Harassment Incident Reporting and Investigation Procedures The company herein strives to create and maintain a work environment in which people are treated with dignity, decency and respect. The environment of the company should be characterized by mutual trust and the absence of intimidation, oppression and exploitation. The company will not tolerate unlawful discrimination or harassment of any kind. 1. Complaint Procedures Complaints should be submitted as soon as possible after an incident has occurred, preferably in writing. The designated officer assigned by the company to collect these complaints will assist the victim in completing a written statement and HR Harassment Form in the event an employee refuses to provide information in writing, the designated officer will dictate the verbal complaint. To ensure the prompt and thorough investigation of a harassment complaints, the victim should provide as much of the following information as is possible: a) The name, department and position of the person or persons allegedly committing harassment. b) A description of the incident(s), including the date(s), location(s) and the presence of any witnesses. c) The effect of the incident(s) on the victim's ability to perform his or her job, or on other terms or conditions of his or her employment. d) What, if any, steps the victim has taken to try to stop the harassment. e) Ensure that the victim understands the company’s procedures for dealing with Harassment. f) Discuss and agree the next steps: either informal or formal complaint, on the understanding: - that choosing to resolve the matter informally does not preclude the victim from pursuing a formal complaint if he/she is not satisfied with the outcome. g) Keep a confidential record of all discussions. h) Respect the choice of the victim. i) Ensure that the victim knows that they can lodge the complaint outside of the company through the relevant country/legal framework. j) Any other information the victim believes to be relevant to the matter. 2. Investigation Procedures Following the collection of the information above the designated officer will refer the matter to the Human Resources Manager to instigate a formal investigation. The person carrying out the investigation will: a) Interview the victim and the alleged harasser separately b) Interview other relevant third parties /witnesses separately c) Decide whether or not the incident(s) of harassment took place by assessing the information from the complaint stage to this stage d) Produce a report detailing the investigations, findings and any recommendations. e) If the harassment took place, decide what the appropriate remedy for the victim is, in consultation with the victim (i.e.- an apology, a change to working arrangements, f) If the victim was transferred (as agreed) as a result of the harassment, training for the harasser, discipline, suspension, dismissal) g) HR Manager must follow up to ensure that the recommendations are implemented, that the behaviour has stopped and that the victim is satisfied with the outcome h) If it cannot determine that the harassment took place, he/she may still make recommendations to ensure proper functioning of the workplace keep a record of all actions taken. i) Ensure that all records concerning the matter are kept confidential. j) Ensure that the process is done as quickly as possible and in any event within days of the complaint being made. 3. Sanctions and Disciplinary Measures I. Anyone who has been found to have sexually harassed another person under the terms of the company’s harassment policy is liable to any of the following sanctions: a) verbal or written warning b) adverse performance evaluation c) transfer d) demotion e) suspension f) dismissal II. The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial. Certain serious cases, including physical violence, will result in the immediate dismissal of the harasser.