, consistent with Section 3 of the JJ Act.

2. Zero Tolerance — The Company shall not tolerate, excuse, or minimise any act of abuse, harassment, or exploitation of a child or student, regardless of the seniority, popularity, or perceived indispensability of the alleged offender.

3. Presumption in Favour of the Child, Fairness to the Accused — While Section 29 of the POCSO Act raises a statutory presumption against the accused once foundational facts are established before a Special Court, this Policy requires that internal inquiries under Clause 9 be conducted fairly, impartially, and expeditiously, according both the complainant and the respondent a reasonable opportunity to be heard, without prejudicing any parallel statutory or criminal process.

4. Confidentiality — The identity of the child, the complainant, and the family, and the particulars of the complaint/inquiry, shall be kept strictly confidential in accordance with Section 23 of the POCSO Act and Section 74 of the JJ Act, subject only to disclosure mandated by law or ordered by a competent authority/court.

5. Non-Discrimination — Protection under this Policy shall be extended equally, without discrimination on the ground of sex, gender identity, sexual orientation, disability, religion, caste, ethnicity, nationality, or economic status.

6. Participation and Age-Appropriate Voice — Children and students shall, consistent with their evolving capacity, be heard and their views given due weight in matters affecting them, including in the design of safety and awareness programmes.

7. Mandatory and Timely Reporting — Every Specified Person shall report Reportable Conduct immediately and without unreasonable delay, in accordance with Clause 8.

8. Accountability and Non-Retaliation — Persons who report concerns in good faith shall be protected from retaliation; those who breach this Policy shall be held accountable through proportionate disciplinary and, where applicable, legal action.

9. Prevention over Cure — The Company shall prioritise preventive safeguards — screening, training, safe infrastructure, and supervision — over reactive redressal.

7. child protection committee (CPC) and internal committee (IC)

7.1 Constitution of the Child Protection Committee

The Board of Directors shall constitute a Child Protection Committee comprising not fewer than five (5) members, to be notified by name and designation within thirty (30) days of adoption of this Policy, consisting of:

• A senior member of management, who shall act as Chairperson;
• The designated Child Protection Officer / Nodal Officer, who shall act as Member-Secretary and single point of contact for all reports;
• At least one (1) faculty/staff member with pedagogical or child-development experience;
• At least one (1) woman member, in view of the composition requirements applicable to institutional safeguarding and Internal Committees;
• One (1) external/independent member with demonstrated experience in child rights, child psychology, social work, or law (to bring external, unbiased expertise, consistent with the spirit of Section 4(2)(c) of the POSH Act and NCPCR guidance for institutional child-safety committees); and
• Wherever feasible, a parent representative and/or (for age-appropriate matters) a student representative in a non-voting/observer capacity.

7.2 Functions of the CPC

1. Overseeing implementation of, and compliance with, this Policy across all Prism schools and programmes of the Company;

2. Receiving and triaging all complaints/reports of Reportable Conduct concerning Minor Students, and ensuring immediate escalation for mandatory reporting under Clause 8 where the matter concerns a child;

3. Conducting, or supervising, preliminary fact-finding and internal inquiry in matters not exclusively requiring police/CWC handling (e.g., breach of the Code of Conduct falling short of a criminal offence), while never delaying or substituting mandatory reporting under Section 19 of the POCSO Act;

4. Recommending interim measures for the safety of the child/student (Clause 11) pending inquiry;

5. Reviewing and updating background-verification, recruitment-screening, and training protocols at least annually;

6. Organising periodic awareness, sensitisation, and capacity-building sessions for staff, students, and parents;

7. Maintaining the confidential Child Safety Register recording all reports, actions taken, and outcomes (Clause 16);

8. Submitting an annual compliance report to the Board of Directors summarising the number and nature of complaints received, action taken, training conducted, and recommendations for improvement.

