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This company is committed to providing a work environment free from harassment of any kind and in particular, a work environment that does not tolerate sexual harassment. We respect the individual dignity of everyone involved in our work, whether they are employees, clients, customers or suppliers. We require all employees to make sure that their behaviour towards others is respectful and courteous at all times.

All employees, contractors, clients, and customers both inside and outside the work environment

1. The Company acknowledges the right of all employees to a working environment free from any form of harassment or bullying. Harassment is defined as any act or conduct that is unwelcome and unacceptable, and could be regarded as offensive, humiliating or intimidating, with a potential negative impact on the work environment.

2. Sexual harassment is defined as any act of a sexual nature, or with a sexual dimension as follows:

2.1. Unwanted conduct of a sexual nature. The unwanted nature of sexual harassment distinguishes it from behaviour that is welcome) and mutual.

2.2. Sexual attention becomes sexual harassment if:

(a) The behaviour is persisted in, although a single incident of harassment can constitute sexual harassment; and/ or

(b) The recipient has made it clear that the behaviour is considered offensive; and/or

(c) The perpetrator should have known that the behaviour is regarded as unacceptable.

3. Forms of sexual harassment can take are defined as:

3.1 Non-verbal - looks, gestures, whistling, suggestive symbols, pictures

3.2 Verbal - spoken words, shouting, unfair and excessive criticism

3.3 Physical - abusive behaviour, production, displaying or circulation of words, pictures, materials,

4. An individual will decide what behaviour is acceptable - not what the perpetrator, employer or another colleague finds acceptable. This policy covers all employees, as well as anyone invited onto the premises, including customers and suppliers.

5. Every manager has a responsibility to maintain the work place free of any form of sexual harassment. Everyone in this company has the responsibility to prevent bullying and sexual harassment and to report any instances that they are party or witness to.

6. Anyone engaging in any improper behaviour or sexual harassment on the premises or anywhere else while on company business will be subject to disciplinary action, up to and including dismissal.

7. Employees who feel that they are being harassed in any way in the workplace are encouraged to approach their own immediate manager, any manager, or the Managing Director. Either the employee or the manager must notify Human Resources.

8. All complaints of harassment will be taken seriously, will be held in strict confidence and will be investigated promptly and in an impartial manner. Only if these instances are reported can the company take action to correct the situation.

9. Any victimisation of, or retaliation against, a complainant or an employee who gives evidence regarding sexual harassment or bullying will be subject to disciplinary action up to and including dismissal.

(a) If possible, a recipient or a witness to an incidence of harassment should approach the perpetrator and ask him/her to stop.

(A) If the recipient or his/her witness is uncomfortable about approaching the perpetrator or if, having been approached, the perpetrator fails to stop, the victim's supervisor will be approached.

(B) If the recipient or witness feels that, for any reason, the victim's supervisor is not the appropriate person to approach, and then any other member of management will be contacted.

(C) All complaints will be investigated and written records kept of all interviews and investigations.

(D) Parties to the issue will have the option to have a colleague or friend present at all interviews.

(E) Penalties may differ depending on the severity of the harassment but the perpetrator will be subject to disciplinary action up to and including summary dismissal.

(F) If it is appropriate that one of the parties be transferred, the complainant will not be transferred unless he/she specifically requests such action.