anti discrimination and equal opportunity policy

version number ……………………………………………………………………….……… 1.0

date ……………………………………………………………………………………………… 1 June 2025

created by ……………………………………………………………………………...………… Kunal Kaushal

reviewed by …………………………………………………………………………...…………. Dennies Vaddakkott

approved by ……………………………………………………………………………………… Harish Rajagopalan

objective

everyone deserves to bring their full, authentic self to work — without fear of bias, judgement, or exclusion. this policy exists to make sure that at CRED, inclusion isn't just a value — it's a practice. we are committed to ensuring equal opportunity for all, regardless of gender identity, disability, sexual orientation, race, caste, religion, nationality, or any other legally protected status.

we want to create a workplace where every employee feels safe, respected, and set up for success — and this policy outlines how we do just that.

TL;DR — how we walk the talk

✅ zero tolerance for discrimination or harassment

🔍 clear redressal mechanisms for reporting issues

🧑‍🤝‍🧑 inclusive benefits for all, including transgender persons & PwDs

♿ accessible infrastructure (physical & digital)

🌈 support for gender expression, pronouns, and inclusive language

policy statement

everyone deserves a workplace where they're seen, supported, and set up to succeed.

this policy is our commitment to building an inclusive environment — one where opportunities are based on potential and performance, not personal identity. it outlines how we support individuals across the spectrum, including persons with disabilities and transgender persons.

through this policy, we aim to:

  • ✔️ support the unique needs of persons with disabilities and transgender persons at work, so they can grow and thrive at CRED
  • ✔️ eliminate all forms of bias — both direct and indirect — and set up clear ways to raise and resolve concerns
  • ✔️ build awareness and empathy among our people, so inclusion becomes part of our everyday behaviour
  • ✔️ create a safe, supportive space for everyone, especially our specially-abled employees

we also understand that no two people are the same — and that every need is personal. we're committed to assessing each situation individually, and doing our best to ensure comfort, fairness, and dignity for all.

while this policy may not anticipate every need of a person with disability, the needs of each such person shall be assessed on a case-to-case basis within the overarching objective of protecting the interests and comfort of such persons while maximising their integration at CRED

this policy aligns with applicable laws, and all decisions continue to be based on merit, potential, and qualifications.

scope

this policy applies to everyone who works with or at CRED — whether you're a full-time employee, part-time contributor, intern, trainee, consultant, or contractor.

it covers all stages of the employee experience: from hiring and onboarding to development, promotions, benefits, and everything in between.

you'll find this policy available across all our usual communication channels — and it applies wherever and however you work at CRED.

definitions

for the purpose of this policy, the following terms apply:

"complaints officer" and/or "liaison officer" refers to Mr. Ayush Shukla or any other person appointed as per this policy.

"CRED" means Dreamplug Technologies Private Limited, including all its subsidiaries and affiliates across office locations in India.

"discrimination" means:

  • – in relation to a transgender person, any unfair or unequal treatment based on gender identity, gender expression, or any other legally protected status.
  • – in relation to a person with disability, any distinction, exclusion, or restriction based on disability that impacts or has the 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.

"employee" includes anyone working at CRED — whether on a regular, temporary, ad-hoc, daily wage, contract, probation, trainee, or apprenticeship basis, and whether employed directly or through a third party.

"gender expression" refers to how someone outwardly presents their gender — for example, through clothing, hairstyle, or behavior. it may or may not align with their gender identity. gender expression may or may not conform to a person's gender identity

"gender identity" is how a person self-identifies — as a man, woman, transgender person, or any other identity, regardless of the sex assigned at birth or primary or secondary sex characteristics.

"person with disability (PwD)" means a person with long term physical, mental, intellectual or sensory impairment which, in interaction with barriers, hinders his full and effective participation in society equally with others.

"private information" includes personal details such as someone's sex, gender, gender identity, gender expression, or medical records.

"reasonable accommodation" means necessary and appropriate adjustments or modifications made to ensure persons with disabilities can access opportunities and environments equally — as long as it doesn't cause undue or disproportionate burden in a particular case.

