Ancoris Anti-Harassment Policy

Introduction

Ancoris respects, appreciates, understands and supports every aspect of diversity. We have zero tolerance for discrimination, bullying, and sexual harassment.

Everyone at Ancoris has a responsibility to prevent and stop harassment. It is expected that everyone will contribute to an inclusive and collaborative working environment and respect each other at all times. This behavior is not limited to internal interactions with each other which occur at work and out of the workplace, but also to interactions with customers, partners and anyone you have business interactions with.

Should you become aware of or witness any form of harassment or behavior that violates this policy or our company values, please report the incident directly to your manager, Chief People Officer or a People Team member immediately for thorough investigation.

Scope

Our Anti-Harassment policy applies to all employees and their interactions with customers, partners and anyone you have business interactions with, as well as on business trips or at work-related events or social functions. It also covers harassment by third parties, such as clients, customers, vendors, or anyone else our employees interact with in a professional capacity. Employment laws must be followed when handling, reporting and investigating incidents of harassment. The People team and legal counsel, if required, will be called upon to ensure compliance and the appropriate legal processes and procedures are followed. All individual contributors, managers, and leaders will be subject to disciplinary action, up to and including termination, for any act of harassment they commit.

Types of Harassment


The following are considered forms of harassment and will not be tolerated:

 

a) Sexual Harassment

Sexual harassment is considered unwelcome conduct of a sexual nature that is sufficiently persistent or offensive enough to interfere with the receiver’s job performance or create an intimidating, hostile or offensive working environment.

Sexual harassment encompasses a wide range of conduct. Examples of misconduct include, but may not be limited to, the following actions:

  1. Physical assaults or the attempt to commit an assault of a sexual nature. This physical conduct can include inappropriate touching, pinching, patting, grabbing or poking another team member's body.
  2. Unwelcome sexual advances, propositions or other sexual comments, such as sexually oriented gestures, noises, remarks, jokes, or inappropriate comments about a person’s sexuality or sexual experience.
  3. Preferential treatment or promises of preferential treatment to a team member for submitting to sexual conduct, including soliciting or attempting to solicit any team member to engage in sexual activity for compensation or reward.
  4. Subjecting, or threats of subjecting a team member to unwelcome sexual attention or conduct or intentionally making performance of the team member's role more difficult because of that team member's sex.
  5. Creating displays, communications, or publications that include content of a sexually offensive nature.
  6. Purposely misgendering people, such as consistently referring to someone as 'he' after repeated requests to use 'she' or vice versa.
  7. Unwanted physical contact, even if seemingly minor (e.g., intentionally brushing against someone).
  8. Sexual jokes, inappropriate innuendo or comments, even if "meant to be funny".
  9. Displaying or sharing sexually suggestive images, videos, or texts (including on personal devices if visible to others).
  10. Repeatedly asking a colleague out after they've said no.
  11. Spreading rumours about someone's sexual activity or orientation.
  12. Making comments about someone's body, clothing, or appearance that are sexualized or objectifying.
  13. Using gender-stereotyped or sexualized nicknames.

Sexual harassment can occur even when there is no direct reporting relationship. Power imbalances can be subtle and based on factors like seniority, popularity, or access to information.

Ancoris will not tolerate harassment of employees by clients, customers, vendors, or anyone else they interact with in a professional capacity. Ancoris could take the following actions to protect employees from a third party: warning the third party,  banning the third party from Ancoris premises, terminating contracts with the third party.

Sexual harassment is unlawful and is considered a form of misconduct. Sanctions will be enforced against individuals engaging in sexual harassment and against supervisory and managerial employees who knowingly allow such behavior to continue. 

b. Discrimination

Having a diverse workforce, made up of team members who bring a wide variety of skills, abilities, experiences and perspectives, is essential to our success. We are committed to the principles of equal opportunity, inclusion, and respect. All employment-related decisions must be based on company needs, job requirements, and individual qualifications. 

