PSEA Policy: Prevention of Sexual Exploitation, Abuse and Harassment, and of Workplace Harassment

At PRONETSYS S.A.S. (hereinafter, “Pronetsys” or “the company”), every person has the right to work and to interact with us in an environment free from violence, exploitation, abuse and harassment. This policy sets out how we prevent, receive, address and investigate sexual exploitation, sexual abuse, sexual harassment, workplace harassment and all other forms of violence at work (collectively, “PSEA and harassment prevention”).

Its approach is centered on the affected person: we believe them, we protect them, we respect their decisions and we prevent them from being victimized again, while guaranteeing due process for the reported person.

1. Zero-tolerance statement

Zero tolerance means that every report is addressed, that protective measures are adopted without delay, that proven conduct has proportionate consequences and that no one suffers retaliation for reporting in good faith.

2. Objective and scope

The objective of this policy is to prevent, detect, address, investigate and sanction this conduct, to protect affected persons and to comply with current Colombian regulations and the international reference standards.

2.1 People

It applies to the partners, executives, employees, contractors, trainees, apprentices, interns, job candidates and suppliers of Pronetsys, whatever the nature of their relationship with the company. It also protects clients, end users and other third parties with whom we have contact by reason of the service. Clients, their staff and other third parties may be either affected persons or potential perpetrators; in both cases, this policy is triggered.

2.2 Places and contexts

The policy applies both during and outside working hours whenever the conduct is related to work, in accordance with the scope set forth in Law 2365 of 2024 and Law 2466 of 2025.

3. Definitions

Sexual exploitation

Any actual or attempted abuse of a position of vulnerability, an unequal power relationship or a relationship of trust for sexual purposes, including obtaining economic, social, employment-related or any other kind of benefit from the sexual exploitation of another person. Definition adapted from the United Nations standards used by the Inter-Agency Standing Committee (IASC).

Sexual abuse

Any actual or threatened physical intrusion of a sexual nature, whether by force, under unequal conditions or through coercion.

Sexual harassment

Any act of persecution, harassment or hounding of a sexual, lewd or libidinous nature or connotation, manifested in vertical or horizontal power relationships and occurring once or several times in the work context (Law 2365 of 2024). It may be verbal, non-verbal, physical or digital. When it is committed by taking advantage of a position of superiority, authority or power, it also constitutes the crime set forth in Article 210A of the Criminal Code.

Workplace harassment

Any persistent and demonstrable conduct exercised against an employee by an employer, a hierarchical superior, a coworker or a subordinate, aimed at instilling fear, intimidation, terror and anguish, causing harm at work, generating demotivation at work or inducing resignation (Law 1010 of 2006).

Violence and harassment in the world of work

A range of unacceptable behaviors and practices, or threats thereof, whether occurring once or repeatedly, that aim at, result in or are likely to result in physical, psychological, sexual or economic harm, including gender-based violence and harassment (Law 2466 of 2025).

Consent

Free, voluntary and informed agreement that may be revoked at any time. There is no consent when there is force, threat, intimidation, deception or abuse of a power relationship, or when the person is not capable of deciding. Silence or lack of resistance does not amount to consent.

Affected person

A person who has suffered or reports having suffered any of the conduct described. This policy also uses the term “victim,” without this prejudging the outcome of the investigation.

Reported person

A person identified in a report as allegedly responsible for the conduct. They are presumed innocent until proven otherwise.

Revictimization

Any additional harm suffered by the affected person because of the way their case is handled, such as repeated questioning, challenges to their conduct or appearance, confrontation with the reported person or disclosure of their identity.

Retaliation

Any harmful action or omission against a person who reports, acts as a witness or cooperates in an investigation, motivated by that action.

3.1 Forms of workplace harassment

Law 1010 of 2006 recognizes the following forms:

3.2 Conduct that does not constitute workplace harassment

Under Law 1010 of 2006, the following do not constitute workplace harassment, provided they are carried out with justification, on objective criteria and without discrimination:

• Acts intended to exercise disciplinary authority, in accordance with due process.
• Reasonable demands for loyalty to the job or to the company.
• Circulars or instructions aimed at setting technical requirements, improving efficiency or evaluating performance using objective and general indicators.
• Requests to perform extra collaborative duties when they are necessary for the continuity of the service or to resolve difficult operational situations.
• Actions aimed at terminating the employment contract on the basis of a legal cause or a just cause.
• Requiring compliance with the obligations, duties and prohibitions set out in the Substantive Labor Code, the Internal Work Regulations and the contract.

3.3 Examples of sexual harassment

Comments, jokes or questions of a sexual nature about a person’s body or intimate life; lascivious looks, obscene gestures or unwanted physical contact; persisting with sexual or romantic invitations after being turned down; sending messages, images or videos of a sexual nature by any means; making a promotion, an assignment, an evaluation, a payment or the provision of a service conditional on sexual favors; and disseminating or threatening to disseminate a person’s intimate content.

