Child Protection Policy

1. GENERAL

G-Tech Infrastructure Private Limited (“G-Tech Infra” or “the Company”) maintains a zero-tolerance approach toward child exploitation and abuse. The Company respects and upholds the rights of children, ensuring protection against violence, exploitation, and harm.

G-Tech Infra expects all members of its workforce—including employees, contractors, subcontractors, and others engaged with the Company—to prioritize the best interests of children in all professional and personal interactions. Ethical conduct and integrity are paramount, and any behavior contradicting this policy, whether during business operations or outside working hours, is strictly prohibited.

1. ACKNOWLEDGEMENT

Each staff member is required to sign a declaration form annexed to this policy, confirming that:

1. They have read and understand the Child Protection Policy.
2. They will promptly report any incident of child abuse or violation of a child's rights to the Child Protection Officer, line manager, or project manager.

1. REFERENCES

This policy aligns with the following legal and regulatory frameworks:

1. The Protection of Children from Sexual Offences Act, 2012 (including related Rules, 2012).
2. The National Policy for Children, 2013.
3. G-Tech Infra Code of Conduct Policy.
4. United Nations Convention on the Rights of the Child (UNICEF Website).

1. PURPOSE

The purpose of this Child Protection Policy is to:

• Provide clear guidance on child protection issues.
• Ensure staff members understand their responsibilities and duties under this policy.
• Establish a framework for reporting and responding to child protection concerns.

1. SCOPE

This policy applies to:

• All employees of G-Tech Infra, regardless of employment status (permanent, contractual, or temporary).
• Subcontractors, sub-consultants, and other third parties conducting business with the Company.
• All operations, dealings, and transactions in every country where G-Tech Infra operates.

1. DEFINITIONS

Child Protection Policy

1. Definitions

1.1 Child

For the purpose of this Policy, a Child is defined as any person below the age of 18 (eighteen) years.

1.2 Child Abuse

Child Abuse or maltreatment encompasses all forms of:

• Physical abuse
• Sexual abuse
• Emotional ill-treatment
• Neglect and negligent treatment
• Commercial or other exploitation

This includes any action that causes, or has the potential to cause, harm to a child.

Child abuse may be a deliberate act or a failure to act to prevent harm. It includes any actions or inactions by individuals, institutions, or processes that result in harming a child or jeopardizing their safe and healthy development into adulthood.

For possible signs of child abuse, refer to Annexure A.

1.3 Child Protection

Child Protection refers to the measures taken to prevent and respond to violence, exploitation, and abuse against children. This includes:

• Commercial and sexual exploitation
• Trafficking
• Child labor
• Harmful traditional practices, such as female genital mutilation and child marriage

In the context of this Policy, Child Protection defines the preventive and responsive measures G-Tech Infra undertakes to ensure that no child is subjected to abuse. This includes the additional responsibilities of the G-Tech Infra workforce (refer to Section E: Scope) to ensure that the Company’s projects, programs, and activities do not expose children to risk.

Policy Framework

 Policy Statement

G-Tech Infra is committed to:

• Upholding the dignity and equality of all individuals in its programs and projects.
• Ensuring that all projects follow the principle of "do no harm".
• Creating a safe environment for children by preventing physical, sexual, and emotional abuse in alignment with:
• The UN Convention on the Rights of the Child
• Relevant statutes of the Government of India

2.2 Principles

This Policy is guided by the following key principles:

• Zero tolerance for child exploitation or abuse.
• Equal rights – Every child has the right to protection from abuse and exploitation.
• Right to life, survival, and development – Each child has a fundamental right to grow in a safe and healthy
• Encouraging potential & combating discrimination – All children should be given the opportunity to fulfill their potential, and inequality and discrimination should be actively challenged.
• Right to be heard – Children should have the right to express their views freely, and their opinions should be given due weight in accordance with their age and maturity.
• Non-discrimination – Every child must be treated with respect and dignity, regardless of:
• Gender
• Nationality or ethnic origin
• Religious or political beliefs
• Age
• Physical or mental health
• Sexual preference or gender identity
• Socio-economic or cultural background
• Any history of conflict with the law
• Shared responsibility – Everyone has a duty to support the care and protection of children.
• No child should suffer harm due to their engagement with G-Tech Infra. This includes children:

Sponsored by the Company

Participating in programs, projects, or advocacy campaigns

These principles extend to all individuals and organizations associated with G-Tech Infra. Therefore, all staff, contractors, and partners must be aware of and adhere to the provisions of this policy.

