1.1 This Anti-Harassment Policy affirms the Organization's unequivocal commitment to providing a work environment that is free from harassment, intimidation, and hostility of any kind. The policy establishes clear definitions of prohibited conduct, the standards of behavior expected of all personnel, the procedures for reporting and investigating complaints, the protections afforded to complainants and witnesses, and the remedies and disciplinary consequences for substantiated violations. The Organization recognises that harassment undermines individual dignity, erodes workplace culture, and exposes the Organization to significant legal and reputational risk.

1.2 This policy applies to all employees, officers, directors, managers, supervisors, contractors, temporary staff, interns, vendors, clients, visitors, and any individual who interacts with the Organization's workforce. It covers conduct occurring in the workplace, at work-related events and social functions, during business travel, and through any form of digital communication, including email, messaging platforms, video conferencing, and social media, where the conduct is connected to the employment relationship or affects the working environment. The policy applies regardless of the location of the conduct and regardless of whether it occurs during or outside of normal working hours, provided there is a sufficient nexus to the workplace.

1.3 The Organization shall appoint a designated Complaints Officer, who shall be a senior member of the HR department or an external professional with relevant expertise, responsible for receiving harassment complaints, coordinating investigations, ensuring the fair and timely resolution of all reported matters, and maintaining confidential records of all complaints and outcomes. The Complaints Officer shall operate independently of line management and shall have direct access to the Head of Human Resources and the Chief Executive Officer to report on matters of policy compliance and systemic concerns. The Organization shall publicise the identity and contact details of the Complaints Officer through multiple channels, including the employee handbook, intranet, and workplace notices.

2.1 For the purposes of this policy, harassment is defined as any unwelcome verbal, written, visual, physical, or electronic conduct based on or related to a protected characteristic, including but not limited to race, color, ethnicity, religion, sex, sexual orientation, gender identity, national origin, age, disability, marital status, pregnancy, or veteran status, that has the purpose or effect of unreasonably interfering with an individual's work performance, creating an intimidating, hostile, degrading, humiliating, or offensive working environment, or affecting an individual's employment opportunities or conditions. Harassment may consist of a single severe incident or a pattern of less severe conduct that cumulatively creates a hostile environment.

2.2 Sexual harassment is a specific form of harassment that includes unwelcome sexual advances, requests for sexual favours, and any other verbal, physical, visual, or electronic conduct of a sexual nature. Sexual harassment may take the form of quid pro quo harassment, where submission to or rejection of sexual conduct is used as the basis for employment decisions such as hiring, promotion, compensation, or continued employment; or hostile environment harassment, where sexual conduct is sufficiently severe or pervasive to alter the conditions of the individual's employment and create an abusive working environment. Examples include, but are not limited to, unwanted physical contact, sexually suggestive comments or jokes, display of sexually explicit materials, sexual gestures, repeated unwelcome invitations, and the transmission of sexual content through any communication medium.

2.3 In addition to sexual harassment, this policy prohibits harassment based on any protected characteristic recognised under applicable federal, state, and local law. This includes, but is not limited to, racial harassment, such as racial slurs, stereotypes, derogatory comments, or the display of racially offensive symbols; religious harassment, such as derogatory comments about religious beliefs, practices, or attire, or pressure to participate in or refrain from religious activities; disability-based harassment, such as mocking a disability, making derogatory remarks about accommodations, or excluding individuals based on disability; and age-based harassment, such as derogatory comments about an individual's age, stereotyping based on generational status, or pressuring older employees to retire. The determination of whether conduct constitutes harassment shall be assessed from the perspective of a reasonable person in the complainant's position.

3.1 Any employee who experiences or witnesses conduct that may constitute harassment under this policy is strongly encouraged to report the conduct promptly. Reports may be made to the employee's direct manager or any other manager within the Organization, the HR department or HR Business Partner, the designated Complaints Officer, or through the Organization's confidential ethics hotline or online reporting portal. Anonymous reporting shall be accepted where permitted by applicable law, although the Organization's ability to investigate anonymous reports may be limited. Employees are not required to confront the harasser directly before filing a report, and the Organization shall not require employees to follow any specific chain of command in reporting harassment.

3.2 Managers and supervisors who receive a harassment complaint, are informed of conduct that may constitute harassment, or personally observe conduct that may constitute harassment are required to report the matter to the HR department or the designated Complaints Officer within 24 hours, regardless of whether the affected individual has filed a formal complaint. Failure by a manager to report known or suspected harassment shall itself constitute a policy violation and may result in disciplinary action. Managers shall not attempt to investigate harassment complaints independently, mediate between the parties, or discourage an employee from filing a complaint. Upon receiving a report, the manager shall take reasonable interim measures to separate the parties and prevent further incidents, pending the commencement of a formal investigation.