7.3 Internal Committee under the POSH Act (for Major Students and Employees)

The Company shall separately constitute, maintain, and publicise an Internal Committee under Section 4 of the POSH Act, 2013 for the receipt and inquiry of complaints of workplace sexual harassment made by women employees. As a matter of institutional best practice and student safety, the Company extends the right to approach the Internal Committee to Major (adult) Students who allege sexual harassment by an employee, faculty member, or another major student, and the Internal Committee shall apply the procedural safeguards, timelines (90 days for inquiry completion, 10 days for the respondent's reply, etc.), and confidentiality obligations of the POSH Act, mutatis mutandis, to such complaints, without prejudice to the complainant's independent right to approach the police under the BNS/BNSS at any stage.

7.4 Nodal / Child Protection Officer

The Company shall designate a named Child Protection Officer ("CPO") whose contact details (name, phone number, and e-mail address) shall be prominently displayed at every Prism school, on the Company's website, and in all student/parent communication material, and who shall be reachable at all times for the reporting of concerns. The CPO shall be responsible for immediate action, including contacting the police/SJPU/Childline (1098) and the CWC as required under Clause 8.

8. code of conduct for staff, faculty, and all specified persons

Every Specified Person shall, as a condition of engagement with the Company, sign an undertaking (Annexure C) affirming compliance with the following Code of Conduct:

8.1 General Conduct

• Treat every child and student with dignity, respect, courtesy, and fairness, regardless of talent, background, or conduct.
• Never use physical punishment, corporal punishment, humiliation, threats, or degrading treatment as a means of discipline, in conformity with Section 17 of the RTE Act.
• Never use language, jokes, or gestures of a sexual, discriminatory, or demeaning nature in the presence of, or directed at, a child or student.
• Never develop a 'special' or preferential relationship with an individual child (including through gifts, special privileges, excessive attention, or secret communication) that could be perceived as, or could facilitate, grooming.
• Never be alone with a single minor student in a closed room with the door locked or blocked from view; wherever one-on-one music instruction is pedagogically necessary, ensure the room has a glass panel/visibility window, keep the door unlocked/ajar, or ensure another adult or a parent is present or within visual/audio range, and inform another staff member of the schedule and location of the lesson.

8.2 Physical Contact

Physical contact with a student shall be limited to what is genuinely required for instructional purposes (e.g., correcting posture, hand position, or embouchure for a wind instrument) and shall:

• Be brief, appropriate to the pedagogical purpose, in a public or visible setting, and, where practicable, explained to the student before the contact is made;
• Never involve touching of private/intimate body parts under any circumstance;
• Be avoided entirely where the student expresses discomfort, and an alternative (verbal instruction or demonstration) used instead;
• Never be initiated in isolation, in the dark, in a vehicle, or in any non-public space.

8.3 Digital and Social Media Conduct

• No Specified Person shall contact, follow, message, or interact with a Minor Student through personal social media accounts, personal phone numbers, or personal messaging applications; all communication with minors shall be through official Company channels, copied to a parent/guardian or another staff member where practicable.
• No Specified Person shall request, store, or share photographs or videos of a child other than through official Company channels for legitimate academic, promotional (with consent per Clause 14), or administrative purposes.
• No Specified Person shall be in possession of, create, distribute, or transmit any Child Sexual Abuse Material, which is a serious offence under Sections 13-15 of the POCSO Act and Section 67B of the IT Act, and shall immediately report any such material encountered (including accidentally) to the CPO and, thereafter, the police, without retaining or forwarding a copy.
• Live-streamed or recorded classes involving minors shall not be conducted from private, unsupervised locations by the faculty member, and recordings shall be stored on Company-approved, accesscontrolled systems only.

8.4 Off-Premises Activities, Transport, and Tours

• Written parental/guardian consent (Annexure D) is mandatory before any minor student is taken off Company premises for a concert, competition, tour, or outstation programme.
• A minimum ratio of adult chaperones to minor students (recommended not less than 1:10, and not less than 1:6 for overnight/residential programmes) shall be maintained, with at least one chaperone of each gender represented among the students travelling.
• No Specified Person shall share a hotel room, sleeping area, or private transport alone with a single minor student unrelated to them.
• Emergency contact information for every travelling minor and a designated on-tour Child Safety Focal Point shall be maintained and shared with parents prior to departure.

