POSH policy
Policy statement & Legal Framework
The purpose of this Policy is as follows :-
1.1 This Policy is framed under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and the Rules framed thereunder, which codified the principles laid down by the Hon’ble Supreme Court of India in Vishaka v. State of Rajasthan (1997) 6 SCC 241. This Policy shall be governed by and interpreted in accordance with the provisions of the PoSH Act, 2013 and the applicable Rules.
1.2 The fundamental objective of this policy is to prevent, prohibit, and redress incidents of sexual harassment in accordance with the principles of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and to uphold a zero-tolerance approach, while ensuring that all complaints are addressed through fair, impartial, and legally compliant processes consistent with the principles of natural justice.
1.3 To undertake a fair, impartial, and timely inquiry into complaints of sexual harassment, to provide appropriate support to the Complainant during the pendency of the inquiry, and to take disciplinary action against the Respondent where allegations are established in accordance with the provisions of the POSH Act, 2013 and the principles of natural justice.
1.4 To inform employees that Cateina Technologies is committed to providing a work environment that is free from sexual harassment and gender-based discrimination, and to addressing such concerns through the mechanisms established under this Policy, in accordance with applicable law.
1.5 Cateina Technologies recognizes its responsibility as an employer under Articles 14, 15, and 21 of the Constitution of India and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, to provide a workplace free from sexual harassment. Sexual harassment, often invisible and under-reported, is a serious violation of dignity and equality. This Policy provides a structured framework to prevent, prohibit, and redress sexual harassment across all levels of the organisation.
1.6 Cateina Technologies shall ensure effective implementation of this Policy in compliance with the PoSH Act, 2013 and applicable employment laws.
1.7 Cateina Technologies is committed to implementing the procedures mandated under the PoSH Act, 2013, including the constitution of a legally compliant Internal Committee, the training and sensitization of all employees on what constitutes sexual harassment, the procedures for lodging complaints, and the process for fair, timely, and and ensuring confidentiality of proceedings as mandated under the Act by the Internal Committee.
1.8 Cateina Technologies is a gender friendly workplace. While the statutory protections under the PoSH Act, 2013 are available to women, Cateina Technologies has extended a discretionary internal redressal mechanism for complaints from all genders, without diluting or substituting the statutory framework. The Policy is gender-neutral and applies to all genders.
1.9 While the statutory framework under the PoSH Act, 2013 applies specifically to complaints of sexual harassment against women, Cateina Technologies has extended the jurisdiction of its Internal Committee to examine complaints of gender-based discrimination or related misconduct through an internal, non-statutory mechanism. Such extension shall not dilute or substitute the statutory rights and remedies available under the PoSH Act.
Scope and Applicability
This Policy applies to:
2.1 all employees of Cateina Technologies, irrespective of their seniority, designation, or nature of employment, including permanent, temporary, contractual, probationary, interns, trainees, and casual employees, while at the workplace or at any place arising out of or in the course of employment.
2.2 all members of the Board, including executive and non-executive Directors, owners, promoters, and shareholders, insofar as their conduct has a nexus to the workplace or arises out of employment-related interactions.
2.3 all contractors, sub-contractors, consultants, service providers, and personnel engaged through third-party agencies, while engaged in work or services connected with the workplace.
2.4 all applicants for employment, during any stage of the recruitment, selection, or interview process, and
2.5 conduct by or against persons who interact with employees of Cateina Technologies in the course of work, including clients, customers, suppliers, visitors, and business associates, whether such interaction occurs in person, by telephone, or through electronic or digital means.
2.6 This Policy shall also apply to conduct occurring during work-related travel, training programs, conferences, offsite meetings, official social events, or any other circumstances arising out of or in the course of employment.
2.7 This Policy applies irrespective of whether employees are working from office premises, client locations, or under remote, hybrid, or virtual working arrangements.
2.8 In addition to complaints of sexual harassment governed by the PoSH Act, 2013, this Policy also extends to complaints of gender-based discrimination or related misconduct through an internal, non-statutory mechanism, as provided under Section 1 of this Policy.
Definitions
3.1 Workplace: For the purposes of this Policy, “Workplace” includes:
3.1.1 All offices, branches, or other premises where the Company’s business is conducted, including work carried out through virtual, remote, hybrid, or digital working environments, where such work arises out of or in the course of employment.
3.1.2 Any place visited by an employee arising out of or during the course of employment, including client sites, training locations, conferences, meetings, or work-related travel; and
3.1.3 Any social, business, or other functions or events where the conduct or comments may have a connection with, or an adverse impact on, the workplace or workplace relations.
3.2 Sexual Harassment: “Sexual Harassment” includes any one or more of the following unwelcome acts or behaviour (whether directly or by implication)::
(a) Physical contact and advances of a sexual nature;
(b) A demand or request for sexual favours;
(c) Making sexually coloured remarks;
(d) Showing pornography;
(e) Any communication, gesture, or invitation of a sexual nature; or
(f) Any other unwelcome conduct of a sexual nature, whether physical, verbal, non-verbal, or digital.
Sexual harassment is determined by the unwelcome nature and impact of the conduct on the aggrieved person, and not by the intent of the respondent. Conduct may constitute sexual harassment even if it occurs once or repeatedly, and even if the respondent believes the behaviour to be harmless or consensual.
3.3 Employer: “Employer” means any person or authority responsible for the management, supervision, and control of the workplace, including authorised representatives of Cateina Technologies at the management level, to whom the Internal Committee submits its inquiry report and recommendations.
3.4 Employee: “Employee” means any person employed by Cateina Technologies for any work, whether on a permanent, temporary, contractual, ad-hoc, part-time, probationary, or daily wage basis, either directly or through an agent, including a contractor, consultant, intern, or trainee, with or without the knowledge of the organisation.
3.5 Aggrieved Person: “Aggrieved Person” means any individual who alleges to have experienced sexual harassment at the workplace.
3.6 Complainant: An Employee or a third party/person who submits a complaint of sexual harassment at the workplace in writing to the Internal Committee.
3.7 Respondent: A person against whom a complaint of sexual harassment at the workplace is made by the Complainant in writing to the Internal Committee.
3.8 Witness: For the purpose of this Policy refers to any individual, whether from within or outside the organisation, who is identified by the Complainant, the Respondent, or the Internal Committee as having information relevant to the complaint or inquiry.
3.9 Quorum: For this Policy, quorum means the minimum number of members of the Internal Committee required to be present to validly conduct proceedings, which shall be in accordance with the PoSH Act, 2013, and shall include the Presiding Officer and at least two other members, one of whom shall be the External Member.
3.10 Principles of Natural Justice: For the purpose of this Policy refers to the fundamental procedural safeguards to ensure fairness in inquiry proceedings, including the right of both parties to be heard, the absence of bias, equal opportunity to present evidence, and reasoned decision-making by the Internal Committee.
Meaning And Forms of Sexual Harassment
4.1 For the purposes of this Policy, the term “Sexual Harassment” shall have the meaning assigned to it under Section 3 of this Policy.
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4. 2 FORMS OF SEXUAL HARASSMENT
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4.2.1 Quid Pro Quo: Quid pro quo sexual harassment refers to situations where employment-related benefits such as recruitment, promotion, remuneration, performance appraisal, training opportunities, assignments, or continued employment are directly or indirectly conditioned upon submission to sexual advances, or where adverse consequences are threatened or imposed for refusal.
4.2.2 Hostile Work Environment: 'Hostile working environment' is a more pervasive form of sexual harassment involving work conditions or behaviour that make the work environment 'hostile' for the individual to be in.
4.2.3 Verbal harassment: Verbal conduct that includes making or using derogatory comments, using obscene or vulgar language, epithets, slurs, or jokes, Eve teasing, sexual advances or propositions, unsavoury, offensive or suggestive remarks, jesting, sounds, questioning, graphic verbal commentaries about an individual’s body, using sexually degrading words to describe an individual.
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4.2.4 Non-verbal harassment: Non-verbal communication such as gestures of a sexual nature, removal of clothing to display parts of the body (flashing), leering or ogling with suggestive overtones, licking lips, holding, or eating food provocatively, hand signal or sign language denoting sexual activity, persistent flirting.
4.2.5 Visual harassment: Visual conduct that includes leering, displaying pornographic materials, drawing sex-based sketches, or writing sex-based letters, sexual exposure, making sexual gestures, or displaying of sexually suggestive objects or pictures, cartoons, or posters, suggestive or obscene letters, emails, texts, SMS, chat messages, notes, or invitations. Other examples include: following, stalking, persistent visiting, telephoning, sending of cell-phone messages, or other invasions of personal privacy, making intrusive inquiries into the private lives of employees, or persistently asking them out, repeated unwanted social invitations, relentless proposals for dates or physical intimacy, gender based insults, sexist remarks, indirect sexual comments and taunts, jokes that are demeaning to women and cause embarrassment, devaluation of women’s work, comments on appearances, clothing and character of women, comments about personal behaviour or a person’s body either alone or in front of others in a group, and especially where there is a gender imbalance in the group such as a single woman in a group of men, group of employees who joke and snigger amongst themselves about sexual orientation of another employee in an attempt to humiliate or embarrass the other employee.
4.2.6 Physical harassment: Physical conduct that includes molestation, touching, assaulting, impeding, or blocking movements, patting, pinching, stroking, brushing up against any part of the body, hugging, kissing, fondling, sexual assault, holding onto a hand or arm longer than is necessary.
With technological advances, there are increased opportunities for the communication of sexually offensive verbal and visual images; therefore, this policy anticipates a range of communication, all of which will be regarded as offensive regardless of the format or style of the communication, or whether the technology exists at the time of the publication of this policy.
4.2.7 Assessment of Unwelcome Conduct: Sexual harassment is determined based on whether the conduct was unwelcome and whether it had the effect of violating the dignity of the aggrieved person or creating an intimidating, hostile, or offensive work environment. While the perception of the aggrieved person is relevant, the Internal Committee shall assess the circumstances objectively, applying the standard of preponderance of probability and the principles of natural justice.
Internal Committee
According to the POSH Act, when the organisation reaches 10 or more employees, it's mandatory to form an Internal Committee (IC) and display the names, roles within the IC, and contact details of its members in both the policy document and within the office premises. Please find below the current members of IC and the same is available in the office notice board.
Responsibility of Internal Committee
6.1.1 The Internal committee is responsible for ensuring that the allegations are dealt with timeously, with due seriousness and confidentiality; and that the allegations are dealt with in a manner which achieves a resolution of the behaviour, rather than in a mechanistic procedural manner.
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6.1.2 Investigate every formal written complaint of sexual harassment.
6.1.3 Take appropriate remedial measures to respond to any substantiated allegations of sexual harassment
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6.1.4 Discourage and prevent employment-related sexual harassment.
6.1.5 Empathy: It is critical that the Internal Committee empathises with the complainant and does not judge the individual by their moral standards. The Internal Committee shall assess the evidence impartially, without bias or predisposition, and determine findings based on the material on record.
6.2. DO's
6.2.1 Ensure complaints are handled sensitively and confidentially, as mandated under Section 16 of the POSH Act, 2013.
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6.2.2 Conduct meetings with the complainant in a private, safe, and respectful setting that promotes trust.
6.2.3 Treat all parties with dignity and fairness during the inquiry process.
6.2.4 Focus on the impact of the alleged behaviour on the complainant and whether it was unwelcome.
6.2.5 Ensure inquiry proceedings follow principles of natural justice — fair hearing to both parties, unbiased inquiry, and reasoned findings.
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6.2.6 Document all proceedings and interactions accurately.
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6.2.7 Provide timely assistance and support to the complainant, including guidance on criminal complaints if requested.
6.3. DON'TS
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6.3.1 Do not predetermine the outcome based on personal biases or stereotypes.
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6.3.2 Do not delay the inquiry process; adhere to the 90-day timeline for inquiry completion as per Section 11(4) of the POSH Act.
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6.3.3 Do not breach confidentiality or share complaint or inquiry details with unauthorized persons; doing so may attract a penalty under Rule 12 of the POSH Rules, 2013.
6.3.4 Do not focus solely on the respondent’s intention; while it may be considered, give primary importance to the impact of the behaviour on the complainant.
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6.3.5 Do not insist on proof beyond reasonable doubt; POSH inquiries follow the preponderance of probability standard (i.e., what is more likely than not).
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6.3.6 Do not allow any form of retaliation or victimisation of the complainant, witnesses, or others involved in the inquiry.
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6.4. IMPORTANCE OF INTERNAL COMMITTEE
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6.4.1 Points to be borne in mind while investigating into the matter.
6.4.1.1 It needs extensive orientation for effective functioning.
6.4.1.2 The complainant, when complaining, has staked his/her personal life and career.
6.4.1.3 The impact sexual harassment has on any individual.
6.4.1.4 It is difficult for any individual to talk about anything sexual. Hence there may be a long time interval between the harassment and the actual complaint.
Reporting
7.1 If any employee experiences or witnesses sexual harassment in the workplace, they should report it immediately to the Internal Committee.
7.2 Employees can raise concerns and make reports without fear of reprisal or retaliation.
7.3 Where to report? - Please email to IC@cateina.com or raise a complaint through the Conduct platform. https://app.getconduct.in
7.4 Complaint email must include (Description of incident, Date and time, Respondent's name and parties working relationship/Respondent's designation).