3.3 The Organization shall acknowledge receipt of all harassment complaints, whether formal or informal, within 3 business days of receipt. The Complaints Officer or HR department shall conduct a preliminary assessment to determine the appropriate course of action, which may include informal resolution where the complainant consents and the conduct is not severe, or a formal investigation. Formal investigations shall commence within 5 business days of the complaint being received and shall be conducted by a qualified investigator who is impartial, has no personal connection to the parties, and has received training in harassment investigation methodology. The Organization shall notify the complainant and the respondent of the investigation process, their rights, and the expected timeline. Investigations shall be completed within 30 calendar days unless the complexity of the matter warrants an extension approved by the Head of Human Resources.

3.4 All harassment complaints and investigation proceedings shall be treated with the highest degree of confidentiality consistent with the Organization's obligation to conduct a thorough investigation and take appropriate corrective action. Information relating to a complaint shall be shared only with individuals who have a legitimate need to know, including the investigator, the Complaints Officer, the HR Business Partner, Legal Counsel, and relevant decision-makers. The complainant, respondent, and witnesses shall be advised of their obligation to maintain confidentiality regarding the investigation and shall be informed that breaches of confidentiality may result in disciplinary action. The Organization shall take reasonable steps to protect the privacy of all parties involved, while acknowledging that absolute confidentiality cannot be guaranteed in all circumstances.

4.1 All investigations shall be conducted impartially, thoroughly, and in a manner that respects the rights and dignity of all parties. The investigator shall interview the complainant, the respondent, and any witnesses identified by either party or by the investigator. Both the complainant and the respondent shall be afforded the opportunity to present their full account of events, provide documentary or electronic evidence, and identify additional witnesses. The investigator shall gather and review all relevant evidence, including emails, messages, CCTV footage, access records, and any other material pertinent to the complaint. The investigator shall apply a balance of probabilities standard in assessing whether the alleged conduct occurred and whether it constitutes harassment under this policy.

4.2 Upon completion of the investigation, the investigator shall prepare a comprehensive written report that includes a summary of the complaint, the investigation methodology, a detailed account of the evidence gathered, factual findings, an assessment of whether the conduct constitutes harassment under this policy, and recommendations for corrective action where a violation is substantiated. The report shall be reviewed by the HR department and Legal Counsel, and the findings and recommended actions shall be presented to the appropriate decision-maker, who shall typically be the Head of Human Resources or, for senior-level respondents, the Chief Executive Officer or the Board. Both the complainant and the respondent shall be informed of the outcome of the investigation and any corrective actions that directly affect them, subject to confidentiality constraints.

4.3 Where the investigation substantiates a finding of harassment, the Organization shall take prompt and effective corrective action to stop the harassment, remedy its effects, and prevent recurrence. Corrective actions for the respondent may include formal written warning, mandatory anti-harassment training, reassignment or transfer, suspension without pay, demotion, or termination of employment, depending on the severity, frequency, and nature of the conduct. Remedial measures for the complainant may include restoration of any lost benefits or opportunities, reassignment at the complainant's request, counselling or employee assistance program referral, and monitoring of the workplace environment. The Organization shall follow up with the complainant within 30 calendar days of the resolution to confirm that the harassment has ceased and that no retaliation has occurred.

5.1 The Organization strictly prohibits any form of retaliation against any individual who in good faith reports harassment, files a complaint, participates in or cooperates with an investigation, provides testimony or evidence, or opposes conduct they reasonably believe to constitute harassment under this policy. Retaliation includes any adverse employment action, such as termination, demotion, suspension, reduction in hours or pay, exclusion from opportunities, negative performance evaluation, or any other action that would discourage a reasonable person from engaging in protected activity. Retaliation shall be treated as a separate and independently actionable violation of this policy, subject to disciplinary action up to and including termination, regardless of the outcome of the underlying harassment complaint.

5.2 This policy shall be reviewed comprehensively at least once every 12 months by the HR department in consultation with Legal Counsel, the Complaints Officer, and the executive leadership team, to ensure alignment with current legislation, regulatory guidance, and best practices. All employees shall receive mandatory anti-harassment training within 30 calendar days of hire and annually thereafter. Training shall cover the definition and examples of harassment, reporting procedures, investigation processes, retaliation protections, and bystander intervention strategies. Managers and supervisors shall receive enhanced training on their obligation to report, respond to, and escalate harassment concerns, and on their role in fostering a respectful and inclusive work environment. Training completion shall be tracked and reported quarterly.

5.3 While the Organization strongly encourages employees to report any conduct they believe may constitute harassment, complaints that are determined to have been filed in bad faith, with malicious intent, or with the deliberate purpose of harming another individual's reputation or career shall be subject to disciplinary action. The determination of bad faith shall require clear and convincing evidence that the complainant knowingly made false allegations with the intent to deceive or cause harm. This provision shall not be applied in a manner that discourages good-faith reporting, and the mere fact that an investigation does not substantiate a complaint shall not, by itself, be grounds for a finding of bad faith. The HR department shall ensure that the distinction between unsubstantiated and bad-faith complaints is clearly communicated to all personnel during training.