Prevention of Sexual Harassment (POSH) Policy

1. preamble, objective and zero-tolerance statement

Prism School of Music, operated by PSOM Studios Private Limited ("PSOM", "the Institution", "the Organisation", "the Management", "we", "us" or "our"), is committed to providing a safe, secure, dignified and harassment-free environment for every individual associated with it, irrespective of gender, designation, or nature of engagement.

PSOM recognises that the right to work with dignity is a fundamental right recognised under Articles 14, 15, 19(1)(g) and 21 of the Constitution of India, and as affirmed by the Hon'ble Supreme Court of India in Vishaka & Ors. v. State of Rajasthan & Ors. (1997) and subsequently codified through the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("the Act") read with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 ("the Rules").

PSOM adopts a strict, unequivocal, and absolute ZERO-TOLERANCE policy towards sexual harassment in any form, at any level, and by or against any person associated with the Institution. Any act of sexual harassment shall be treated as a grave act of misconduct, inviting disciplinary action up to and including termination of engagement, without prejudice to the aggrieved person's right to pursue criminal proceedings under the Indian Penal Code, 1860 / Bharatiya Nyaya Sanhita, 2023, as applicable.

1.1 Objectives of this Policy

• To prevent, prohibit and eliminate sexual harassment of women at the workplace in all its forms.
• To provide a fair, time-bound, confidential and effective mechanism for reporting and redressal of complaints of sexual harassment.
• To ensure compliance with the Act, the Rules, and all applicable amendments, circulars and judicial pronouncements.
• To create awareness amongst all persons associated with PSOM regarding their rights, duties and the consequences of sexual harassment.
• To ensure that the dignity, confidentiality and interests of the aggrieved woman, the respondent, and witnesses are protected throughout the process.
• To foster an organisational culture of equality, mutual respect and professionalism, extending beyond the strict letter of the law wherever practicable.

Note: While the Act specifically protects "women", PSOM, as a matter of good governance and organisational culture, extends the reporting mechanism, protection against victimisation, and the principles of natural justice under this Policy to complaints of sexual harassment raised by any employee, regardless of gender, save that statutory timelines, the constitution of the Internal Committee, and rights specifically conferred by the Act shall apply strictly to women complainants as mandated by law. Complaints by persons other than women will be examined under this Policy read with PSOM's general Code of Conduct and applicable service rules.

2. scope and applicability

This Policy applies uniformly across all establishments, premises, studios, branches, franchise-operated schools (to the extent under PSOM's operational control), and virtual/remote working arrangements of PSOM, and covers:

• All permanent, probationary, temporary and contractual employees, faculty, music instructors and trainers, whether full-time or part-time.
• Interns, trainees, apprentices and articled clerks, whether paid or unpaid.
• Consultants, retainers, freelancers and independent contractors engaged by PSOM.
• Third-party vendors, service providers, contract staff (e.g., housekeeping, security, catering, transport, technical/AV support) and their employees while present at PSOM premises or events.
• Visitors, guests, parents/guardians of students, prospective clients, and any other third party who visits or interacts with PSOM in connection with its business.
• Students of Prism School of Music who are 18 years of age or above, in their interactions with employees, faculty or staff of PSOM (interactions involving minor students shall additionally be governed by PSOM's Child Protection Policy and the Protection of Children from Sexual Offences (POCSO) Act, 2012, which shall apply on a mandatory and non-derogable basis).
• Members of the Board, promoters, partners and key managerial personnel of PSOM Studios Private Limited.

2.1 Coverage of "Workplace" — Physical and Extended

This Policy applies not only to work performed at PSOM's registered office, studios and teaching premises, but extends to:

• Remote work, work-from-home, and hybrid working arrangements, including conduct occurring over calls, video-conferences, or while an employee is logged in for official purposes from any location.
• Off-site locations visited in connection with work, including client premises, examination schools, recording studios, concert/performance venues, and competition venues.
• Travel arranged by or for the purposes of PSOM's business, including transportation provided or arranged by the employer.
• Any social, cultural, promotional or networking event connected with or arising out of employment, including offsites, retreats, farewells, felicitations and after-work gatherings, whether hosted on or off PSOM premises.
• Any digital or virtual space used for work-related communication, including official email, instant messaging platforms, video-conferencing tools, internal collaboration software, and work-related social media groups.

