Equal Opportunities Policy

SATSURE ANALYTICS INDIA PRIVATE LIMITED

EQUAL OPPORTUNITY POLICY

for Persons with Disabilities

Issued under Section 21 of the Rights of Persons with Disabilities Act, 2016 and Rule 8 of the Rights of Persons with Disabilities Rules, 2017

Effective Date: 01 April 2025 | Version 1.0

Table of Contents

1. Purpose and Objective

SatSure Analytics India Private Limited (“the Company”) is committed to providing equal opportunity in employment to persons with disabilities and to fostering a workplace free of discrimination on the ground of disability. This Equal Opportunity Policy (“Policy”) sets out the measures the Company will take to give effect to this commitment, in pursuance of Section 21 of the Rights of Persons with Disabilities Act, 2016 (“the Act”) and the Rights of Persons with Disabilities Rules, 2017 (“the Rules”).

2. Applicability and Scope

This Policy applies to all employees, contractors, and applicants for employment at SatSure Analytics India Private Limited, across all locations and functions of the Company, including recruitment, training, promotion, transfer, compensation, benefits, and separation. The Company employs more than twenty (20) persons and is accordingly governed by the additional requirements prescribed under Rule 8(3) of the Rules for private establishments of this size.

3. Legal Framework

This Policy is issued in accordance with:

• Section 21 of the Rights of Persons with Disabilities Act, 2016;

• Rule 8 of the Rights of Persons with Disabilities Rules, 2017;

• Any State-specific rules or notifications issued by the Government of Karnataka under the Act, as applicable.

4. Definitions

“Person with disability” means a person with long-term physical, mental, intellectual, or sensory impairment which, in interaction with barriers, hinders full and effective participation in society on an equal basis with others, as defined under the Act. “Benchmark disability” means a person with not less than forty percent (40%) of a specified disability, as certified by a competent medical authority. “Establishment” means SatSure Analytics India Private Limited, being a private establishment as defined under the Act. “Reasonable accommodation” means necessary and appropriate modification, without imposing a disproportionate or undue burden, to ensure persons with disabilities can enjoy their rights equally with others.

5. Equal Opportunity and Non-Discrimination

The Company shall not discriminate against any person with disability in any matter relating to employment, including recruitment, promotion, training, transfer, or termination. No employee or applicant with a disability shall be denied any opportunity available to other similarly placed employees solely on the ground of disability. The Company shall ensure that its recruitment processes, workplace policies, and employee communications do not directly or indirectly discriminate against persons with disabilities.

6. Facilities and Amenities

The Company shall, to the extent practicable, provide the following facilities and amenities to enable persons with disabilities to effectively discharge their duties:

• Barrier-free access to workspaces, meeting rooms, and common areas, in accordance with the Company’s phased accessibility roadmap;

• Assistive devices and adaptive technology relevant to the employee’s role, on request and subject to feasibility assessment;

• Flexible work arrangements, including remote or hybrid work options, where the nature of the role permits;

• Accessible restrooms and washroom facilities at Company premises, being implemented in phases as set out in the Company’s accessibility roadmap;

• Modification of workstations, equipment, or software tools to accommodate specific requirements, on a case-by-case basis.

7. Identification of Posts and Manner of Selection

The Company shall periodically identify roles and functions suitable for persons with disabilities, having regard to the nature of work, physical requirements, and reasonable accommodation feasible for that role. Selection for identified posts shall follow the Company’s standard, merit-based recruitment process, with reasonable accommodation extended at the interview and assessment stage on request (for example, accessible interview locations or additional time for assessments). The People & Culture function shall maintain and periodically review the list of roles assessed as suitable, in consultation with the relevant business or functional heads.

8. Training, Development and Career Progression

Employees with disabilities shall have equal access to the Company’s training, learning and development programmes, and to internal job postings and promotion opportunities. Where a specific accommodation is required for an employee with disability to participate in a training programme, the People & Culture function shall coordinate reasonable arrangements with the concerned function.

9. Reasonable Accommodation

Employees with disabilities, or applicants at the recruitment stage, may request reasonable accommodation by writing to the People & Culture function. Requests shall be assessed on a case-by-case basis, in consultation with the employee, and implemented to the extent feasible without imposing disproportionate or undue burden on the Company. The Company shall not charge any cost of reasonable accommodation to the employee.

10. Assistive Devices and Barrier-Free Accessibility

The Company recognises its obligations under Sections 40 to 46 of the Act relating to accessibility of premises, information, and communication technology. The Company’s approach to barrier-free physical accessibility, including restrooms, ramps, signage, and related infrastructure, is set out in its separate Accessibility Implementation Roadmap, which shall be read alongside this Policy and updated periodically as milestones are achieved.

11. Grievance Redressal

Any employee who believes they have been discriminated against on the ground of disability, or who wishes to raise a concern regarding accessibility or accommodation, may raise the matter with the People & Culture function or through the Company’s existing grievance redressal channels. All such complaints shall be handled promptly, confidentially, and without retaliation against the complainant.

12. Liaison Officer

The Company shall designate a Liaison Officer to oversee matters relating to the recruitment, welfare, and reasonable accommodation of persons with disabilities, and to serve as the primary point of contact for queries relating to this Policy.

13. Maintenance of Records

The Company shall maintain records relating to the employment of persons with disabilities, including facilities provided and related information, in accordance with Section 22 of the Act, and such records shall be available for inspection by authorised persons as required under law.

14. Publication and Registration

This Policy shall be published on the Company’s website and, where not practicable, displayed at conspicuous places within the Company’s premises, in accordance with Rule 8 of the Rules. A copy of this Policy shall be registered with the State Commissioner for Persons with Disabilities, Karnataka, or such other authority as may be applicable.

15. Review and Amendment

This Policy shall be reviewed periodically, and no less than once every two years, or as required by amendments to the Act or the Rules, to ensure continued compliance and relevance.

16. Approval and Effective Date

This Policy has been approved by the management of SatSure Analytics India Private Limited and is effective from the date of adoption stated below.

Approved on behalf of SatSure Analytics India Private Limited