Group Anti-Harassment& Anti-Discrimination Policy

For an inclusive and respectful workplace

First publication: March 2018

Current publication: January 2023

Version:3

Document type

: Policy

Scope: GlobalInternal

Policy nameGroup Anti-Harassment & Anti-Discrimination Policy

PurposeAs stated in Schneider Electric’s Trust Charter, the Group Anti-Harassment & Anti-Discrimination Policy(the Policy) sets forth a zero-tolerance policy for harassment and discrimination.

Schneider Electric (the Company) is committed to providing a safe and respectful environment for all,free from all forms of harassment and discrimination.

Audience
This Policy applies to Schneider Electric and all operating companies and subsidiaries under its
operational control worldwide.

Content
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Definitions
What is an inclusive and respectful workplace?
How to recognize potential misconduct?
What are Employees’ rights and responsibilities?
How do we prevent misconduct?
How do we address complaints?
What are Company responses to Policy violations?
Questions

Confidentiality Status: Public
Local adaptation authorization
This Policy may be supplemented by local policies containing additional requirements or outlining local
procedures related to investigations. It should be read in accordance with relevant local laws, which
includes local anti-harassment or anti-discrimination laws. Local adaptations, when needed.

Document Owner: Sandrine Reinneis, Group HR Compliance Officer
Document Reviewers:
Peter Wexler, SVP Chief Legal Officer
Nicolas Vlieghe, SVP Chief Compliance Officer
Tina Mylon, SVP Talent and Diversity
Karine Armand-Fedida, SVP Total Rewards and Performance

Document Approvers:
Hervé Coureil, EVP Chief Governance Officer & Secretary General
Charise Le, EVP Chief Human Resources Officer

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1. Definitions
Workplace – Anywhere where Schneider Electric’s employees are conducting business and/or where
they operate on the Company’s behalf.
➔ This Policy applies to any of our Workplaces worldwide.
➔

This includes, but is not limited to, conducting business in person on Schneider Electric premises,on the phone, virtually, or through email or other social media and/or during after-hours events suchas, but not limited to, business meetings, dinners, trainings, and during work-related travel.

Employee – Any person working on the Company’s premises, including apprentices, temporary
workers and trainees.
Harassment – Any offensive, inappropriate, unwelcomed, or even inadvertent behaviors at theworkplace, that has:•••the effect and/or purpose of violating a person’s dignity or creating a degrading, humiliating or
offensive/hostile work environment, orthe effect and/or purpose of unreasonably interfering with an individual’s work performance, oran adverse effect on the individual’s employment opportunities.

The harasser’s intent (whether intentional or not) does not justify inappropriate behavior. Harassment
occurs when the behavior is unwanted and/or objectionable or offensive to the recipient or witness tothe conduct. Harassment also includes, for purposes of this Policy, sexual harassment.
Sexual Harassment – Unwelcome, non-consensual conduct of a sexual or sexist nature that has theeffect and/or purpose of being offensive, degrading or humiliating. Sexual harassment can take manydifferent forms and may include physical contact, comments or other behavior that could create a hostileworking environment.
Discrimination – Unjustly or unfairly denying equal treatment or opportunity to individuals or groups
with respect to the terms, conditions, or privileges of employment based on a personal characteristic,
including any of the characteristics listed below in Section 3.2. This may include unfair treatment related
to hiring, firing, promotions, training, scheduling, or compensation.

The definitions of Harassment, Sexual Harassment and Discrimination may vary according to local
applicable laws.

2. What is an inclusive and respectful workplace?
“We want our employees - no matter who they are, or where they live in the world - to feel
uniquely valued and safe to contribute their best.” - Jean-Pascal Tricoire, Chairman and CEO

Schneider Electric’s purpose is to empower all to make the most of our energy and resources, bridging
progress and sustainability for all. We lead with inclusion and care; and strive to positively impact ourpeople, our company, and our society, as stated in our Trust Charter.
Our Diversity, Equity & Inclusion ambition is to be one of the most inclusive and caring companies in
the world, by offering equal opportunities to everyone, everywhere and ensure all Employees are
uniquely valued and safe to contribute their best. We believe everyone, everywhere in the company
deserves the same chance of success, and the right to bring their full and authentic selves into theworkplace.