2.2 Duration of Applicability

This Policy shall apply during working hours as well as outside working hours if the conduct complained of has a nexus with the employment relationship or occurs at a place falling within the extended definition of "workplace" above. This Policy shall remain in force with effect from the date of its adoption by the Management and shall be reviewed periodically as set out in Section 15.

3. definitions

For the purposes of this Policy, unless the context otherwise requires, the following expressions shall bear the meanings assigned to them under the Act, and are reproduced/adapted below for ease of reference:

3.1 "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 by the respondent, and includes co-terminously a woman visiting the workplace, whether as a client, customer, student (18 years or above), or otherwise, irrespective of her employment status with PSOM.

3.2 "Respondent"

Means a person against whom the aggrieved woman has made a complaint under this Policy and the Act. The Respondent may be an employee, faculty member, contractor, vendor, visitor, client or any other person covered under Section 2 above, irrespective of designation or seniority.

3.3 "Employee"

Means a person employed at a workplace for any work, on a regular, temporary, ad hoc or daily wage basis, either directly or through an agent, including a contractor, with or without the knowledge of the principal employer, and includes a co-worker, a contract worker, probationer, trainee, apprentice, or a person called by any other name, and further includes faculty, visiting instructors, interns and consultants engaged by PSOM.

3.4 "Workplace"

Includes: (a) any department, organisation, undertaking, establishment, enterprise, institution, office, branch or unit established, owned, controlled by PSOM, including Prism School of Music and all its studios/schools; (b) any place visited by the employee arising out of or during the course of employment, including transportation provided by the employer for undertaking such a journey; and (c) a private venue or residence, where such venue or residence is used for hosting an event connected with the employment or business of PSOM.

3.5 "Internal Committee" or "IC"

Means the Internal Committee constituted by PSOM under Section 4 of the Act, as detailed in Section 4 of this Policy.

3.6 "Sexual Harassment" — Exhaustive Definition

"Sexual Harassment" includes any one or more of the following unwelcome acts or behaviour (whether directly or by implication), namely:

• Physical contact and advances of a sexual nature, including unwelcome touching, brushing against, patting, pinching, or any other unwelcome physical proximity;
• A demand or request for sexual favours, whether express or implied, including any suggestion that submission to or rejection of such conduct will influence employment decisions ("quid pro quo" harassment);
• Sexually coloured remarks, jokes, innuendos, comments on a person's body, appearance or attire, or unwelcome sexual advances made verbally, in person or over telephone/video calls;
• Showing pornography or any sexually explicit visual, printed or digital material without consent;
• Any other unwelcome physical, verbal or non-verbal conduct of a sexual nature, including leering, stalking, unwelcome gestures, or persistent unwelcome romantic or sexual attention after being informed that such attention is unwelcome;
• Creating a hostile, intimidating or offensive work environment for the aggrieved woman, whether or not connected to a specific employment benefit;
• Humiliating conduct constituting a health and safety problem, or adverse treatment in employment (including in recruitment, promotion, appraisal or continuation of employment) related to or arising from the rejection of unwelcome sexual conduct;

3.6.1 Digital, Online and Technology-Facilitated Harassment (Expressly Covered)

In recognition of contemporary modes of workplace interaction, this Policy expressly clarifies that "sexual harassment" includes, without limitation, the following when perpetrated using electronic, digital or online means, whether on official or personal devices/accounts, where there is a nexus with the workplace or working relationship:

