Page 29 - O'Kelly Sutton Employee Handbook June 23 Revision 2 2020

as defined by the Employment Equality Acts, 1998-2015 being conduct which has the purpose or effect
of violating a person's dignity and creating an intimidating, hostile, degrading, humiliating or offensive
environment for the person.

3.3.2 Behaviour that may constitute harassment
Many forms of behaviour may constitute harassment including: -

• Verbal harassment - jokes, comments, ridicule, or songs.
• Written harassment - including faxes, text messages, e-mails, or notices.
• Physical harassment - jostling, shoving or any form of assault.
• Intimidatory harassment - gestures, posturing or threatening poses.
• Inappropriate use on on-line social media platforms and/or forums
• Visual display such as posters, emblems or badges or on-line content posted to social media
platforms
• Isolation or exclusion from social activities.
• Pressure to behave in a manner that the employee reasonably thinks is inappropriate, for
example, being required to dress in a manner unsuited to a person's ethnic or religious
background.

3.3.3 Definition (Sexual Harassment)
Sexual harassment is defined as unwanted verbal, non-verbal or physical conduct of a sexual nature
being conduct which has the purpose or effect of violating a person's dignity and creating an
intimidating, hostile, degrading, humiliating or offensive environment for the person.

3.3.4 Behaviour that may constitute sexual harassment
Many forms of behaviour may constitute sexual harassment including:

• Unwelcome acts of physical intimacy.
• Unwelcome requests for sexual favours.
• Any other act or conduct including spoken words, gestures or the production, display or
circulation of written words, pictures or other material that is unwelcome and which has the
purpose or effect of violating a person's dignity and creating an intimidating, hostile,
degrading, humiliating or offensive environment for the person. This may include jokes, pin
ups, comments about a particular sex in general or about someone's sexuality in particular. A
single incident may constitute sexual harassment.

3.3.5 Duty of those responsible for employees
All supervisory personnel are responsible for eliminating any harassment or bullying of which they are
aware. Failure to take appropriate steps will be considered failure to fulfil all the responsibilities of the
position and may be dealt with under the Company's disciplinary procedure.

3.3.6 Sanctions and Miscellaneous matters
All employees have the right to be treated with dignity and respect and complaints by employees will
be treated with fairness and sensitivity and in as confidential a manner as possible. Sexual harassment,
harassment and bullying by the Company, its employees, clients, customers or business contacts will
not be tolerated and may lead to disciplinary action (in the case of employees) and other sanctions,
for example, the suspension of contracts or services or exclusions from premises (in the case of non-
employees).

The protection afforded by the policy extends to sexual harassment, harassment and bullying by co-
workers, clients, customers or other business contacts either in the workplace or beyond the
workplace including conferences and training and may extend to work related social events. It includes

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