POLICY TEMPLATEGENDER-BASED VIOLENCEAND HARASSMENT AT WORKThis gender-based violence and harassment Policy Template aims to assist WEPs signatories in recognizing and assessing the risks of workplace-based violence and harassment on the basis of gender.
It also aims to help signatories establish clear guidelines for employees to report incidents of violenceand harassment. The text can be used as is or customized according to your company’s requirements.

I.

INTRODUCTION
The Company recognizes that in all organizations, there is a risk of workplace-based violence and workplacebased harassment on the basis of gender. The company acknowledges the multiple and intersecting formsof discrimination and its impact on experiences of violence and harassment, and that gender-based violenceand harassment disproportionately affects women and girls, and LGBTQ+.
This Policy is intended to set out the Company’s guidelines for recognizing and assessing the risks ofworkplace-based violence and harassment on the basis of gender. It also addresses ways to report incidents
of potential or actual incidents of workplace-based violence and harassment on the basis of gender(To explore UN Women resources for WEPs signatories, please visit the WEPs website).

• The Company is a signatory of the Women’s Empowerment Principles(WEPs) since 20__.
• Signing the WEPs was part of our overall goal to promote gender equality
and women’s empowerment in the workplace, marketplace and community.
• As part of this commitment, we believe strongly in safety and security of all
our employees whether at work or at home.

II.

SCOPE
This Policy applies to all Company workers as well as the Company’s agents, guests, customers, vendors,
and other third parties. This Policy applies to conduct in the workplace and in any work-related settingsoutside the workplace, such as during business trips, tours and Company-sponsored or authorized social
events and other functions. This Policy applies to the Company worldwide, except where compliance withthis Policy would cause an operating unit or divisions to violate any law in the country in which it is located.

Explanatory Note: The specific contractual status of a target/victim/affected individual should notconstitute a barrier to filing a complaint.

III. DEFINITIONSIn this policy the following terms have the following meanings:
Bystander is a person who is present at/a witness of an incident of violence or harassment but does nottake part.1 A Bystander approach is used to promote victim empathy and notions of how the workplacecommunity is responsible for preventing sexual harassment. An empowered bystander is somebody who
observes an act of violence, discrimination or other unacceptable or offensive behaviour and takes action(e.g. speak out against violence and harassment; intervene to support a colleague being targeted; talking
privately to a colleague exhibiting this behavior).
Impacted individuals may include the target/victim/affected individual as well as witnesses and persons
who intervene in the situation involving inappropriate behaviour and possible violence and harassment.
Report refers to formal and/or informal reporting unless otherwise specified.
Sexual harassment is any unwelcome conduct of a sexual nature that might reasonably be expected or beperceived to cause offense or humiliation, when such conduct interferes with work, is made a condition of
employment or creates an intimidating, hostile or offensive work environment. Sexual harassment may
occur in the workplace or in connection with work. While typically involving a pattern of conduct, sexual
harassment may take the form of a single incident. In assessing the reasonableness of expectations orperceptions, the perspective of the person who is the target of the conduct shall be considered.
Sexual harassment can take a variety of forms – from looks and words though to physical contact of asexual nature. Examples of sexual harassment (non-exhaustive list) include:2• Unwelcome touching, including pinching, patting, rubbing, or purposefully brushing up
against another person• Staring in a sexually suggestive manner2• Repeatedly asking a person for dates or asking for sex• Rating a person’s sexuality• Making sexual comments about appearance, clothing, or body parts• Name-calling or using slurs with a gender/sexual connotation• Making derogatory or demeaning comments about someone’s sexual orientationor gender identity• Sending sexually suggestive communications in any format• Sharing sexual or lewd anecdotes or jokes• Making inappropriate sexual gestures, such as pelvic thrusts• Sharing or displaying sexually inappropriate images or videos in any format• Attempted or actual sexual assault, including rape
Target/victim/affected individual is the person or persons in the workplace or in connection with work
towards whom the conduct constituting possible harassment and violence is directed.
Offender/alleged offender is the person or persons in the workplace or in connection with work whose
conduct constitutes harassment and violence, if established under applicable policies.
Violence and harassment in the world of work refers to a range of unacceptable behaviours and practices,or threats thereof, whether a single occurrence or repeated, that aim at, result in, or are likely to result inphysical, psychological, sexual or economic harm, and includes gender-based violence and harassment.
Gender-based violence and harassment, including sexual harassment, means violence and harassment
directed at persons because of their sex or gender or affecting persons of a particular sex or gender
disproportionately. 3
Worker includes employees, independent contractors and consultants who provide services to the Company.
Workplace means any land, premises or location in or for which a worker works.
Workplace violence means: (a) the exercise of physical force by a person against a worker, in a workplace,that causes or could cause physical injury to the worker; (b) an attempt to exercise physical force against
a worker, in a workplace, that could cause physical injury to the worker; and (c) a statement or behaviour
that it is reasonable for a worker to interpret as a threat to exercise physical force against the worker,
in a workplace, that could cause physical injury to the worker.
Workplace harassment means engaging in a course of vexatious comment or conduct that is known orought reasonably to be known to be unwelcome. Harassment also includes discriminatory, abusive, or
offensive verbal, visual, or physical conduct directed at a person due to their gender, gender identity orsexual orientation. Examples of behaviours that may be considered harassment include, but are notlimited to, direct or indirect comments, actions, or tactics such as verbal or psychological abuse used toharm an individual or an attempt to harm an individual. Harassment or bullying can involve repeatedincidents or can be one single incident.