4. Core PSEA principles

Pronetsys adopts, as adapted to its activities, the six Core Principles relating to sexual exploitation and abuse of the Inter-Agency Standing Committee (IASC), in their revised 2019 version, the international reference standard on the subject:

1. Serious misconduct. Sexual exploitation, abuse and harassment constitute serious misconduct and may be grounds for termination of the contract or of the contractual or business relationship.
2. Protection of children and adolescents. All sexual activity with persons under the age of 18 is prohibited, regardless of the age of consent established by law. Error or mistaken belief regarding age is not an excuse.
3. Prohibition of exchanges. Exchanging money, employment, promotions, assignments, contractual benefits, goods or services—including the services we provide to our clients—for sex or sexual favors is prohibited, as is any humiliating, degrading or exploitative behavior.
4. Misuse of position. Any sexual relationship that involves misuse of rank, post or position is prohibited, especially between a supervisor and a supervisee, or between a service provider and the person who depends on that service. Romantic relationships between a person and someone under their supervision must be disclosed as a conflict of interest, in accordance with the Code of Ethics and Conduct.
5. Duty to report. Any person who has concerns or suspicions regarding sexual exploitation, abuse or harassment by a worker, whether or not they belong to the company, must report them through the channels established in this policy.
6. Protective environment. Everyone must contribute to creating and maintaining an environment that prevents this conduct. Those who lead teams have a special responsibility to establish and maintain the systems that make this possible.

5. Legal framework

This policy is based on the following regulations, whose validity was verified for this version:

6. Prevention measures

6.1 Training and awareness

• Onboarding: every person who joins receives this policy and basic training before their first client visit or their first contact with users.
• Annual training: all staff take part at least once a year in an activity on harassment prevention, consent, bystander intervention, respectful use of digital channels and response pathways.
• Specialized training: the Ethics and Compliance Officer, the members of the Workplace Coexistence Committee and those who lead teams receive training in non-revictimizing care, psychological first aid, confidentiality and due process.

6.2 Psychosocial risk management

Psychosocial risk factors are assessed at the frequency required by Resolution 2764 of 2022, and the results feed into intervention plans, in accordance with the Occupational Health and Safety Policy.

6.3 Protocol for visits to client premises

1. Traceable scheduling. Every visit is scheduled through a ticket or service order, with the address, contact person and time slot, and the Support Lead knows where each technician is.
2. Identification. The team member presents themselves with identification, and the client knows in advance who will attend.
3. Suitable spaces. Common or visible areas are preferred. When the service takes place in a home, efforts are made to ensure that a responsible adult is present, and team members never remain alone with children or adolescents.
4. Accompanied visits. When there is a history or signs of risk, or the team member so requests, the visit is carried out in pairs or rescheduled.
5. Right to withdraw. Any team member may suspend the visit and leave if they feel unsafe or are subjected to harassing conduct, without negative consequences. They must inform the Support Lead immediately.
6. Staff conduct. Professional treatment, without comments on people’s appearance, without accessing personal information outside the scope of the service and without contacting clients through non-corporate channels.
7. Response to the client. In the event of harassment by a client or its staff, the company may suspend in-person service, demand measures or terminate the relationship, in accordance with the contract and the Support Service Terms.

6.4 Other measures

Work communications take place through corporate channels, under the rules of the Workplace Conduct Handbook. At company events, responsible consumption of alcohol or abstention, and a safe return home, are promoted. This policy is incorporated into the Internal Work Regulations, into employment and service contracts and, where applicable, into contracts with suppliers and clients; selection processes include reference checks and express acceptance of the policy; and it is disseminated on this website and through periodic reminders to staff.

7. Reporting channels

Anyone may report: the affected person, a witness or anyone with knowledge of the facts, whether a team member, client, supplier or third party. Reports may be made anonymously. Anonymity may limit some actions, but it does not prevent the company from adopting measures.

7.1 Internal channels

If the person reported for sexual harassment is the Legal Representative, as the company’s highest-ranking superior, the complaint must be filed with the Labor Inspectorate, in accordance with Law 2365 of 2024; the company provides guidance on and facilitates that process, and the highest corporate body or an independent third party appointed for that purpose adopts the internal protective measures. Other conduct involving the Legal Representative is handled internally through that same route.

7.2 External channels

Using the internal channels is not a prerequisite for going to the authorities. Affected persons may at any time use:

