Prohibition of Harassment
The Company does not tolerate any form of harassment including but not limited to sexual
harassment of its employees in the workplace. In particular, the following are contrary to this
Policy and therefore prohibited:
Any employee engaging in conduct deemed to be harassment that is unwelcomed
and unsolicited by the person(s) harassed.
Any form of retaliation directed against an employee or third party who either
complains about harassment or who participates in any investigation concerning
harassment. Retaliation includes dismissal, demotion, unwanted transfer, denial of
opportunities or harassment as a result of the complaint or participation in the
This prohibition applies to all full-time, probationary, and seconded employees. Our
harassment policy will be made known to agents, vendors and contractors of the Company
so that they should be aware that harassment of employees will not be tolerated.
The Company’s zero-tolerance position on harassment in the workplace applies to all
aspects of employment:
Harassing another is a breach of a term or condition of employment;
The career development of an employee will not be compromised as a result of the
actions of a harasser; and
Employees are expected to behave in a non-threatening and non-offensive manner.
Disciplinary actions including dismissal may be taken against any employee who
contravenes this policy. The Company is duty bound to take stern actions against
Harassment in the workplace
Harassment means any verbal, written or physical conduct that is known or ought
reasonably to have been known to be unwelcome, inappropriate or otherwise offensive to a
person, and that such conduct demeans, humiliates, threatens him/her or otherwise violates
his/her dignity. Harassment has the purpose or effect of:
creating an intimidating, hostile or offensive workplace;
interfering with the performance of an employee’s functions, duties and
affecting employment opportunities or compensation
The above are examples and are not exhaustive
Harassment may be motivated by one of these grounds inter alia : race or ethnicity; skin
colour; religion; sex or gender; place of origin; ancestry; culture; age; mental or physical
disability; sexual orientation; family, marital or social status; economic or financial
background; and political affiliation. In particular, this Policy identifies and seeks to eliminate
the following types of harassment:
Harassment in the work conditions or working environment on the basis of
race is intended to cause, or has the effect of causing, physical, mental or
emotional distress at the workplace. It is also a form of discrimination.
Such harassment refers to conduct or behaviour that is of a sexual nature
and includes such matters for instance a request for sexual favours by a
manager, superior, colleague or even a non-employee. It usually takes the
following two forms:
Quid pro quo – This is when a Manager, Head of Department or a person of
authority gives or withholds a work-related benefit in exchange for sexual
favours. Typically, the harasser requires such favours from the victim, either
rewarding or punishing the victim in some manner.
Hostile environment – This is when a victim is subjected to unwelcome and
severe or pervasive repeated sexual comments, innuendoes, touching or
other conduct of a sexual nature which creates an intimidating or offensive
place for employees to work. Sexual harassment is frequently more about
power than about sex. It occurs in situations where there is unequal power
between the people involved and is an attempt by the harasser to assert
power over the victim.
Abuse of authority
Abuse of authority happens when a person uses his/her authority to interfere
with an employee or the employee’s job. It includes humiliation, intimidation,
threats and coercion.
Although not exhaustive, the following conduct or behaviour would constitute harassment:-
Insulting behaviour or comments (verbal or written);
Verbal, written or physical abuse, threats and assaults;
Derogatory remarks, slurs, epithets or language;
Unacceptable, annoying or unwanted nicknames or negative stereotyping;
Racist, pornographic or otherwise offensive signs, images, pictures or materials
Coercion, unwelcome demands, invitations or requests of a sexual nature;
Lewd, leering, obscene or suggestive gestures;
Unwanted or inappropriate physical contact that is non-consensual, such as kissing,
pinching, stroking, fondling, patting, touching and brushing up against a person;
Derogatory or offensive pranks and practical jokes;
Isolation or exclusion of a person from others;
Bullying and victimization, for example, unreasonable and persistent criticism or
humiliation, unreasonable distribution of work and responsibilities;
Inappropriate inquiries or comments about a person’s sex life, religious or cultural
norms, sexual orientation, family background, source of income or lifestyle;
Abusive and offensive language or shouting including abusing a person loudly,
usually when others are present;
Repeated threats of dismissal or other severe punishment for no reason;
Sarcasm or constant ridicule and being put down;
Constant unreasonable criticism about work or academic performance, often about
petty or insignificant matters;
Leaving offensive messages on e-mail or the telephone;
Electronic harassment such as through email, SMS, Facebook, Twitter or others;
Threatening gestures or actual violence;
Sabotaging a person’s work, for example, by deliberately withholding or supplying
incorrect information, hiding documents or equipment, not passing on messages and
getting a person into trouble in other ways;
Deliberate exclusion, isolation or alienation of an employee including maliciously
excluding and isolating a person from workplace activities;
Persistent and unjustified criticisms, often about petty, irrelevant or insignificant
Humiliating a person through gestures, sarcasm, criticism and insults, often in front
of clients, Management or other workers;
Allocation of humiliating or demeaning tasks, or sabotaging a person's work;
Spreading gossip or false, malicious rumours about a person with an intent to cause
the person harm;
Inappropriate comments about a person’s appearance;
Making the person undertake harmful or humiliating actions.
