Guidelines and Policies

This Policy forms an integral part of, and is to be read together with, the Delivery Partner Services Agreement (“Agreement”) executed between Airxy Tech Private Limited (“Company”) and the Delivery Partner engaged on the platform of the Company.

This Policy supplements Clause 12 (Prevention of Sexual Harassment) and Clause 8 (Code of Conduct) of the Agreement and sets out the detailed policy, procedure, and grievance redressal framework, as applicable to the engagement of Delivery Partners with the Company. Capitalised terms used but not defined in this Policy shall have the meaning ascribed to them in the Agreement.

1. Preamble and Policy Statement:

• The Company is committed to fostering a safe, respectful, and dignified environment for all Delivery Partners engaged with its platform, in furtherance of its founding objective of enabling safe and dignified earning opportunities for women, persons with disability, and transgender persons.

• The Company adopts this Policy voluntarily, as a matter of business practice, platform governance, and duty of care towards its Delivery Partners, recognising that Delivery Partners may, in the course of rendering services, interact with Company representatives, hub personnel, other Delivery Partners, customers, merchants, and other third parties.

• Nothing contained in this Policy, including the use of expressions such as “Committee”, “Complainant”, “Respondent”, “redressal”, “inquiry”, or any other expression that may resemble terminology used under applicable law in the context of employer-employee relationships, shall be construed as an admission, acknowledgment, or creation of any employment, agency, partnership, principal-employee, or master-servant relationship between the Company and the Delivery Partner. The Delivery Partner’s engagement remains, at all times, on an independent-contractor and service-oriented basis, as set out in Clause 2 (Nature of Engagement) of the Agreement, and this Policy shall be interpreted consistently with, and subordinate to, that characterisation.

• The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and allied jurisprudence (“Reference Framework”) have been used as drafting guidance to structure a protective and well-governed mechanism. Reference to, or alignment with, the Reference Framework is a matter of the Company’s own policy choice and shall not be construed as an admission by the Company that the Reference Framework applies as a matter of law to the engagement contemplated under the Agreement.

2. Definitions:

• “Active Engagement Period” means the period means the period during which a Delivery Partner is engaged in rendering services through the Company’s Portal, commencing when the Delivery Partner logs into the Company’s application, or checks in at a Mini Command Centre/hub, for the purpose of undertaking deliveries, and ending when the Delivery Partner logs out of the application or checks out from the hub.

The Active Engagement Period includes:

1. time spent travelling to or from a pickup or delivery location in connection with an assigned order;
2. time spent at a hub, Mini Command Centre, pickup point, or delivery address in connection with the services;
3. participation in any training, orientation, or event organised or facilitated by the Company; and
4. any communication, whether through the Company’s application, telephone, or otherwise, arising out of or connected with the services, irrespective of when such communication takes place.

• “Company” means Airxy Tech Private Limited, and includes its officers, representatives, and hub/Mini Command Centre personnel.

• “Complainant” means a Delivery Partner who alleges that they have been subjected to conduct constituting Sexual Harassment under this Policy.

• “Engagement Environment” means the physical and virtual locations connected with the Delivery Partner’s services, comprising any hub or Mini Command Centre or locations contained in “Extended Engagement Environment”, where they are required to be present during the “Active Engagement Period”.

• “Extended Engagement Environment” means any location, interaction, or circumstance beyond a hub/Mini Command Centre that bears a proximate connection to the Delivery Partner’s services;

Which includes:

1. Appropriate proximities of pickup or delivery location; or
2. Prescribed/ reasonable transit undertaken in connection with an assigned order; or
3. The venue of any Company-organised training, orientation, or event, irrespective of where it is held; or
4. any in-person, telephonic, or application-based interaction arising out of or connected with the Delivery Partner’s engagement, in each case occurring during the “Active Engagement Period”, irrespective of the physical location of the persons involved.

• “Internal Complaint Committee” or “IC” means the committee constituted under Clause 8 of this Policy to receive and address complaints under this Policy.

• “Respondent” means the person against whom a complaint is made under this Policy, and may include a Company representative, hub personnel, another Delivery Partner, a customer, a merchant, or any other “Third party” encountered within the “Engagement Environment”.