• Sending sexually explicit, suggestive or offensive emails, text messages, or messages on WhatsApp, Slack, Microsoft Teams, or any other messaging/collaboration platform used for work;
• Sharing, forwarding or displaying sexually explicit images, memes, GIFs, videos or links, including via social media, official groups, or during virtual meetings (e.g., inappropriate content shared via screen-share);
• Cyberstalking, persistent unwelcome messaging, or unwelcome sexual advances on social media platforms directed at a colleague, student, or other covered person;
• Non-consensual capturing, morphing, circulation or threat of circulation of a person's photographs or videos of a sexual or intimate nature ("revenge content"), including "deepfakes";
• Sexually inappropriate conduct or comments made during video-conferences, virtual classes, or online rehearsals/recordings, including inappropriate camera angles, attire, or gestures directed at another participant;
• Online quid pro quo harassment, including offering favourable grades, roles, opportunities, bookings, or professional advancement in exchange for sexual favours communicated digitally.

3.7 "Circumstances Amounting to Sexual Harassment" (Section 3(2) of the Act)

Any of the following circumstances, among other circumstances, if it occurs or is present in relation to or connected with any act or behaviour of sexual harassment, may amount to sexual harassment:

1. Implied or explicit promise of preferential treatment in employment;

2. Implied or explicit threat of detrimental treatment in employment;

3. Implied or explicit threat about present or future employment status;

4. Interference with work or creating an intimidating, offensive or hostile work environment; and

5. Humiliating treatment likely to affect health or safety.

4. internal committee (IC) — constitution, tenure and powers

Pursuant to Section 4 of the Act, PSOM has constituted (or shall constitute, at each administrative unit/branch employing 10 or more employees or as otherwise required) an Internal Committee to receive and inquire into complaints of sexual harassment. Where any office or branch of PSOM has fewer than 10 employees, or where the complaint is against the employer itself, complaints shall instead be referable to the Local Committee constituted by the District Officer under Section 6 of the Act for the relevant district.

4.1 Composition of the Internal Committee

The Internal Committee shall comprise the following members, nominated by the Management:

Note: Not less than one-half of the total members nominated for the Internal Committee shall be women, as mandated under the proviso to Section 4(2) of the Act. PSOM shall ensure this ratio is maintained at all times, including during interim vacancies.

4.2 Tenure of Members

• The Presiding Officer and every member of the Internal Committee shall hold office for a period not exceeding three (3) years from the date of their nomination, as prescribed under Section 4(3) of the Act.
• The External Member shall be paid such fees or allowances for holding the proceedings of the Internal Committee as may be prescribed under Rule 9 of the Rules, or as reasonably determined by the Management, subject to a ceiling of ₹62,500 per case/inquiry as prescribed.
• A vacancy arising from the resignation, disqualification, or cessation of employment of any member shall be filled by a fresh nomination within a reasonable time, and in any case before the next complaint is taken up, to preserve compliance with the composition requirements.

4.3 Disqualification of Members (Rule 4)

A member of the Internal Committee shall be disqualified and removed from the Committee if such member:

• Has been convicted of an offence, or an inquiry into an offence under any law is pending against them; or
• Is found guilty in any disciplinary proceedings, or a disciplinary proceeding is pending against them; or
• Has abused their position so as to render their continuation in office prejudicial to the public interest.

4.4 Powers of the Internal Committee

For the purposes of conducting an inquiry, the Internal Committee shall have the powers vested in a civil court under the Code of Civil Procedure, 1908, when trying a suit, in respect of the following matters:

• Summoning and enforcing the attendance of any person and examining them on oath;
• Requiring the discovery and production of documents; and
• Any other matter which may be prescribed.

4.5 Contact Details of the Internal Committee

Every complaint, communication or query relating to sexual harassment may be addressed to the Internal Committee at the dedicated, confidential email address and physical address below. The IC's contact details shall be prominently displayed at all PSOM premises, in the employee handbook, and on PSOM's internal communication channels, as mandated under Section 19(b) of the Act: Mode Details

Complaints and queries for the Internal Committee may be sent to mgmt@prismschoolofmusic.com, marked for the attention of the Internal Committee, or handed in writing to the administrator at any Prism school for onward transmission to the Committee. The names and contact details of the Internal Committee members shall be displayed at every Prism school.