8.5 Prohibited Conduct (Illustrative, Not Exhaustive)

• Any act amounting to penetrative sexual assault, sexual assault, or sexual harassment as defined in Sections 3, 7, and 11 of the POCSO Act;
• Grooming behaviour, including secretive communication, isolation of a child from peers/family, or inappropriate gift-giving;
• Corporal punishment or physical abuse;
• Verbal abuse, ridicule, or humiliation based on a student's ability, appearance, gender, or background;
• Bullying, cyberbullying, or facilitation of bullying between students;
• Use, possession, distribution, or facilitation of access to CSAM;
• Consumption of alcohol, tobacco, or any intoxicant in the presence of, or provision thereof to, a minor student;
• Any act of discrimination or exclusion on grounds prohibited under Clause 6(5) of this Policy.

9. safe recruitment and screening

1. No individual shall be engaged as an employee, faculty member, visiting artist, intern, or volunteer with recurring access to children until the Company has obtained, at minimum: (a) identity and address proof; (b) at least two independent professional/character references, contacted directly by the Company; (c) a signed self-declaration (Annexure E) disclosing whether the individual has ever been convicted of, chargesheeted for, or is presently under investigation for any offence involving a child or of a sexual nature; and (d) where reasonably available, a police verification certificate.

2. The Company shall maintain a record of the outcome of each such verification and shall re-verify at periodic intervals not exceeding three (3) years, or immediately upon receipt of any adverse information.

3. Any material misrepresentation or non-disclosure discovered subsequently shall constitute grounds for immediate termination of engagement and, where warranted, a report to the police.

4. The probation/induction period for every new Specified Person with access to children shall include mandatory training on this Policy, to be completed before independent, unsupervised access to students is permitted.

5. The Company shall check, so far as reasonably practicable and to the extent any such mechanism is publicly available, whether a candidate's name appears on any register of sexual offenders or in any published Special Court conviction under the POCSO Act.

10. training, awareness, and capacity building

10.1 For Staff and Faculty

• Mandatory induction training on this Policy, the POCSO Act, the Code of Conduct, and reporting obligations for every Specified Person before commencing independent interaction with students, and refresher training at least once every twelve (12) months.
• Training on recognising signs of abuse, neglect, grooming, and distress in children, and on traumainformed, non-leading communication with a child who discloses abuse.
• Training records, including attendance and dates, to be maintained by the CPC.

10.2 For Students

• Age-appropriate personal-safety and "good touch/bad touch" awareness sessions for minor students, conducted by qualified personnel, at least once every academic year.
• Clear communication, in language and format suited to the student's age, of the existence of this Policy, the identity and contact details of the CPO, and the student's right to report any concern without fear.
• For major students, orientation on the Internal Committee, the POSH Act, and general grievanceredressal channels.

10.3 For Parents/Guardians

• Annual orientation informing parents of this Policy, safe pick-up/drop-off protocols, communication channels, and the process for raising concerns.
• Provision of a copy of, or accessible link to, this Policy at the time of admission/enrolment of a minor student, together with the emergency contact details of the CPO and the CPC.

11. mandatory reporting obligations

11.1 Statutory Duty to Report

In accordance with Section 19 of the POCSO Act, every person, including every Specified Person, who has apprehension or knowledge that an offence under the POCSO Act has been, is being, or is likely to be committed against a child, shall immediately provide such information to the SJPU or the local police, or, where the person is in charge of the Company (including the Chairperson of the CPC or the CPO), ensure that such report is made without delay. Failure to report is itself an offence under Section 21 of the POCSO Act, punishable with imprisonment and/or fine (and, for an in-charge of a company/institution, more severe consequences where the failure to report is by a person responsible for the management of the institution).

