Page 33 - O'Kelly Sutton Employee Handbook June 23 Revision 2 2020

advance.

The investigator(s) will meet with the complainant and alleged perpetrator(s) and any witnesses or
relevant persons on an individual confidential basis with a view to establishing the facts surrounding
the allegation(s). Both the complainant and alleged perpetrator(s) may be accompanied by a work
colleague or representative if so desired.

Every effort will be made to carry out and complete the investigation as quickly as possible and
preferably within an agreed timeframe. On completion of the investigation, the investigator(s) will
submit a written report to management containing the findings of the investigation.

Both parties will be given the opportunity to comment on the findings before management decides
upon any action.

The complainant and the alleged perpetrator(s) will be informed in writing of the findings of the
investigation.

3.4.6 Outcome
Should management decide that the complaint is well founded, the alleged perpetrator(s) will be given
a formal interview to determine an appropriate course of action. Such action could, for example,
involve counselling and/or monitoring or progressing the issue through the disciplinary and grievance
procedure of the employment.

If either party is unhappy with the outcome of the investigation, the issue may be processed through
the normal employment relations' mechanisms.

3.4.7 Confidentiality
All individuals involved in the procedures referred to above must maintain confidentiality on the
subject.

3.5 EQUAL OPPORTUNITIES POLICY
The Company positively encourages a culture of equality for all, where employees are recruited,
developed, remunerated, and promoted on the basis of their skills and suitability for the work
performed.

The Company is committed to making full use of the talents and resources of all its employees, and to
ensuring that no employee receives objectively unjustified less favourable treatment on the grounds
of their gender, race, colour, ethnic origin, membership of the travelling community, marital status,
family status, disability, religion, sexual orientation, age, nationality, part-time or fixed term status. All
employees will be made aware of the provisions of this policy and are required to ensure that the
policy is carried out in its entirety.

There are 3 forms of discrimination
• Direct discrimination: When a person is treated less favourably than another person would be
treated in the same circumstances.

• Indirect discrimination: When a person is obliged to comply with a condition of employment,
with which a substantially greater proportion of one group than another group can comply and
when a requirement that is the same for everyone has an unfair effect on some people because
of gender, marital status, family status, sexual orientation, age, disability, race, religion, or
membership of the Traveller community.
• Discrimination by Association: When a person is associated with another person who falls into
one of the categories listed above and is then treated less favourably because of that
association.

Page 32 of 82