5. filing a complaint

5.1 Limitation Period

A written complaint of sexual harassment must be filed by the aggrieved woman with the Internal Committee within a period of three (3) months from the date of the incident, and in case of a series of incidents, within three (3) months from the date of the last incident, in accordance with Section 9(1) of the Act.

Extension of time: Where the Internal Committee is satisfied that the circumstances were such which prevented the aggrieved woman from filing a complaint within the said period, it may, for reasons to be recorded in writing, extend the time limit by a further period not exceeding three (3) months, making the outer limit six (6) months from the date of the incident.

5.2 Manner of Filing

• The complaint must ordinarily be made in writing. Where the aggrieved woman is unable to make the complaint in writing, the Presiding Officer or any member of the Internal Committee shall render all reasonable assistance to reduce the complaint to writing.
• The aggrieved woman may submit six (6) copies of the complaint along with supporting documents and the names/addresses of witnesses, to the Internal Committee, or may email a soft copy to the dedicated IC email ID, in which case the IC shall be responsible for making the requisite copies.

5.3 Filing on Behalf of the Aggrieved Woman (Section 9(2))

Where the aggrieved woman is unable to make a complaint on account of her physical or mental incapacity, or death, or otherwise, her complaint may be filed under this Policy by:

• Her relative or friend; or
• Her co-worker; or
• An officer of the National Commission for Women or State Commission for Women; or
• Any person who has knowledge of the incident, with the written consent of the aggrieved woman; or
• In the case of the aggrieved woman's death, her legal heir, in each case, subject to the written consent of the aggrieved woman (except in the case of death or established incapacity), as prescribed under Rule 6 of the Rules.

5.4 Conciliation (Section 10)

Before initiating a formal inquiry, and only at the written request of the aggrieved woman, the Internal Committee may take steps to settle the matter between the aggrieved woman and the respondent through conciliation, subject to the following safeguards:

• No monetary settlement shall be made as a basis of conciliation. Under no circumstances shall the Internal Committee facilitate, permit, or record any settlement involving payment of money by the respondent to the aggrieved woman in lieu of withdrawal of the complaint or in settlement thereof.
• Where a settlement is arrived at, the Internal Committee shall record the settlement so arrived and forward the same to the employer to take action as specified in the recommendation.
• The Internal Committee shall provide copies of the settlement to the aggrieved woman and the respondent.
• Where a settlement has been reached, no further inquiry shall be conducted, provided that if the terms of settlement are not complied with by the respondent, or if a fresh complaint of a similar nature is filed, the Internal Committee shall proceed with a full inquiry.
• Conciliation shall never be forced upon the aggrieved woman, and her refusal to conciliate shall not be held against her or affect the fairness of the subsequent inquiry in any manner.

6. inquiry process and timelines

6.1 Preliminary Steps

• On receipt of a complaint, the Internal Committee shall, within seven (7) working days, send one copy of the complaint to the respondent, as mandated under Rule 7(1) of the Rules.
• The respondent shall file their reply to the complaint, along with supporting documents and details of witnesses, within a period not exceeding ten (10) working days from the date of receipt of the complaint.

6.2 Principles of Natural Justice

The Internal Committee shall, at all stages of the inquiry, strictly observe the principles of natural justice, including:

• Providing both parties a fair and adequate opportunity of being heard;
• Furnishing the respondent with a copy of the complaint and all relevant material relied upon;
• Allowing both parties to present evidence, produce documents, and lead witnesses in support of their respective cases;
• Permitting both parties to be assisted (not represented) by a person of their choice during the inquiry proceedings, other than a legal practitioner, as clarified under Rule 7(6) of the Rules;
• Maintaining impartiality and avoiding any conflict of interest amongst IC members in relation to either party;
• Recording minutes of every hearing, duly signed by the parties present.