11.2 Reporting Procedure

1. Upon receiving information, or forming a reasonable apprehension, of Reportable Conduct against a Minor Student, the Specified Person shall immediately inform the CPO/CPC and, without waiting for internal inquiry or confirmation, ensure that a report is made to the nearest police station/SJPU (dial 100 or 112) and, where the child requires care and protection, to the Child Welfare Committee, and/or Childline (1098).

2. The report to the police shall, wherever possible, be reduced to writing, but a Specified Person shall not delay an oral report on account of unavailability of writing facilities. Where the information discloses a cognizable offence, the police are statutorily bound to register an FIR without a preliminary inquiry.

3. No Specified Person shall attempt to independently investigate, confront the alleged offender, mediate a 'settlement', or persuade the child/family to withhold or withdraw a report — such conduct itself risks liability under Section 21 and may amount to an offence under the BNS (e.g., causing disappearance of evidence).

4. The identity of the child and the details of the report shall be kept strictly confidential under Section 23 of the POCSO Act; disclosure of the child's identity in media/publication, except with the permission of the Special Court in the interest of the child, is itself punishable.

5. Where the alleged offender is a Specified Person, the Company shall, pending the outcome of the criminal process, consider interim measures under Clause 12 (including relieving the individual of duties involving access to children) without characterising such interim measure as a finding of guilt.

6. A false complaint or false information given with the intent to defame or humiliate a person is punishable under Section 22 of the POCSO Act; provided that this provision shall never be used to discourage, penalise, or intimidate a child or a genuine complainant, and no punitive action shall be taken against a complainant unless a competent authority/court conclusively finds the complaint to have been knowingly false or malicious.

11.3 Reporting in Respect of Major Students

Where the person affected is a Major Student, the Specified Person shall encourage and facilitate the student's own decision to report the matter to the police (BNS/BNSS) and/or the Internal Committee, respect the adult student's autonomy and confidentiality wishes to the extent legally permissible, and shall not be under the mandatory Section 19 POCSO reporting duty (which applies only where the affected person is a child); provided that if the conduct in question also affects, or is connected with, any child, the reporting duty under Clause 11.1/11.2 shall apply in full.

11.4 Emergency Contact Directory

The following numbers shall be displayed at every Prism school and on the Company website:

12. complaint and internal redressal mechanism

12.1 Who May Complain

A complaint under this Policy may be made by the affected child/student, a parent/guardian, any Specified Person, any other student, or any third party with knowledge of Reportable Conduct. A child may report verbally, in writing, or through a trusted adult, teacher, or the CPO, and shall never be required to complain in the presence of the alleged offender.

12.2 Modes of Complaint

• In-person or telephonic report to the CPO or any member of the CPC;
• Written complaint (letter/e-mail) addressed to the CPO or Chairperson of the CPC;
• A dedicated, confidential suggestion/complaint box maintained at each Prism school for students (with provision for anonymous submissions, which shall nonetheless be acted upon to the extent verifiable);
• A dedicated e-mail address / helpline number displayed prominently at every Prism school and on the Company's website and communication materials;
• Direct report to the police/SJPU/Childline/CWC, which any person is free to make at any time, independent of, and without first exhausting, the Company's internal mechanism.

12.3 Procedure and Timelines

1. Acknowledgement of the complaint within twenty-four (24) hours of receipt.

2. Immediate mandatory reporting to police/SJPU/CWC where the complaint concerns a child and discloses a POCSO offence (Clause 11), undertaken in parallel with, and not postponed for, any internal process.

3. Preliminary assessment by the CPO/CPC within three (3) working days to determine interim safety measures (Clause 13).

4. Where the matter also falls to be inquired into internally (e.g., breach of the Code of Conduct, or a POSH matter concerning a major student), the CPC/Internal Committee shall complete its inquiry, so far as practicable, within ninety (90) days, according both parties a fair hearing, maintaining written records, and submitting a reasoned report with recommendations to the Board/management.

5. The complainant/child shall be kept informed, in an age-appropriate and sensitive manner, of the general status of the matter to the extent consistent with confidentiality and the integrity of any ongoing investigation.