8. Response procedure

8.1 Pathway for sexual harassment, exploitation, sexual abuse and other forms of violence

1. Receipt and registration (same day). The report is registered with a case code and forwarded to the Ethics and Compliance Officer. Only those persons who strictly need to know are informed.
2. First contact (no later than the next business day). Receipt is acknowledged and the affected person is offered a safe space to be heard in detail only once, accompanied by someone they trust if they wish. They are informed of their rights, the pathways and the available measures, and their decision on how to proceed is respected, except where there is a risk to them, to other persons or to minors.
3. Risk assessment and protective measures (immediate). The risk is assessed and urgent measures are adopted immediately. Measures requested by the affected person are adopted no later than five (5) business days after the request, in accordance with Law 2365 of 2024. See section 11.
4. Psychological first aid and referral. Active listening is provided, without judgment or unnecessary questions, and the person is referred to the emotional and psychological support of the occupational risk insurer (ARL), to the health insurer (EPS) and, if there is imminent risk, to Line 123. The person is informed of their right to file a complaint with the Attorney General’s Office and, if they so request, the company immediately forwards the complaint to the competent authority.
5. Investigation with due process (up to 30 business days). The investigation is conducted by one or more impartial, trained persons with no conflict of interest, who may be external. The parties are heard separately, never face to face, and the reported person is informed of the facts and may respond and submit evidence. The deadline may be extended once, with written justification.
6. Decision. Based on the report, Management decides—or the highest corporate body or the appointed third party, if there is a conflict. Sanctions on employees follow the Internal Work Regulations and Article 115 of the Substantive Labor Code; contractual measures, including termination, apply to contractors, suppliers or clients. The affected person is informed of the outcome and of the measures that remain in place.
7. Follow-up and closure (at least six months). The situation of the affected person and of the witnesses is monitored for at least six (6) months to verify that there is no retaliation or repetition, the measures are adjusted and the lessons learned are recorded before the case is closed.

8.2 Pathway for workplace harassment before the Workplace Coexistence Committee

Workplace harassment complaints are handled before the Workplace Coexistence Committee in accordance with Resolution 3461 of 2025, with the stages and deadlines detailed in the Workplace Conduct Handbook: receipt within the following five (5) calendar days, individual hearing of each party, voluntary dialogue sessions with an improvement plan, monthly follow-up on commitments and, if no agreement is reached or the conduct persists, a report to senior management and closure. The entire process may not exceed sixty-five (65) calendar days, and the affected person retains the right to go to the Labor Inspectorate or to a judge. Complaints received through the Ethics Hotline are forwarded to the Committee with the authorization of the person who reports.

The proceedings before the Committee do not prevent the company from initiating disciplinary proceedings when the facts constitute misconduct. If facts of sexual harassment or another form of sexual violence are identified during the proceedings, the case is immediately transferred to the pathway in section 8.1.

9. Coexistence route, disciplinary route and criminal route

10. Victim-centered approach, confidentiality and non-revictimization

Confidentiality yields only to a legal obligation, an order from a competent authority or a serious and imminent risk to a person’s life or integrity; in such cases, the affected person is informed.

11. Prohibition of retaliation and protective measures

11.1 Protective measures

Depending on the case and with the participation of the affected person, the company may adopt, among others: treatment free from gender stereotypes; emotional and psychological support through the ARL; a change of area, team, shift, client or visit route without worsening their conditions; temporary work from home or telework when there is a risk; reassignment of tasks to avoid all contact with the reported person, with a no-contact instruction and access restrictions if necessary; and confidentiality of identity with a guarantee of no confrontation.

Measures must never harm the affected person. Those adopted with respect to the reported person are preventive and do not constitute a sanction.

11.2 Prohibition of retaliation

12. Rights of the reported person

• Presumption of innocence and dignified treatment.
• To know the facts attributed to them within the procedure and to be heard.
• To present a defense and evidence, and to challenge the evidence submitted against them.
• Impartiality of those who investigate and decide.
• A reasoned and proportionate decision, and the possibility of challenging it in accordance with the Internal Work Regulations.
• Confidentiality regarding their identity and the proceedings.

Reports submitted with knowledge of their falsehood and for the purpose of causing harm are not protected and are handled in accordance with the Internal Work Regulations. A report that cannot be substantiated is not, for that reason alone, a false report.

13. Responsibilities

14. Training, records and indicators

• Training records: Human Resources keeps proof of attendance at onboarding, annual training and specialized training.
• Confidential case register: the Ethics and Compliance Officer maintains a register with the case code, dates, type of conduct, pathway applied, measures, deadlines, decision and follow-up, with restricted access and retention in accordance with the law.
• Semiannual publication: in accordance with Law 2365 of 2024, the company publishes every six months, in anonymized form, the number of sexual harassment complaints processed and of sanctions imposed, and submits that information to the Integrated Gender-Based Violence Information System (Sivige) within the last ten (10) days of each six-month period, through the means enabled by the authorities.
• Workplace Coexistence Committee reports: quarterly and annual reports to senior management, in accordance with Resolution 3461 of 2025.
• Monitoring indicators: number of reports by type of conduct and channel; time elapsed until first contact and until measures are adopted; percentage of cases closed within the deadline; percentage of staff trained; and number of retaliation reports.

15. Review and effective date

This policy is effective upon publication and is reviewed at least once a year, after any serious case and whenever the applicable regulations change. It is complemented by the Code of Ethics and Conduct, the Workplace Conduct Handbook, the Occupational Health and Safety Policy and the Wellbeing and Workload Policy. Inquiries may be sent to lineaetica@pronetsys.com.co.