6.3 Statutory Timelines

6.4 Interim Relief During Pendency of Inquiry (Section 12)

During the pendency of the inquiry, on a written request by the aggrieved woman, the Internal Committee may recommend to the Management to:

• Transfer the aggrieved woman or the respondent to any other workplace/branch/school of PSOM; or
• Grant leave to the aggrieved woman up to a period of three (3) months, in addition to her regular leave entitlement, which shall not be construed as leave for any other statutory purpose; or
• Permit the aggrieved woman to work from home / remotely, where the nature of her work so permits; or
• Restrain the respondent from reporting on the work performance of the aggrieved woman, and assign such reporting/appraisal function to another superior, during the pendency of the inquiry; or
• Grant such other relief to the aggrieved woman as may be prescribed.

Such interim measures shall be implemented by the Management within a reasonable time, and in no case later than the timelines specified under the Rules, and shall be without prejudice to the rights of either party in the final inquiry.

6.5 Inquiry Report and Findings

• On completion of the inquiry, the Internal Committee shall provide a report of its findings to the Management within ten (10) days of completion of the inquiry, and such report shall be made available to both parties.
• Where the Internal Committee arrives at the conclusion that the allegation against the respondent has not been proved, it shall recommend that no action is required to be taken.
• Where the Internal Committee arrives at the conclusion that the allegation against the respondent has been proved, it shall recommend to the Management to take action for sexual harassment as misconduct in accordance with the provisions of the applicable service rules, or, in the absence thereof, in accordance with Section 13(3)(i) of this Policy and the Act, including deduction of compensation as detailed in Section 7 below.

7. disciplinary action, penalties and compensation

7.1 Range of Disciplinary Action

Where the Internal Committee, after inquiry, holds the allegation of sexual harassment to be proved, the Management shall, within sixty (60) days of receipt of the report, act upon the recommendation, which may include one or more of the following, depending on the gravity and nature of the proven misconduct:

• A written apology to the aggrieved woman;
• A formal warning or written reprimand placed on the respondent's personnel file;
• Withholding of promotion, increment, or variable pay/bonus for a specified period;
• Mandatory counselling and/or sensitisation training for the respondent;
• Community service, at the discretion of the Management, in appropriate cases;
• Suspension, demotion, or transfer of the respondent;
• Termination of employment/engagement of the respondent, in cases of grave or repeated misconduct;
• Debarment of vendors, contractors, or third parties found guilty from further engagement with PSOM;
• Reporting the matter to the police for registration of an FIR under applicable criminal law, where the conduct also constitutes a cognisable offence, without prejudice to the disciplinary action above.

7.2 Compensation to the Aggrieved Woman (Sections 13 and 15)

In addition to disciplinary action against the respondent, the Internal Committee may recommend, and the Management shall pay, compensation to the aggrieved woman, having regard to the following factors prescribed under Section 15 of the Act:

6. The mental trauma, pain, suffering and emotional distress caused to the aggrieved woman;

7. The loss in career opportunity due to the incident of sexual harassment;

8. Medical expenses incurred by the victim for physical or psychiatric treatment;

9. The income and financial status of the respondent;

10. Feasibility of such payment in a lump sum or in instalments.

Such sum shall be recovered from the respondent's salary/dues, or, where the respondent is not an employee (e.g., a contractor, vendor or visitor), such sum shall be directed to be paid directly by the respondent, and in the event of default, the Internal Committee may forward the matter to the Local Committee/District Officer for recovery as an arrear of land revenue.

8. protection against victimisation and retaliation

PSOM strictly prohibits any form of retaliation, victimisation, or adverse action against:

• An aggrieved woman who, in good faith, files a complaint of sexual harassment;
• Any witness who provides evidence or testimony in relation to a complaint;
• Any person who assists the aggrieved woman in filing or pursuing a complaint;
• A respondent, pending the outcome of the inquiry — no presumption of guilt shall attach merely by virtue of a complaint having been filed, and the respondent shall be treated with dignity and fairness throughout the process.