6. No obligation to mediate, reconcile, or arrive at a compromise shall apply to any complaint involving a Minor Student and an allegation of a sexual offence; compromise/mediation in POCSO matters involving penetrative or aggravated offences is legally impermissible.

12.4 Support to the Child/Student During the Process

• The child shall be permitted to have a parent/guardian, trusted adult, or (where the investigating agency permits) support person present during statements, subject to the procedure under Section 26 of the POCSO Act and applicable BNSS provisions for recording of a child's statement (preferably by a woman police officer, at the residence of the child or a place of the child's choice, avoiding uniform where possible, and not repeatedly).
• Access to free legal aid, as available under the Legal Services Authorities Act, 1987 and POCSO Rules, shall be facilitated.
• Access to counselling and psychological support (Clause 13.3) shall be offered regardless of whether the matter proceeds to a formal complaint.

13. interim relief, medical care, and psychological support

13.1 Interim Protective Measures

1. Pending inquiry/investigation, the CPC (in consultation with management) may direct interim measures including reassignment of classes, suspension of the accused Specified Person from duties involving contact with children, altered class schedules, or supervised interaction, to ensure the safety of the child/student and the integrity of the process, without such measures amounting to a pre-judgment of guilt.

2. Interim relief shall be provided to the child in accordance with Rule 9 of the POCSO Rules, 2020, including facilitating access to emergency medical care, shelter, or protection where the child's immediate safety is at risk, in coordination with the CWC/police.

3. Interim compensation to the child victim may be recommended to the appropriate authority (District Legal Services Authority) under the POCSO Rules and applicable victim-compensation schemes, without prejudice to the child's right to seek further compensation through the Special Court.

13.2 Medical Examination

Where medical examination of the child is required, it shall be conducted strictly in accordance with Section 27 of the POCSO Act, i.e., in the presence of the parent/guardian or another person the child trusts, and, where the victim is a girl child, by a woman doctor, without any avoidable delay and, in all cases, within twenty-four (24) hours of receipt of information, in conformity with the medico-legal protocol prescribed by the Ministry of Health and Family Welfare.

13.3 Counselling and Psychological Support

• The Company shall facilitate access to qualified counselling/psychological support for any child or student affected by, or witness to, Reportable Conduct, at the Company's cost where the matter concerns a Specified Person's conduct, for a reasonable period as recommended by the counsellor.
• Support shall also be made available, where appropriate, to the peer group/class affected by an incident, and to staff involved in reporting or responding to a disclosure.
• Referral to a District Child Protection Unit, One Stop School, or empanelled mental-health professional shall be maintained as a ready resource by the CPC.

14. digital safety, photography, and data protection of children

14.1 Consent for Photography, Recording, and Publicity

• No photograph, audio/video recording, or likeness of a Minor Student shall be captured, used, or published (including on the Company's website, social media, brochures, or press material) without the prior written consent of the parent/guardian (Annexure D), specifying the purpose and duration of use, revocable at any time by written notice.
• Consent for one purpose (e.g., an internal newsletter) shall not be treated as consent for another (e.g., public social media promotion or third-party licensing).
• Recordings of classes/lessons involving minors shall be stored only on access-controlled Company systems, retained no longer than necessary for the stated academic purpose, and never shared with third parties without fresh consent.

14.2 Personal Data of Children — DPDP Act, 2023

As a Data Fiduciary processing the personal data of children under the Digital Personal Data Protection Act, 2023, the Company shall, under Section 9 thereof: (a) obtain verifiable consent of the parent/lawful guardian before processing a minor student's personal data; (b) refrain from processing personal data that is likely to cause any detrimental effect on the well-being of the child; (c) refrain from undertaking tracking, behavioural monitoring, or targeted advertising directed at children; and (d) apply data-minimisation, purpose-limitation, and reasonable security safeguards to all student data (academic records, contact details, recordings, attendance, and health information), in accordance with the Company's separate Privacy Policy.