"RPwD rules" refers to Rights of Persons with Disabilities Rules, 2017;

"RPwD act" refers to Rights of Persons with Disabilities Act, 2016;

"sex" refers to a person's biological status as assigned at birth, typically categorized as male, female, or intersex (i.e., atypical combinations of features that usually distinguish male from female).

"sexual orientation" refers to whom a person is sexually or romantically attracted to — whether of the same, different, or multiple genders.

"TP act" refers to the Transgender Persons (Protection of Rights) Act, 2019.

"TP rules" refers to the Transgender Person (Protection of Rights) Rules, 2020.

"transgender person" refers to someone whose gender identity doesn't match the gender assigned at birth. this includes trans men, trans women, intersex persons, genderqueer individuals, and those identifying as kinner, hijra, aravani, jogta, etc., whether or not they have undergone sex reassignment surgery or hormone therapy or laser therapy or such other therapy.

"transgender employee" refers to employees at CRED who identify as transgender persons.

"workplace" refers to the physical premises of CRED's offices.

📝 note: these definitions are here to support understanding — not to label. no employee is required or expected to identify within these categories. your identity is yours to define.

guidelines

🟢 equal opportunity

at CRED, every employment decision — whether it's about hiring, promotion, development, or benefits — is based only on professional capability and fit for the role.

no matter your background, ability, or identity, you'll be treated with fairness and respect throughout your journey with us.

that means:

  • ● no discrimination — ever, throughout your employment relationship, including but not limited to hiring, promotions, training and development, compensation and benefits.
  • ● everyone gets a fair shot at opportunities, support, and growth.
  • ● our environment is built to be inclusive, not just compliant.

we're committed to ensuring that:

  • ● no one is denied a role or opportunity merely on the ground of a disability or gender identity
  • ● the right tools, spaces, and support systems are in place so persons with disabilities and transgender persons can succeed
  • ● all posts and positions within the organization are open to all individuals, regardless of disability status, gender identity, or gender expression. however, in rare instances where the physical nature of duties or prevailing social conditions may reasonably and demonstrably inhibit the safe or effective performance of responsibilities — such as in the case of roles involving field-based recovery and collection activities — certain limitations may apply. any such exceptions will be assessed objectively, based on the inherent requirements of the role and in line with applicable laws and best practices on reasonable accommodation

📄 maintaining records (RPwD compliance)

we'll collect and maintain the data on employees who are persons with disabilities as required under the rights of persons with disabilities (RPwD) act and rules — and we'll keep it strictly confidential. inquiries regarding disability of employees can be made for ensuring convenience of such employee, for providing reasonable accommodation at workplace and for assessing their needs

this information will be used only to meet legal and operational requirements and will be handled with care and sensitivity.


🛡 protection from intimidation

raising your voice should never cost you your peace.

anyone who files a complaint or helps with an investigation under this policy is protected — by law and by us.

we will not tolerate:

  • ● coercion
  • ● retaliation
  • ● interference
  • ● or any form of intimidation

because speaking up should feel safe, not scary.


inclusive benefits

we believe inclusion isn't just a policy — it's a practice. and that means backing it up with real, everyday support.

🧱 physical infrastructure

we will aim to ensure that our offices are designed to be accessible for all at all times — as per the accessibility standards prescribed by applicable laws and requirements for the persons with disabilities and transgender persons

if you ever face barriers or accessibility issues, reach out to the liaison and complaints officer under this policy — we'll take it from there.


🌐 digital infrastructure

we're working to make all our digital tools and systems including communication channels easy to use for everyone. auxiliary aids, assistive tools and specialised software for accessibility shall be made available upon request.

need help navigating tech or tools? drop a note to itsupport@cred.club or contact the complaints officer.


