Our policies, management and internal controls have been strengthened over time, with inputs and recommendations from periodic reviews as well as from adapting best practices from peers, and of course in strict compliance with the laws and regulations of the Government of India. We of course will continue to learn and adopt best practices in particular, those that make us effective in our work and accountable.

Our key policies are as follows:

Preface
CSE maintains a robust internal culture that actively discourages nepotism, illegal, actions, and corruption. Our internal systems incorporate checks and balances to prevent such practices, alongside a staff grievance policy.

However, we recognize the need for a formalized whistleblower policy to empower staff to report any concerns without fear of personal repercussions. Responsibility in utilizing this policy is crucial to avoid trust abuses and organizational misunderstandings. To ensure accountability, the policy mandates that the reporting staff member not remain anonymous, while management must handle complaints carefully to protect the whistleblower's identity.

What is a whistleblower?
A whistleblower is a staff member (including employees on payroll and on contract) reporting someone else's wrongdoing, whether it's a past act, ongoing, or in the planning stages.

Why do we need this policy?
The policy establishes a framework to promote responsible and secure whistle blowing, safeguarding directors and employees raising concerns about serious irregularities within the institution. (ii) It doesn't release directors and employees from their duty of confidentiality or serve as a route for personal grievances, which are handled separately through CSE's staff grievance systems.

What does the policy cover?
The policy addresses malpractices involving:
Abuse of authority b. Breach of contract c. Negligence causing substantial danger to public health and safety d. Manipulation of institution data/records e. Financial irregularities, including fraud or suspected fraud f. Criminal offenses g. Pilferage of confidential/proprietary information h. Deliberate violation of law/regulation i. Wastage/misappropriation of institution funds/assets j. Breach of employee Code of Conduct Policy or any other unethical event

This policy must not be used for malicious or unfounded allegations against colleagues.

Procedure to lodge a complaint:
CSE staff/employees may submit complaints to the designated official, currently the HR Head, regardless of their designation, type of employment, or location. Complaints can be submitted in writing, in person or via a sealed envelope, with the complainant's name and signature. Anonymous complaints will not be entertained. Complaints from external sources can be sent through email or a sealed envelope addressed to the Director General or the Executive Director (P&O). If deemed necessary, the HR head can ask the Director General for constitution of a committee to look into the matter.

The complaint will receive a written acknowledgment, and detailed information is required to facilitate the investigation.

How will CSE address the complaint?
CSE will ensure immediate hearing of the complainant and create a detailed written record including facts, previous complaints, financial implications, and findings. The complaint should be resolved within 15 working days, unless certain circumstances require more time.

Guiding principles during investigation:
a. Prevent victimization of the complainant or investigating committee members. b. Treat victimization seriously, initiating disciplinary action if necessary. c. Maintain complete confidentiality. d. Take disciplinary action against anyone destroying or concealing evidence. e. Provide an opportunity for all involved parties to be heard. f. Communicate the findings and decisions of the Investigation Committee within 15 days. g. If the complaint warrants investigation by a committee the DG will update both the CSE Board and the relevant donor. Furthermore, CSE will also communicate the investigation outcomes to the CSE Board and the concerned donor, unless restricted by law.

Disqualifications:
Whistleblowers making complaints found to be mala fide, frivolous, or malicious will be held liable under CSE's Code of Conduct.

Definition
Conflict of interest is a situation in which an individual's private interests conflict with their professional or official responsibilities. In official terms, conflicts of interest can be described as any scenario where an individual or organization may exploit a professional or official capacity for personal or organizational gain.

Purpose of the Policy:
This policy aims to safeguard the organization's name, reputation, and integrity. It establishes procedures to prevent impropriety charges involving officers, directors, or trustees by prohibiting staff and board members from using their job title, position, or the organization's name or property for private profit or benefit.

Situations Leading to Conflict of Interest:
Conflicts of interest may not always be obvious, but any situation that might make an impartial observer question the influence of private interests on actions is considered. Examples include involvement in CSE processes affecting personal relationships, external organizations conflicting with CSE, and financial gains related to CSE activities.