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This Policy prohibits harassing or discriminatory conduct directed at anyone by anyone, including by
our Employees towards other Employees, and covers conduct by or directed at applicants, vendors,
contractors, business partners, or any other person working at Schneider Electric in any capacity or at
our customers’ or suppliers, including, but not limited to technical experts, sales team and office staff,
and anyone with whom we do business. We do not tolerate such behaviors and make it visible andenforced to all.
All our Employees and stakeholders are responsible for contributing to a culture of respect at Schneider
Electric, where everyone is psychologically safe to be their authentic self, free from harassment, bullying,
discrimination, and retaliation of any kind. By building on the foundations of respect and trust, we create
an open work environment that seeks out and embraces different perspectives.
Schneider Electric counts on the commitment and judgment of all Employees and stakeholders to apply
these standards.

3. How to recognize potential misconduct?
3.1. What are the different types of Harassment?
The following types and examples provide a general description of potential situations of harassment. They
do not constitute an exhaustive panorama of the various circumstances under which cases of harassment
may arise and may vary depending on local applicable laws.
Type

Description• Use of aggression with the effect and/or
purpose to harm or demean another Employee.

Bullying

Sexual harassment• Can be constituted when the behavior
becomes repetitive.

Unwelcomed sexual or sexist conduct (physical,
visual, verbal or written) which has the effectand/or purpose of affecting an individual’sdignity and creating an intimidating, hostile oruncomfortable working environment. It may be apattern of behavior or a single occurrence.
Sexual harassment may occur regardless ofgender, gender identity, or gender expression
and can be between same-sex or opposite-sex
individuals.

ExamplesWritten, verbal, or physical act and/or
communication, harming an employee orproperty, damaging someone’s ability to work,or creating an unsafe work environment.

• Verbal manifestations: words, advances,
propositions, or requests for sexual favors.
Vexatious comment or jokes against a person
because of sexual orientation, self-identified or
perceived sex, gender identity or expression.
• Written manifestations: sending any type of
written communication, including emails or text
messages, with unwelcome or offensive
sexual tone, requests, inquiries, jokes oradvances.
• Visual manifestations: leering, making sexual
gestures, displaying offensive sexuallysuggestive objects or pictures, cartoons or
posters, subtle or explicit demands for sexual
favors.
• Physical manifestations: unsolicited or
unwelcomed actions including touching or
assault.

Physical harassment(also called “violence”)

Unwelcome and inappropriate physical conduct,or actions which has the effect and/or purpose ofcreating an unsafe and intimidating work
environment.

Physical attack, humiliation and/or physicalthreat or assault in situations relating to work.

Discriminatory
harassment

Unjustly or unfairly denying equal treatment toan individual or a group based on a personal
characteristic.

When an objectionable or offensive conduct isdemonstrated, based on a particularcharacteristic. Examples may include:

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4• ethnicity: racial insults/jokes, hate symbols
associated with a particular race/ethnicity.
• religion: degrading comments or insulting
jokes on religions, stereotypical religious
comments.
• gender: display of material (videos, pictures)degrading to any gender.
• sexual orientation: jokes or degrading
comments about an individual’s sex or sexual
orientation, exclusion of an Employee becauseof their sex or sexual orientation or
expression.
Psychological harassment means improper
behavior, micro aggressions over a period, in asystematic or repetitive manner, involving
physical behavior, spoken or written language,
gestures or other acts that are intentional andmay undermine the dignity or psychologicalintegrity of any person.

Psychologicalharassment• Isolating or denying an employee’s presence.
• Discrediting or spreading rumors on someone.
• Belittling someone’s thoughts or work.
• Repeated verbal abuse.

Verbal harassment, or more generally,
inappropriate, or demeaning verbal behaviors,
micro aggressions.
It can be generated through the tone that isbeing used. The way something is said can be as
humiliating and demining as the words
themselves.
Verbal harassment
WARNING!
Difference with conflict: A conflict does notnecessarily constitute harassment.
Disagreement and different points of view
happen every day and are not necessarily
detrimental. Whenever a conflict arises,
employees have to resolve it in a respectfulmanner.

Threatening, yelling, insulting or cursing at anindividual in public or in private.

Malicious, demeaning and/or inappropriate
communications or tones through online / digitalcommunication tools.

