PURPOSE

Clicktech Retail Private Limited (hereafter referred to as “CRPL” or “Company”) is committed to being a responsible and equal opportunity employer. CRPL firmly believes that every individual deserves dignity, respect, and a fair chance to thrive — regardless of their abilities, identity, or health status. The purpose of this policy is to ensure maximum compliance of provisions in line with key legislations that safeguard the rights of individuals covered under: (a) Rights of Persons with Disabilities Act, 2016 (“RPWD Act”); (b) HIV and AIDS (Prevention and Control) Act, 2017 (“HIV & AIDS Act”); and (c) Transgender Persons (Protection of Rights) Act, 2019 (“TPPR Act”). This policy represents our commitment to creating a workplace where differences are not just respected but valued. Our commitment to equal opportunity extends across the entire employment lifecycle spanning recruitment and selection to onboarding, training, performance management, promotions, compensation, job rotations, and separation. This policy also governs our approach to workplace facilities, health and safety, grievance redressal, and access to benefits and development opportunities.

SCOPE

This policy extends to all full-time employees (FTEs), interns, and fixed term contractors (FTCs) on CRPL payroll. This policy does not apply to third-party contractors and third-party consultants. In addition:

• These guidelines shall form part of the terms and conditions of employment of all personnel and shall be deemed to be incorporated therein.
• It will come into effect immediately and will remain in force subject to future amendment(s), which may be made in these guidelines from time to time as per Management discretion.

KEY TERMS & DEFINITIONS

1. Discrimination: Any distinction, exclusion, restriction, or exercised preference, whether intentional or unintentional, that has the purpose or effect of impairing or nullifying the recognition, enjoyment, or exercise on an equal basis with others of all human rights and fundamental freedoms in the political, economic, social, cultural, civil or any other field and includes all forms of discrimination and denial of reasonable accommodation on the basis of disability, gender identity, HIV status, or any other protected characteristic. Discrimination may be direct (overt, explicit) or indirect (arising from seemingly neutral policies or practices that disproportionately disadvantage certain groups).
2. Reasonable accommodation: a) For the purposes of RPWD Act, ‘Reasonable accommodation’ shall mean necessary and appropriate modifications, adjustments – without imposing a disproportionate or undue burden, to ensure to persons with disabilities, the enjoyment or exercise of rights equally with others. b) For the purposes of HIV & AIDS Act, Reasonable accommodation’ means minor adjustments to a job or work that enables an HIV-positive person who is otherwise qualified to enjoy equal benefits or to perform the essential functions of the job or work, as the case may be.
3. Person with Disability (PwD): As defined under the RPWD Act, a Person with disability (PwD) 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.
4. Person with benchmark Disability: A person with not less than 40% of a specified disability, as certified by a competent medical authority in accordance with the RPWD Act and its rules.
5. Gender identity: An individual’s deeply felt internal and individual experience of gender, which may or may not correspond with the sex assigned at birth. Gender identity includes selfidentification as male, female, transgender, non-binary, or any other gender.
6. Gender Expression: The outward manifestation of an individual’s gender identity, including but not limited to appearance, dress, mannerisms, speech, and behavior.
7. Transgender person: A person whose gender does not match the gender assigned at birth and includes trans men, trans women (whether or not such person has undergone sex reassignment surgery or hormone therapy or laser therapy or such other therapy), persons with intersex variations, genderqueer individuals, and persons with socio-cultural identities such as Kinnar, Hijra, Aravani, or Jogta.
8. Person living with HIV (PLHIV): Any individual who has been diagnosed as HIV-positive, whether symptomatic or asymptomatic.
9. Protected Person (under HIV/AIDS Act): As per the HIV & AIDS Act, a “protected person” includes any person living with HIV, any person who is HIV-affected, or any person presumed, known, or suspected to be HIV-positive, including their partners, family members, or persons living in their household.
10. Confidentiality: In the context of this policy, confidentiality refers to the obligation(s) to protect sensitive personal information — including disability status, gender identity or expression, HIV status, or medical data — from unauthorized access, use, or disclosure. Such information may be shared only with the individual’s written informed consent, or where disclosure is required by law or a court order.
11. Equal Opportunity Officer (EOO): An officer designated by CRPL to oversee the implementation of this policy, ensure compliance with applicable laws, address grievances, coordinate reasonable accommodations, and maintain relevant records.
12. Liaison Officer (for Persons with Disabilities): A representative appointed under Section 21 of the RPWD Act, 2016, responsible for identifying suitable positions for persons with disabilities, facilitating workplace accessibility, and monitoring policy implementation specific to disability inclusion.
13. Workplace: For the purpose of this policy this refers to any job site of the Company or any place visited by personnel of the Company, arising out of or during the course of employment. The latter may include but is not restricted to business related travel, Company sponsored team outings, team offsite meetings etc., including events where transportation is provided by the Company for undertaking such journey.
14. Types of Employees: a) FTE (Full-Time Employee): An FTE is a permanent employee working full-time hours and receiving all statutory benefits like provident fund, gratuity, and leave as per Indian labour laws. b) FTC (Fixed Term Contract Employee): An FTC employee is hired for a set period with similar benefits as permanent employees, but their employment ends automatically when the contract expires. c) Intern: An intern is a student pursuing a relevant educational course who is on a fixed term engagement with the Company to gain work experience. An intern may receive a stipend but is not entitled to statutory benefits. d) Third Party Contract Employee: A third-party contract employee works on Company premises but is hired and paid by an external agency, receiving salary and benefits from the contracting agency.

