Version: September 2026

Policy on Prevention of Sexual Harassment (PoSH) in the Workplace (India)

Introduction

This policy on Prevention of Sexual Harassment (PoSH) in the Workplace (“Policy”) has been framed in accordance with the provisions of “The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013” and rules framed thereunder (hereinafter “the Act”). Accordingly, while the Policy covers all the key aspects of the Act, it widens the policy to apply to all employees, or visitors to Cielo offices, regardless of gender. For any further clarification reference shall always be made to the Act, and the provisions of the Act shall prevail.

At Cielo Talent India Private Limited (“Cielo”), we recognize that our differences make us stronger, and that our success is driven by the diverse background, thoughts and experience of our people. We are committed to being an organization that encourages our employees to be their authentic self and supports their ambition in being and becoming their best self in an environment that is inclusive and equitable. We do not tolerate any form of harassment or discrimination.

This Policy intends to provide protection against sexual harassment of people in the Workplace and the prevention and redressal of complaints of sexual harassment and matters related to it. This Policy confirms the specific and express commitment of Cielo’s to promote a Workplace free of sexual harassment towards anyone in Cielo’s Workplace, promote gender-safe spaces and remove underlying factors that contribute to a hostile work environment. Sexual harassment at the Workplace is unlawful and amounts to misconduct under the law in India.

Cielo has zero tolerance for any form of sexual harassment in the Workplace. When a formal complaint is brought forward, we will promptly take appropriate steps to investigate and deal with concerns that have been raised.

You may download the full policy here.

Internal committee

1. Presiding Officer
Aditi Bhatnagar, Talent Management Business Partner
+91 9644405802

2. Member 1
Anam Wilayat, Manager – Brand & Digital
+91 8795192571

3. Member 2
Anjali Yadav, Global Benefits Specialist
+91 9971145585

4. Member 3
Renu Choudhary, Manager – Financial Shared Services
+91 8700398007

5. Member 4
Bhavya Dave, Manager – Client Operations
+91 9717427776

6. Member 5
Ravi Nandrajog, Senior Recruiter
+91 9999770263

7. External Member
Dr. Aparna Sethi, Director
+91 9900592229

Full policy

Please refer to Cielo India PoSH policy for understanding policy & procedure, which you can download here.