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Good conduct policy

Good conduct policy
– to prevent harassment, including sexual harassment

Introduction
This good conduct policy to prevent harassment and sexual harassment describes the steps Give Steel is taking to prevent abusive behaviours and actions. The purpose of this policy is to prevent and protect our employees against abusive actions in relation to their work.

The good conduct policy must help to ensure that all employees are familiar with Give Steel’s attitude to abusive behaviours and how they will be dealt with.

What is considered acceptable conduct and what is considered inappropriate can vary from person to person and from situation to situation, so it is very important in this regard that the level and severity of the offence should be determined by the offended party.

Transparency about this issue is extremely important and you must react if you hear, see, are aware of or are exposed to abusive behaviour.

Torben Larsen
CEO

Common guidelines for the prevention and management of sexual harassment, bullying and other abusive behaviours have been prepared by CSR and the Safety Committee. Discussed in the Security Committee on 2 December 2020.

With the preparation of these local guidelines, Give Steel wants to send a clear signal that:

  •  The tone within the company must be appropriate and characterised by mutual respect for each other.
  • Bullying and harassment are unacceptable and must not occur at the company under any circumstances.
  • Openness is very important. Do not remain silent if abusive behaviours are experienced or noticed.
  • The level and severity of the offence must always be determined by the offended party.

Give Steel’s stance on harassment, sexual harassment and abusive behaviour
We consider any kind of harassment to be unacceptable.
It is important for Give Steel to ensure a good and safe working environment where employees are able to thrive and develop, and where management and employees are part of a constructive collaboration. Accordingly, no forms of harassment can be tolerated.

Behaviour at the workplace
At Give Steel, it is important that the collaboration should proceed in a professional and respectful manner so that everyone feels comfortable.
At Give Steel, we share knowledge, listen to each other and are helpful. We communicate with each other in a spirit of openness and confidence, and we do not accept abusive and derogatory behaviour. Humour is important, and there must be room for that, but offensive and derogatory humour is not accepted.
Compliance with this and our other personnel policies is therefore a prerequisite for your employment at Give Steel.

What constitutes harassment and abusive behaviour?
Harassment is an act that violates a person’s dignity and being.
Harassment can be and is manifested and expressed in many different ways and will often have the character of e.g. insinuations, bullying, problematic rhetoric and miscommunication. It can also involve very specific physical assaults, unwanted touching and other transgressions.
There is no objective boundary between acceptable behaviour between individuals and actual harassment. Perception often varies greatly from person to person, which is precisely why it is important that the offended person should believe in their own experience of a given situation.
Harassment can be, but is not limited to, discriminatory behaviour in relation to: gender, gender identity and/or expression, ethnicity, religion, disability, sexual orientation, age.
It is the offended party who determines what is unwanted, transgressive or offensive.

Rules of conduct/guidance
Guidance for victims
It is never easy to be the victim of a violation. You may feel guilt and doing something about the situation can seem like an insurmountable task.

The victim of abusive behaviour determines
whether a behaviour is unwanted and transgressive.

It is important to signal that the overall responsibility for the working environment lies with the CEO and that Give Steel does not support an abusive culture. All employees and managers have a responsibility to contribute to a good working environment where bullying and harassment among employees do not exist.

Intervention and follow-up – Who will help you?
If you are a victim of harassment, it is important that you:

  • Trust what you yourself experience and feel. Be aware of what is happening to you both physically and mentally. If necessary, write down your thoughts and feelings.
  • Talk to people you trust. Involve others (friends, family, colleagues) to help you deal with the situation.
  • Try to react as quickly as you can when you experience harassment. This takes courage and strength, but do not wait until it has seriously affected you, mentally and physically. Conversely, it is never too late to react.
  • Take advantage of the opportunities you have to receive help:
  • Seek the support and backing of your friends and colleagues.
  • Seek help internally in connection with harassment:
    • Internal guidance of employees: If you experience or are in doubt as to whether what you are experiencing is harassment, contact xxx by email at xxxxx, by telephone on xxxxx or in person, and you will receive further help with how to deal with the situation.

In all cases, any such conversations will be confidential and subject to a duty of secrecy.

  • You can also use the above contacts/telephone line if you witness others being subjected to abusive behaviours.
  • If the violation is of a criminal nature, it must be reported to the police. This applies to violations such as violence, rape or obscenity.

Guidance for managers, shop stewards and employees

How should you react?

As a manager, shop steward and employee, you have a special responsibility to ensure that there is no harassment at the workplace. You are a role model for how employees should treat each other. You must be aware that you yourself may be misunderstood and perceived as an offender solely on the basis of the language you use.

  • Clearly demonstrate that you do not accept harassment.
  • Be open and listen for signs of harassment. Always take it seriously and show sensitivity if an employee feels badly treated and chooses to tell you about it. Security and trust are paramount, and it must be made clear that such conversations are conducted in confidence and are subject to a duty of confidentiality.
  • Activate passive witnesses, i.e. actively intervene if you become aware of harassment. You have a shared responsibility if you just let it happen.
  • Go to the CEO if you become aware of violations. The CEO will take up the matter and deal with it according to its nature.
  • Make sure that there is an awareness of the support mechanisms that exist within the company that the victim can contact for help.
  • Be aware that you can be misunderstood. It is important that the victim does not feel that you are taking the abuser’s side.

Reactions
Give Steel takes harassment and abusive behaviour extremely seriously and there can be consequences for the abuser’s employment or education.

The CEO is responsible for following up on any violations that management becomes aware of. The CEO will then present the case to the manager whose conduct has been perceived as offensive.

In cases that can be dealt with by a change in behaviour, the CEO has the option to issue a reprimand or a warning followed by a period of probation. In serious cases and in cases where a warning does not result in a change of behaviour, the person whose behaviour is abusive may find their employment terminated.

Any such legal consequences for employment will always be implemented in compliance with the general principles of employment and administrative law, such as objectivity and proportionality.

Safety Committee
All personnel matters are subject to a duty of confidentiality and can therefore not be discussed within the company.

If the victim desires full anonymity, there is no justification for the case to be conducted on an open basis, so the whole process will be handled without communicating or informing internal and external parties.

The task of the safety committee is to contribute to a safe, healthy and harassment-free working environment. On a day-to-day basis, this means that the working environment group pays particular attention to whether managers and employees are in compliance with rules and policies for acceptable conduct. The Safety Committee also has the daily task of promoting a corporate culture that is free of harassment.

The Safety Committee also performs workplace assessments (WPA), including practical work with mapping, assessment, action plans and follow-up.

If workplace assessments reveal that one or more employees experience that sexual harassment is taking place within the company, the Safety Committee will discuss the need to implement measures to strengthen prevention.

Once a year, the Safety Committee conducts a working environment discussion where the organisation of health and safety issues are determined for the coming year, including how the collaboration should proceed in practice.

If measures have been launched in the past year to strengthen the prevention of sexual harassment, the annual discussion will include an assessment of whether the goal of these activities has been met. Likewise, plans for new preventive measures will be discussed in connection with the annual working environment discussion.