• “Sexual Harassment” means unwelcome conduct of a sexual nature directed at or by a Delivery Partner. The acts and behaviour that constitute Sexual Harassment for the purposes of this Policy are set out exhaustively in Clause 5 (Prohibited Conduct) of this Policy, which is to be read as forming part of this definition.

This includes any one or more of the following unwelcome acts or behaviour, whether direct or implied: (i) physical contact or advances; (ii) a demand or request for sexual favours; (iii) sexually coloured remarks; (iv) showing pornography; or (v) any other unwelcome physical, verbal, or non-verbal conduct of a sexual nature; and includes stalking, repeated unwanted communication, and any conduct that a reasonable person would consider to create an intimidating, hostile, humiliating, or unsafe environment for the Complainant.

• “Third Party” means any person who is not a Delivery Partner or Company representative, including but not limited to, customers, merchants, vendors, and members of the public, whose conduct occurs within the “Engagement Environment” during the “Active Engagement Period”.

• “Workplace” means, for the purposes of this Policy, the “Engagement Environment” considered together with the “Active Engagement Period”, and includes the “Extended Workplace”.

The Workplace does not include:

1. any period outside the proximate scope of “Engagement Environment”, i.e. period during which the Delivery Partner is neither logged into the Company’s application nor checked into a hub/Mini Command Centre, and is not engaged in any activity connected with an assigned order or the services; or
2. a personal errand, relationship, or activity unconnected with an assigned order or the services, notwithstanding that it may coincide with a period or location that would otherwise fall within the scope of “Engagement Environment” or “Active Engagement Period”; or
3. an interaction with a customer, merchant, or other third party that the Delivery Partner voluntarily initiates or continues for a purpose unconnected with the services, after closure of the relevant order and crossing the reasonable proximities of “Engagement Environment”.

3. Objective:

The objective of this Policy is to:

1. provide Delivery Partners with a clear, accessible, and time-bound mechanism to report incidents of sexual harassment by Respondents defined under clause 2.7;
2. define the relevant terms, scope, and applicability of this Policy so as to clarify its substance and avoid any ambiguity regarding its interpretation and implementation;
3. establish an Internal Complaint Committee to receive and address complaints in accordance with this Policy;
4. enable prompt and fair examination of complaints; and
5. deter conduct that compromises the safety and dignity of Delivery Partners

4. Scope and Applicability:

• This Policy applies to every Delivery Partner engaged by the Company and to conduct occurring within the Engagement Environment during the Active Engagement Period, irrespective of whether the Respondent is a Company representative, hub personnel, another Delivery Partner, or a Third Party.

• Conduct occurring outside the Active Engagement Period or the Engagement Environment, and unconnected with the Delivery Partner’s engagement with the Company, falls outside the scope of this Policy, without prejudice to the Complainant’s right to pursue any remedy available under applicable law before the appropriate authorities.

• For the avoidance of doubt, this Policy extends to harassment by customers and merchants encountered by a Delivery Partner in the course of pickup or delivery of orders, recognising that such persons, while Third Parties, form part of the Engagement Environment.

5. Prohibited Conduct:

No person within the Engagement Environment shall subject a Delivery Partner to Sexual Harassment as defined in Clause 2.8. Without limiting the generality of the foregoing, the following constitute prohibited conduct:

1. Unwelcome physical contact or proximity;
2. Sexually suggestive remarks, jokes, or gestures;
3. Solicitation of sexual favours, whether or not accompanied by an implied or express promise or threat;
4. Display of sexually explicit or offensive material;
5. Stalking, following, or repeated unwanted contact by calls, messages, or through the Company’s application;
6. Use of order details, application data, or contact information to initiate unwelcome personal contact; and
7. Any other conduct of a sexual nature that is unwelcome and creates an intimidating, hostile, or offensive environment for the Delivery Partner.

6. Reporting a Complaint:

• A Complainant may report an incident through any of the following channels:

1. the SOS function on the Company’s application;
   1. the Company’s support helpline;
   1. in-person or written report to the hub/Mini Command Centre manager; or
   1. a written complaint (including by e-mail) addressed to the Internal Committee at the contact particulars notified by the Company from time to time.

