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IW Sexual Harassment Policy 2021

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SEXUAL HARASSMENT POLICY

1. PREAMBLE

The Company takes a strong view on the promotion of human dignity among its employees. Moreover,
recent industrial relations changes have emphasised the need for the Company to adopt a policy and
procedures specifically on sexual harassment.

Sexual harassment is a form of misconduct that can be very serious. Sexual harassment can cause
embarrassment, humiliation, anxiety and depression in the individual who is subjected to such conduct.
Because matters associated with sexual harassment are sensitive, the policy described below shall be
adhered to before the provisions of the disciplinary code and procedure are invoked.

2. AIM

The aim of this policy is to deal with sexual harassment decisively.

3. DEFINITIONS

The following terms shall have the meanings ascribed, unless the context indicates otherwise:

Sexual harassment: Any unwelcome or unwanted attention or conduct of a sexual nature by someone in
the working environment that causes discomfort, humiliation, offence or distress, and/or interferes with
the emotional wellbeing or member of management irrespective of the sex of the person (male/
female).

4. OBJECTIVES

The objectives of this policy are to ensure the following:

• That all employees (male and female) have the right to work in an environment free from sexual
harassment, and to be treated with dignity
• That the Company takes all reasonable steps to ensure that employees are not subjected to
sexual harassment within the working environment

• That no form of sexual harassment is tolerated or condoned

• That no victimisation of complainants, witnesses or accused persons occurs

• That all reports of harassment are treated professionally and sympathetically, and are
investigated thoroughly and confidentially

• That appropriate disciplinary action is taken against anyone found to be guilty of sexual
harassment

• That false or vindictive accusations are viewed in a very serious light

5. THE NATURE OF SEXUAL HARASSMENT

Sexual harassment may be of a serious or less serious nature and may consist of any or all of the
following:

• Sexual advances

• Requests for sexual favours in return for employment benefits

• Verbal abuse with sexual overtones

• Innuendos, including remarks about a person’s appearance, body or clothing

• Physical contact

• Obscene gestures or indecent exposure

• Staring, leering, whistling

• Display of sexually offensive or explicit material, including posters, magazines, pictures or


objects

• Direct sexual propositions

• Continued pressure for dates and sexual favours

• Letters or calls of a sexual nature

• Any of the above as a form of coercion or blackmail for advancement or for lack of advancement
or dismissal if the recipient refuses

• Any other unwelcome form of physical or verbal behaviour that has sexual overtones (dirty
jokes are not necessarily viewed as sexual harassment except if aimed at an individual with the intention
of causing embarrassment or offence)
In every case of sexual harassment, the victim shall indicate clearly and immediately that she or he does
not approve of what is being said, done or suggested. This is most important, since everyone’s
perception differs. What one person perceives as sexual harassment might not appear as such to
another.

The severity of the harassment is determined largely by the psychological effect it has on the victim, not
by the intention of the person who performed the harassment. The severity will depend on the
circumstances and nature of the offence. However, even a single serious act of sexual harassment could
warrant suspension of the perpetrator.

6. REPORTING SEXUAL HARASSMENT

Any employee who feels that she/he has been harassed shall bring the complaint to the Human
Resource Manager, who will then evaluate the evidence and the severity of the complaint and will
decide whether the matter can be resolved informally between parties or must be pursued in
accordance with the disciplinary process. This will be done as confidentially as possible – the basic
human right to fair treatment and the confidentiality of complainants and of those against whom
allegations are made will be protected.

The Human Resource Manager will deal most severely with any victimisation resulting from the lodging
of a complaint, regardless of whether sexual harassment is subsequently proven. The Human Resource
Manager will also take disciplinary steps against anyone who makes a false accusation. A person who
falsely accuses another may be required to publicly clear the name of the person against whom the false
complaint was laid. The Human Resource Manager will appoint a panel of mediators that will investigate
matters. Such an investigation will be confidential to protect those involved.

7. PROCEDURE FOR DEALING WITH SEXUAL HARASSMENT ALLEGATIONS

Two procedures are possible for dealing with sexual harassment: an informal procedure and, failing a
satisfactory solution, a formal procedure.

7.1 Informal procedure


The informal procedure involves discussion and/or conciliation after the matter has been brought to the
attention of the Human Resource Manger. The Human Resource Manger will appoint mediators to
discuss and mediate. Mediators have (20) twenty working days to resolve the complaint after which it
will be referred to a formal process. If the complaint cannot be resolved to the complainant’s
satisfaction and it is found through discussion that the incident warrants more serious action, formal
disciplinary procedures will be instituted against the alleged offender.

7.2 Formal procedure

The formal process will follow if:

• the mediators cannot resolve the matter within the period indicated,

• the complaint cannot be resolved to the satisfaction of the complainant

• it is found through discussion that the incidents warrant more serious action.

The written complaint must be fully documented and cite witnesses, where appropriate/possible. The
mediator(s) must send a report that outlines the major issues of the case. The alleged perpetrator must
in turn be invited to state his/her case in writing. The matter will then be dealt with under the applicable
disciplinary provisions for employees. There will be a thorough, objective and discreet investigation.

7.3 Criminal or civil charges

Particularly in the case of physical abuse the above procedures do not override your right as employees
to lay criminal or civil charges against the person involved without consulting the Human Resource
Manager/Employer.

Cases of assault and rape are criminal activities and will in any event be referred immediately to the
police service by the Company. If the procedures of the Company fail in other instances, a victim can
take the matter to a criminal or a civil court.

8. DISCIPLINARY STEPS
Sexual harassment will be regarded as gross misconduct. Depending on the severity of the harassment,
disciplinary steps could include any or a combination of the following:

• Verbal warning

• Written warning

• Final written warning

• Suspension

• Dismissal

An offender may also be required to attend suitable counselling or workshops via Human Resource
Managers offices.

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