POLICY TEMPLATE: GENDER-BASED VIOLENCE AND HARASSMENT AT WORK

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IV. WORKERS’ RIGHTS AND RESPONSIBILITIESWorkers are entitled to work free from workplace violence and workplace harassment.
Workers are responsible for working together in a professional manner and resolving issues in a
non-violent manner.
Formal reports of possible violence and harassment may be made by persons who consider that they were
the targets/victims/affected individuals or by persons who have direct knowledge of possible violence andharassment or by any third-party. Formal reports may be made anonymously and are not subject to deadlines.
Targets/victims/affected individuals may prefer and are encouraged to discuss their situation with aconfidential informal resource, such as [e.g. confidential provider of advice/assistance] who can assist thetargets/victims/affected individuals by explaining the applicable legal framework and the options available
under a company’s policies and practices and indicate resources available for support purposes.
Workers who observe or become aware of inappropriate behaviour or a situation of possible violence andharassment should, with training, ideally be able to support the affected individual with unbiased listening,
information and referrals; confidentially report the incident or incidents to human resources, welfare officer),and take other actions that could help mitigate hostility in the environment or harm to individuals.
Workers should cooperate in the investigation of a violent or harassing incident. Anyone who gives evidence
or information in an investigation or is involved in the process, must keep this information confidential,
except when it is necessary to deal effectively with the issue. Appropriate steps will be taken to ensure thesafety of the worker in the workplace. Workers shall complete all workplace violence or harassment training
required of them by the Company.

V.

MANAGEMENT’S RESPONSIBILITIESManagement must ensure, as much as reasonably possible, that no workers are subjected to workplace
violence or harassment.
Targets/victims/affected individuals who believe they may have been subject to inappropriate behaviouror instances of possible violence and harassment may raise this with their supervisor or other workers intheir workplace if the situation allows, and they feel comfortable doing so. Any manager approached by atarget/victim/affected individual shall inform that person that confidential advice, assistance and information
about the options available under the company’s legal framework to address such possible conduct may
be obtained from [office that provides confidential advice/assistance and support such as welfare officer,
staff counsellor, helpline or other trusted point of contact].

