This policy provides dedicated equal opportunity provisions for persons with disabilities and transgender persons in one document. It identifies the responsible officer, workplace support and the complaint procedure applicable to each statutory framework.
Application of the two statutory parts
Part A is the Company’s dedicated equal opportunity policy for persons with disabilities under section 21 of the Rights of Persons with Disabilities Act, 2016 and Rule 8 of the Central Rules. Part B is its dedicated equal opportunity policy for transgender persons under Rule 12 of the Transgender Persons (Protection of Rights) Rules, 2020. Each Part is adopted and published as an identifiable statutory policy within this document, together with the common approval and contact provisions at the end.
References to a numbered section are to that section of the same Part unless another Part is specified. A matter involving both disability and transgender protections shall receive the safeguards of both Parts. The Company shall comply with each applicable time limit; the longer timeline under one framework shall not postpone action required sooner under another. Mandatory law and binding directions prevail over any inconsistent term.
Anya Batra, email anya@jhana.ai, is designated as disability Liaison Officer under Part A and Complaint Officer under section 11 of the TP Act under Part B, effective upon the Company’s written approval below. Each role retains its own responsibilities and statutory process.
Part A Equal opportunity for persons with disabilities
1 Purpose and legal framework
1.1 Jhana Labs Private Limited (the "Company") shall provide equal opportunity, protect dignity and autonomy, prevent discrimination on the ground of disability, and provide reasonable accommodation. This policy is adopted under the Rights of Persons with Disabilities Act, 2016, as amended (the "RPWD Act"), particularly sections 3, 21 and 22, read with the Rights of Persons with Disabilities Rules, 2017, as amended (the "Central Rules"), including Rules 3, 8 and 9, and applicable State rules, accessibility standards, notifications and binding judicial directions.
1.2 The policy includes facilities and amenities required for a private establishment with fewer than twenty employees under Rule 8(4). The Company also adopts the detailed policy subjects in Rule 8(3), including identification of suitable roles and appointment of a Liaison Officer. These commitments continue irrespective of changes in headcount. Mandatory law prevails over any inconsistent provision, and more favourable lawful Company benefits remain available.
2 Scope and definitions
2.1 This policy applies to recruitment and all stages of employment or engagement, including remuneration, benefits, training, promotion, transfer, posting, leave, retention and separation. It covers directors, employees, applicants, interns, trainees, consultants, contractors and agency personnel, as appropriate to their relationship with the Company. Accessibility and respectful-treatment commitments also apply to customers, visitors and other persons accessing the Company’s premises, products or services.
2.2 It applies at all Company workplaces, including the Bengaluru corporate office at WeWork Galaxy, 43, Residency Road, Bengaluru, Karnataka 560025; other Company premises; remote and hybrid workplaces; Company digital systems; business travel; client sites; and work-related meetings, communications and events. The Company shall coordinate with landlords, coworking operators, clients and contractors without treating their involvement as an exemption from its own obligations.
2.3 A "person with disability" has the meaning in section 2(s) of the RPWD Act and includes a person with a long-term physical, mental, intellectual or sensory impairment which, in interaction with barriers, hinders full and effective participation in society equally with others. Protection is not confined to visible disabilities or to persons with forty per cent or greater disability. Certification required for a particular statutory benefit shall not be used as a blanket condition for seeking accommodation under this policy.
2.4 "Reasonable accommodation" means necessary and appropriate modifications and adjustments in a particular case, without imposing a disproportionate or undue burden, to enable equal enjoyment or exercise of rights. "Discrimination" includes exclusion, restriction and denial of reasonable accommodation as defined in the RPWD Act. A "barrier" includes physical, digital, communication, institutional and attitudinal obstacles.
3 Responsibility and liaison officer
3.1 The Liaison Officer is Anya Batra, email anya@jhana.ai. She shall coordinate accessible recruitment, facilities and amenities, accommodation requests, training, recordkeeping, publication, policy registration and grievance handling. Her details shall appear in the published policy and be displayed and circulated internally. The Company shall provide a functioning, monitored email account and accessible ways to contact her.
