Star’s quest for competitive excellence consists of our commitment to lawful and ethical conduct and adhering to corporate governance philosophy. Integrity, honesty and respect for people remain some of our key values at work.

We are committed to provide a safe and conducive work environment to all our employees. Towards this end it is essential that each employee deals with their women colleagues and third parties with full fairness and respect and realizes that their behavior will be attributed to the Company and can affect its inward and outward reputation.

Every female employee has the right to be protected against sexual harassment, regardless of whether the respondent considers their own behavior to be normal or acceptable and whether the aggrieved woman had the opportunity to avoid the sexual harassment.

Star is committed to providing a safe working environment to its women employees free of sexual harassment. Sexual harassment is a form of workplace harassment of any unwelcome acts of a sexual nature that affects the dignity of women at work.

The Star Prevention of Sexual Harassment Policy for women at workplace is formulated pursuant to the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (“ Act”) and the Rules thereunder which came into effect from December 09, 2013. This policy has been formed to prohibit, prevent or/and deter the commission of acts of sexual harassment at workplace and to provide the procedure for redressal of complaints pertaining to sexual harassment.

No person shall indulge or cause to be indulged under instructions from superior or otherwise in sexual harassment of women at workplace.

With a view to promote the well-being of all women employees at the work place the following code of conduct is prescribed in relation to Sexual Harassment:

This Policy applies to all persons employed at Star India, its subsidiaries and affiliates in India (hereinafter collectively referred to as “Star” or the “Company”) for any work on regular, temporary, ad hoc or daily wages, enter directly or through an agent, including a contractor, with or without the knowledge of the Company whether for remuneration or not whether the terms of employment are express or implied and includes co-workers, a contract worker, probationer, trainee, apprentice or called by any other such name.

What is Sexual Harassment?

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

(a) physical contacts and advances. For e.g., unwelcome grabbing or deliberately touching or brushing against any part of the body of another person and the like; or

(b) a demand or request for sexual favours. For e.g., forcing a subordinate to provide sexual favours by promising promotion, pay increases or an easier work life; or

(c) making sexually coloured remarks For e.g., questioning about anyone’s sex life, making sexual innuendos or gender based sexist remarks or jokes which are sexually coloured; or

(d) showing pornography. For e.g., displaying of pornographic pictures, cartoons or sayings in the workplace; or

(e) any other unwelcome physical, verbal or non-verbal conduct of sexual nature (whether by words, gestures or actions). Some examples are, forcing a woman to drink or dance against her wishes, sharing or emailing sexist jokes or making sexist remarks.

The act or conduct must be ‘unwelcome’ and of a sexual nature in order to constitute sexual harassment. It is the impact and effect the conduct has on the woman that will define the behavior as sexual harassment.

2. The following circumstances, among other circumstances, if it occurs or in present in relation to or connected with any act or behavior of sexual harassment may amount to sexual harassment:

(a) implied or explicit promise of preferential treatment in her employment; or

(b) implied or explicit threat of detrimental treatment in her employment; or

(c) implied or explicit threat about her present or future employment status; or

(d) interference with her work or creating an intimidating or offensive or hostile work environment for her; or

(e) humiliating treatment like to affect her health or safety.

3. Sexual harassment of women is also a criminal offence.

4. Sexual harassment of women is not only physically abusive but also emotionally abusive and creates an unhealthy, unproductive atmosphere at the workplace.

“Workplace” includes the company premises and any other place visited by the employee arising out of or during the course of employment. This includes company offsite, office meetings held outside the office premises whether in a hotel, restaurant or at an employee’s residence or any other place. A restaurant where an employee stops by for a meal during the course of visiting or returning from a business meeting outside the office would be deemed to be a workplace.

The Internal Complaints Committee

Pursuant to and in compliance with the provisions of the Act, an Internal Complaints Committee has been constituted to address and prevent all sexual harassment complaints. The Internal Complaints Committee (“Internal Committee”) comprises of the following members-

Dealing with a Complaint

1. It is the obligation of all employees to report sexual harassment experienced by them personally. Anonymous complaints will not be entertained.

2. Once the complaint is received, it will be kept strictly confidential.

3. The person accused (“respondent”) will be informed that a complaint has been filed against him/her and no unfair acts of retaliation or unethical action will be tolerated.