4Managers should provide advice, assistance and/or information in a timely, sensitive and impartial mannerby [list possible mechanisms provided in the company’s policies for managerial intervention such asproviding an opportunity for facilitated discussion among colleagues about the conduct in question;
also refer to the possibility of enlisting support from company units providing advice/assistance on suchmatters]. The intervention may allow for the matter to be addressed promptly at the managerial level.
A record will be maintained consistent with and as specified in the company’s policy about the matter,and any managerial intervention taken.
Management will not disclose the name of a complainant or the circumstances of the complaint to anyone
except where disclosure is: (i) necessary to investigate the complaint; (ii) required to take corrective action;or (iii) required by law.
Management will ensure that all workers are aware of the risks of workplace violence and harassment andare properly trained and equipped to protect themselves.
Management will undergo regular training on violence and harassment, including on raising awarenessabout the issue within the workforce, communicating commitments to supporting employees, spotting andacting on warning signs, building trust, and providing confidential, non-judgmental listening, workplace
supports and referrals.

VI. POLICY
1.

All workers are prohibited from engaging in violence or harassment as defined in this Policy and are
expected to report all incidents of violence or harassment.

2.

All workers are prohibited from any unwelcome conduct of a sexual nature that might reasonably be
expected or be perceived to cause offense or humiliation, when such conduct interferes with work,
is made a condition of employment or creates an intimidating, hostile or offensive work environment.

3.

In the event that a worker is subjected to actual or threatened harassment or violence in the workplace,the worker can report to the following:I.

a trusted manager or supervisor;II.

human resources;III.

a trusted individual on the senior management team;IV.

a joint health & safety representative or committee, if applicable;V.

a sexual harassment committee, if applicable; orVI.

a trade union, if applicable. Nothing in this policy prohibits the worker from making a report orcomplaint directly to a human rights tribunal or commission, a court, or another applicable external
administrative body within the jurisdiction of employment.

POLICY TEMPLATE: GENDER-BASED VIOLENCE AND HARASSMENT AT WORK

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4.

Management must inform the target/victim/affected individual that the information will be handled asconfidentially as possible, but that it must be disclosed to the extent necessary to conduct an appropriate
investigation. Management must act promptly and decisively to investigate and stop any known or suspectedviolence or harassment that occurs within their unit. Management must not ignore or otherwise condone
any act of violence or harassment.

5.

Agents, guests, customers, vendors and other non-workers are also prohibited from engaging in violenceor harassment as defined in this Policy. Workers may refuse to work with any non-worker who engages inviolence or harassment. Any non-worker who, in the sole opinion of the Company, violates this Policy,
may be barred from the Company’s premises and the Company may seek to terminate its relationshipwith the offender.

6.

Any worker who is determined to have engaged in violence or harassment will be subject to disciplinary
action, up to and including suspension without pay and/or termination of employment. Records of all
disciplinary action will be retained in the worker’s personnel file. In addition, the offender may be required
to participate in appropriate training or counselling.

7.

Complaints may be written or verbal and may be made in person, by email, by telephone, to a company
hotline, or other means.4 Every complaint will be investigated and resolved as expeditiously as possible,
having regard to such things as the nature of the complaint, the number of witnesses and whether theinvestigation should be conducted internally or externally. Where the conduct complained of is extremely
serious, or where the conduct is alleged to have been made by senior management, an external andindependent investigation will be preferred. In the event that there were witnesses to the complained about
behavior, witnesses will be interviewed. Every effort will be made to prevent disclosure of confidential
and/or sensitive information, while at the same time ensuring that each incident is carefully and completely
investigated. In particular, any party interviewed during an investigation will be reminded in writing prior
to their interview of the need to keep the investigation and their evidence confidential, as well as the factthat retaliation is strictly prohibited.

8.

Subject to the laws of the jurisdiction where the alleged conduct takes place, consideration may be given
to shifting the burden of proof to the alleged harasser.

9.

The target/victim/affected individual as well as the alleged offender will be provided with updates fromtime to time through the investigation process. Both parties will be advised in writing of the results of theinvestigation as well as next steps, at the conclusion of the investigation

10. The Company will not tolerate any retaliation against a worker who makes a good faith report of violenceor harassment under this Policy or anyone providing information on a good faith basis as part of any related
investigation, even if after the investigation no violence or harassment is found to have occurred. Any worker
who subjects another worker to such retaliation will be subject to disciplinary action, up to and including
termination of employment. Likewise, a known or proven false accusation of violence or harassment will
not be tolerated and any individual who makes a false accusation may be subject to disciplinary action,
up to and including termination.
11.

