October 2018
FERONIA INC
(the “Corporation” or “Company”)
Our Commitment
Feronia is committed to maintaining and promoting a safe, heathy and respectful working environment where all employees and workers, irrespective of status, seniority, function or gender, are treated with dignity and free from all forms of sexual misconduct, including harassment, humiliation or intimidation of a sexual nature and behave in a respectful manner towards others while undertaking their duties on behalf of the company.
Feronia will not tolerate any form of sexual misconduct or harassment within its workplace and any form of misconduct will be investigated and treated with the upmost seriousness.
The aim of this Respect at Work Policy and the associated guidance and support is to:
- ensure that employees, workers, external contractors, suppliers and other individuals working for the Company are treated with dignity and respect at all times.
- ensure the Company’s working practices protect and support local communities in respect of sexual misconduct.
- minimise risks to workers and communities from 3rd parties and contractors operating on behalf of the Company by implementing appropriate standards and controls, training and education.
- ensure all workers, external suppliers, and local community members are aware of the mechanism to raise any concerns regarding offensive and unacceptable behaviour that they have directly experienced or witnessed.
- create a culture where individuals feel confident and comfortable in raising any concerns and are assured of Company action to prevent recurrence or retribution.
Scope
This Respect at Work Policy (the “Policy”) applies to Feronia Inc. and each of its subsidiaries (collectively, the “Corporation” or “Company”) which are in the United Kingdom, Belgium, the Democratic Republic of Congo and Canada.
Definition
Feronia defines sexual misconduct as any unwanted conduct of a sexual nature including verbal, non-verbal, visual, psychological or physical harassment.
Although this list is not exhaustive, it provides examples of situations in which it might be appropriate for an employee or contractor to report sexual misconduct, or for a member of the public to report an alleged incidence of sexual misconduct perpetrated by employees, workers, external contractors, suppliers or other individuals working for the Company:
- Insinuate, propose or demand sexual favours of any kind.
- Abuse a position of seniority through promises of preferential treatments or through implied or overt threats to employment status on the basis of sexual favours.
- Stalk, intimidate, coerce or threaten another person to get them to engage in sexual acts.
- Send or display sexually explicit objects or messages.
- Comment on someone’s looks, dress, sexuality or gender in a derogatory or objectifying manner or a manner that makes them uncomfortable.
- Invade another person’s personal space (e.g. inappropriate touching).
- Make obscene comments, jokes or gestures that humiliate or offend someone.
- Pursue or flirt with another person persistently without the other person’s willing participation.
- The most extreme form of sexual harassment is sexual assault. This is a serious crime and the Company will support individuals who want to press charges against offenders.
Making a Report
If an individual feels they are a victim of sexual misconduct, or witnesses or suspects another person is the victim of sexual misconduct; they should report the incident to their Line Manager or Area Personnel Manager in the first instance.
Where the employee or worker feels unable to approach their Line Manager or Area Personnel Manager, complaints of this nature can also be filed via the Company Grievance Procedure or can be brought to the Company’s attention via Union representatives. Contractors and community members who wish to make a report relating to the behaviour of someone working for or on behalf of the company, can also file complaints via the Company Grievance Procedure or can speak to their local Community Liaison Officer.
The Company will investigate all complaints of sexual misconduct and no complaint will be considered as too minor to be dealt with.
During the investigation of complaints, the Company will maintain the highest levels of confidentiality possible. Throughout the investigation this discretion will equally apply to the victim and the alleged perpetrator as well as any witnesses who come forward.
Where complaints are upheld, the Company will instigate proceedings under the Company Disciplinary Policy. Serious incidents and repeat offences of sexual harassment will be dealt with as gross misconduct under the Company Disciplinary Policy. The Company may also involve the police if requested or legally required.
The Company will also take steps to protect the claimant against any further harassment or victimisation as a result of raising an issue and will ensure all victims are treated with empathy and understanding and offered appropriate support. The Company will also take steps to protect any persons involved in the investigation of a complaint.
Where allegations are investigated and found to be groundless or malicious, appropriate action will be taken by Company, after taking all circumstances into consideration.
Policy Implementation
The Company will communicate proactively with employees, workers, external contractors, suppliers to ensure they are aware of their responsibilities under this Policy and are empowered to apply it through the necessary education, training , associated guidance and support.
The Company has in place Grievance Procedures which provide mechanisms by which employees, workers, external contractors, suppliers and community members can raise any concerns or issues in connection with this policy. Alongside the implementation of this policy, the Company is raising awareness amongst its stakeholders about the Grievance procedures it has in place.
It is the responsibility of Senior Management to monitor the efficacy of the Respect at Work Policy and to ensure appropriate management controls and monitoring are in place.
The Company will report any serious breaches of this policy to its ESG Board Committee and will provide its ESG Board Committee with a general annual update report.