Digital harassment

In addition, on internal and external social media,
the following rules apply:• As per Yammer Usage Policy, it is prohibited“to harass, abuse or harm another person,
including sending unwelcomed communications
to others using the community”.
• As per Social Media Policy:“Respect everyone - Respect your audience andtheir privacy, ensuring you are professional inyour participation - Do not post content that could
be seen as offensive, spam or inflammatory”.

Online inappropriate and/or disrespectfulcommunication (over digital devices like cell
phones, computers, and tablets or through
SMS, emails, Instant Messaging, and apps, insocial media, forums, or gaming…).

3.2. What are the different types of Discrimination?
Discrimination can occur:oDirectly, when a person or group is treated less favorably than another person or group in asimilar situation because of an actual or perceived personal characteristic;o

Indirectly, when a requirement, condition or practice is imposed that has, or is likely to have,the effect of disadvantaging people with a personal characteristic protected by Schneider
Electric, unless if such limitation is objectively justified by a legitimate aim and the means toachieve that aim are necessary and appropriate.

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At Schneider Electric, all decisions regarding selection, hiring, promotion, compensation, career
management and development, and all other terms and conditions of employment, are made without
regard to personal characteristics, or any other prohibited grounds of discrimination under local laws.
Personal characteristics can include the following:
o
o
o
o
o
o
o
o
o
o
o
o
o
o
o

a disability or temporary disability (including but not limited to: physical, cognitive, sensory or
psychological disability)
a disease or injury, including work-related injury
parental status
supposed race, skin color, descent, national origin, or ethnic backgroundage, generation
sex, including pregnancy, childbirth, or related medical conditions
gender or gender identity
membership to an industrial organization, like a trade union
religion
nationality, immigration status, citizenship, or ancestry
sexual orientation
marital statuspolitical opinionsocio-economic backgroundmedical record.

This list is not exhaustive and may be supplemented by local law.

4. What are Employees’ rights and responsibilities?
4.1. Employees
All Employees are entitled to:
o
o
o
o

o

recruitment and career development decisions based on qualifications
a workplace free from Harassment and Discrimination
have fair and equal treatment and/or development opportunities
voice concerns or complaints in good faith and in a respectful manner, through any reporting
channels, as provided for below and as outlined in the Group Whistleblowing Policy (see section
6)
psychological support, where applicable and appropriate

All Employees must:
o

o
o
o

follow the standards of behavior outlined in this Policy and our Trust Charter, in particular treat
everyone with dignity, courtesy, and respect. We believe “it all starts with respect” to create andmaintain a safe and inclusive workplace
offer support to people who experience Harassment and Discrimination, including providing
information about how to make a complaint
speak up if they observe or learn of behavior that may violate this Policy, even if they are notcertain if a violation has occurred
avoid malicious allegations and gossip and respect the confidentiality of case management

Harassment or Discrimination by non-Schneider employees

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If a situation of Harassment and/or Discrimination is reported on a potential wrongdoer who is
not a Schneider Employee, management will provide assistance to the potential victim andencourage reporting to the Trust line.

4.2. Human Resource Business Partners & Managers
As stated in our Trust Charter, Managers (both hierarchical and functional), as well as Human Resource
Business Partners “set the tone and exemplify our culture”. As such, they are expected to:
o
o
o
o

o
o

model appropriate standards of behaviors as per this Policy
take steps to educate and make teams aware of their obligations under this Policy
act fairly to resolve issues and enforce workplace behavioral standards
take action when they become aware of inappropriate behavior, including timely reporting
concerns about violations or potential violations of this Policy to the appropriate reporting
channels (see section 6)
ask questions and seek guidance from Human Resources, Legal Counsel, or a Regional
Compliance Officer when issues or concerns arise
implement and follow-up on the corrective actions in the case of a violation (see section 7)

5. How do we prevent misconduct?
Speak-Up Mindset:
Schneider Electric Employees must feel free and psychologically safe to share their ideas, opinions,and concerns without fear. The Company is committed to creating an atmosphere that makes people
feel comfortable voicing doubts.
Make it applicable for all Employees, everywhere:
This Group Policy covers the various types of Harassment and Discrimination mentioned above, lists
are not exhaustive and are deployed in each Region and/Country to adapt to local laws and policies.
Make it visible and shared to all:We make our commitment visible, and we share awareness to our Employees and stakeholders to build
further Schneider Electric’s integrity.
Embed expected behaviors in our performance management:
Schneider Electric Employees are expected to live up to and demonstrate respectful behaviors in theworkplace, in line with our Core values (for all Employees) and Leadership Expectations (for Managers).
Each year, our Employees are evaluated on the “how” they perform, as at Schneider’s, the “how” is as
important as the “what”.
Grow Employees’ awareness through specific training modules, available to all Employees in the
Responsible Workplace playlist on our training platform.

