Code of conduct policy

Code of Conduct at Right People Group

At Right People Group (“the Company”), we require that all of our employees conduct themselves according to the highest standards of ethics, integrity, and behavior when dealing with our clients, colleagues and other stakeholders. This includes, but is not necessarily limited to, full compliance with all legal obligations imposed by statute or any other source of law.

This Code establishes our policies for the standards of behavior that must be met by all employees. Where these standards are not met, appropriate disciplinary action will be taken. In cases where the breach involves serious misconduct, this may result in summary dismissal. In cases where a breach of the policy involves a breach of any law, then the relevant government authorities or the police may be notified.

Operation

The purpose of the code of conduct and the attached policies is to make it clear what the Company expects from employees, and employees are required to be familiar with and comply with the terms of this policy at all times. Failure to do so may result in disciplinary action, including potentially termination of employment. In so far as this code of conduct and the attached policies imposes any obligations on the Company, those obligations are not contractual and do not give rise to any contractual rights. To the extent that this code of conduct and the attached policies describes benefits and entitlements for employees, they are discretionary in nature and are also not intended to be contractual. The terms and conditions of employment that are intended to be contractual are set out in an employee’s written employment contract.

The Company may unilaterally introduce, vary, remove or replace this code of conduct and the attached policies at any time.

Standards of conducts

The standards expected of employees include:

● Compliance with all Company and workplace policies, procedures, rules, regulations and contracts.

● Compliance with all laws.

● Compliance with all reasonable and lawful instructions given by or on behalf of the Company.

● Devotion of the employee’s entire time, attention and skill during normal working hours and at other times as reasonably necessary for the employee to perform their duties.

● To be honest and fair in dealings with customers, clients, co-workers, Company management and the general public, and to treat them with courtesy and respect.

● To be faithful and diligent, and actively pursue the Company’s best interests at all times.

● To work in a safe and compliant manner, and to observe all workplace health and safety rules and responsibilities.

● Refraining from any discriminatory, bullying or harassing behavior toward customers, clients, co-workers, Company management and the general public.

● To not make any statements about the Company on social media, or any other public platform, that may harm the Company’s reputation.

● To not, in connection with the employee’s employment, accept any financial or other benefit from any entity other than the Company – unless acceptance of such benefit is in accordance with the Company’s other workplace policies or is otherwise disclosed to the Company and expressly permitted by the Company.

● To not engage in any employment or provide any services to any person or entity other than the Company, except with the Company’s prior written consent.

● To not engage in any employment or provide any services to a supplier or competitor of the Company, except with the Company’s prior written consent.

● Immediately disclosing any potential, perceived or actual conflict of interest (whether direct or indirect) that may give rise to a conflict with the performance of the employee’s obligations to the Company, or the Company’s business, confidential information or reputational interests. The Company may direct employees to take action to eliminate or reduce any such conflict, and employees must comply with such directions.

● To not engage in conduct, whether during or after work hours, that in the opinion of the Company causes damage or potential damage to the Company’s property or reputation.

● To not use, or come to work while affected by use of prohibited drugs or alcohol.

● To not discriminate on the basis of personal characteristics including (but not limited to) sex, race, disability, pregnancy, age, marital status or sexual orientation.

● To ensure and maintain punctuality.

● To respect the Company’s property.

● To not use Company internet to access and/or download sexually explicit or other offensive material.

● To not use Company email to send sexually explicit or suggestive material, or other offensive or harassing material.

● To maintain both during employment and after termination of employment with the Company, the confidentiality of any confidential information, records or other materials acquired during the course of employment.

● At all times, behave in a way that upholds the Company’s core values and the integrity and good reputation of the Company.

● Reporting any conduct of other workplace participants which is in breach of any of the above, or potentially in breach of any of the above, without delay.

Other policies

Employees and are encouraged to read this policy in conjunction with other relevant Company

policies, including:

● Workplace Anti-Bullying & Anti-Harassment Policy

● Equal Employment Opportunity and Anti-Discrimination Policy

● Staff Social Functions Policy

● Grievance handling policy

Who does this code of conduct and attached policies apply to

● All employees of Right People Group and related holdings, daughter and sister-companies.