14.3 Online Conduct and Cyber-Safety

• Students and parents shall be sensitised annually on safe internet use, recognising online grooming, and reporting cyberbullying or online harassment.
• The Company shall promptly report any instance of online sexual exploitation, CSAM, or grooming to the police/cybercrime cell (cybercrime.gov.in, helpline 1930) and, in the case of a child, to the SJPU/CWC as required under Clause 11.
• Any breach involving unauthorised access to or leakage of student data/recordings shall be treated as a data breach under the DPDP Act and reported to the Data Protection Board of India and affected data principals as required by law.

15. disciplinary action and consequences

1. Any Specified Person found, upon internal inquiry and/or through the outcome of a statutory investigation/trial, to have engaged in Reportable Conduct shall be subject to disciplinary action proportionate to the gravity of the misconduct, ranging from written warning and mandatory retraining (for minor, non-abusive breaches of the Code of Conduct) to suspension, demotion, and summary termination of employment/engagement (for abuse, harassment, or any POCSO/BNS offence), without prejudice to, and independent of, criminal prosecution.

2. Termination for cause on grounds of a substantiated child-safety violation shall be recorded as such in the individual's service record, and the Company shall extend full cooperation to law-enforcement and judicial authorities, including production of records and witnesses.

3. Where the misconduct is committed by a student against another student, age-appropriate corrective and restorative measures shall be adopted (counselling, parental engagement, disciplinary committee review), together with mandatory reporting under Clause 11 where the conduct against a Minor Student amounts to a POCSO offence (noting that POCSO applies without exception based on the offender's age, subject to the JJ Act's separate framework for children in conflict with law).

4. The Company shall not enter into any settlement, confidentiality/non-disparagement arrangement, or resignation-in-lieu-of-inquiry arrangement that has the effect of concealing a substantiated child-safety violation from statutory authorities or from acting as a reference-check bar for future employers.

16. confidentiality, non-retaliation, and protection of complainants

16.1 Confidentiality

All information relating to a complaint, the identity of the child/complainant, the alleged offender, and the proceedings shall be disclosed strictly on a need-to-know basis, in compliance with Section 23 of the POCSO Act, Section 74 of the JJ Act, and the confidentiality obligations under the POSH Act, and shall not be published or disclosed to the media except with the leave of the Special Court where required in the interest of the child.

16.2 Protection Against Retaliation

No child, student, parent, or Specified Person who, in good faith, reports a concern, makes a complaint, or participates in an inquiry under this Policy shall be subjected to retaliation, victimisation, adverse academic/employment consequence, or hostile treatment. Any act of retaliation shall itself be treated as serious misconduct, independently actionable under this Policy.

16.3 Protection Against False and Malicious Complaints

While Section 22 of the POCSO Act penalises knowingly false complaints made to defame or humiliate a person, the burden of establishing that a complaint was knowingly false and malicious rests on cogent evidence and is a matter for a competent authority/Special Court to determine; the possibility of this provision shall never be cited internally to dissuade a child or genuine complainant from reporting, nor shall any adverse inference be drawn against a complainant merely because an allegation is not, in the event, substantiated.

17. safe physical infrastructure

1. Practice/lesson rooms used for one-on-one instruction shall, where feasible, have a glass panel or visibility window, and doors shall not be locked or blocked from external view during a lesson involving a minor student.

2. Common areas, corridors, and entry/exit points shall, where feasible, be covered by CCTV surveillance (excluding washrooms and changing areas, which shall never be under surveillance), with recordings retained for a reasonable period and accessed only for safety/inquiry purposes on a need-to-know basis and in compliance with the DPDP Act.

3. Washrooms and changing areas for minors shall be gender-segregated, supervised at entry/exit where practicable, and no Specified Person of any gender shall enter a student washroom/changing area occupied by a minor student except in a genuine emergency.

4. A visitor-management protocol (sign-in, identification, and escort) shall be maintained at every Prism school to control access by outsiders to areas where children are present.

