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Prevention of Sexual Harassment Guidelines
Dreamplug Technologies Private Ltd — for any concern, write to safe@circlebycred.club.

Objective

These guidelines apply to all Experts, Users, and CRED employees interacting through the Circle platform. Circle has a zero-tolerance policy toward sexual harassment. Every session on Circle, whether text, audio, or video, is a workplace interaction under these guidelines.

Key Definitions

Who is covered?
Experts (independent contractors on Circle), Circle Platform Users, and CRED Relationship Managers and employees. All are covered equally under these guidelines.
Dreamplug Technologies Private Ltd & its entities, including Circle, have an inclusive policy, and all employees, experts & members have an equal right to raise a complaint against harassment, sexual or otherwise, that they may be subjected to.
Any complaint of sexual harassment raised by a female employee, expert, or member will be addressed by the Internal Committee (IC) constituted under the aegis of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (SHWW(PPR) Act, 2013).
The same committee (IC) has been designated to address any complaint of sexual harassment raised by an employee, expert, or member other than a female.
The recommendations post an inquiry in such cases related to anyone other than females will be as per the company’s Disciplinary Code of Conduct.
What is sexual harassment?
Any unwelcome act or behaviour of a sexual nature, including:
  • Demand or request for sexual favours
  • Making sexually coloured remarks
  • Showing pornography or explicit content
  • Any other unwelcome verbal or non-verbal conduct of a sexual nature
The following also amount to sexual harassment when they occur during a Circle session or platform-mediated interaction:
  • Creating a coercive or intimidating session environment of a sexual nature
  • Conditioning ratings, referrals, or continued engagement on personal favours of a sexual nature
  • Persistent unwelcome conduct across multiple sessions that creates a hostile experience

Consequences of Violation

  • For Experts: suspension or permanent removal from Circle, and forfeiture of pending payouts or any other measure the Internal Committee deems to be appropriate.
  • For Users: permanent platform ban or any other measure the Internal Committee deems to be appropriate. Compensation may also be payable to the aggrieved person.
In serious cases, the Internal Committee reserves the right to assist the complainant in bringing the matter to the attention of law enforcement authorities.
Retaliation against anyone who files a complaint or cooperates with an investigation is unlawful and will not be tolerated. Retaliation includes, without limitation, deprioritising an Expert in matching, search, or referral visibility, or reducing session opportunities, because they filed a complaint, were named in one, or cooperated with an enquiry.

How to File a Complaint

File within three months of the incident (extendable by three months in exceptional circumstances) via any of the following:
Complaints must be in writing, and if available, include supporting material such as session reference IDs, screenshots, descriptions of the unwelcome conduct, or descriptions of the flagged content.

During the Enquiry

All efforts will be made to complete the inquiry within the stipulated 90-day period. While it is underway, the Internal Committee may:
  • Temporarily suspend the Expert's access to the platform
  • Temporarily block the User's ability to initiate new sessions
  • Restrict platform contact between the parties
Both the Expert and User involved may be restricted from the platform until a resolution is reached, at the discretion of the IC.
The Complainant will be required to share the information requested by the Internal Committee and/or participate in the proceedings conducted by the Internal Committee, whether via video conferencing or in person. The Internal Committee may halt or suspend the proceedings in relation to the complaint if no information or participation is forthcoming from the Complainant when requested by the Internal Committee.
The Respondent will also be required to share the information requested by the Internal Committee and/or participate in the proceedings conducted by the Internal Committee, whether via video conferencing or in person.
In the event that the Respondent does not share the Information requested or refuses to cooperate with or participate in the proceedings of the internal committee, the Internal Committee may proceed on the assumption that the Respondent has no information to share. In a situation where either party does not cooperate, the IC under the SHWW(PPR) Act, 2013, is within its rights to terminate the investigation or take an ex parte decision on the matter.
Within 10 days of completing the enquiry, the Internal Committee will submit its findings and recommendations. Action on those recommendations, including any consequence under “Consequences of Violation” above, will be taken within 60 days of submission.

False Complaints

If a complaint is found to have been filed with malicious intent, including through the deliberate use of false evidence, the Internal Committee may recommend suspension or removal of the complainant from the platform. A complaint that is not ultimately substantiated, or that fails for lack of evidence, will not by itself be treated as malicious or false.

Confidentiality

All complaint contents, identities of parties, and enquiry proceedings are strictly confidential and will not be disclosed to the public or media in any manner.

Internal Committee

  • Priyanka Singh — Presiding Officer
  • Sahil Bhagtani — Member
  • Ashwathi Umaria — Member
  • Ishita Lath — Member
  • Tasneem Biviji — External Member
To reach the Internal Committee: safe@circlebycred.club
Dreamplug Technologies Private Ltd | CIN: U93090MH2018PTC308253 | www.cred.club