🛠 reasonable accommodation

if you need specific adjustments to work comfortably and effectively — we've got you.

just let us know what support you need, and we'll work together to figure it out. this applies to hiring, onboarding, training, promotions — every step of your journey. all provision of reasonable accommodation shall be made on a case-to-case basis after needs evaluation and in accordance with applicable laws

we will ensure advertisements for openings at our workplace are accessible to all. do not hesitate to let our hiring representatives know of your specific needs during job applications and interviews and we will do our best to accommodate them


👔 dress code

there's no dress code that limits how you express your identity.

come as you are — wear what aligns with your gender identity and still fits within a professional environment.


🧳 accessible facilities for PwDs

we'll ensure that employees with disabilities have:

  • ✔️ accessible entrances and workstations
  • ✔️ assistive devices or tools (based on need) to help them perform their best at work
  • ✔️ support with travel or transport where possible for official and business trips
  • ✔️ preference when allocating office space and workstations
  • ✔️ presence of lifts, wheelchairs and ramps to ensure accessibility
  • ✔️ clear signages on each floor of office premises
  • ✔️ common utilities such as cafeteria, eating halls, parking, drinking water, beverages, vending machines etc. accessible without barriers
  • ✔️ as a matter of policy, CRED does not provide housing to any of its employees. however, we are happy to help you find a suitable accommodation close to your office. we will also accommodate all reasonable requests in relation to relocation in case you are moving cities to join us.

📚 training and development

growth opportunities are for everyone.

that includes leadership programs, workshops, upskilling sessions, and onboarding — with necessary accommodations like sign language interpretation or accessible content when needed and upon prior request.


📈 promotions and transfers

no one should be left behind.

employees with disabilities will get equal consideration for promotions and preference for transfers (as and when applicable) or relocations based on accessibility needs. no promotion shall be denied to an employee merely on the ground of disability. no private information of an employee shall be used to the prejudice of such employee in the course of their employment or in the promotion process.


🧑‍👧 caregiver support & special leave

we understand caregiving is real work too.

based on eligibility, CRED may offer:

  • ● special leave for employees with disabilities
  • ● caregiver/childcare leave for dependents with disabilities
  • ● education support for dependents with special needs

💼 employee benefits

all benefits at CRED apply equally — to everyone.

this includes persons with disabilities, transgender employees, and their partners, spouses, children, or other dependents, regardless of identity or physical condition.

in addition, we may:

  • ● provide health insurance that covers gender-affirming care like hormone therapy or surgeries based on eligibility and suitability to the interests of the organisation
  • ● offer counselling and mental health support for any employee who needs it

🏷 pronouns

your name and pronouns are yours to choose — and we'll respect that.

you don't need to provide a legal certificate or undergo any procedure to be addressed the way you identify.

you're encouraged to:

  • ● include your pronouns in your email signature or slack bio
  • ● let your team know how you'd like to be addressed

others are expected to honour this — no questions asked.


💬 inclusive language

we all play a role in making CRED a safe space.

that starts with how we speak and write.

everyone is expected to:

  • ● use respectful, bias-free language — always in both formal and informal occasions and channels
  • ● avoid terms or jokes that stereotype race, gender, age, or ability
  • ● hold each other accountable — kindly and clearly

any use of discriminatory language which may be derogatory or offensive to certain individuals based on their race, religion, sex, gender, colour, age, national origin and physical disability — even unintentionally — will be taken seriously and will lead to disciplinary action.


🗃️ official records

you can ask us to update your official CRED records to reflect your preferred name and pronouns. we will do our best to accommodate your request subject to applicable law

for certain government-linked records (like EPF or ESIC), legal changes may be needed before we can update your records — and we'll support you through that process where possible.


🔐 privacy & confidentiality

your private information including identity and medical history are your business.

unless disclosure is legally mandated, you may decide:

  • ● if, when, and how you want to share private information
  • ● who gets to know — and why

no one should ever ask about someone's gender identity or medical details or other private information — even casually. and if something must be shared, it'll only be with your consent and on a need-to-know basis.


🚻 restrooms

you can use whichever restroom aligns with your gender identity that is safe and appropriate according to you.

we also offer unisex restrooms and continue to expand gender-neutral and disabled friendly facilities across locations.