3.2 The Board of Directors shall ensure implementation and resources. The director who has ultimate management and control of the relevant establishment is the "Head of Establishment" for this policy. The Board shall record that responsibility in its internal authorisation records. Managers shall implement approved accommodations and promptly refer requests or concerns to the Liaison Officer.
3.3 If the Liaison Officer is absent, involved in a complaint or otherwise conflicted, the Head of Establishment shall immediately appoint an unconflicted substitute in writing and communicate the contact details to affected persons. Complaints involving the Head shall be handled by unconflicted directors or an independent person appointed by them. Anya’s simultaneous role under Part B does not merge the two statutory frameworks or their timelines.
4 Equal treatment and protection from retaliation
4.1 No person shall be rejected, harassed, segregated, denied access or disadvantaged because of disability, an accommodation request or a good-faith complaint. Harassment, derogatory language, disclosure of disability information without authority, inaccessible practices and retaliation are prohibited.
4.2 Decisions shall be based on the essential functions of the role and the individual’s ability to perform them with reasonable accommodation. Stereotypes, assumed incapacity or a blanket medical-fitness condition shall not replace individual assessment. The Head of Establishment shall prevent misuse of the legitimate-aim exception in section 3(3); any restriction must satisfy the applicable legal test and be supported by recorded reasons.
4.3 An acquired disability shall not result in termination, reduction of rank or pay, or a forced resignation on account of the disability. The Company shall conduct an individual job-fit assessment within sixty calendar days of becoming aware of the acquired disability, provide reasonable accommodation for continuation in the same role and, if continuation is not possible, explore suitable alternatives at the same pay. Pending a suitable role, it shall retain the employee on a supernumerary basis to the extent required by binding directions in force. Decisions shall be made in consultation with the employee, consistently with applicable law, without using disability as a pretext for adverse treatment.
4.4 Where an employee acquires disability in the course of employment, the Company shall meet the reasonable medical expenses, including hospitalisation, surgery, rehabilitation and ongoing treatment, required by applicable law and binding directions, whether or not insurance covers those expenses. Insurance arrangements shall not displace the Company’s own legal obligations or any binding commitment it has made.
5 Suitable roles and accessible recruitment
5.1 The Company identifies the following functions as capable of being performed by persons with disabilities with appropriate accommodation: software engineering and quality assurance; artificial intelligence, machine learning and data work; product management, design and research; legal research and content work; sales, customer support and business operations; and finance, human resources and administration. This is an inclusive list of functions, not a reservation of vacancies, a representation that each function currently has a vacancy, or a closed list excluding any person or disability category.
5.2 Each vacancy shall be assessed by its actual essential functions. Other roles shall be considered on the same individual basis. The Liaison Officer shall maintain and periodically update the list of suitable roles with managers, taking account of technology, workplace arrangements and available accommodations.
5.3 Vacancy notices, applications, interviews, tests and onboarding shall be accessible. Applicants shall be told how to request accommodation, including accessible formats, alternative communication, assistive technology, an accessible venue, remote participation, interpreters or additional assessment time where appropriate. Selection criteria and medical checks shall be relevant and proportionate to the work. Disability disclosure shall be voluntary except where specific law or a necessary, proportionate assessment requires limited information.
6 Facilities amenities and accessibility
6.1 The Company shall provide and maintain the facilities and amenities necessary for persons with disabilities to work effectively. These include accessible entry and movement routes, lifts or other compliant access between floors where required, accessible toilets, suitable workstations and seating, clear signage, adequate lighting, accessible meeting and common areas, and accessible parking where applicable. Accessible toilets and routes shall remain usable and unobstructed.
6.2 The Company shall provide suitable assistive devices, accessible software and hardware, screen-reader and keyboard access, magnification, speech input, captions, transcripts, communication assistance, ergonomic equipment and accessible documents, according to assessed need. Employees shall not bear the cost of an accommodation that the Company is required to provide.
6.3 The Company shall comply with applicable accessibility standards under sections 40 to 46 and Rule 15, including relevant notified standards for the built environment and information and communication technology, and binding Karnataka directions in force. It shall apply accessible design and testing to its websites, recruitment systems, employee tools and customer-facing products and services. WCAG 2.1 Level AA shall be the Company’s minimum web-accessibility design benchmark, together with any more stringent applicable requirement.