Duty to Disclose:
If unsure about a potential conflict of interest, individuals should discuss the matter with their director, unit head, or HR director. Failure to disclose a conflict may result in penalties. When conflicts arise, the responsible person will review and provide guidance, potentially requiring withdrawal from certain activities.

Procedure to Determine and Resolve Conflicts:
Disclosure alone is insufficient; the policy requires addressing conflicts. After disclosure, a committee, formed by the Director General, will follow procedures similar to the Whistle Blower Policy to address and resolve the issue. This involves treating information with confidentiality, seeking guidance, making pragmatic decisions, communicating decisions, and retaining documentation.

Defining Corruption:
Corruption, defined as the misuse of entrusted power for private gain, encompasses bribery, fraud, embezzlement, and extortion. This policy addresses the various forms of corruption to maintain good governance, sustainable development, democratic processes, and fair business practices.

The Target Group:
This policy applies to all CSE employees, requiring adherence to prevent breaches. CSE, entrusted with funds from various donors, holds the responsibility to avoid corruption and ensure transparent fund utilization.

The Purpose:
This policy aims to promote behavior characterized by high standards of personal and organizational integrity, both internally and with external stakeholders.

Various Aspects of Corruption:
Corruption manifests in different forms, including conflicts of interest, abuse of power, extortion, fraud, embezzlement, bribery, nepotism, favoritism, and gifts and hospitality.

Conflict of Interest:
CSE employees must avoid conflicts between personal and organizational interests, managing them judiciously. Principles in this regard are outlined in CSE's conflict of interest policy.

Abuse of Power and Extortion:
Employees must refrain from using their official position for personal gain and avoid using CSE resources for private purposes without permission. Extortion in any form is strictly prohibited.

Fraud and Embezzlement:
Fraud and embezzlement, defined as illegal methods for personal gain, are strictly forbidden concerning CSE or any stakeholders.

Bribery:
Giving or accepting bribes in any form is prohibited, emphasizing cooperation based on mutual ownership, accountability, participation, equality, harmonization, and alignment.

Nepotism and Favoritism:
Favoring friends, family, or personal relations in recruitment, procurement, or aid delivery is strictly prohibited. Exceptions can be made if conflicts of interest are handled appropriately.

Gifts and Hospitality:
Accepting gifts that may influence judgment is discouraged. Cash gifts are never accepted, and employees are expected to use good judgment, consulting with superiors when in doubt.

Solicitation:
No staff should engage in coercing or enticing others to commit bribery or other crimes, emphasizing the prevention of such acts. This anti-corruption policy encourages ethical conduct and emphasizes accountability among CSE employees.

Procedure to lodge and address a complaint
CSE staff/employees may submit complaints to the designated official, currently the HR Head, regardless of their designation, type of employment, or location. Complaints can be submitted in writing, in person or via a sealed envelope, with the complainant's name and signature. Anonymous complaints will not be entertained. Complaints from external sources can be sent through email or a sealed envelope addressed to the Director General or the Executive Director (P&O). If deemed necessary, the HR head can ask the Director General for constitution of a committee to look into the matter. The complaint will receive a written acknowledgment. CSE will ensure immediate hearing of the complainant and create a detailed written record including facts, previous complaints, financial implications, and findings. The complaint should be resolved within 15 working days, unless certain circumstances require more time.

Policy Statement
CSE is dedicated to fostering a secure working environment for all employees, free from discrimination and harassment, including sexual harassment. The organization maintains a zero-tolerance stance against any form of sexual harassment, conducting thorough and timely investigations into all allegations. Victimizing individuals who file complaints is strictly prohibited. Disciplinary actions up to and including termination, will be taken against anyone found guilty of sexual harassment. CSE adheres to the guidelines outlined in the Prevention of Sexual Harassment (POSH) Act of 2013.

What is POSH?
POSH, or the Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013, is a pioneering legislation addressing the prevention, prohibition, and redressal of sexual harassment at the workplace. Enforced from December 9, 2013, the Act is binding on all organizations, public or private, with more than 10 employees.