Notwithstanding all of the above, in situations where both the target/victim/affected individual and thealleged harasser wish to try to resolve matters, mediation, training, counselling and/or restorative justice
may be considered (“alternative forms of justice”). The target/victim/affected individual should have thefinal word in determining whether or not alternative forms of justice will be undertaken.

612. In the event of harassment or violence against a worker, the Company will inform the worker about allavailable support during and after the complaints process, including trade unions or worker representatives,
if applicable, EAP (Employee Assistance Programmes), or other internal or external resources (including
community services).
13. The target/victim/affected individual has the right to be accompanied by a staff member or other third
party in accordance with the company’s policy during the formal or informal processes provided such person
is reasonably available for the provision of support to the target/victim/affected individual.
14. The Company will provide training to all managerial and supervisory workers with respect to understanding
how to handle complaints.
15. This Policy does not affect the rights of workers to pursue complaints under the relevant laws of theappropriate jurisdiction.
16. A complaint can be made at any time. There is no statute of limitations.
17.

V.

In the event of any questions in relation to this Policy, please contact [Human Resources].

IMPLEMENTATION
See Appendix A, which provides a sample workplace
violence & harassment implementation procedure.

POLICY TEMPLATE: GENDER-BASED VIOLENCE AND HARASSMENT AT WORK7

APPENDIX ASAMPLE PROCEDURE: WORKPLACE VIOLENCE & HARASSMENT
1. RISK IDENTIFICATION
Prevention and mitigation of the risk of workplace violence and harassment can be addressed by identifying
workplace conditions or personnel issues which may contribute to the likelihood of workplace violenceand harassment as indicated in this procedure. In identifying factors which may contribute to the risk ofworkplace violence and harassment, consider evaluation of the following:• Previous incidents of verbal or physical violence or harassment• Situations where workers interact with members of the public• Staffing levels, particularly for early starts and late finishes• Integrity of site security, equipment and lighting• Effectiveness of emergency procedures• Procedures in place and used for consultation and communication with violence in caseof emergency• Procedures used in cash handling• Design of premises (e.g. location of pay office, cash sales, car parks)• Procedures for releasing contact phone numbers, names and addresses of workers
only to authorized individuals• Training of workers who deal with customers• Results of regular facility safety and security inspections• Follow-up and implementation of recommendations from previous audit reports• Gender-responsive procedures in place to deal with grievances and conflicts• Gender-responsive procedures in place for disciplinary action• Availability of an immediate response team• Support of workers at risk of domestic violence in the workplace (see further guidance here).

2. RISK ASSESSMENT
A gender-responsive workplace violence and harassment risk assessment must be performed as often asnecessary to protect workers and to provide a safe working environment. Relevant stakeholders should
be involved and consulted, including representatives of affected groups of workers. When evaluating any
required actions to eliminate or reduce the probability of workplace violence and harassment, it is important
to be able to quantify the level of the associated risk as this will assist in determining the safeguards orcontrol strategies which should be established.

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When completed, the results of the risk assessment must be provided to management and any
occupational health and safety committee or representative within the Company. This reporting
requirement also applies to any repeated risk assessments performed to assess and prevent workplace
violence and harassment incidents.

3. RISK CONTROLThe development of safeguards or control strategies will emerge from the risk identification and assessment
process. Where the risk of workplace violence or harassment has been identified, safeguards or control
strategies shall be established commensurate with the identified risk level. These may include but are notlimited to the following prevention-related activities:

Policy planning and execution• Promote workplace culture of trust• Document safe operating procedures for at risk tasks.
• Put in place or update emergency procedures that include means to mobilize
assistance if required.
• Develop gender-sensitive safeguards and control strategies by consulting
representatives of affected groups, particularly women.
• Take corrective action where deficiencies are identified.
• Equipment and safety measures• Upgrade site security equipment or arrangements.
• Install adequate lighting in and around premises.
• Ensure access to transport is safe for very early morning and late evening or night shifts.
• Change to electronic transfer of funds for worker payment.
• Providing personal protective equipment where indicated.