POLICY DESCRIPTION

As an environmentally responsible corporate organization we ensure environmentally safe and sound management of e-waste. In order to achieve this, we Clicktech Retail Private Limited have tied up with Reteck Envirotech Private Limited a Producer Responsibility Organisation (PRO) who will support us in the channelization of E-waste from end customer to the dismantling premise and establishment of collection points. Professional Logistics Private Limited is the e-waste managing partner of our PRO for reverse logistics facility which will facilitate collection of e-waste from the collection points and also support with door to door collection of e-waste in environmentally safe and sound manner and E[1]scrappy Recycler is its recycling partner.

1. Equal Opportunity for Persons with Disabilities:

In compliance with the RPWD Act, CRPL asserts the following provisions made towards ensuring equal opportunity for persons with disability:

1.1 Recruitment and Hiring:

CRPL does not discriminate or allow any discrimination against persons with disabilities at any stage of the recruitment and selection process. Job postings and descriptions will be written in an accessible and inclusive manner, focusing on essential job functions and responsibilities, without any direct or indirect reference to physical, mental, cognitive or other individual-specific attributes. All positions are open for people with all types of disabilities. In addition:

• All vacancy advertisements will include an appropriate short statement on equal opportunities for people with disabilities.
• Candidates with disabilities will be provided with reasonable accommodation during assessments, interviews, and onboarding to ensure equal access.
• Interviewers will be sensitized to assess candidates based on merit and no bias will be entertained or allowed on grounds of disability.
• Employees seeking statutory benefits or benefits arising out of this policy are requested to report the existence of any disability, in order to ensure the protection of their rights under this policy. Subject to applicable law, the Company respects the privacy of every employee (including prospective employees) and ensures utmost confidentiality of its information or concerns in relation to disability, or any other personal information shared with the Company.

1.2 Workplace Accessibility and Facilities:

• CRPL will ensure that the physical infrastructure of our workplaces (including buildings, facilities, restrooms, and common areas) is accessible to employees with disabilities.
• CRPL will provide necessary workplace adjustments such as ramps, handrails, signage, assistive technologies, ergonomic equipment, and accessible platforms.
• Employees with disabilities may request reasonable accommodations — such as flexible work schedules, or provision of assistive devices — which will be considered without undue delay.

1.3 Career Development and Progression

Persons with disabilities shall have equal access to career growth avenues, including (but not limited to) training, career advancement, promotions, and all developmental opportunities. Performance evaluations for persons with disability will be based solely on merit and achievement of job-related objectives, with reasonable accommodations considered where applicable.

1.4 Liaison Officer and Recordkeeping:

• A Liaison Officer will be appointed to identify suitable posts for persons with disabilities, coordinate accommodations, and monitor compliance with this policy.
• The Equal Opportunity Officer appointed in furtherance of this policy shall also be deemed to be the Liaison Officer.
• A confidential register of employees with disabilities will be maintained (with their consent) to facilitate reporting and policy evaluation.

2. Equal Opportunity for Transgender Persons:

In compliance with the TPPR Act, CRPL asserts the following provisions made towards ensuring equal opportunity for transgender persons:

2.1 Non-Discrimination and Inclusion

• In employment decisions, CRPL will not discriminate against any individual during recruitment, selection, onboarding, training, career development, compensation and benefits, promotion, separation, or any other act of employment based on their gender identity or gender expression.
• Every individual has the right to self-identify their gender or withhold the same. No medical or legal documentation will be required for recognition of self-identified gender for workplace purposes.

2.2 Workplace Dignity and Recognition

• CRPL will ensure that all internal systems — including HR databases, email directories, ID cards, and payroll — reflect an employee’s self-identified name and gender upon request.
• Pronouns and gender identity shall be respected in all official and interpersonal communication.
• Dress codes, workplace policies, and behavioural expectations will be gender-neutral and inclusive.