Equal Employment Opportunity & Anti-discrimination policy

Right People Group (“the Company”) is committed to providing a safe, flexible and respectful environment for staff and clients free from all forms of discrimination, bullying and sexual harassment.

All staff is required to treat others with dignity, courtesy and respect.

By effectively implementing our Equal Employment Opportunity & Anti-Discrimination Policy we will attract and retain talented staff and create a positive working environment for staff.

Scope

This policy applies to:

● Board members

● All staff, including: managers and supervisors; full-time, part-time or casual, temporary or permanent staff; job candidates; student placements, apprentices, contractors, sub-contractors and volunteers;

● How the Company provides services to clients and how it interacts with other members of the public;

● All aspects of employment, recruitment and selection; conditions and benefits; training and promotion; task allocation; shifts; hours; leave arrangements; workload; equipment and transport;

● On-site, off-site or after-hours work; work-related social functions; conferences – wherever and whenever staff may be as a result of their duties;

● Staff treatment of other staff, of clients, and of other members of the public encountered in the course of their duties.

Staff right and responsibilities

● All staff are entitled to:

● Recruitment and selection decisions based on merit and not affected by irrelevant personal characteristics;

● Work free from discrimination, bullying and sexual harassment;

● The right to raise issues or to make an enquiry or complaint in a reasonable and respectful manner without being victimized;

● Reasonable flexibility in working arrangements, especially where needed to accommodate their family responsibilities, disability, religious beliefs or culture.

All staff must:

● Follow the standards of behavior outlined in this policy;

● Offer support to people who experience discrimination, bullying or sexual harassment, including providing information about how to make a complaint;

● Avoid gossip and respect the confidentiality of complaint resolution procedures and the grievance policy;

● Treat everyone with dignity, courtesy and respect.

Additional responsibilities of managers and supervisors

Managers and supervisors must also:

● Model appropriate standards of behavior;

● Take steps to educate and make staff aware of their obligations under this policy and the law;

● Intervene quickly and appropriately when they become aware of inappropriate behavior;

● Act fairly to resolve issues and enforce workplace behavioral standards, making sure relevant parties are heard;

● Help staff resolve complaints informally;

● Refer formal complaints about breaches of this policy to the appropriate complaint handling officer for investigation;

● Ensure staff who raise an issue or make a complaint are not victimized;

● Ensure that recruitment decisions are based on merit and that no discriminatory requests for information are made;

● Seriously consider requests for flexible work arrangements.

Unacceptable workplace conduct

Discrimination, bullying and sexual harassment are unacceptable at the Company and furthermore are unlawful under legislation. Staff (including managers) found to have engaged in such conduct might be counseled, warned or disciplined. Severe or repeated breaches can lead to formal discipline up to and including termination of employment.

Under the law staff can be held personally liable for certain breaches of discrimination law and the Company can also be vicariously liable for staff members’ conduct.

Discrimination

Discrimination is treating, or proposing to treat, someone unfavorably because of a personal characteristic protected by the law, such as sex, age, race or disability.

Protected personal characteristics under discrimination laws include:

● A disability, disease or injury, including work-related injury;

● Parental status or status as a career, for example, because they are responsible for caring for children or other family members;

● Race, color, descent, national origin, or ethnic background;

● Age, whether young or old, or because of age in general;

● Sex;

● Industrial activity, including being a member of an industrial organization like a trade union

or taking part in industrial activity, or deciding not to join a union;

● Religion;

● Pregnancy and breastfeeding;

● Sexual orientation, intersex status or gender identity, including gay, lesbian, bisexual,

transsexual, transgender, queer and heterosexual;

● Marital status, whether married, divorced, unmarried or in a de facto relationship or same sex relationship;

● Political opinion;

● Social origin;

● Medical record;

● An association with someone who has, or is assumed to have, one of these characteristics, such as being the parent of a child with a disability.