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7.5. The time period for filing the complaint is 90 days from the date of incident, extended to further 90 days as per law basis valid reason.
Overview
Complaints may be resolved either through (a) conciliation (only at the written request of the aggrieved employee, before inquiry begins) or (b) a formal inquiry by the Internal Committee (IC). The IC shall adhere to the principles of natural justice and conduct a fair, timely, and confidential process.
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8.1 Raising/filing a complaint
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8.1.1 Lodging a complaint - A complaint of sexual harassment shall be made in writing to the IC within 3 (three) months from the date of the incident, and in case of a series of incidents, within 3 (three) months from the date of the last incident. The IC may extend this timeline by a further period of 3 (three) months, if it is satisfied that circumstances prevented the Complainant from filing within time.
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8.1.2 Complaint filing channel and contents of complaint: The employee may lodge a complaint either by emailing to IC@cateina.com or through the GetConduct platform. The complaint should be in writing, preferably no later than 3 months from the date of the incident or last date of the incident. The Complaint letter must include the following:-
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Description of incident/s
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Date, Time and Place of the incident
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Name of the Respondent
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Parties working relationship (Designation)
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Witness name with their contact details. if any.
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Any evidence.
8.1.3 Assistance for written complaint: If the Complainant is unable to make the complaint in writing, the IC shall provide reasonable assistance to reduce the complaint to writing.
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8.1.4 Complaint filing through a representative (as permitted under Rules): Where the Complainant is unable to file the complaint due to physical or mental incapacity or death, the complaint may be filed by a legal heir / relative / friend/co-worker or any person knowing about the incident, in the manner permitted under the POSH Rules, 2013.
Compliant Handling Process
9.1 Process after receipt of complaint:
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9.1. 1 Acknowledgement: The IC shall acknowledge receipt of the complaint within 48 hours and schedule a first interaction with the Complainant at the earliest (within 7 working days from the receipt of the complaint), to understand the facts, clarify missing information, and explain next steps.
9.1.2 Forwarding to Respondent: Within 7 (seven) working days of receipt of the complaint, the IC shall forward a copy of the complaint to the Respondent.
9.2 CONCILIATION
9.2.1 What is Conciliation? Conciliation is a voluntary process provided under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, whereby the Complainant may seek an amicable resolution of the complaint, without proceeding to a formal inquiry. Conciliation is intended to facilitate resolution where the Complainant prefers settlement over adjudication.
9.2.2 When Conciliation may be initiated? Conciliation may be initiated only upon a written request made by the Complainant to the Internal Committee, and prior to the commencement of the formal inquiry. The Internal Committee shall not initiate conciliation suo motu, nor shall it compel or pressure either party to opt for conciliation.
9.2.3 Nature of conciliation process: Where a written request for conciliation is received:
9.2.3.1 The Internal Committee shall facilitate discussions between the Complainant and the Respondent in a neutral and non-coercive manner;
9.2.3.2 The process shall be confidential and conducted with due sensitivity.
9.2.3.3 Participation in conciliation shall be entirely voluntary for both parties.
9.2.4 What cannot form part of Conciliation?: No monetary settlement shall form the basis of conciliation. Conciliation shall not result in any agreement that is unlawful, coercive, discriminatory, or contrary to the provisions of the PoSH Act, 2013.
9.2.5 Settlement and recording: If a settlement is arrived at through conciliation:
9.2.5.1 The terms of settlement shall be recorded in writing;
9.2.5.2 Both parties shall sign the settlement;
9.2.5.3 A copy of the settlement shall be provided to the Complainant and the Respondent;
9.2.5.4 The Internal Committee shall forward the settlement to the Employer for implementation.
Upon settlement under this Section, no further inquiry shall be conducted by the Internal Committee in respect of the same complaint, in accordance with Section 10(4) of the PoSH Act, 2013.
9.3 INQUIRY:
9.3.1 Investigation – The Internal Committee shall examine the Complainant, the Respondent, and relevant Witnesses in accordance with the principles of natural justice.
9.3.2 Interim measures during pendency of inquiry: During the pendency of the inquiry and upon written request of the Complainant, the Internal Committee may recommend to the Employer:
9.3.2.1 Change in reporting lines or work arrangements;
9.3.2.2 Grant of leave to the Complainant up to three months in addition to existing leave;
9.3.2.3 Transfer of either party;
9.3.2.4 Any other appropriate measure to ensure a safe working environment.
The Employer shall implement such recommendation promptly from the date of receipt of IC’s written interim recommendation.