2.3 Facilities and Safety

• Access to restrooms, and any other gender-segregated facilities will align with the employee’s self-identified gender.
• Where feasible, gender-neutral facilities will also be provided to enhance inclusivity.
• All employees will be protected from harassment, bullying, or hostile behaviour based on their gender identity or expression. Any violation will result in disciplinary action which shall be addressed by the Workplace Incidents Committee (WIC) at CRPL.

2.4 Health and Welfare

• CRPL will endeavour to provide group health insurance and welfare benefits that cover genderaffirming healthcare and related needs, subject to applicable insurance frameworks.
• Leave and flexible work arrangements will be available for medical or transition-related purposes, treated equivalently to other medical needs.

2.5 Awareness and Sensitization

• Sensitization sessions and awareness training will be conducted for managers and employees to build awareness of gender diversity, and to eliminate stereotypes, and promote respectful interactions free from any bias or discriminatory content or conduct.
• Upon request and with the individual’s consent, sensitization sessions may be conducted for specific teams to support a transitioning employee.

3. Equal Opportunity for Persons Living with HIV or Affected by HIV:

In compliance with the HIV & AIDS Act, CRPL asserts the following provisions made towards ensuring equal opportunity for transgender persons:

3.1 Non-Discrimination and Employment Rights

• Pre-employment HIV testing or mandatory disclosure of HIV status is strictly prohibited.
• HIV status will not affect eligibility for any role unless a qualified medical practitioner certifies that the condition poses a direct risk that cannot be mitigated through reasonable accommodation.
• The Company will not discriminate or deny employment, continuation of employment, promotion, or any employment benefit to any person on the basis of their actual, perceived, or suspected HIV status.

3.2 Confidentiality and Data Protection

• All information related to an employee’s or candidate’s HIV status is strictly confidential. It will not be recorded, shared, or disclosed without the individual’s written informed consent, except when required by law or a court order or any equivalent legal action thereof.
• Access to such information will be restricted to authorized personnel and used only for the purpose for which it was collected.

3.3 Workplace Support and Accommodation

• Employees living with HIV shall be entitled to reasonable accommodations such as flexible work hours, medical leave (as per Leave policy), or task reallocation when medically necessary.
• There will be no segregation, isolation, or exclusion from workplace activities or common facilities based on HIV status.
• Company will actively seek group health insurance plans that do not exclude HIV-related treatment, subject to prevailing regulations.

3.4 Awareness and Stigma Reduction

• Annual awareness sessions will be conducted to dispel myths and misconceptions about HIV and AIDS, and to build a culture of empathy and support.
• Any form of stigma, harassment, or retaliation against persons living with or affected by HIV will result in disciplinary action which shall be addressed by the Workplace Incidents Committee (WIC) at CRPL.

3.5 Role of Employees or Co-Workers

• As a co-worker, it is the responsibility of employees to not discriminate against colleagues on the basis of their HIV status.
• Employees also have to ensure that the HIV status if known to them is not disclosed to anyone without the informed consent of such employee having HIV. Any form of stigma, harassment, or retaliation against persons living with or affected by HIV will result in disciplinary action which shall be addressed by the Workplace Incidents Committee (WIC) at Company.

3.6 Complaints Officer

• A Complaints Officer shall be appointed by CRPL who shall dispose of complaints of violations of the provisions of the HIV & AIDS Act and this policy.
• The Equal Opportunity Officer appointed in furtherance of this Policy shall also be deemed to be the Complaints Officer.

REASONABLE ACCOMMODATION PROCESS

Employees or candidates seeking accommodation under this policy may submit a request to the Equal Opportunity Officer (EOO). The request will be acknowledged within three working days, and a formal review panel comprising of the CEO, Group Head of HR, and the Group Head of Legal and CS will be instituted to formally evaluate the submitted request and explore feasible adjustments. Decisions will be communicated within 15 working days following the date of acknowledgement of the request by the EOO. If a request is denied, reasons will be provided in writing, and alternative measures will be considered. No person shall face retaliation or any adverse consequences for requesting accommodation.

GRIEVANCE REDRESSAL

1. Any individual who believes they have been discriminated against or treated unfairly under this policy may file a written or verbal complaint with the EOO or the HR Department, or may write to the WIC (wic-crpl@clicktechretail.in).
2. All complaints will be investigated promptly, confidentially, and impartially.
3. Appeals against grievance outcomes may be made to the Group Head of HR within 15 working days of receiving the decision.
4. All information shared during the grievance process — including identity, disability status, gender identity, or HIV status — will be kept strictly confidential.
5. Retaliation, victimisation, or intimidation of any individual for filing a grievance, participating in an investigation, or supporting another’s complaint is strictly prohibited.

The following timelines would be applicable for a grievance redressal request: