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• 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
nonemployees).
The protection afforded by the policy extends to sexual harassment, harassment and bullying by
coworkers, 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
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

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