6.4 The Liaison Officer shall coordinate an initial and thereafter annual accessibility assessment of premises and relevant digital services, using qualified assistance where necessary. For shared premises, she shall obtain the operator’s accessibility information and coordinate the necessary audits and corrections. Gaps shall be recorded with responsible owners and completion dates within applicable legal deadlines. Immediate interim access arrangements shall be provided without treating them as a substitute for mandatory permanent compliance.
6.5 Individual emergency evacuation arrangements shall be agreed where needed, including accessible alarms, communication, assistance and safe exits. Staff responsible for emergency response shall be trained. Personal assistance or a support person shall be facilitated where reasonably required, with appropriate privacy and safety arrangements.
7 Requesting and deciding accommodation
7.1 A person may contact Anya Batra at anya@jhana.ai, their manager or the Head of Establishment by email, orally, in writing or through an authorised representative or accessible communication method. No prescribed form is mandatory. A request should identify the barrier and assistance sought; the Company shall help record it where necessary. Managers shall forward requests promptly, and the Company shall act on an apparent access need even without a formal request.
7.2 The Liaison Officer shall acknowledge a request within two working days, discuss effective options with the person and manager, and arrange urgent interim assistance immediately where needed. Only information reasonably necessary to assess the functional limitation or adjustment may be requested, with confidentiality safeguards. Unnecessary medical history, repeated certification or disclosure to unrelated persons shall not be required.
7.3 The Head of Establishment shall ensure a reasoned written response within thirty calendar days of receipt, or sooner where urgency or applicable law requires. An approval shall identify the accommodation, responsible person, implementation date and review arrangements. Procurement or third-party delay shall not justify silence or postponement of necessary interim measures.
7.4 A refusal or alternative proposal must record the individual assessment, effective alternatives explored and any demonstrated disproportionate or undue burden, applying the legal test and available resources and support. General cost assertions or a standard policy are insufficient. The person may seek prompt reconsideration by an unconflicted director and use the grievance procedure or external remedies. Accommodations shall be reviewed with the person when needs, work or technology change.
8 Training career progression and other facilities
8.1 Induction, post-recruitment and pre-promotion training, learning materials, examinations, meetings and performance systems shall be accessible. Managers shall assess performance with the approved accommodations in place. Disability or use of accommodation shall not itself prevent promotion, pay progression, development or access to benefits.
8.2 In transfer, posting and business travel decisions, the Company shall give preference to arrangements meeting disability-related needs, including accessible premises, proximity to treatment and support, and the individual’s stated location preference, subject to a lawful, individually assessed operational justification. Remote or hybrid work, flexible hours and adjustment of non-essential duties shall be considered where effective.
8.3 Applicable statutory and contractual leave shall be available without discrimination. The Company shall consider additional disability-related special leave, rehabilitation or treatment time and flexible attendance as reasonable accommodation, recording the duration and pay treatment and preserving any greater legal entitlement. Accommodation requests shall not be rejected solely because ordinary leave is exhausted.
8.4 If the Company provides or allots residential accommodation, it shall give preference to accessible accommodation suitable to the person’s needs and shall assess necessary adjustments. Where it provides no residential accommodation, this policy does not create a general housing benefit.
8.5 At least annually, the Company shall conduct disability awareness and accessibility training for personnel, with additional training for recruiting managers, IT and facilities staff and the Liaison Officer. Training shall address respectful communication, invisible disabilities, accommodation, confidentiality, emergency assistance and grievance handling.
9 Complaints inquiry and corrective action
9.1 Any employee, applicant, visitor, customer or other affected person may complain of disability discrimination, denial of accommodation, inaccessibility or retaliation to the Liaison Officer at anya@jhana.ai, or directly to the Head of Establishment or any unconflicted director. Email and offline complaints are accepted; assistance and accessible formats shall be provided. A representative may assist. Anonymous information shall be assessed to the extent it permits action. No internal filing deadline removes a statutory remedy.
9.2 The Liaison Officer or substitute shall acknowledge every complaint within forty-eight hours of receipt and give it a unique reference number. She shall conduct an initial inquiry or inspection within fifteen calendar days, preserve relevant evidence and provide appropriate interim protection. Parties shall have a fair opportunity to give their account and respond to material allegations, with accessible communication and an impartial decision-maker.