• A complaint should ordinarily be lodged within ninety (90) days of the incident, provided that the Internal Committee may, for reasons recorded in writing, extend this period where the Complainant was prevented by sufficient cause from reporting within time.

• Where a Complainant is unable to make a complaint in writing on account of physical or other incapacity, the hub manager or a member of the Internal Committee shall render reasonable assistance to enable the complaint to be recorded.

7. Immediate and Interim Measures:

Pending inquiry, the Internal Committee may recommend such interim measures as it considers appropriate for the safety and well-being of the Complainant, including:

1. directing that the Respondent (where a Company representative, hub personnel, or another Delivery Partner) have no contact with the Complainant;
2. reassignment of delivery zones, hub, or shift timings of the Complainant or Respondent, on a voluntary and non-punitive basis as regards the Complainant;
3. blocking or restricting a customer or merchant account from being assigned to the Complainant;
4. facilitating safe transport or escort for the Complainant; and
5. any other measure, recorded in writing, that the Internal Committee considers necessary in the circumstances.

Interim measures under this Clause are protective in nature and shall not be treated as a finding on the merits of the complaint.

8. Internal Committee:

• The Company shall constitute an Internal Committee comprising:

1. a Presiding Officer, being a woman associated with the Company at a senior position;
2. two (2) representatives of the Company (preferably dedicated to causes of women/having legal knowledge); and
3. one (1) external member with relevant experience in women’s safety, law, or social work, associated with a non-governmental organisation or similar organisation.

Please Note: – 1 half of the total number of members i.e., 2 members herein, shall be women.

• The Internal Committee shall be the body responsible for receiving, examining, and making recommendations on complaints under this Policy.

• The Internal Committee shall be constituted and reconstituted from time to time at the sole discretion of the Company. The constitution of the Internal Committee is a measure of internal governance and shall not, by itself, be construed to alter the nature of the engagement between the Company and any Delivery Partner.

9. Inquiry Process:

• On receipt of a complaint, the Internal Committee shall record the same and, where appropriate, share a copy with the Respondent, who shall be entitled to submit a response within a reasonable time not exceeding ten (10) days.

• The Internal Committee shall conduct such examination as it considers necessary, which may include recording statements of the Complainant, the Respondent, and witnesses, and reviewing relevant records available to the Company (including application, order, call, or location records).

• The Internal Committee shall endeavour to complete its examination and submit its recommendations within ninety (90) days of receipt of the complaint, or such further time as the complexity of the matter may reasonably require.

• Proceedings before the Internal Committee shall be conducted with sensitivity, and the Complainant and Respondent shall each be given a reasonable opportunity to be heard.

10. Action on Substantiated Complaints:

1. Where a complaint against a Company representative, hub personnel, or another Delivery Partner is substantiated, the Company may, on the Internal Committee’s recommendation and at its sole discretion, take action including:

1. issuance of a warning;
2. suspension of engagement or access to the Company’s application for a specified period;
3. termination of the Respondent’s association or agreement with the Company, in accordance with the terms applicable to such Respondent; and/or
4. reporting the matter to the police or other appropriate authority, where the conduct alleged discloses a criminal offence.

1. Where a complaint against a customer or merchant is substantiated, the Company may, at its sole discretion and subject to the terms of its arrangement with such customer or merchant, take such action as is available to it within its platform, including blocking the account of such customer or merchant, declining to assign further orders involving such customer or merchant to the Complainant, and/or reporting the matter to the police or other appropriate authority.

1. No action taken under this Clause shall be construed as an admission by the Company of any employer-employee relationship, agency, or vicarious liability as between the Company and the Respondent or the Complainant.

11. False or Malicious Complaints:

Where the Internal Committee finds that a complaint has been made with the knowledge that it was false, or with malicious intent, the Company may, on the Internal Committee’s recommendation, take appropriate action against the person making such complaint, provided that a mere inability to substantiate a complaint, or insufficiency of evidence, shall not by itself attract action under this Clause.

12. Confidentiality:

1. The identity of the Complainant, the Respondent, and any witnesses, the contents of the complaint, and the proceedings before the Internal Committee shall be kept confidential, save to the extent necessary to conduct the inquiry, implement interim measures, comply with applicable law, or report the matter to law enforcement authorities.