ROLES AND RESPONSIBILITIES

1. Child Protection Officer

The Child Protection Officer (CPO) is responsible for:

• Receiving and acting upon any reported child protection concerns.
• Ensuring the implementation and promotion of this Policy.
• Promoting best safeguarding practices across the Company’s partnership network.
• Serving as the first point of contact for child protection issues within the Company, for the public, and for external stakeholders.

G-Tech Infra has designated the following individual as the Child Protection Officer:

Mr. Shivam Saxena

2. Human Resources (HR) Department

The HR Department is responsible for:

• Implementing and monitoring compliance with this Policy.
• Establishing and maintaining an ethical culture within the Company.
• Applying the highest standards in recruitment and vetting procedures.

As part of the recruitment process, HR shall:

1. Conduct reference checks, obtaining at least two positive references from previous employers to confirm that there is no known reason why the applicant should not work with children.
2. Conduct criminal record checks to verify that the prospective employee has no history of crimes against sexual freedom and morality, crimes against minors, or any ongoing criminal proceedings related to such offenses.

3. Department Heads/Managers

Department Heads and Managers are responsible for:

• Ensuring that all staff members under their supervision are aware of and comply with this Policy.
• Actively promoting a culture of child protection within their teams.

4. Individual Staff Members

All staff members have a personal responsibility to:

• Act in the best interests of children and ensure their protection.
• Adhere to the Child Protection Policy in all aspects of their professional conduct.
• Report any concerns or suspicions regarding child abuse or exploitation through the established reporting mechanisms.

5. Subcontractors/Sub-consultants

• All written agreements between G-Tech Infra and Subcontractors/Sub-consultants (both individuals and firms) must include a shared commitment to child protection.
• Subcontractors and sub-consultants must ensure that their behavior towards children aligns with the principles outlined in this Policy.
• If required by the Client, each subcontractor must prepare and follow an appropriate Child Protection Policy and Procedures.
• If any member of the workforce develops concerns or suspicions regarding child abuse or exploitation—whether within the Company or externally—they must immediately report such concerns using the established reporting mechanisms.

1. CHILD PROTECTION - CODE OF BEHAVIOUR

All employees, subcontractors, and individuals associated with G-Tech Infra must adhere to the following standards of behaviour when interacting with children:

1. General Conduct

• Act in good faith and treat all children with respect, dignity, and fairness, without discrimination, harassment, abuse, or neglect.
• Ensure that personal and professional conduct aligns with G-Tech Infra’s Vision, Mission, and Core Values and does not bring the Company into disrepute.
• Take reasonable action to protect others from harm and challenge infringements of children's rights.
• Maintain the highest standards of behaviour when dealing with children, both within and outside the workplace.

2. Protection Measures

• Avoid physical and verbal abuse of children, even if it is culturally acceptable.
• Use non-violent and positive discipline methods to manage children's behaviour.
• Create and maintain an environment that prevents all forms of abuse and exploitation.
• Managers at all levels must support systems that promote child protection.

3. Appropriate Interaction and Communication

• Do not use inappropriate, abusive, sexually suggestive, demeaning, or harassing language or behaviour towards children.
• Do not establish online friendships with children who come into contact with G-Tech Infra via social media platforms (e.g., Facebook, Twitter, Instagram, etc.).
• Obtain permission from the child and their parent/guardian before taking photos or videos of them.

4. Prohibited Conduct

• Do not engage in any sexual relationships with persons under 18 years of age, regardless of the local age of consent. Mistaken belief about the child's age is not a defense.
• Do not exchange money, employment, goods, or services for sex, including sexual favours or any form of humiliating, degrading, or exploitative behaviour.
• Do not take children to your home or any private space where they will be alone with you.
• Do not share a bed or sleep in the same room as a child you interact with through work.
• Do not perform personal tasks for a child that they can do for themselves.
• Do not be under the influence of alcohol or drugs while responsible for children.