9.3 For a substantiated complaint, the Head of Establishment shall issue a reasoned corrective direction within thirty calendar days of original receipt, identifying the action, owner and deadline. The outcome shall be communicated to the affected person, subject to lawful confidentiality limits. The Liaison Officer shall verify implementation within sixty calendar days of original receipt. Pending action shall be escalated to the Board and the competent District Accessibility Committee and thereafter the State Commissioner as required by applicable directions.
9.4 Remedies may include providing accommodation, removing access barriers, correcting an employment decision, restoring an opportunity, training, directions to a service provider and proportionate disciplinary action under applicable service rules and law. Lack of substantiation alone is not proof of bad faith. No person shall suffer retaliation for requesting access, making a good-faith complaint, assisting another person or participating in an inquiry.
9.5 Internal reconsideration may be sought from an unconflicted director, who shall provide a reasoned response promptly, ordinarily within fifteen calendar days. This does not suspend the preceding deadlines. Persons may approach the State Commissioner for Persons with Disabilities, the competent District Accessibility Committee or a court or other competent authority as permitted by law, without being required to exhaust this process. External remedies remain available at all times.
10 Confidentiality records and inspection
10.1 Disability and health information shall be collected for a specific lawful purpose, kept securely with access limited to those who need it, and handled under applicable privacy and data-protection law. Managers ordinarily need to know the functional adjustment rather than the diagnosis. Disclosure shall be limited to informed consent, a lawful requirement or another lawful and necessary basis, with appropriate safeguards.
10.2 The Company shall maintain records of persons with disabilities employed, their work and periods of employment, facilities and amenities provided, requests and decisions, grievances and corrective action, training and accessibility reviews, to the extent required by section 22 and Rule 9 and, additionally, as necessary to administer this policy. Records shall distinguish voluntary disclosure from mandatory information; avoid unnecessary medical details; and be retained only for the applicable legal or documented operational period, subject to preservation for pending proceedings.
10.3 The Company shall permit inspection by duly authorised authorities and provide information lawfully required by them. Privacy controls shall not be used to obstruct statutory inspection. Registration, publication and other compliance evidence shall be maintained separately from confidential medical and complaint records.
11 Publication registration and review
11.1 The Company shall publish this dedicated policy on its website in an accessible format and display it, including the Liaison Officer’s name and contact details, conspicuously at its workplaces and through accessible internal channels. An accessible copy shall be supplied on request. Employees shall receive the policy on induction and be informed of material changes.
11.2 Under section 21(2), the Company shall register a copy of its disability equal opportunity policy with the competent Commissioner. For its Bengaluru establishment it shall submit this document, including the complete Part A and the common adoption and appointment record, to the Karnataka State Commissioner for Persons with Disabilities for registration under the RPWD Act. It shall comply with the authority’s current filing requirements, provide a separately identifiable Part A extract if required, and obtain and retain acknowledgement and registration confirmation. Any further filing required for an establishment in another State or by a competent authority shall also be completed. RPWD registration does not constitute registration or approval under the TP Act.
11.3 The Liaison Officer shall maintain the submitted version, covering correspondence, filing evidence, acknowledgement or registration particulars and subsequent updates. Submission and completed registration shall be recorded distinctly; no registration number shall be represented as issued before it is received. The Company shall provide this evidence for its applicable contractual compliance obligations.
11.4 The Company shall review this policy at least annually and promptly on a change in law, binding directions, workforce, premises or access needs. The Liaison Officer shall consult affected persons where appropriate and report implementation and outstanding gaps to the Board. Officer details shall be updated promptly in the published policy and communicated to the registering authority where required. The Board shall ensure timely implementation of all applicable accessibility and filing obligations.
Part B Equal opportunity for transgender persons
1 Purpose legal framework and coverage
1.1 Jhana Labs Private Limited (the "Company") prohibits discrimination against transgender persons and shall provide a safe, respectful and inclusive working environment. This policy implements the Transgender Persons (Protection of Rights) Act, 2019, as amended from time to time (the "TP Act"), including sections 3 and 9 to 11, and the Transgender Persons (Protection of Rights) Rules, 2020, as amended (the "TP Rules"), particularly Rules 12 and 13, together with applicable State rules and binding directions.