Any act of retaliation, including but not limited to demotion, denial of promotion or increment, unwarranted transfer, exclusion from work assignments, harassment, or termination, taken against any of the above persons on account of their participation (in good faith) in the complaint/inquiry process, shall itself be treated as a separate act of serious misconduct, inviting independent disciplinary action against the person responsible for such retaliation.

8.1 Confidentiality (Section 16)

PSOM and all persons involved in the complaint and inquiry process shall maintain strict confidentiality in relation to:

• The identity and addresses of the aggrieved woman, respondent and witnesses;
• The contents of the complaint, the inquiry proceedings, the recommendations of the Internal Committee, and any action taken thereon,

save and except where disclosure is required for the purposes of the inquiry itself, or is directed by a court of competent jurisdiction, or is required to be disseminated in relation to the outcome, without disclosing the name, address, identity or particulars of the aggrieved woman, respondent or witnesses, in accordance with Section 16 of the Act. Breach of this confidentiality obligation by any employee shall attract disciplinary action, and, in case of a member of the Internal Committee, may additionally attract penalty under Rule 12 of the Rules.

9. malicious or false complaints

PSOM recognises that the protections afforded under the Act must not be misused to file false, frivolous or malicious complaints, while equally recognising that a genuine complaint must never be discouraged by the fear of counter-action. Accordingly:

• Mere inability to substantiate is not malice: The Internal Committee shall not recommend action against the complainant merely because the complaint could not be substantiated or proved during the inquiry. A finding of "not proved" shall never, by itself, be equated with a false or malicious complaint.
• Action for a malicious complaint shall be recommended only where the Internal Committee, after due inquiry, arrives at a specific and reasoned conclusion that the complaint was made with malicious intent and is false, or that the complainant has produced forged or misleading documents, and such conclusion shall be duly recorded in writing with reasons, in accordance with Section 14 of the Act.
• Similarly, any witness who has given false evidence or produced forged/misleading documents during the inquiry may, upon a similar reasoned finding by the Internal Committee, be proceeded against.
• Before recommending any action under this Section, the Internal Committee shall take into account the same disciplinary framework applicable under the respondent's service rules, and shall independently and separately record its satisfaction of malicious intent, distinct from its findings on the merits of the original complaint.
• PSOM shall exercise extreme caution and restraint before invoking this provision, so as to ensure that it does not have a chilling effect on the reporting of genuine grievances.

10. appeal

Any person aggrieved by the recommendations of the Internal Committee, or by the non-implementation of such recommendations by the Management, may prefer an appeal to the appropriate Court or Tribunal in accordance with the service rules applicable to such person, or, where no such service rules exist, in the manner prescribed under the Act, within a period of ninety (90) days of the recommendations, as provided under Section 18 of the Act.

11. duties and obligations of the employer (section 19)

PSOM, as the employer, undertakes to:

• Provide a safe working environment at the workplace, including safety from persons coming into contact at the workplace;
• Display at any conspicuous place in the workplace the penal consequences of sexual harassment and the composition of the Internal Committee;
• Organise workshops and awareness programmes at regular intervals for sensitising employees on the provisions of the Act, and orientation programmes for members of the Internal Committee;
• Provide necessary facilities to the Internal Committee for dealing with complaints and conducting inquiries;
• Assist in securing the attendance of the respondent and witnesses before the Internal Committee;
• Make available such information to the Internal Committee as it may require in relation to the complaint;
• Provide assistance to the aggrieved woman, if she so chooses, to file a complaint under the Indian Penal Code / Bharatiya Nyaya Sanhita or any other applicable law;
• Initiate action, under the Indian Penal Code / Bharatiya Nyaya Sanhita or other applicable law, against the perpetrator, or if the aggrieved woman so desires, where the perpetrator is not an employee, in the workplace at which the incident of sexual harassment took place;
• Treat sexual harassment as misconduct under the applicable service rules and initiate action for such misconduct;
• Monitor the timely submission of reports by the Internal Committee.