It is also against the law to treat someone unfavorably because you assume they have a personal characteristic or may have it at some time in the future.

Bullying

If someone is being bullied because of a personal characteristic protected by equal opportunity law, it is a form of discrimination.

Bullying can take many forms, including jokes, teasing, nicknames, emails, pictures, text messages, social isolation or ignoring people, or unfair work practices.

Under law, this behavior does not have to be repeated to be discrimination – it may be a one-off event.

Behaviors that may constitute bullying include;

● Sarcasm and other forms of demeaning language;

● Threats, abuse or shouting;

● Coercion;

● Isolation;

● Inappropriate blaming;

● Ganging up;

● Constant unconstructive criticism;

● Deliberately withholding information or equipment that a person needs to do their job or access their entitlements;

● Unreasonable refusal of requests for leave, training or other workplace benefits.

Any form of bullying is unacceptable in the Company and may also be against workplace health and safety law. The Company has a separate Workplace Anti-Bullying and Anti-Harassment Policy which employees must read and abide by, this deals with bullying and harassment that is not a form of discrimination (i.e. where not based on a protected personal characteristic).

Sexual harassment

Sexual harassment is a specific and serious form of harassment. It is unwelcome sexual behavior, which could be expected to make a person feel offended, humiliated or intimidated. Sexual harassment can be physical, spoken or written. It can include:

● Comments about a person’s private life or the way they look;

● Sexually suggestive behavior, such as leering or staring;

● Brushing up against someone, touching, fondling or hugging;

● Sexually suggestive comments or jokes;

● Displaying offensive screensavers, photos, calendars or objects;

● Repeated unwanted requests to go out;

● Requests for sex;

● Sexually explicit posts on social networking sites;

● Insults or taunts of a sexual nature;

● Intrusive questions or statements about a person’s private life;

● Sending sexually explicit emails or text messages;

● Inappropriate advances on social networking sites;

● Accessing sexually explicit internet sites;

● Behavior that may also be considered to be an offence under criminal law, such as physical assault, indecent exposure, sexual assault, stalking or obscene communications.

Just because someone does not object to inappropriate behavior in the workplace at the time, it does not mean that they are consenting to the behavior. Sexual harassment occurs in the workplace when it happens at work, at work-related events, between people sharing the same workplace, or between colleagues outside of work.

All staff and volunteers have the same rights and responsibilities in relation to sexual harassment. A single incident is enough to constitute sexual harassment – it doesn’t have to be repeated.

All incidents of sexual harassment – no matter how large or small or who is involved – require employers and managers to respond quickly and appropriately.

The Company recognizes that comments and behavior that do not offend one person can offend another. This policy requires all staff and volunteers to respect other people’s limits.

The Company will not tolerate or accept any form of sexual harassment, in the workplace or in any work-related context such as conferences, work functions and business trips. All staff members are responsible for their own behavior, and under the law may be held personally liable if they engage in sexual harassment. The Company may also be vicariously liable for staff members found to have engaged in any form of sexual harassment.

Victimization

Victimization is subjecting or threatening to subject someone to a detriment because they have asserted their rights under equal opportunity law, made a complaint, helped someone else make a complaint, or refused to do something because it would be discrimination, sexual harassment or victimization. Victimization is against the law.

It is also victimization to threaten someone (such as a witness) who may be involved in investigating an equal opportunity concern or complaint.

Victimization is a very serious breach of this policy and is likely (depending on the severity and circumstances) to result in formal discipline against the perpetrator.

The Company has a zero-tolerance approach to victimization.

Vilification

Vilification is where a person commits a public act which is reasonably likely to offend, insult, humiliate or intimidate another person because of their race, sex, religion, sexuality or sexual identity. Hatred or vilification due to an attribute protected under equal opportunity laws is unlawful.

The Company will not tolerate or accept any form of hatred or vilification due to a protected attribute of another person.

Any conduct that can possibly be observed by the public or any sort of communication either verbal or in writing to the public can be considered a public act. Workplaces can be public places.