We do not tolerate discrimination against anyone, including team members, customers, partners, or other stakeholders. Any form of discrimination towards an individual is strictly prohibited, including:

  • On the basis of race, color, religion, ethnicity, national origin, sex (including pregnancy), age, disability, HIV status, sexual orientation, gender identity, marital status, past or present military service, religious belief or lack of religious belief, life expectancy, or any other status protected by the laws or regulations in the locations where we operate.

c. Bullying / Workplace Violence

Ancoris does not tolerate violent acts or threats of violence. The company will not tolerate fighting, bullying, coercion, or use of abusive or threatening words directed to, about, or against a co-worker, lead, manager, executive, candidate, client/customer, partner, vendor, contributor, or any other person. No individual employed by Ancoris should commit or threaten to commit any violent act or discuss committing such offenses, even in a joking manner.

4. Bystander Intervention

Bystanders play a crucial role in preventing and stopping harassment, including sexual harassment. Employees are encouraged to intervene safely and effectively when they witness harassment, using techniques such as:

  • Directly addressing the harasser ("That's not appropriate.")
  • Supporting the person being harassed ("Are you okay? Do you want me to stay with you?")
  • Reporting the incident to the People Team or a manager
  • Distracting the harasser or creating a diversion
  • Talking to the harasser later in private about their behaviour

5. Speaking up during a public situation

If someone says or does something which is not inline with this policy, people are encouraged to speak up publicly and within the moment, in order to let that person and others know that what happened was not inclusive behavior.

This makes for a situation from which all parties can learn, and is one which promotes understanding. Additionally it makes it possible for that person to de-escalate the situation by correcting themselves and apologising.

This does not ensure there will be no consequences. However, it will greatly reduce the chance of escalation and has the potential to help a situation.

6. Reporting a Physical Threat

If a threat is made against you or someone else that makes you or another team member question their safety due to an issue, email or other work related matters do not hesitate to initiate the following process:

  1. Contact local law enforcement. Note the proper number to contact in your locality and whether the emergency, or non-emergency number should be called.
  2. Notify the People Team. A private conversation may then be started with the People Team and other teams assisting with the situation such as the security team.
  3. The following steps may be taken based on the threat:
    • Internal threat assessment
    • Temporary accommodation (friends, family, hotel, etc.)
    • Transportation to alternate location (stay with family/friends for example)
    • Time off from work
  4. The above can be triggered by the People Team in the event that it isn’t safe for you to do so. Whenever it is safe to do so, please follow step 1 and 2, contacting the local law enforcement yourself. If a threat is credible and potentially imminent, immediate action may be taken by the People Team or a senior stakeholder to ensure safety.
  5. The Chief People Officer will advise when it is best to halt any of the above tasks.

7. Reporting Alleged Harassment

  1. If you are being harassed or bullied, consider whether you feel able to raise the problem informally with the person responsible. You should state clearly that their behavior is not welcome and why it makes you uncomfortable.
  2. Of course, this can be very intimidating so if you’re finding it too difficult or the behavior doesn’t cease, you should speak to your line manager, the People team, or another trusted member of the team to help you deal with the situation in an informal or formal manner.
  3. Once reported, an impartial investigation will be conducted by a People Team member or by an independent third party, depending on the severity and circumstances of the complaint.
  4. If raising the matter informally has not stopped the bullying and harassment, then you should raise the matter formally using our Disciplinary and Grievance policy. You can also contact the People team for guidance. 

We will investigate complaints in a timely and confidential manner. The investigation will be conducted by someone with appropriate experience and no prior involvement in the complaint, where possible.

Details of the investigation and the names of the person making the complaint and the person accused must only be disclosed on a "need to know" basis. We will consider whether any steps are necessary to manage any ongoing relationship between you and the person accused during the investigation.

