Sexual Harassment Policy

Effective Date: 14/02/2025

Applicable To: All employees, contractors, students, and associates of ZenithWave Capital Limited
Company Name: ZenithWave Capital Limited
Company Address: Southbridge House, Southbridge Place, Croydon, CR0 4HA

1. Purpose & Scope

ZenithWave Capital Limited ("Company") is committed to providing a work and learning environment free from sexual harassment, discrimination, and misconduct. This policy applies to all employees, contractors, students, and any individuals associated with the Company.
Sexual harassment is unlawful under the Equality Act 2010 and will not be tolerated in any form within the workplace, training sessions, or interactions involving the Company.

2. Definition of Sexual Harassment

Sexual harassment includes unwelcome sexual advances, requests for sexual favors, and other verbal, non-verbal, or physical conduct of a sexual nature when:

• It creates an intimidating, hostile, or offensive work or learning environment.
• It interferes with an individual’s work or learning performance.
• It is used as a basis for employment, training, or investment decisions.

Examples of Sexual Harassment:

• Verbal: Unwelcome sexual remarks, jokes, suggestive comments, or repeated unwanted advances.
• Non-Verbal: Display of sexually explicit images, gestures, or suggestive looks.
• Physical: Unwanted touching, patting, hugging, or any inappropriate physical contact.
• Online/Virtual: Sending sexually explicit messages, inappropriate emails, or harassment via social media or online platforms.

3. Reporting & Complaint Procedure

If any individual experiences or witnesses sexual harassment, they should report the matter through the following channels:

Step 1: Informal Resolution (If Safe to Do So)

If the complainant feels comfortable, they can inform the harasser that the behavior is unwelcome and request it to stop. If not, proceed to Step 2.

Step 2: Formal Complaint

The complainant should report the incident to:
HR Department: compliance@zenithwavecapital.com
Management Representative: Major Singh – majorsingh@zenithwavecapital.com
Include: date, time, and location of the incident, description, and any witnesses.

Step 3: Investigation Process

The Company will conduct a confidential, fair, and timely investigation within 7 days of receiving the complaint. Both parties will have an opportunity to provide statements and evidence.

Step 4: Resolution & Action

If substantiated, action may include:

• Formal warning
• Suspension
• Termination of employment/contract/training

4. Protection Against Retaliation

Individuals reporting harassment in good faith will not face retaliation. Any retaliation will lead to disciplinary action.

5. Confidentiality

Complaints will be handled with discretion and shared only on a need-to-know basis.

6. Responsibilities of Employees & Management

• All individuals must adhere to this policy.
• Managers must ensure a safe environment and act promptly on complaints.

7. Training & Awareness

Training will be provided, and this policy reviewed annually to remain compliant with UK laws.

8. Legal Compliance & Governing Law

This policy complies with the Equality Act 2010 and other applicable laws under the jurisdiction of England and Wales.

9. Contact for Assistance

For concerns or questions, please contact:
Email: compliance@zenithwavecapital.com
Phone: 07990064079

By engaging with ZenithWave Capital Limited, all employees, students, and contractors acknowledge and agree to comply with this policy.