The Company may be vicariously liable for staff members found to have engaged in any form of unlawful hatred or vilification. Staff may also be sued personally or prosecuted criminally under criminal laws.

Conduct that may constitute vilification can include verbal or written statements, or even be the reproduction or distribution of already published information. Examples include:

● Offensive material on the internet, including e-forums, blogs, social networking sites and video sharing sites;

● Offensive comments or images published in a publication such as a leaflet, flyer, internal message board or workplace intranet;

● Offensive speeches at public events, work functions or in the workplace;

● Abusive comments in any public place, such the workplace, or any other place attended in connection with employment; or

● In some instances, the reproduction or distribution of already published information around the workplace.

Confidentiality

It is unacceptable for staff at the Company to talk with other staff members, clients or suppliers about any complaint of discrimination or harassment without the Company’s express permission.

Breaching the confidentiality of a formal complaint investigation or inappropriately disclosing personal information obtained in a professional role (for example, as a manager) is a serious breach of this policy and may lead to formal discipline.

Decisions to be based on merit

All recruitment and job selection decisions at the Company will be based on merit – the skills and abilities of the candidate as measured against the inherent requirements of the position – regardless of personal characteristics.

It is unacceptable and may be against the law to ask job candidates questions, or to in any other way seek information, about their personal characteristics, unless this can be shown to be directly relevant to a genuine requirement of the position.

Resolving issues

The Company strongly encourages any staff member who believes they have been discriminated against, bullied, sexually harassed, vilified or victimized to take appropriate action by making a complaint in accordance with the Grievance Handling Policy.

Any staff member who has witnessed any discrimination, bullying, sexual harassment, vilification or victimization should report this to their manager or other responsible person in the Company, or can raise a complaint in accordance with the Grievance Handling Policy.

Workplace Anti-bullying policy and Anti-harassment

Policy

Right People Group (“the Company”) seeks to provide a work environment that is safe and enjoyable for all.

Workplace bullying has a detrimental effect on the Company and its people. It can create an unsafe working environment, result in a loss of trained and talented workers, cause the breakdown of teams and individual relationships, increase absenteeism and reduce efficiency and productivity. People who are bullied can become distressed, anxious, withdrawn and can lose self-esteem and self-confidence. Workplace bullying is also in some circumstances against the law. For these reasons bullying will not be tolerated by the Company.

The Company recognizes that workplace bullying may involve comments and behaviors that offend some people and not others. The Company accepts that individuals may react differently to certain comments and behavior. That is why a minimum standard of behavior is required of workers. This standard aims to be respectful of all workers.

The Company recognizes that workplace bullying can take place though a number of different methods of communication including face to face, email, text messaging and social media platforms. As such, this Policy applies to all methods of communication through which workplace bullying can take place.

This Policy applies to behaviors that occur:

● in connection with work, even if it occurs outside normal working hours;

● during work activities, for example, when dealing with clients;

● at work related events and functions, for example, at Christmas parties;

● on social media platforms where workers interact.

This Policy applies to all workers including employees, contractors and volunteers.

What is workplace bullying?

Workplace bullying occurs when an individual, or a group of individuals, repeatedly behaves

unreasonably towards a worker, or a group of workers, and the behavior creates a risk to health

and safety. It includes both physical and psychological abuse.

Bullying behaviors can take many different forms, from the obvious (direct) to the more subtle (indirect).

The following are some examples of direct bullying:

● abusive, insulting or offensive language or comments;

● violent, aggressive or intimidating conduct;

● belittling or humiliating comments;

● Victimization; and practical jokes or initiation.

The following are some examples of indirect bullying:

● unjustified criticism or complaints;

● deliberately excluding someone from work-related activities;

● withholding information that is vital for effective work performance;

● setting unreasonable timelines or constantly changing deadlines;

● setting tasks that are unreasonably below or beyond a person’s skill level;

● denying access to information, supervision, consultation or resources to the detriment of the worker;

● spreading misinformation or malicious rumors;

● changing work arrangements such as rosters and leave to deliberately inconvenience a particular worker or workers.