1.2 This policy applies regardless of workforce size or whether any person has disclosed a transgender identity. It covers applicants, employees, directors, officers, interns, trainees, consultants, contractors and agency personnel, as appropriate to their relationship with the Company, and conduct by customers, vendors, visitors and other business contacts. It applies at Company premises, remote and hybrid workplaces, digital communications, client sites, business travel, meetings and work-related events.
1.3 The statutory term "transgender person" has the meaning in the TP Act as in force. As a separate Company commitment, the protections in this policy extend to persons of all gender identities and expressions, including trans men, trans women, non-binary and gender-diverse persons and persons with intersex variations. This broader internal coverage does not change the statutory definition or determine eligibility for any statutory certificate, scheme or external remedy.
1.4 No person must obtain or disclose a transgender identity certificate, undergo medical intervention, or provide medical history to use the Company’s internal equality, facilities or complaint process. If a specific legal or statutory-benefit process requires a document, the Company shall request only what that process lawfully requires and explain the purpose. Mandatory law prevails over an inconsistent provision of this policy.
2 Equal employment and service conditions
2.1 The Company shall provide equal access to recruitment, selection, onboarding, work allocation, remuneration, benefits, training, appraisal, promotion, transfer, posting, retention and separation. Decisions shall be based on relevant qualifications, skills and essential job requirements. Gender identity or expression, transition, perceived identity, documentation differences or a complaint shall not be used as a pretext for adverse treatment.
2.2 All Company rules, service conditions and benefits shall apply to transgender employees on equal terms with other employees, subject to any mandatory statutory eligibility conditions. Administrative systems, dress requirements and facilities shall be administered without discriminatory exclusion. Any necessary distinction must have a lawful basis; convenience or prejudice is insufficient.
2.3 Recruiting teams shall use inclusive notices, forms and interviews and permit a private method of disclosing support needs. Personnel shall use the individual’s communicated name, pronouns and respectful form of address in ordinary workplace communications. Payroll, tax, insurance and other statutory records shall use particulars legally required for those records; differences shall be handled privately and shall not delay equal treatment unnecessarily.
2.4 Harassment, bullying, deliberate and repeated disrespect of communicated gender identity, derogatory remarks, intrusive questions about anatomy or treatment, unauthorised disclosure of identity, threats, exclusion and retaliation are prohibited. A person shall not be forced to conceal identity, undergo treatment, resign or accept inferior work because of gender identity. The Company shall take appropriate action concerning third parties as well as its own personnel.
3 Facilities safety and amenities
3.1 The Company shall provide safe, dignified and non-discriminatory access to toilets, washing and other workplace facilities. It shall provide a private unisex or gender-neutral toilet facility and coordinate the required arrangements with the landlord or coworking operator at shared premises. No employee shall be compelled to use a segregated facility or be denied access solely because of gender identity.
3.2 The Company shall provide appropriate hygiene products and disposal arrangements, clean and private facilities and necessary amenities enabling transgender persons to perform their duties effectively. Changing or rest facilities, where provided, shall have appropriate privacy and equal access. Facilities shall also be accessible to transgender persons with disabilities, with accommodation coordinated under Part A.
3.3 The Company shall implement workplace safety and security measures suited to its premises and work arrangements, including trained security personnel or coordination with the premises operator, safe entry and exit, and safe transportation arrangements where required by law or reasonably needed for work-related safety. Company-arranged transport and security services shall operate without discriminatory refusal, harassment or forced disclosure of identity.
3.4 An individual may request privacy, flexible arrangements, reasonable changes to work or facilities, time for necessary appointments, or other support by contacting the Complaint Officer or a manager. The Company shall assess the need promptly and sensitively, preserve applicable leave and benefit entitlements and provide immediate interim protection where safety requires. It shall record the action, responsible owner and completion date and check whether the arrangement is effective.
3.5 Managers shall report facility or safety gaps promptly to the Complaint Officer and Head of Establishment. The Company shall fund and implement necessary corrections, coordinate with premises and service providers and communicate effective interim arrangements.