Actions that are not workplace harassment
Legitimate and reasonable management actions and business processes, such
as actions taken to transfer, demote, discipline, redeploy, retrench or dismiss a
worker are not considered to be workplace harassment, provided these actions
are conducted in a reasonable way. Managers are expected to offer constructive
and reasonable advice and comment as a legitimate aspect of their role.
Appropriate provisions of guidance, conducting performance counselling,
invoking diminished performance procedures, unsatisfactory performance
procedures or misconduct procedures does not constitute harassment.
For the purposes of this policy, reference to the workplace means any place where the
Company’s business is carried out and other locations and situations, such as work-related
off-site assignments and business travel, work-related conferences, training or social
gatherings, or other locations where the prohibited conduct might have a subsequent impact
on the work relationship, environment or performance.
Any employee who is experiencing or affected by harassment may take an informal
approach, if he/she considers appropriate, in resolving the problem by raising the matter
directly with the person responsible (the “alleged harasser”). It is possible that the alleged
harasser may not realise that this behaviour is unwelcome or offensive. The employee may
make an initial attempt to make it clearly known to the alleged harasser that his/her
behaviour is contrary to this Policy and that he/she should stop behaving in this manner.
Alternatively, the employee may seek the help of his/her immediate supervisor or Head of
Department to informally approach the alleged harasser on his/her behalf.
If the employee is dissatisfied with the informal approach or finds it inappropriate in the
circumstances, he/she may proceed with a formal complaint at any time. Nothing prevents
the employee from making such a complaint immediately if he/she feels that the conduct is
serious enough to warrant such an approach. The formal complaint should be directed in
writing to the Head of Finance & Administration Department or Manager of Human Resource
An employee who has been directly harassed or has witnessed or is affected by the
harassment of others, should report such conduct to the Head of Finance & Administration
Department or Manager of Human Resource Section. If the employee needs help in
determining whether harassment has occurred, or whether to take the formal or informal
approach, he/she could seek advice from the Head of Finance & Administration Department
or Manager of Human Resource Section. If the employee is not comfortable approaching
the above mentioned official or if the latter is the subject of the complaint, the employee
could/should raise the matter to the Managing Director.
Allegations of harassment will be treated seriously and due regard to the need for
confidentiality will be given. The Company aims to resolve any complaints as quickly as
possible. Under no circumstances shall the employee alleging the harassment be required
to file a complaint with the person responsible for the alleged harassment.
The right to raise at any time the issue of harassment by way of complaint or as witness in
an investigation should be exercised without fear of reprisal. As noted above, the Company
prohibits any form of retaliation against employees.
An investigation will be conducted as discreetly as possible to avoid any embarrassment to
the parties. Both the employee and the alleged harasser will be separately interviewed, as
will any individuals who may be able to provide relevant information. Every employee is
expected to cooperate in any investigation if so requested. The outcome of the investigation
will be communicated to the employee making the complaint. Where the employee is
dissatisfied with the outcome of the investigation, he/she may appeal to the Managing
Director in writing within fourteen (14) days from the date he/she is officially informed of that
A complaint received by the Head of Finance & Administration Department or Manager of
Human Resource Section or any other person will be kept strictly confidential. Information
acquired from the investigation will also be kept confidential. All parties involved in the
investigation, including both the victim and the harasser (alleged or otherwise), are required
to keep such information secret.
Although the Company encourages an employee suffering from harassment to report the
matter, any false accusations, fabricated allegations or otherwise complaints against
another made in bad faith are considered as misconduct and there may be disciplinary
measures taken against the employee making such accusations, allegations or complaints.
Roles and Responsibilities
Every employee reserves the right to be treated fairly and respectfully in the
workplace and shall treat colleagues, managers and stakeholders in general in
a way that respects individual’s differences.
Employees are encouraged to address their concerns if someone behaves in a
way that is offensive, humiliating or degrading and to speak up or report the
complaint to an immediate supervisor or the Head of Finance & Administration
Department or Manager of Human Resource Section.
Employees should keep a written record of the details of the alleged incident(s)
of harassment, including time, locations and name of witnesses, if any. All
information should be kept confidential. These are serious issues and privacy
must be respected.
Employees shall also attend training sessions on harassment organised by the
Company. All employees have a responsibility to cooperate in any investigation
of a harassment complaint.
Heads of Department should also be familiar with this policy and are expected
to be alert to any signs of harassment, such as an unexplained change in an
employee’s performance, rumours or an employee isolating himself/herself or
seemingly distracted. If something does not seem right, Heads of Department
should speak to the employee concerned. Having someone willing to listen often
helps the employee to talk about a problem. Heads of Department also have a
responsibility of ensuring that the workplace remains free of harassment and in
doing so, they should apply this Policy consistently.
Human Resources Section
The Human Resources Section is in charge of ensuring that this policy and its
applicable procedures for dealing with harassment are understood by all
employees. It includes making sure this Policy is consistently applied in all
The Human Resources Section is also responsible for conducting investigations
when required and review this policy and its procedures so that the aims of this
policy are achieved.