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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 Company Director. If the employee would find this embarrassing, or the
complaint is about the immediate manager/supervisor, the report should be made to a
colleague.

b) All complaints will be handled in a timely, confidential and sensitive manner and employees
will receive a fair and impartial hearing.
c) If possible, the employee who believes they have been the subject of harassment should
confirm in writing:

• The name of the alleged harasser;

• The date of the incident/incidents;

• The nature of the conduct complained of;

• The names of any persons present.

d) If the investigation reveals the complaint is valid, prompt attention and action designed to
stop the harassment immediately and prevent its recurrence will be taken and the Company's
disciplinary procedure will be used as appropriate. In such circumstances if relocation is
appropriate every effort will be made to relocate the harasser and not the recipient.

3.4 BULLYING
SI 17 of 2002 (Code of Practice detailing procedures for addressing bullying in the workplace) defines
bullying as per 3.4.1 below.

3.4.1 Definition (Bullying)
"Workplace Bullying is repeated inappropriate behaviour, direct or indirect, whether verbal, physical
or otherwise, conducted by one or more persons against another or others, at the place of work
and/or in the course of employment, which could reasonably be regarded as undermining the
individual's right to dignity at work. An isolated incident of the behaviour described in this definition
may be an affront to dignity at work but, as a once off incident, is not considered to be bullying".

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