4. The Internal Committee shall ensure that a fair and just investigation is undertaken immediately.

Process of filing Complaints

1. Any aggrieved woman employee may file a written complaint before the Internal Committee addressing it to the Presiding Officer within a period of 3 (three) months from the date of the incident and in case of a series of incidents within a period of 3 (three) months from the date of the last incident. The complaint can be filed using any of the following modes of communication:

a) By electronic communication, by sending an e-mail to any of the members of the Internal Committee.

b) By regular mail, by addressing the complaint to any of the Internal Committee members at Star India Private Limited, Star House, Urmi Estate, 95 Ganpatrao Kadam Marg, Lower Parel (West), Mumbai 400013.

c) By registering a complaint with the immediate manager. The immediate manager will submit the complaint to the Internal Committee and accordingly apprise the aggrieved woman.

2. Where the aggrieved woman cannot make the complaint in writing, any member of the Internal Committee shall render reasonable assistance to the woman for making such complaint in writing;

3. Where the aggrieved woman is unable to make a complaint on account of her physical incapacity or for any other reason is unable to make a complaint, such complaint may be filed by any person being her relative, friend or co-worker who has knowledge of the incident, with her written consent;

4. The complaint shall contain the name of the accused/respondent and details of the incident preferably including date, time and place of the occurrence.

5. The aggrieved women employee may, in addition to the above, seek legal remedies, as may be provided under the various laws for the time being in force.

All persons who receive such complaint shall maintain absolute confidentiality and forward the same to the Internal Committee to take action as enumerated hereunder.

Conciliation:

a) The Internal Committee, may, before initiating an inquiry, at the request of the aggrieved woman take steps to settle the matter between her and the respondent through conciliation provided that no monetary settlement shall be made as a basis of conciliation.

b) Where a settlement has been arrived, the Internal Committee shall record the settlement so arrived and forward the same to STAR’s Management, comprising the CEO, COO and CFO.

c) The Internal Committee shall provide the copies of the settlement as recorded to the aggrieved woman and the respondent.

d) If any of the terms or conditions of the settlement is not complied with by the respondent then the Internal Committee shall proceed to make an inquiry into the complaint.

Pendency of inquiry

The Internal Committee during the pendency of the inquiry, on a written request made by the aggrieved woman, may recommend to the STAR Management (employer), which shall be implemented by them to:

a) Transfer the aggrieved woman or the respondent to any other workplace; or

b) Grant leave to the aggrieved woman up to a period of three months; or

c) Grant such other relief to the aggrieved woman as may be prescribed.

The leave granted to the aggrieved woman shall be in addition to the leave she would be otherwise entitled.

d) Restrain the respondent from reporting on the work performance of the aggrieved woman or

writing her confidential report, and assign the same to another officer/Manager.

The Internal Committee shall provide a report of its findings to the STAR Management within 10 days from the date of completion of the inquiry.

Criminal Proceedings:

Where any conduct of sexual harassment amounts to a specific offence under the Indian Penal Code or under any other applicable law, the Internal Committee shall, if the aggrieved woman so desires or chooses, assist in or initiate appropriate action in accordance with law including filing/registering a complaint with the appropriate authority.

Disciplinary Action

Where any misconduct on account of sexual harassment is found by the Internal Committee, pursuant to an enquiry, appropriate disciplinary action shall be taken against the accused/respondent as per the prescribed procedure for STAR. Disciplinary action may include transfer, withholding promotion, suspension or even dismissal. This action shall be in addition to any legal recourse sought by the complainant.

Third Party harassment:

Where sexual harassment occurs with a STAR employee as a result of an act by a third party or outsider, while on official duty, wherever they may be (whether within or outside STAR premises), we will take all steps necessary and reasonable to assist the affected STAR employee in terms of support and preventive action.

Confidentiality

All information received shall be kept strictly confidential. All persons including the respondent, witnesses and members of the Internal Committee shall maintain strict confidentiality. Any person (including witnesses) who breach the confidentiality shall be subject to disciplinary action.

Protection against retaliation

Regardless of the outcome of the complaint that is made in good faith, the employee who is lodging the complaint and any person providing information or any witness, will be protected from any form of retaliation. While dealing with complaints of sexual harassment, the Internal Committee shall ensure that the complainant or the witness are not victimized or discriminated against by the accused. Any unwarranted pressures, retaliatory or any other type of unethical behaviour by the accused/perpetrator against the complainant while the investigation is in progress should be immediately reported by the complainant to the Internal Committee. Disciplinary action will be taken by the Internal Committee against any such complaints which are found genuine.

Documentation