4 Confidentiality and personnel information
4.1 Gender identity, previous names, transition-related information and medical or identity documents shall be handled confidentially. Information shall be collected only for a specific lawful and necessary purpose, with access restricted to authorised persons who need it. Gender identity shall not be disclosed to colleagues, clients, vendors, family members or the public without the person’s informed consent, except where a lawful requirement or other lawful and necessary basis permits disclosure.
4.2 The Company shall explain any mandatory documentation requirement, permit confidential submission and update relevant records promptly on receipt of legally sufficient information. Where the Company is the issuing authority for an official document covered by the TP Rules, it shall make the applicable name, gender or photograph changes within fifteen calendar days of a legally sufficient application, or any shorter mandatory period. Ordinary workplace directories and communications shall use the person’s communicated name consistently, while legally required records are maintained accurately and privately. Historic information shall not remain generally visible merely because it exists in an internal system.
4.3 Records shall be secured under applicable privacy and data-protection law, retained only for a legally required or documented necessary period and protected from unauthorised access. Complaint records shall be held separately with restricted access. Necessary disclosure for a fair inquiry or lawful authority shall be limited in scope; the Company shall not promise absolute secrecy that prevents due process or compliance with law.
5 Complaint officer and responsibility
5.1 The Company designates Anya Batra, email anya@jhana.ai, as the "Complaint Officer" under section 11 of the TP Act. She shall receive and inquire into complaints concerning violations of the TP Act and this policy, coordinate interim support and facility corrections, maintain records and report to the Head of Establishment. Her name and contact details shall form part of the published policy and be displayed at the workplace.
5.2 The director having ultimate management and control of the relevant establishment is the "Head of Establishment" for this policy; the Board shall record that responsibility in its internal authorisation records. The Head shall ensure a timely, fair inquiry and act on the Complaint Officer’s report. The Board shall provide necessary resources, training and access to decision-makers.
5.3 Where Anya is absent, the complaint concerns her or another conflict exists, the Head shall immediately designate an unconflicted substitute in writing and communicate the person’s details. A complaint against the Head shall be referred to unconflicted directors, who shall arrange independent handling. The fifteen-day inquiry and action deadlines continue to apply. Anya also serves as disability Liaison Officer under Part A, but each complaint shall follow every applicable legal process.
6 Making a complaint and immediate support
6.1 Any affected person may complain to Anya Batra at anya@jhana.ai or to the Head of Establishment or any unconflicted director. Complaints may be oral, written, emailed or made through an accessible method or an authorised representative. Assistance shall be provided to record an oral complaint. No prescribed form, legal language or medical or identity certificate is required to initiate the Company’s process.
6.2 A complaint should, where available, identify the conduct, persons involved, dates, supporting material, preferred contact method and assistance sought. Missing details do not justify refusal to receive a complaint. Anonymous information shall be assessed to the extent practicable. A person may complain without disclosing their identity more widely than is necessary for handling the matter. No internal filing deadline restricts a statutory remedy.
6.3 The Complaint Officer shall acknowledge receipt promptly, ordinarily within two working days, assign a reference number, explain the procedure and assess immediate safety, confidentiality and support needs. Interim measures may include protection from contact, changes requested by the affected person, preservation of evidence, access to a safe facility or other necessary support. Measures shall not punish the complainant or prejudge the outcome.
7 Inquiry findings and action
7.1 In accordance with Rule 13(2), the Complaint Officer shall inquire into a complaint and submit the inquiry report to the Head of Establishment within fifteen calendar days of receipt. She shall act impartially, hear the affected persons, give the respondent a fair opportunity to answer material allegations, obtain relevant evidence and record findings and proposed corrective steps. Assistance, an interpreter, accessible communication or a support person shall be permitted where appropriate, consistently with fairness and confidentiality.
7.2 The report shall identify the issues, relevant evidence, findings and reasons and the action proposed. The parties shall be informed of the outcome and reasons to the extent permitted by law and third-party privacy. The process shall not require withdrawal, forced conciliation or an agreement to waive legal rights.
7.3 Under Rule 13(3), the Head of Establishment shall take action on the report within fifteen calendar days of its submission. Action shall include appropriate corrective measures, the responsible person, implementation deadline and communication of the outcome. Where a deadline has been missed, the Head shall act forthwith under Rule 13(4), record the reason for delay and notify unconflicted directors; delay does not extinguish the complaint or extend a legal deadline.
