Page 30 - O'Kelly Sutton Employee Handbook June 23 Revision 2 2020

the different treatment of an employee because he/she has rejected or accepted the sexual
harassment, harassment or bullying, and further includes persons working with the Company who are
working through employment agencies or on vocational training.

It is a matter for the recipient of the behaviour to decide whether that behaviour is unwelcome,
irrespective of the attitude of others to the matter.

Employees who make a complaint or who give evidence at proceedings will not be victimised by the
Company in any way. The Company expects its senior employees to have a particular responsibility to
ensure that sexual harassment, harassment, and bullying do not occur and that complaints are
addressed speedily. Company Directors, managers and supervisors therefore will provide good
example by treating all in the workplace with courtesy and respect, promote awareness of company
policy and complaint procedures, be vigilant for signs of harassment and take action before a problem
escalates, respond sensitively to an employee who makes a complaint of harassment, explain the
procedures to be followed if a complaint of sexual harassment or harassment is made, ensure that an
employee making a complaint is not victimised for doing so, and monitor and follow up the situation
after the complaint is made so that the sexual harassment or harassment does not recur.
Employees of the Company are expected to contribute to the achieving of a sexual harassment free
and harassment free environment through co-operation with strategies to eliminate sexual
harassment and harassment and that sexual harassment and harassment by employees constitutes
misconduct and may lead to disciplinary action.
Sexual harassment and harassment by non-employees such as clients, customers and business
contacts may lead to termination of business contracts, suspension of services or the exclusion from
premises or the imposition of other appropriate sanctions.

A company sexual harassment policy is to be communicated to all those potentially affected by it. For
employees this is by means of company handbook. For other parties this may be by way of newsletter,
website, e-mail, or notice board. All employees are required to sign their acceptance of this
handbook and by so doing they signify that they have read this policy.

The Company will keep a record of all complaints of sexual harassment and harassment and a note of
the outcome or resolution. The Company will monitor this information at regular intervals to evaluate
the success of the policy.

The Company may require staff to attend training on issues of sexual harassment, harassment, and
bullying. Employees are referred to the detailed complaints procedure set out hereafter. This sexual
harassment, harassment and bullying policy will be reviewed at regular intervals in line with changes
in the law, relevant case law or other developments.

3.3.7 Complaints Procedure
Employees need not fear that they will be victimised for forwarding a complaint of harassment or
sexual harassment. Retaliation against an employee for complaining about or giving evidence about
harassment or sexual harassment is a disciplinary offence. Wherever possible an employee who
believes that they have been the subject of harassment should in the first instance ask the person
responsible to stop the harassment or sexual harassment, and if any person suffers adverse
employment consequences or any detriment, a complaint under the procedure should be made as
follows:

a) The employee who believes they have been the subject of harassment should report the
alleged act to a MANAGER. If the employee would find this embarrassing, or the complaint is
about the immediate manager/supervisor, the report should be made to a colleague.
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