5. Employment and Labour Practices

• Do not condone or engage in child labour, including:
• Slavery, human trafficking, or forced labour
• Recruitment of children for armed conflict
• Commercial sexual exploitation of children
• Involvement of children in crime, including drug production or trafficking
• Work that harms a child's health, safety, or moral development
• Do not employ children in ways that interfere with their education.

6. Equal Treatment and Anti-Bullying

• Do not shame, belittle, or degrade a child.
• Do not show favouritism to specific children at the exclusion of others or apply rules inconsistently.
• Do not stigmatise children based on gender, race, ability, class, or any other factor.
• Challenge all forms of bullying and child-to-child abuse.

Note: These rules do not intend to interfere with normal family interactions but ensure a professional and ethical work environment.

1. PREVENTIVE MEASURES
2. Recruitment & Vetting

G-Tech Infra upholds the highest standards in its recruitment and vetting policies as outlined in the HR Manual.

1.1 Recruitment Process

• Job advertisements must state that G-Tech Infra is an equal opportunity employer committed to child protection.
• Reference checks:
• At least two references must be obtained from previous employers.
• References must confirm there is no known reason why the candidate should not work with children.

G-Tech Infra does not employ any staff member (including those on contract) below the age of 18 years and where, during or upon recruitment, concerns come to light in relation to the applicant's unfavourable conduct with children.

1. Training/ Awareness

All staff members receive child protection training to make them aware of the importance of protecting children and to be fully aware of procedure for reporting the concerns. The trainings in the following stages:

1. Induction of new employees;
2. Universal training/ awareness programme for all staff members;
3. Tailored training as per the requirement of programme/ project.

• Risk Assessment

In the projects/ programmes involving potential contact with children, we undertake risk assessment in the 'Risk Register', to identify and manage risk(s) to children appropriately. The Corporate Risk and Compliance (CRC) Department reviews the risk registers on half yearly basis.

1. Commitment from Suppliers

All agreements with Suppliers shall reflect Supplier's commitment to Child Protection, including an undertaking that Supplier does not employ any staff member below the age of 18 years/ in contravention of the law of land (as applicable).

1. REPORTING PROCEDURE

Staff members and other personnel are duty bound to disclose any Child Abuse and Child Protection concerns, including non-compliance of this Policy by anyone within the scope of this Policy in connection with official duties or business, immediately upon identification.

Whom to report?

An individual can get in touch with the designated Child Protection Officer for recording the possible Child Abuse and Child Protection concern. These shall also include any reporting of any historic unreported concern or disclosure regarding possible Child Abuse and Child Protection concern.

Where the concern has been submitted with MD/ COO/ Department Head, the same will be duly forwarded to Child Protection Officer for investigations.

What to report?

If any staff member suspects abuse, or if a person external to the Company reports to the Company a suspicion or allegation relating to G-Tech Infra staff or activities, the following steps should be taken:

Avoid any delay;

Write down what you've heard or seen;

         Email or record the suspicion/ concern with the Child Protection Officer (refer above — Whom to Report?)

The report must specify the nature of the suspicion/ concern and name(s) of the alleged abuser. The suspicion/ concern should include date and time of specific event(s), names of witnesses, if any and/or any evidence that support the allegation(s).

1. INVESTIGATIONS

The Company will act without delay, prioritising the safety of the child/ren involved, in the event of a concern or allegation of child abuse being reported.

The Child Protection Officer will convene a meeting within 48 hours — which can be face to face, by phone, Skype or email (all emails should be signalled as confidential). The following (apart from child Protection Officer) member shall be present in the meeting:

1. For local oversight: Head of Department/ Project Manager (it may also include branch head)
2. For Risk and HR expertise: Head — CRC and Head — HR, respectively
3. Representative of management: Advisor — Corporate Communication & Quality Assurance

The members will instigate and investigate if there has been a breach of this policy by subject staff member (alleged perpetrator). An investigation will gather evidence and interview relevant parties in order to establish the probable facts in relation to the complaint/ disclosure. If needed, the members will record the statement of the child in the presence of parents of the child, at a place where the Child resides or at a place of his choice.