🛑 zero tolerance for harassment or bullying

inclusion means more than support — it means safety. we strive to maintain a safe, healthy, and productive work environment that is free from any form of harassment or discrimination from any person

we do not tolerate:

  • ● harassment
  • ● bullying
  • ● or discrimination — from anyone

our complaints officer is here to ensure fair, timely, and confidential resolution of any issue.


♿ barrier-free accessibility

we actively:

  • ● conduct regular internal checks of both physical and digital spaces to make sure they're accessible
  • ● upon request, provide or reimburse assistive devices, based on need or medical prescription to employees with disabilities

your role as a CRED employee

inclusion isn't just top-down — it's all of us, every day.

each one of us is expected to:

  • ● respect the choices, dignity, and identities of others
  • ● work with awareness of our own unconscious biases
  • ● collaborate with empathy and openness

in short: build the kind of culture we'd all want to be part of.


if this policy is breached

violating any part of this policy — by anyone at CRED or associated with us — is serious and will lead to action in line with our code of conduct and applicable laws.

if you feel you've faced discrimination (or witnessed it), speak up at the earliest practical opportunity. this includes both adverse discrimination, or impermissible positive discrimination.

you can write to: complaintsofficer@cred.club

the sooner, the better — we'll support you through the process.


liaison & complaints officer

we've appointed a dedicated officer to ensure this policy works in practice and as required under RpWD act and rules.

👤 Ayush Shukla liaison officer & complaints officer (for persons with disabilities)

📩 complaintsofficer@cred.club

📆 tenure: 2 years (renewable)

📞 contact: published on Darwinbox (employee portal)

responsibilities include:

  • ● being the nodal point of contact i.e. go-to person for PwD-related queries or concerns
  • ● ensuring we follow the RPwD act, rules and CCPD recommendations
  • ● working with HR to identify suitable improvement areas and make accommodations
  • ● periodically reviewing how this policy is working — and improving it
  • ● investigating and resolving complaints under this policy as per applicable law and our code of conduct
  • ● creating awareness about this policy and the rights and duties of individuals under this policy
  • ● designing mechanisms to protect persons from coercion, intimidation, interference, discrimination or retaliation for filing a complaint or assisting in an investigation under the applicable laws

in case of any change in the liaison and complaints officer, this policy shall be promptly updated and employees notified of the same


grievance redressal – how we support you when you speak up

we know it's not always easy to raise a concern. that's why we've designed a process that's clear, confidential, and committed to resolving things fairly.

your first point of contact: Ayush Shukla, our liaison and complaints officer

📩 complaintsofficer@cred.club

they're here to:

  • ✔️ receive and review any complaints from persons with disabilities, transgender persons, or anyone under this policy
  • ✔️ provide support — not just in resolving the issue, but also in making you feel heard and safe
  • ✔️ drive actions to build a more inclusive workplace

timelines matter — our aim is to resolve every grievance within 30 days of receiving it

all grievances lodged by employees with disabilities shall be addressed and resolved as per the applicable procedure contained in the RpWD Act and RPwD Rules. the liaison and complaints officer shall also apprise the complainant of the available remedies under such provisions.


building awareness together

we believe inclusion isn't a one-time session — it's ongoing learning.

that's why we commit to:

  • 📅 regular training sessions every year focused on disability inclusion and gender diversity and provisions of this policy
  • 🧠 awareness modules during onboarding and leadership development
  • 📣 regular comms — think posters, nudges, slack updates — to keep the conversation alive

training sessions shall be include the following themes:

  • ● promote values of inclusion, tolerance, empathy and respect for diversity;
  • ● advance recognition of the skills, merits and abilities of persons with disabilities and of their contributions to the workforce
  • ● provide orientation and sensitisation on disabling conditions and rights of persons with disabilities to employers

review & access

we'll review and update this policy every year to keep it relevant and effective.

you'll find it on the Darwinbox (employee portal), in accessible formats — and it'll be part of your onboarding too.


questions?

confused about any part of this policy? want clarity or need support?

just write to complaintsofficer@cred.club — or drop by for a chat.

this policy can be accessed on the CRED website too.