5. Safe pick-up/drop-off protocols shall be maintained, including a written authorisation list of persons permitted to collect a minor student, verified at the time of drop-off/pick-up.

18. peer-to-peer safety: anti-bullying and anti-ragging

The Company adopts a zero-tolerance approach to bullying, cyberbullying, hazing, or ragging-type conduct between students, whether minor or major, recognising that such conduct, though not always a POCSO offence, can cause serious psychological harm and may, depending on severity, additionally attract liability under the BNS (e.g., criminal intimidation, causing hurt, outraging modesty, defamation) or the IT Act (in respect of online conduct).

• Reports of bullying/cyberbullying shall be addressed through the same complaint channels as Clause 12, with corrective, restorative, and, where necessary, disciplinary measures proportionate to severity and age.
• Where bullying involves conduct of a sexual nature directed at a Minor Student by another minor or an adult, the mandatory POCSO reporting obligation under Clause 11 shall apply in full.
• Senior students, monitors, or peer mentors shall be sensitised on their responsibility to model respectful behaviour and to report concerns regarding younger or vulnerable peers.

19. record-keeping, monitoring, and reporting to the board

1. The CPC shall maintain a confidential Child Safety Register recording the date, nature, and outcome of every complaint/report, interim measures taken, statutory reports made, and final disposition, accessible only to the CPO, the Chairperson of the CPC, and (on a need-to-know basis) legal counsel and statutory authorities.

2. Records of background verification, training attendance, consent forms (photography/off-premises activity), and Internal Committee/CPC proceedings shall be retained for a minimum period as required under applicable law (including limitation periods for POCSO offences, which are not time-barred, and the Companies Act record-retention norms) and in any event not less than eight (8) years, or such longer period as any ongoing legal proceeding may require.

3. The CPC shall place before the Board of Directors, at least annually, a report on the number and nature of complaints received, action taken, training conducted, and recommended improvements to this Policy, without disclosing the identity of any child or complainant.

4. All record-keeping shall be undertaken consistent with the confidentiality obligations of Clause 16 and the data-protection obligations of Clause 14.2.

20. summary of roles and responsibilities

21. review, amendment, and interpretation

1. This Policy shall be reviewed by the Board of Directors (or a committee thereof) at least once every twelve (12) months, and earlier upon: (a) any amendment to the POCSO Act, JJ Act, POSH Act, BNS/BNSS/BSA, IT Act, DPDP Act, or related rules/notifications; (b) any significant incident or nearmiss revealing a gap in this Policy; or (c) a recommendation of the CPC/IC.

2. In the event of any conflict between this Policy and applicable law, the applicable law, as amended or judicially interpreted from time to time, shall prevail, and this Policy shall be deemed automatically modified to the extent of such conflict pending formal amendment.

3. Employees and Specified Persons shall be notified of material amendments and, where the amendment affects the Code of Conduct, shall be required to re-acknowledge the updated Policy.

4. This Policy supplements, and shall be read together with, the Company's POSH Policy, Data Privacy Policy, Code of Conduct, HR Manual, and Whistle-Blower Policy; in matters specifically concerning a child, the child-protection provisions of this Policy shall prevail over any general provision to the contrary in such other policies.

22. miscellaneous

1. Nothing in this Policy shall be construed to limit any right of a child, student, parent, or any person to approach the police, a Child Welfare Committee, a Special Court, the National/State Commission for Protection of Child Rights, or any other statutory or judicial authority directly and at any time, independent of the Company's internal process.

2. This Policy does not create any employment right beyond what is provided under applicable labour and employment law, and disciplinary action under this Policy shall be without prejudice to the Company's rights and obligations under applicable service rules and law.

3. Headings are inserted for convenience of reference only and shall not affect the interpretation of this Policy.

4. This Policy shall be made available in English and, so far as practicable, in the principal regional language(s) of the location of each Prism school, and shall be prominently displayed at every Prism school and published on the Company's website.

23. adoption

This Policy has been adopted by the Board of Directors of PSOM Studios Private Limited and is in force from the date of its publication on the Company's website.