Once the investigation is complete, we will inform you of our decision. If we consider you have been harassed by an employee the matter will be dealt with under the Disciplinary and Grievance Policy as a case of possible misconduct or gross misconduct. If the harasser is a third party such as a customer or other visitor, we will consider what action would be appropriate to deal with the problem. Whether or not your complaint is upheld, we will consider how best to manage any ongoing working relationship between you and the person concerned.

Please note:

  • Rest assured that if you bring up an issue around harassment and bullying, it’ll be taken seriously and handled confidentially.
  • If you notice someone else in the team struggling with bullying and harassment, you can help! We always aim to respect everyone’s confidentiality however we also have a duty of care towards our colleagues, so be sure to report situations like these so none of our colleagues suffer in silence.
  • If raising the matter informally has not stopped the bullying or harassment, then you should raise the matter formally using our Disciplinary and Grievance policy

a) Retaliation

It takes a lot of courage to raise issues around harassment. Employees who make informal or formal complaints or who participate in good faith in any investigation must not suffer any form of retaliation or victimisation as a result. Anyone found to have retaliated against or victimised someone in this way will be subject to disciplinary action under our Disciplinary and Grievance policy.

Retaliation of any sort will not be tolerated. If you believe you have been retaliated against, please contact the Chief People Officer or a member of the People Team.

b) Record-keeping

Information about a complaint by or about an employee may be placed on the employee's file, along with a record of the outcome and of any notes or other documents compiled during the process. These will be processed in accordance with our Data Protection Policy.

8. The Role of Managers

If managers become aware of alleged harassment, they must deal with any allegations expeditiously, seriously, confidentially, and fairly, whether or not there has been a written or formal complaint made to the People Team. Managers are expected to:

  1. Take all complaints or concerns of alleged harassment seriously no matter how minor or who is involved.
  2. Ensure that any form of harassment or misconduct is immediately reported to the People Team.
  3. Take appropriate action to prevent retaliation, or the alleged misconduct from recurring, during and after an investigation.

Managers who knowingly allow or tolerate any form of harassment or retaliation, including the failure to immediately report it to the People Team, are in violation of this policy and subject to disciplinary action, including termination.

9. The Role of Individual Contributors

All employees have the responsibility to help create and maintain a work environment free of bullying and harassment and can help by:

  1. Being aware of how their own behavior may affect others, and changing it if necessary.
  2. Treating their colleagues with dignity and respect.
  3. Taking a stand if they think inappropriate jokes or comments are being made to others.
  4. Making it clear to others where they find their behavior unacceptable.
  5. Intervening, if possible, to stop harassment or bullying from occurring.
  6. Reporting promptly to their manager or the People Team any incident of bullying or harassment witnessed by them.

10. The Role of the People Team

The People Team is responsible for:

  1. Ensuring that any individual filing a formal complaint and any accused individual(s) are made aware of the seriousness of misconduct.
  2. Exploring informal means of resolving potential harassment if a written (formal) complaint is not made when verbal allegations are shared.
  3. Explaining Ancoris’ no tolerance harassment policy and investigation procedures to all individuals included in a complaint.
  4. Arranging for an immediate investigation of alleged misconduct and the preparation of a written report summarising the results of the investigation and making recommendations for remediation to designated company officials.
  5. Notifying appropriate authorities (police) when criminal activities are alleged.

11. Classification of disciplinary action

All individual team members, managers, and leaders will be subject to disciplinary action, up to and including termination, for any act of harassment they commit. Disciplinary action will be specific to each case, and you can read the full details of our disciplinary procedure here.

12. Training & Guidance

Training and guidance on understanding, preventing, and dealing with bullying, discrimination and harassment, including sexual harassment is provided to all employees on a mandatory annual basis using our LMS platform.

Courses

Failure to complete this training in a timely manner as requested by the business will result in disciplinary action.

13. Resources

Employees can access the following resources for support and guidance on harassment-related issues:

The Ancoris Anti-Harassment Policy is also available on our website.