• Any person who discloses information in breach of this Clause, otherwise than as permitted above, shall be liable to such action as the Company may consider appropriate.

13. Non-Retaliation:

No Delivery Partner shall be subjected to any adverse consequence in relation to their engagement with the Company on account of having, in good faith, made a complaint, provided information, or participated in an inquiry under this Policy.

14. Third-Party (Customer / Merchant) Incident Protocol:

1. Recognising that Delivery Partners interact with customers and merchants who are Third Parties to the Agreement, the Company has instituted the following operational escalation framework to enable a prompt response to safety incidents encountered during the Active Engagement Period:

Level	Incident Type	Escalation Flow
Level 1	Customer unresponsive; incorrect address	Delivery Partner contacts Support; Support resolves directly.
Level 2	Customer misbehaviour; verbal abuse	Delivery Partner contacts Support; order reassignment / customer account flagged as inappropriate.
Level 3	Harassment, stalking, or unsafe area	Delivery Partner activates SOS; Support contacts Delivery Partner; Delivery Partner assisted to a safe location; customer account restricted; incident logged.
Level 4	Accident	Delivery Partner activates SOS; Support coordinates emergency assistance; emergency contact informed; insurance process initiated, where applicable.
Level 5	Theft, robbery, or physical harm	Delivery Partner activates SOS; Support alerts local law enforcement; hub/Mini Command Centre manager informed; incident report filed; insurance claim initiated, where applicable.
	Other conduct of a similar nature	Appropriate action may be taken.

2. On activation of the SOS function, the Company’s support team shall endeavour to:
   • contact the Delivery Partner immediately;
   • ascertain the Delivery Partner’s location;
   • contact the Delivery Partner’s designated emergency contact, where necessary; and
   • alert local law enforcement, where the circumstances so warrant.

3. The measures set out in this Clause represent operational, best-efforts assistance extended by the Company through its platform and support infrastructure. They are extended as a matter of business practice and shall not be construed as an assumption of liability by the Company for the acts of Third Parties, which liability, as between the Company and the Delivery Partner, continues to be governed by Clause 9 (Safety & Insurance) of the Agreement.

15. Preventive and Safety Measures:

       The Company shall, as a matter of business practice, endeavour to:

1. provide orientation on this Policy to Delivery Partners at the time of onboarding;
2. maintain a functioning SOS mechanism and support helpline;
3. maintain, at each hub/Mini Command Centre, a first-aid kit, emergency contact list, and incident register; and
4. review and update safety guidelines (including guidance on delivery timings and areas) from time to time, in its sole discretion, based on operational experience and safety considerations.

16. Data Privacy:

Information collected in connection with a complaint under this Policy shall be processed in accordance with the Company’s obligations under applicable data protection law and Clause 11 (Confidentiality & Data Protection) of the Agreement, and shall be used solely for the purposes of this Policy, save as may be required by applicable law or a competent authority.

17. Relationship of Parties:

For the avoidance of doubt, this Policy is extended by the Company as a voluntary business and welfare practice in furtherance of its commitment to the safety of Delivery Partners engaged on an independent-contractor basis. Nothing in this Policy confers on any Delivery Partner any right, status, or entitlement associated with employment, and Clause 2 (Nature of Engagement) of the Agreement shall prevail in the event of any conflict or ambiguity between this Policy and the Agreement.

18. Amendment:

The Company reserves the right to review, modify, or withdraw this Policy, in whole or in part, at its sole discretion, with reasonable prior communication to Delivery Partners, to reflect operational, legal, or regulatory developments.

19. Severability:

If any provision of this Policy is held to be invalid or unenforceable, the remaining provisions shall continue in full force and effect, and shall be interpreted to give effect to the intent of the Company and the Delivery Partner as nearly as possible to the original provision.

20. Governing Law and Dispute Resolution:

This Policy shall be governed by the laws of India and subject to the jurisdiction of the courts at Mumbai, Maharashtra, and any disputes arising out of or in connection with this Policy shall be resolved through arbitration under the Arbitration and Conciliation Act, 1996, consistent with Clause 17 (Jurisdiction & Legal) of the Agreement.

21. Emergency Contacts:

Chandigarh: +91 9855127770

Delhi: +91 9163991265

Pune: +91 9270394626

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