DAZN is committed to a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that romotes equal employment opportunities and prohibits discriminatory practices, including harassment. The company will not tolerate any form of harassment and is committed to take all necessary steps to ensure that its employees are not subjected to any form of harassment. Therefore, Dazn expects that all relationships among persons in the workplace will be business-like and free of bias, prejudice and harassment.

Scope, Individuals and Conduct Covered

This policy applies to all employees (full-time, part-time, trainees and those on contractual assignments) of the Company including all subsidiaries and affiliated companies at their workplace or at client sites. The Company will not tolerate sexual harassment, if engaged in by clients or by suppliers or any other business associates.

The workplace includes:

1. All offices or other premises where the Company’s business is conducted.
2. All company-related activities performed at any other site away from the Company’s premises.
3. Any social, business or other functions where the conduct or comments may have an adverse impact on the workplace or workplace relations.

Definitions of Harassment

• Sexual harassment constitutes discrimination and is illegal under local law. For the purposes of this policy, sexual harassment is defined, as in the Equal Employment Opportunity Commission Guidelines, as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when, for example:
  • submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment
  • submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or
  • such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile or offensive working environment.

Sexual harassment may include a range of subtle and not so subtle behaviours and may involve individuals of the same or different gender. Depending on the circumstances, these behaviours may include, but are not limited to:

• unwanted sexual advances or requests for sexual favours;
• sexual jokes and innuendo;
• verbal abuse of a sexual nature;
• commentary about an individual's body, sexual prowess or sexual deficiencies;
• leering, catcalls or touching;
• insulting with obscene comments or gestures;
• display or circulation in the workplace of sexually suggestive objects or pictures (including through e-mail/WhatsApp/SMS);
• and other physical, verbal or visual conduct of a sexual nature

Sex-based harassment, that is, harassment not involving sexual activity or language (e.g., male manager yells only at female employees and not males) may also constitute discrimination if it is severe or pervasive and directed at employees because of their sex.

• Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal or physical conduct that denigrates or shows hostility or aversion toward an individual because of his/her race, color, religion, national origin, age, disability, citizenship status, marital status, creed, or any other characteristic protected by law or that of his/her relatives, friends or associates, and that:
  • has the purpose or effect of creating an intimidating, hostile or offensive work environment;
  • has the purpose or effect of unreasonably interfering with an individual's work performance; or
  • otherwise adversely affects an individual's employment opportunities.

Harassing conduct includes, but is not limited to: nicknames, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes and display or circulation in the workplace of written or graphic material that denigrates or shows hostility or aversion toward an individual or group (including through e-mail).

Retaliation is prohibited

Dazn prohibits retaliation against any individual who reports discrimination or harassment or participates in an investigation of such reports. Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of a claim of harassment or discrimination is a serious violation of this policy and, like harassment or discrimination itself, will be subject to disciplinary action.

Internal Complaints Committee

The law states that an organization that has 10 or more employees, must constitute an Internal Complaints committee (“ICC”) to receive and redress complaints on sexual harassment at workplace. An ICC, as the name suggests, is an internal complaints committee of a workplace to receive and redress complaints of sexual harassment. It is required to consist of a minimum of four members:

The company shall, from time to time, establish an Internal Complaints Committee (ICC) to deal with sexual harassment issues. The committee shall consist of

• A presiding officer who shall be a woman, holding a senior position in the company
• Two Vice Chair Persons, One male and one female
• An external member, preferably from an NGO or an Association who works to safeguard women from sexual harassment in the country
• The law also states that at least half of the total Members of the IC should be women

The term of office of the above said members, if unless otherwise specified, shall be for a period of three years and after the expiry of the said period, the company shall reconstitute the committee.

The Committee members will be appointed in consultation with Head of HR and will be notified widely with their contact numbers and email IDs.

Primary responsibilities of the committee shall be:

i. To ensure and supervise proper functioning of the committee
ii. To organize regular workshops and training programs
iii. To formulate programs for the spread of awareness of the policy and awareness on anti-sexual harassment.
iv. To include the annual report of the committee in the Annual report of the company which is to be submitted to the board.
v. To submit the report to the district local body constituted for the purpose.