6. How do we address complaints?
Schneider Electric empowers Employees, contractors and external stakeholders to speak up without
fear of harm, as they are our first line of defense.

Any person who believes in good faith that they have witnessed a violation of our Trust Charter, thisGroup Anti-Harassment & Anti-Discrimination Policy
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Policy and/or related law and regulations, or who becomes aware of such misconduct, is encouraged
to report it through:
▪
▪
▪
▪
▪

the Schneider Electric’s whistleblowing system, Trust Line, which may be done anonymously(as per local law),a trusted Manager,
Human Resources Business Partner,
Legal Counsel,
Regional Compliance Officer.

For jurisdiction-specific reporting options, see the Group Whistleblowing Policy or further guidance.
Schneider Electric takes all allegations of Harassment, Discrimination, and retaliation seriously andconducts, when applicable, prompt, thorough and confidential investigation. All concern submissions
are handled impartially, respectfully and in respect of applicable laws by the Ethics & Compliancedepartment.
The intent of the Policy is to deter conduct that is unwanted, unreasonable, and demeaning. Therefore,
the Company may find a violation of the Policy even where the actions fall short of unlawful harassment
under applicable law. The Company considers whether a reasonable person could conclude that the
conduct created an intimidating, hostile, degrading, or demeaning environment.
IMPORTANT - Protection against retaliation: Schneider Electric strictly prohibits retaliation against
anyone who, in good faith, reports violations of this Policy or participates in an investigation, even if theinvestigation does not ultimately prove the concerns. Dishonest, bad faith, or otherwise abusive reports(such as false or personal attacks aimed at specific individuals) are however prohibited and may resultin disciplinary and/or legal action up to and including termination.
For more information, please consult the Group Whistleblowing Policy and the Case Management &Investigation Policy.

7. What are Company responses to Policy violations?
7.1. Disciplinary and corrective measures
Failure by an employee to comply with this Policy and/or applicable laws will result in corrective actions,disciplinary measures and/or legal action up to and including termination, as per the Group
Whistleblowing Policy.
Corrective and disciplinary measures may include:
o
o
o
o
o
o

Behavioral managerial development
Verbal warning
Written warning
Internal action (change of role, etc.)
Contract termination
Other legal action

This list is not exhaustive. Sanctions are proportionate to the misconduct and may vary as they will be
determined in full compliance with relevant applicable local labor laws and procedures (refer to the CaseManagement & Investigation Policy).

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8Mediator
To secure safe, respectful, and inclusive collaboration, Schneider Electric may propose intervention of
an internal or external mediator to help rebuild respectful collaboration.

7.2. Remediation measures
In case of an alert and to protect our Employees’ safety and ability to perform their best, Schneider
Electric may offer the following set of remediation measures, with employee’s consent (not exhaustivelist):
o
o
o
o
o
o

o

Safety measures (distancing)Temporary accommodations
Flexible Time management and/or location
Support for civil and penal actions
Change of function/service (temporary assignment and/or change of reporting line)
Internal or external mediation
Psychological support, where applicable

8. Questions
If in doubt about any aspect of this Policy, Employees should seek advice from the Human Resources
community or contact their Regional Compliance Officer. In addition, the Company has appointed
Ethics Delegates as a further point of contact for Employees, internally to help them with any question
about Trust Charter and Schneider Electric Policies. They are there to advice and talk about ethics
dilemma.
Local law may establish a different mandatory standard or requirement related to workplace conduct,harassment and discrimination, and that standard or requirement will apply. Where there isinconsistency between this Policy and local laws (including the definitions of harassment anddiscrimination), local laws will apply unless this Policy provides greater protection.

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