9.3.3 The Internal Committee shall also review any/all pertinent evidence, documents and records.
9.3.4 Final Report - The Internal Committee will prepare a written report regarding the findings, conclusions and recommendations for the disciplinary action to be taken. This report shall be furnished to the Management of the company, the complainant, and the respondent. The report shall be submitted to the management within the timeline mentioned below
90 days to complete inquiry + decide findings and 10 more days to submit the report formally
The report has to be drafted and submitted in 10 days and not later than 90 days from the date of
receipt of the complaint. The Chief Executive Officer and Directors will ensure corrective action on the recommendations of the Internal Committee.
9.4 Outcome - When the investigation is completed, the concerned employee will be informed of the outcome of the investigation. The recommendations of the Internal Committee shall be binding on the Employer and shall be implemented within sixty (60) days from receipt of the inquiry report. The Employer shall inform the Internal Committee of the action taken.”
9.4.1 In the event, after investigation, the allegation does not fall under the purview of Sexual Harassment, or the allegation does not constitute an offence of Sexual Harassment, the findings will be recorded with reasons and communicated to the complainant. If the Internal Committee determines that the allegations constitute an act of sexual harassment, they will proceed to investigate the allegation.
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9.4.2. CORRECTIVE ACTION
9.4.2.1 If the Internal Committee (IC) concludes, after conducting an inquiry in accordance with the POSH Act, 2013, that sexual harassment has occurred:
The IC shall recommend appropriate action against the respondent, which will be treated as misconduct under the company’s service rules.
Recommended actions may include, but are not limited to:
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Written apology
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Warning or reprimand
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Censure
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Withholding of promotion or pay raise
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Suspension without pay
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Transfer or change of role
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Demotion
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Termination of employment
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Deduction from salary or wages for payment of compensation to the complainant, as determined by the IC under Section 13(3)(ii) of the POSH Act
9.4.2.1.2 If the IC concludes that the complaint was maliciously false, or that any complainant or witness knowingly produced forged or misleading documents or evidence, the IC may recommend appropriate action against such individual, following a separate inquiry as required under Section 14 of the POSH Act.
9.4.2.1.3 It is clarified that inability to substantiate a complaint, or the mere dismissal of a complaint, does not attract action against the complainant.
9.4.2.1.4 All corrective actions recommended will be proportionate to the gravity of the misconduct, in accordance with principles of natural justice, and implemented by the employer in a timely manner.
9.4.3. DISCIPLINARY ACTION
DISCIPLINARY ACTION MAY INCLUDE THE FOLLOWING:
9.4.3.1 Warning - repeated incidents of less serious behaviour or more serious behaviour may lead to a warning or a final warning to the respondent and a copy of it will be maintained in the employee’s file.
9.4.3.2 Transfer / Change of work assignment of either the respondent or the aggrieved – Sanctions to avoid dismissal such as transfer to a different position or department may be considered, where appropriate and where possible within the company structure and depending upon the nature of the work undertaken by the complainant and the person responsible for the behaviour. If transfer of one of the employees is involved, the person required to move shall be the respondent not the aggrieved.
9.4.3.3 Suspension or termination of the employee found guilty of the offence - serious incidents of sexual harassment may lead to summary dismissal and immediate termination
9.4.4 Legal action includes the following:
9.4.4.1 If conduct, of the accused, amounts to a specific offence under the law, Cateina Technologies shall initiate appropriate action in accordance with law by making a complaint with the appropriate authority.
9.4.4.2 The severity of the corrective action shall be determined by the severity and/or frequency of the offence(s).
9.4.5 Malicious Complaint: Anyone who abuses the procedure (for example, by maliciously putting an allegation knowing it to be untrue) will be subject to disciplinary action. In case the complaint is found to be false, the Complainant shall, if deemed fit, be liable for appropriate disciplinary action by the Management.
9.5 Non-Cooperation and Ex-Parte Proceedings
If either party fails to appear before the Internal Committee for three consecutive hearings without sufficient cause, the Committee may proceed ex-parte or terminate proceedings.
Prior to doing so, written notice of at least fifteen (15) days shall be issued to the concerned party.
Documentation and Record Keeping
10.1 The Internal Committee shall document all the results of sexual harassment complaint or investigation and the corrective action. Follow up on any corrective action with the respondent’s supervisor and document the same so that the employee doesn’t take advantage of companies polices/procedures, and to prevent sexual harassment from occurring again in the future.