12. awareness, training and capacity building

• PSOM shall conduct mandatory induction training on this Policy for every new employee, faculty member, intern and consultant at the time of onboarding.
• PSOM shall conduct periodic refresher training and awareness sessions, at least once every year, covering all employees across all locations, including remote/work-from-home staff, on the provisions of the Act and this Policy.
• Members of the Internal Committee shall undergo specialised capacity-building workshops, orientation programmes and skill-training (including on conducting inquiries, recording evidence, and handling sensitive matters) at periodic intervals, and shall be kept updated on amendments to the Act, Rules and relevant judicial precedents.
• PSOM shall prominently display this Policy, the composition of the Internal Committee, and the consequences of sexual harassment at all its premises, on its intranet/internal portal (if any), and in the employee/faculty handbook.
• Awareness material shall be made available in the local language(s) predominantly used at each PSOM school, to ensure comprehension by all categories of staff, including support and contract staff.

13. annual report and statutory filings

13.1 Internal Committee's Annual Report

The Internal Committee shall prepare, in the prescribed format under Rule 14 of the Rules, an annual report containing:

• The number of complaints of sexual harassment received in the year;
• The number of complaints disposed of during the year;
• The number of cases pending for more than ninety (90) days;
• The number of workshops or awareness programmes conducted; and
• The nature of action taken by the employer.

13.2 Filing with the District Officer

PSOM shall ensure that the Internal Committee submits the annual report referred to above to the employer, and the employer shall include the information in its own Annual Report (if applicable under other laws) and shall additionally submit the report to the District Officer of the relevant district(s) in which PSOM operates, within the timelines prescribed under the Act and Rules, for onward compilation by the District Officer for submission to the State Government.

13.3 Disclosure in Board's Report / Statutory Filings

Where applicable under the Companies Act, 2013 and rules made thereunder, PSOM Studios Private Limited shall disclose in its Board's Report the number of complaints received and disposed of during the financial year, and the number of complaints pending for more than ninety (90) days, in accordance with the Companies (Accounts) Rules, 2014.

14. miscellaneous provisions

• Extension to third parties: Where the respondent is not an employee of PSOM (e.g., a vendor, visitor, or client), the Internal Committee shall, in addition to the recommendations under this Policy, advise the aggrieved woman of her right to file a complaint under applicable criminal law, and PSOM shall extend all reasonable assistance in this regard, including, where necessary and permissible, terminating or suspending the business relationship with such third party.
• Non-applicability of settlement waiver: No employee may be required, as a condition of employment or otherwise, to waive their right to file a complaint under this Policy or the Act.
• Interaction with other policies: This Policy shall be read harmoniously with PSOM's Code of Conduct, Anti-Bullying Policy, Whistleblower Policy, Child Protection Policy (in relation to minor students) and IT/Acceptable Use Policy. In case of any conflict specifically relating to sexual harassment, this Policy shall prevail.
• Record retention: All records relating to complaints, inquiries, and outcomes shall be maintained by the Internal Committee/HR in a confidential and secure manner for a minimum period as required under applicable law, and in any event not less than three (3) years.
• No contracting out: The rights and protections available under this Policy and the Act cannot be waived, diluted or contracted out of by any agreement, appointment letter, consultancy agreement or vendor contract.
• Severability: If any provision of this Policy is held to be invalid or unenforceable, the remaining provisions shall continue in full force and effect, and the invalid provision shall be substituted with a valid provision that most closely reflects its original intent.
• Governing law: This Policy shall be governed by and construed in accordance with the laws of India, and shall be read subject to, and shall stand automatically amended to the extent of, any amendment to the Act or the Rules.

15. policy review

This Policy shall be reviewed at least once every year, or earlier if warranted by a change in law, organisational structure, or operational experience, by the Management in consultation with the Internal Committee. Any amendment to this Policy shall be communicated to all employees and covered persons promptly upon adoption.

For and on behalf of PSOM Studios Private Limited (Prism School of Music):