Definition of Sexual Harassment
Sexual harassment involves unwelcome conduct of a sexual nature that causes offense, humiliation, and/or intimidation. It encompasses situations where sexual activity is coerced as a condition of employment and environments that are hostile, intimidating, or humiliating. Examples of sexual harassment include physical, verbal, and non-verbal conduct.

CSE acknowledges that sexual harassment often arises from power imbalances in the workplace, such as those between managers or supervisors and employees. The policy applies to all individuals associated with CSE, including employees, clients, customers, casual workers, contractors, or visitors.

Setting up Internal Complaints Committee (ICC)
Initially named ICC (Internal Complaints Committee), the committee was later substituted by Internal Committee (IC) on May 9, 2016, broadening its role beyond complaint resolution. As per the POSH Act, organizations with 10 or more employees must establish an ICC for sexual harassment redressal. The IC submits an annual report to the employer and the District Officer.

CSE's Internal Complaints Committee Details
CSE, in compliance with the POSH Act, has constituted an Internal Complaint Committee to address sexual harassment complaints. The current ICC members are as follows:

Presiding Officer:
Ms. Anumita Roy Chowdhury
Email: anumita@cseindia.org

External Member:
Ms. Ratna Appnender

Member:
Mr. Saroj Kumar Sahoo

Member:
Ms. Sushma Malik

Training for ICC
This training is essential for ICC members to gain insight into the POSH Act, understanding its formation, functioning, powers, responsibilities, and the redressal system.

Complaints Procedure
Victims are encouraged to inform the alleged harasser that the conduct is unwelcome. However, if this is not possible, victims can approach HR or designated ICC staff for complaint resolution. The procedure includes:

• Recording incident details.
• Ascertaining the victim's desired outcome.
• Explaining CSE's procedures.
• Offering informal or formal resolution options.<
• Maintaining confidentiality.
• Respecting the victim's choice.
• Informing about three complaint resolution methods.
• Informal Method of Complaint Resolution
• If the victim opts for an informal resolution, the designated person:
• Allows the alleged harasser to respond.
• Facilitates discussion for an acceptable resolution.<
• Keeps confidential records.
• Follows up on the resolution's effectiveness.
• Formal Method of Complaint Resolution (Within Office)
• If the victim pursues a formal complaint, the designated person refers the matter to the HR Head for investigation, either handled internally, externally, or by the ICC.
• Formal Method of Complaint Resolution (Outside Office)
• Victims can also file complaints outside CSE, utilizing national mechanisms available to them.
• Redressal Process

Conciliation:
• ICC may attempt conciliation if requested by the complainant.
• Monetary settlement cannot be made the basis of such conciliation. In case a settlement has been arrived at, the ICC shall record it and forward it to the CSE to take action as specified in the recommendation of the ICC.
• If successful, ICC records and forwards the settlement to CSE.
• If unsatisfied, the complainant can request an inquiry.

Inquiry:
• Conducted when conciliation fails.
• ICC forwards the complaint to the respondent, who responds within 10 working days.
• Hearing principles of natural justice are followed.
• Inquiry completion within 90 days.
• ICC provides a report with findings and recommendations within 10 days of completion of the enquiry.

Inquiry Report and Actions:
• No action if allegations are unproven.
• Recommendations for actions if allegations are proven.
• Actions include written apology, warning, reprimand, suspension, termination, or legal action.
• ICC's recommendations implemented within sixty days.

Compensation:
Determined based on mental trauma, loss in career opportunity, medical expenses, and perpetrator's income and status.

Interim Relief:
ICC may recommend workplace transfer, leave, or other relief during the inquiry.

Malicious Complaint:
ICC may recommend action against a complainant for malicious intent or false allegations.

Appeal Against Recommendations of ICC:
Individuals aggrieved by ICC recommendations can appeal to the appropriate authority.

Penalty for Non-Compliance of POSH Act:
Organizations violating the POSH Act may face fines of up to ₹50,000.

Amendments:
• CSE reserves the right to amend the policy to comply with evolving laws and regulations.
• Implementation of This Policy
• All new employees undergo training on this policy during their induction as part of orientation on policies and procedures at CSE.
• Full staff training on the subject will be provided by CSE, once a year.