10.2 The documents will be filed in sealed envelopes marked confidential and lodged with the HR Manager or the person responsible for the retention of personnel records.
Confidentiality
11.1 All allegations of sexual harassment will be quickly and discreetly investigated.
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11.2 At all stages of the procedures, informal and formal, and from the first discussions when the potential allegations of sexual harassment are discussed, all parties to the discussion are required to be aware of the sensitivity of the matters under discussions, the potential impact on individual lives and careers, and to exercise extreme caution in the disclosure of the information, and where possible to maintain the confidentiality of the receiver/complainant and the person responsible for the behaviour.
11.3 To the extent possible, confidentiality of the employee, that of any witnesses and the alleged respondent will be protected against unnecessary disclosure. Any person who shares or discloses information about a complaint, inquiry, or related proceedings in violation of this policy and the law will have to pay a penalty of ₹5000 as per Rule 12 of the POSH Rules, 2013. This is in addition to any disciplinary action under the company’s service rules
11.4 All persons involved in seeking resolution of the unwelcome behaviour will respect the dignity and confidentiality of the persons involved.
11.5 All complaints of sexually offensive behaviour shall be brought to the attention of the Internal Committee immediately.
Protection to
Complainant &
Aggrieved
Cateina is committed to ensuring that no employee who brings forward a harassment concern will be subject to any form of reprisal. Any reprisal will be subject to disciplinary action. The Company will ensure that the Complainant or witnesses are not victimized or discriminated against while dealing with complaints of sexual harassment.
Offense by Third party
Where sexual harassment occurs because of an act or omission by any third party or outsider, the Internal Committee and the person’s in-charge shall take all steps necessary and reasonable to assist the affected employee in terms of support and preventive action.
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However,
Appeal: Any person aggrieved by the recommendations of the Internal Committee may prefer an appeal in accordance with Section 18 of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 within ninety (90) days.
Health, Support
& Counselling
Physical and Mental Health
14.1 Sexual harassment can have a devastating effect upon the health, confidence, morale, and performance of those affected by it. The anxiety and stress produced by sexual harassment commonly leads to those subjected to it taking time-off work due to sickness, being less efficient at work, or leaving their job to seek work elsewhere.
14.2 The Internal Committee may seek appropriate professional advice and arrange for trauma counselling for the complainant and aggrieved; where this is required the initial trauma counselling shall take place within a few days of the incident; follow-up counselling over a longer period may also be necessary.
14.3 Leave of absence may be necessary, and Management will give permission for this, and if the complainant’s leave entitlement is exhausted, additional leave may be granted.
Prevention, Awareness &
Compliance
Cateina Technologies is committed to preventing sexual harassment at the workplace through structured, institutional, and statutory measures in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.
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15.1 Employer’s Preventive Responsibility
In order to discharge its statutory obligation under Section 19 of the PoSH Act, the Employer shall:
(a) Provide and maintain a safe working environment free from sexual harassment;
(b) Display at conspicuous places in the workplace the penal consequences of sexual harassment and the details of the Internal Committee members;
(c) Organise regular awareness and sensitisation programmes for employees;
(d) Provide orientation and capacity-building programmes for members of the Internal Committee;
(e) Assist in securing the attendance of Respondents and witnesses before the Internal Committee;
(f) Provide necessary facilities to the Internal Committee for conducting inquiries;
(g) Monitor timely submission of reports by the Internal Committee;
(h) Ensure timely implementation of recommendations made by the Internal Committee;
(i) Include in the annual report the number of cases filed and disposed of, as required under the Act.
15.2 Employee Responsibility
Every employee shall:
(a) Refrain from engaging in conduct that may amount to sexual harassment;
(b) Cooperate with the Internal Committee during any inquiry;
(c) Maintain confidentiality in accordance with this Policy and the Act;
(d) Respect the dignity and rights of others at the workplace.
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15.3 Awareness and Training
The Company shall:
(a) Conduct periodic awareness sessions for all employees regarding the provisions of this Policy;
(b) Ensure that new employees are informed of this Policy during induction;
(c) Provide specialised training to managers and Internal Committee members to ensure fair and legally compliant handling of complaints.
Conclusion
In conclusion, Cateina Technologies reiterates its commitment to providing its employees, a workplace free from any form of sexual harassment and where every employee is treated with dignity and respect.
Annexure
In conclusion, Cateina Technologies reiterates its commitment to providing its employees, a workplace free from any form of sexual harassment and where every employee is treated with dignity and respect.

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