The above examples are not an exhaustive list of bullying behaviors. They are indicative of the type of behaviors that may constitute bullying and are therefore unacceptable to the Company. If you are unsure whether behavior not provided on this list constitutes bullying you should contact your direct supervisor in the first instance.

What is not workplace bullying?

Reasonable management action taken by managers or supervisors to direct and control the way work is carried out is not considered to be workplace bullying, if the action is taken in a reasonable and lawful way.

The following are some examples of reasonable management action:

● realistic and achievable performance goals, standards and deadlines;

● fair and appropriate rostering and allocation of working hours;

● transferring a worker to another area or role for operational reasons;

● deciding not to select a worker for a promotion where a fair and transparent process is followed;

● informing a worker about unsatisfactory work performance in an honest, fair and constructive way

● informing a worker about unreasonable behavior in an objective and confidential way;

● implementing organizational changes or restructuring; and

● taking disciplinary action, including suspension or terminating employment where appropriate or justified in the circumstances.

Other unacceptable conduct

Single incidents of unreasonable behavior (such as harassment, violence or threatening behavior) can also present a risk to health and safety and will not be tolerated.

Harassment is considered to be any form of behavior that is:

● unwanted;

● offends, humiliates or intimidates; or

● creates a hostile environment.

Where such conduct occurs towards a person due to a particular characteristic of that person (such as when based on sex, sexual orientation, pregnancy, marital status, age, disability, ethnicity or race, etc.) this may be unlawful under discrimination and equal opportunity law, even if it is limited to a single incident.

For example, sexual harassment is unlawful even where it is not repeated conduct. All workers are required to comply with the Company’s Equal Opportunity and Anti-Discrimination Policy which provides further guidance in this area.

The Company will also not tolerate any form of workplace violence. Workplace violence is considered to be any incident where a person is physically attacked or threatened in the workplace, whether this is directed to a co-worker, subcontractor, client, customer or visitor.

It includes (but is not limited to):

● Any type of direct physical contact such as punching, pushing, tripping, spitting, blocking of

● someone’s way, etc.;

● any form of unwanted physical contact.

Manager’s roles

Managers and supervisors have an important role to play in terms of fostering a culture that does not tolerate or encourage harassment, bullying or workplace violence and should ensure that they do not engage in any conduct of this nature themselves.

Managers and supervisors should also ensure that workers understand this Policy and consequences of non-compliance. When managers and supervisors observe harassment, bullying or workplace violence occurring, they should take steps to prevent this conduct from continuing and warn the person or people involved of the consequences if the behavior continues (including disciplinary measures up to and including termination of employment).

Managers and supervisors must also treat all grievances raised by workers in accordance with the Company’s Grievance Handling Policy.

Worker’s roles

The Company expects workers:

● not to engage in harassment, bullying or workplace violence;

● not to aid, abet or encourage others to engage in harassment, bullying or workplace violence;

● to behave in a responsible and professional manner;

● treat others in the workplace with courtesy and respect;

● listen and respond appropriately to the views and concerns of others; and

● to be fair and honest in their dealings with others.

Are you experiencing bullying, harassment or being subject to violence?

Complaints of bullying, harassment and workplace violence will be taken seriously and will be handled in accordance with the Company’s Grievance Handling Policy.

If you make a complaint of workplace bullying, harassment or violence it will be taken seriously and will be dealt with sympathetically and in a confidential manner (except where the Company deems it is necessary to disclose information in order to properly deal with the complaint).

You will not be victimized or treated unfairly for making a complaint.

If the claim is found to be substantiated, the Company will act in accordance with the law and the

Companies policies.

Please note that any worker found to have fabricated a complaint may be subject to disciplinary action, up to and including termination of employment.

Other measures

The Company also recognizes the need for open communication in the workplace. The Company may implement what training it considers necessary in relation to behavioral standards and where appropriate will hold meetings to address standards, expectations and any issues. The frequency, dates and form of this training and meetings will be determined by management of the Company.