Complaint Procedure

Reporting an Incident of Harassment, Discrimination or Retaliation

Dazn strongly urges the reporting of all incidents of discrimination, harassment or retaliation, regardless of the offender's identity or position. Individuals who believe they have experienced conduct that they believe is contrary to Dazn ’s policy or who have concerns about such matters should file their complaints with the Internal Complaints Committee, before the conduct becomes severe or pervasive.

i. Early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment. Therefore, such complaint should be registered within 3 months of occurrence of any such incident. Dazn will make every effort to stop alleged harassment before it becomes severe or pervasive but can only do so with the cooperation of its staff/employees.
ii. Complaint may be oral or in writing, but any oral complaint must be followed up with written communication within two days of raising oral complaint.
iii. Immediately upon receipt of the complaint, not later than 4 working days, the chairperson shall convene a meeting of the committee. The committee shall ensure a quorum of at least 4 members when taking a decision or while conducting investigations.
iv. Complaint copy should be sent to the accused within seven days of its receipt, asking him/her to reply in 10 days.

The Investigation

Any reported allegations of harassment, discrimination or retaliation will be investigated promptly, thoroughly and impartially. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge.

Confidentiality will be maintained throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action. The investigatory process is to be completed in 90 days and has to be documented.

Responsive Action

Within 10 days of the completion of the enquiry, the report has to be submitted to the HR and the employer. Upon receipt of the complaint, Dazn shall take necessary action, as recommended by the report of ICC, within 60 days.

Misconduct constituting harassment, discrimination or retaliation will be dealt with promptly and appropriately.

Responsive action may include,

• referral to counselling,
• training,
• monitoring of the offender and/or disciplinary action such as warning, reprimand,
• withholding of a promotion or pay increase,
• reduction of wages,
• demotion,
• transfer,
• reassignment,
• temporary suspension without pay or
• termination, as Dazn believes appropriate under the circumstances.

Access to Reports and Documents

All records of complaints, including contents of meetings, results of investigations and other relevant material will be kept confidential by the Company except where disclosure is required under disciplinary or other remedial processes.

Protection of Complainant/Victim

The Company is committed to ensuring that no employee who brings forward a harassment concern is subject to any form of reprisal. Any reprisal will be subject to disciplinary action.

The Company will ensure that the victim or witnesses are not victimized or discriminated against while dealing with complaints of sexual harassment.

However, anyone who abuses the procedure (for example, by maliciously putting an allegation knowing it to be untrue) will be subject to disciplinary action

In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for appropriate disciplinary action by the Management. (For more details, refer to the pictorial representation of the process flow given in Annexure A)

Appeal Any person aggrieved by the recommendations made by ICC under this Policy or for nonimplementation of such recommendations may prefer an appeal to the court or tribunal constituted in accordance with the service rules applicable to the said person.

Such appeal shall be preferred within a period of ninety days of the recommendations by the ICC

Duties of the Employer

Dazn and its management or board or committee shall abide by the duties as enumerated in Section 19 of The Sexual Harassment of Women at Work place (Prevention, Prohibition and Redressal) Act, 2013 (in short “the said Act”).

Expectation from Employees

Employees are encouraged to familiarize themselves with each other with the key elements of the policy and should:

i. Abstain from committing any act which amount to sexual harassment at the workplace
ii. Report incidents of sexual harassment without fear or favour.
iii. Create an environment of conduciveness for co-workers to work together without fear of harassment.
iv. Get clarifications from HR whenever in doubt.
v. It is incumbent on all employees of APPL to follow this policy and the guidelines formulated herein. Sexual Harassment at the work place will be deemed to be a violation/breach of terms of employment, and a criminal offence in addition to violation of gender equality guaranteed under the Constitution.

ICC to submit annual report and Employer to include information in annual report

ICC shall in each calendar year prepare and submit an annual report to the Employer which shall have the following details:-

1. Number of complaints of sexual harassment received in the year.
2. Number of complaints disposed of during the year.
3. Number of cases pending for more than ninety days.
4. Number of workshops or awareness programme against sexual harassment carried out.
5. Number of action taken by employer.
6. The Employer shall include in its report the number of cases filed, if any, and their disposal under this Act in the annual report.

Conclusion

In conclusion, the Company reiterates its commitment to providing its employees, a workplace free from harassment/ discrimination and where every employee is treated with dignity and respect.

Individuals who have questions or concerns about these policies should talk with the Human Resources Department.