7.4 Action may include stopping the conduct, restoring access or an employment opportunity, correcting records, providing facilities or support, training, directions to contractors and disciplinary action in accordance with applicable service rules and law, up to termination where warranted. A respondent shall receive the procedural protections required for disciplinary action. An unproved allegation or inability to supply sufficient evidence does not by itself establish malice.
7.5 Retaliation against a complainant, witness, representative, person requesting support or person assisting an inquiry is prohibited and shall be addressed promptly. This includes threats, disclosure of identity, adverse work allocation, exclusion, unjustified transfer and pressure to resign. The Complaint Officer shall check implementation and any risk of continuing retaliation.
8 Other legal processes and external remedies
8.1 Where conduct also falls within the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, the Company shall facilitate referral to its Internal Committee or the competent Local Committee as required by that law. The Complaint Officer shall coordinate applicable TP Act duties and immediate protection without replacing the statutory sexual-harassment inquiry. Applicable timelines, confidentiality and rights under each framework shall be preserved.
8.2 Internal handling does not prevent a person approaching the police, a competent court, government grievance mechanism, helpline, outreach centre, Transgender Protection Cell or another competent authority under applicable law. In the absence of another prescribed forum for an objection to the Head of Establishment’s decision under Rule 13(3), the person may approach the relevant State Human Rights Commission in accordance with the Supreme Court’s applicable directions. Assistance shall be provided where requested. No person must exhaust the internal process, accept confidentiality terms waiving rights or obtain Company permission to use an external remedy.
8.3 A party may seek internal review by an unconflicted director. The director shall respond promptly, ordinarily within fifteen calendar days, without suspending the inquiry or action deadlines or external remedies. Requests concerning disability-related barriers shall also be handled under Part A and its applicable safeguards.
9 Training records publication and review
9.1 The Company shall communicate this policy at induction, conduct awareness and sensitisation programmes at least annually, and train recruiting managers, supervisors, the Complaint Officer, HR, security and relevant service-provider personnel. Training shall cover non-discrimination, respectful conduct, facilities, confidentiality, reporting and non-retaliation.
9.2 The Complaint Officer shall maintain a confidential register of complaints, receipt dates, inquiry reports, action dates, outcomes and implementation; retain evidence of appointment, publication and training; and report implementation and unresolved gaps to the Board. Records and information lawfully required by a competent authority shall be provided, including information for statutory monitoring, with appropriate privacy safeguards. Identifiable case details shall not be included in general awareness reports.
9.3 The Company shall publish this policy, including Anya Batra’s name and contact email, on its website in an accessible format, display it conspicuously at its workplaces and circulate it internally. Updated versions and officer changes shall be communicated promptly. An accessible copy shall be available on request.
9.4 The Board shall review the policy and implementation at least annually and promptly after a legal change, binding direction, significant complaint or change in facilities or personnel. Changes shall preserve mandatory rights and any more favourable lawful benefits. The review shall verify the provision of facilities, complaint handling, publication and completion of corrective action.
Common contact and access arrangements
Disability Liaison Officer and transgender Complaint Officer: Anya Batra. Email for both roles: anya@jhana.ai. Corporate office: WeWork Galaxy, 43, Residency Road, Bengaluru, Karnataka 560025. The Company shall maintain a functioning, monitored account and accessible methods of contact, and display these particulars in the published policy and at its workplaces.
A request or complaint may be emailed or made orally, in writing, through an authorised representative or another accessible method. The Company shall assist anyone who needs help recording it. Relevant dates, the barrier or event, persons involved, the assistance or outcome sought and the preferred contact method will assist handling, but no prescribed form or unnecessary identity or medical document is a prerequisite. No fee is payable to the Company.
Confidential offline correspondence may be delivered to the corporate office or addressed to the Board at the Company’s current registered office, whose address shall be maintained on the Company’s website and in its internal directory. A complaint involving Anya may be sent directly to the Head of Establishment or an unconflicted director as provided in the relevant Part. Current external authority contact details shall be maintained in an accessible directory.