The members of the meeting may recommend management of the Company through Head — HR to serve the suspension notice to the subject staff member (alleged perpetrator), until the investigation has been completed.

In case the members of the committee records serious malpractice against the subject staff member in its report, appropriate action shall be initiated, which shall include termination from G-Tech Infra and may involve informing statutory authorities, as per the law of land.

Confidentiality

Given the sensitive nature of investigations and its impact on the child/ren as well as the person against whom such allegations are levelled, the Company is committed to maintaining strict confidentiality in relation to such complaints and the resultant investigations/ inquiry,

All proceedings, including the statements and other material adduced as evidence before the investigating members shall be strictly confidential and the members shall not divulge the details to any other employee within the Company or to any person outside. This includes Minutes of the Meetings, findings, recommendations, decisions of the members and any document or any verbal communication. Also, to other Employees involved in such discussions, the members should emphasize the necessity for confidentiality and the consequences of possible disciplinary action in case of transgression.

Appropriate sanctions will be applied in cases of malicious and deliberate false accusations of Child abuse/ exploitation, which may include, but not limited to, termination.

1. DISCIPLINARY ACTION

While it will be ensured that staff member(s) who raises genuine disclosure are accorded complete protection from any kind of unfair treatment as herein set out, any abuse of this protection or this Policy will warrant disciplinary action.

Any person, who negligently or malafidely broadcasts confidential information in relation to investigations shall warrant disciplinary action.

Any person who makes any disclosure malafidely and knowingly that it was incorrect or false or misleading or frivolous or reported otherwise than in good faith, shall invite disciplinary action including initiation of civil or criminal proceedings and/ or termination from employment with G-Tech Infra and its subsidiaries.

1. PROTECTION AGAINST RETALIATION

The Company takes reports of retaliation seriously. We will not tolerate any attempt to deter anyone from reporting suspicions of Child Abuse or incidents of repercussions/ victimisation against anyone who, in good faith, reports/ discloses a concern or cooperates with investigations even when allegations are found to be unsubstantiated. Any employee of G-Tech Infra who retaliates against another employee in violation of this Policy is subject to disciplinary action, up-to and including termination. This also includes attempts to deter anyone from reporting suspicions of Child Abuse.

1. COMPLIANCE

This Policy cannot describe all Child Abuse situations that may arise. Therefore, employees (and other individuals) must use their respective good judgment to avoid any appearance of impropriety.

If any staff member has any question whether a course of conduct constitutes Child Abuse, it is the responsibility of that individual to obtain an advice from his/her line manager and act in accordance with that advice. Alternatively, the concerned individual can get in touch with the Child Protection Officer listed under point (K) above to clear any misconceptions.

1. MONITORING AND REVIEW

Head — HR will monitor the effectiveness and review the implementation of this Policy, on annual basis.

G-Tech Infra reserves right to modify this Policy unilaterally at any time, without notice. Modifications may be necessary to maintain compliance with local regulations and/ or accommodate organisational changes in the company. Any revisions in this Policy including amendments or changes under respective clauses will be duly notified to employees through email communication. Also, such revised Policy or notification/ circular/ internal communication on such revisions will be updated in the HR Documents>>Policies section  and Corporate Website (www.gtechinfra.in ). The employee shall be deemed to have read, understood and acknowledged the changes thereof which will supersede the terms of current Policy or any subsequent document/communication related to the Policy.

Annexure A

I,______________________[Your Full Name], hereby declare that I have read and understood G-Tech Infrastructure Private Limited’s Child Protection Policy, and I fully agree to abide by its provisions.

Furthermore, I declare that:

1. I have never been convicted of any offence, nor is there any pending civil or criminal proceeding against me as of the date of this declaration, involving any form of harm to a child or children.
2. I have not been subjected to any disciplinary action related to child abuse, neglect, or violence of any kind.

I understand that any false declaration or failure to disclose relevant information may result in disciplinary action, including termination of my association with G-Tech Infra Limited.

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