Staff Social Functions Policy

At Right People Group (“the Company”) we believe that socializing between co-workers, management, clients and customers can help to build staff morale and positive and productive working relationships.

The Company may organize staff social functions from time to time. These functions may be held either on work premises or at another venue. Whilst these functions are for the enjoyment of staff, clients and business colleagues may attend these functions on occasion.

Employees are reminded that they must conduct themselves in a professional and responsible manner during staff functions and all employees are expected to meet the following behavioral standards:

● If alcohol is served during a staff function, employees must take an appropriate and responsible approach to alcohol consumption;

● Any use of illegal drugs during staff functions is strictly prohibited;

● Equal opportunity and anti-discrimination are a high priority within the Company and employees are required to be mindful of their behavior consistent with the Workplace Anti-Bullying & Anti-Harassment Policy and Equal Employment Opportunity and Anti-Discrimination Policy;

● Abusive language and threatening or violent behavior are not permitted in work situations including during staff functions;

● Employees are required to treat all company property or other facilities (such as where a staff function is held at a different venue) with respect and care.

● Employees are encouraged to remind colleagues or their manager or other senior person about the Company’s policies if the colleague display lack of appropriate and responsible approach.

A breach of this policy may result in disciplinary action up to and including termination of employment.

Workplace Health Policy

Right People Group (“the Company”) is committed to providing a safe and healthy workplace, safe working methods and is open to supporting staff that might encounter personal issues.

Workplace health is considered by management to be an integral and vital part of the successful performance of any job.

This policy sets out the responsibilities of the Company and its employees with the aim that together we can keep the workplace healthy and productive.

The Company is committed to:

● Integrating workplace health into all aspects of its operations;

● Ensuring that relevant health and safety laws that apply to working conditions and the work environment are observed and enforced;

● Ensuring that the behavior of all persons in the workplace is safe and physically and mentally healthy;

● Attempting to remedy all problems relating to workplace health including supporting staff that might experience personal problems including (but not limited to) stress, alcohol/drug/medical abuse;

● Consulting with workers and other parties to address health issues and improve decision making on workplace health

All employees and contractors are required to:

● Adhere to safe and healthy work practices, instructions and rules;

● Immediately report any unsafe or unhealthy work condition to the Company;

● Perform all work duties in a manner which ensures individual health and safety and that of

all other people in the workplace;

● Encourage fellow employees to create and maintain a healthy work environment;

● Cooperate with all other employees to enable the health responsibilities of all employees to be achieved.

Communication and consultation

We recognize that employee consultation and participation in our health system is vital and improves decision–making about health and safety matters in the workplace. Employees shall be actively involved in the workplace safety system. Suggestions for change and improvements to policies, procedures or practices are encouraged, through reporting to management. Meetings to consult and inform employees on health issues shall be conducted through group or staff meetings, as regularly as is necessary.

Grievance handling policy

At Right People Group (“the Company”) we aim to foster good relations amongst employees and between employees and management. We acknowledge that the enjoyment you experience in your job is reflected in how well you work and how well you relate to your colleagues and customers.

We also acknowledge that problems can arise at work that may sometimes cause you to feel aggrieved. These problems can sometimes arise from the behavior or decisions of management or other employees.

The purpose of this policy is to allow you to have such problems, referred to as grievances, addressed internally in a timely and confidential manner.

A grievance can be about anything done, or not done, by management or another employee or employees, which you feel affects you unfairly or unjustly. A grievance can also be about discrimination, harassment, bullying or any other employment related decision or behavior that you think is unfair, unjust or upsetting.

This Grievance Handling Policy outlines the procedures you should follow to try to resolve a grievance and also outlines the steps the Company will take to resolve your grievance if you make a formal complaint.

What are your options if you have a grievance?

In general, there are three options to consider if you have a grievance, being:

● Deal with the matter informally. A grievance can be dealt with informally by approaching the person involved in your grievance, if you feel comfortable in doing so. You can tell them that their behavior, decision, actions, etc. was unfair, offensive, discriminatory etc., and why you believe this to be so. The person may have been totally unaware of the effect of their behavior or decision on you. By telling them you will give them a chance to redress the situation. This may not be appropriate in some cases, particularly if you do not feel comfortable with speaking to the person.

● Speak to your manager or other senior person or Group HR function. If you do not want to speak to the person directly, you can tell your manager about your grievance. They should be able to tell you what your options are. They may approach the person complained about and talk to them informally about your grievance. They may decide to take more formal action. Generally, they will seek your approval before doing anything – although sometimes they may decide that taking action will be necessary even if you do not wish them to do so (for example where failure to do so pose a health and safety risk).

If your grievance is about your manager, you may wish to speak to another senior person.

Alternatively, you may decide to make a formal complaint.

● Make a formal complaint. If you do decide to make a formal complaint, this can be done by putting the complaint in writing and reporting it to your manager (or other senior person or Group HR function). The written complaint should contain a description of the incident(s), decision, behavior in question, the time and date of the incident(s), the names of any witnesses, your signature and date of the complaint.

● If you wish to speak to an external party – that is engaged with and have a formal arrangement with the group – you can contact:

Frederik Bruhn

Lawyer/Partner

Mobile: +45 22 95 13 75

Direct: +45 88 91 98 11

Mail: fbr@dahllaw.dk

Communication with this resource can be confidential and the resource will know how to approach different issues.

If you make a formal complaint how will your grievance be handled?

Grievances will be handled in accordance with the following guidelines:

● grievances will be treated with the utmost confidentiality (except where the Company deems it is necessary to disclose the complaint for the purpose of dealing with it effectively; disclosure will be no wider than is strictly necessary). It is important that you also maintain confidentiality and do not discuss your complaint with others, unless the Company gives you permission to do so.

● any grievance will be taken seriously, handled impartially and any steps taken will be in accordance with the principles of procedural fairness;

● employees who raise grievances are protected from victimization;

● grievances will be dealt with promptly, taking into account all of the circumstances; and

● generally, you may have a support person with you at any stage of the process.

The investigation

Where a grievance cannot be resolved informally and the Company deems an investigation is required, the matter will be investigated by such an appropriate person as the Company deems appropriate. This may be an external investigator.

How the investigation is to be conducted is at the complete discretion of the Company. The following are general guidelines only.

During the investigation, you will generally be interviewed first, following which any witnesses, the person against whom the complaint is made, and any other relevant people will be independently interviewed. Both you and the person against whom the complaint is made will generally be allowed to have a support person present when the interview is being conducted.

● If the complaint is substantiated, appropriate action will be taken (see below).

● If the complaint is unsubstantiated, you will generally be given an explanation as to why that finding was made.

● If the complaint is found to have been fabricated or vexatious, appropriate disciplinary action may be taken against you up to and including termination of employment.

What are the possible outcomes?

If the investigation reveals that your complaint is valid, a number of actions may be taken, depending on the nature of the complaint. The person against whom the complaint is made may be asked to give you a written apology, he/she may be given a written warning, counseling, transfer, demotion, or may be subjected to disciplinary action up to and including termination of employment.

If the investigation is inconclusive, i.e. the complaint cannot be proved due to lack of evidence or the conduct is not sufficiently serious to justify disciplinary action, the Company may nevertheless take a number of actions. These may include training and/or monitoring of relevant staff.

If the complaint is found to have been fabricated appropriate action may be taken against you in accordance with Company policies including counseling, a formal warning, transfer, demotion, or disciplinary action up to and including termination of employment, depending on the seriousness of the circumstances.

What is expected after an outcome?

Parties are expected to accept the outcome or escalate the matter further. If parties accept the outcome the Company expects the parties to in general adhere to the Company’s policies and to - at the best of their ability – to work to maintain a professional relationship with each other.

What if you are not satisfied with the outcome?

If at any point you are not satisfied with the way in which your grievance is being or was handled, you may wish to consider escalating the grievance from being informally handled to speaking with your manager, other senior person or Group HR or filing a formal complaint. You may at any point want to consider seeking advice from a union or legal advisor.