Training and awareness raising• Conduct a capacity assessment to identify the gaps in knowledge and skills that yourteam and employees have on gender-based violence at the workplace• Select the methodology or tool that is adapted to your context:5– Bystander training: Training individuals on how to safely intervene in cases where
they may observe sexual harassment and other forms of violence against women isimportant. This training can enable staff to be able to identify inappropriate behavior
and attitudes at work that contribute to a culture of gender inequality and discrimination.
– Training on unconscious and implicit bias: This approach unpacks how unconscious
bias influences decisions about recruitment, career advancement, and harmful
attitudes about women and men, which result in negative behaviors.

POLICY TEMPLATE: GENDER-BASED VIOLENCE AND HARASSMENT AT WORK

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– Civility training: A positive form of training based on prevention that can help reducebullying or conflict, while promoting respect in the workplace. Training activities havea strong focus on interpersonal skills, communication and negotiation, conflict
resolution, and positive supervisory techniques.
• Identify a safe location where you can guarantee privacy and confidentiality to
conduct the training sessions. Set the training sessions for a time that accommodates
employees’ availability and preferences• Conduct multiple and in-person training and awareness raising so that workers
understand the risks and the controls which must be followed for preventing exposureand responding to workplace violence and harassment. Training sessions should beinteractive, prompt critical reflections, challenge adverse social and cultural norms,
and tailored for the given audience.
• Engage women and men employees, managers, supervisors in training and education
to deal with customers or clients.

Data and monitoring• Collect gender disaggregated data for informed decision-making.
• Monitoring the uptake and effectiveness of control measures through safety
inspections, seeking feedback from workers and analysis of incident reports.
• Evaluate the quality and uptake of the referral services; adjust partnerships or service
providers accordingly.
• Collect post-training feedback and use it to enhance future training.

4. NOTICESIn the event that a worker is critically injured or killed due to workplace violence, immediate notice mustbe given to the [Ministry of Labour] and the company’s occupational health and safety committee or
representative. In addition, as required by applicable occupational health and safety legislation, a written
report describing the circumstances of the fatality or injury must be submitted to the [Ministry of Labour]
within <> hours of the occurrence.
When documenting an incident, the following information is to be included:

Type of Incidents as follows:• Threat – verbal, verbal threat by phone, written threat (including e-mail), throwing objects,
possessing and or displaying knives or other weapon, or other similar threat.
• Physical Assault – Struck, pushed, bitten, pinched or other incidents pertaining tophysical assault.
• Harassment – Bullying, vexatious comments, humiliation, gestures, abusive or offensive
verbal, visual or physical conduct directed at a person due to their sex, gender identity
or sexual orientation.

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When describing the incident ensure that you have answered all of the questions:• Who? – What? – Where? – When? – Why? – How?

For workplace violence incidents, describe immediate actions taken:• What actions were taken for the victim and the perpetrator?
• What actions were taken to secure the scene? (including any photos taken)• Police Notification• Company Notification• Have statements been taken from the victim, perpetrator and any witnesses?
• If applicable, has the victim been provided with transportation and encouraged toseek medical help?

ENDNOTES
1.

Read more about bystander interventions in UN Women, 2019. What Will it
Take? Promoting Cultural Change to End Sexual Harassment. Available here.

2. United Nations, 2018. UN System Model Policy on Sexual Harassment.
Available here.
3. ILO Convention 190. Convention concerning the elimination of violence andharassment in the world of work, pg.8. Available here.

POLICY TEMPLATE: GENDER-BASED VIOLENCE AND HARASSMENT AT WORK

4. Please note that multiple grievance mechanisms, procedures and channels
trusted by employees increases the likelihood of employees reporting theincidences of violence and harassment. See further here (page 25).
5. See further in UN Women & ILO, 2019. Handbook on Addressing violence andharassment in the world of work. Available here.

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ACKNOWLEDGEMENTS:
This policy template was prepared through pro bono support from the international law firm, Dentons, also a signatory to the
Women’s Empowerment Principles. The support was provided to WE EMPOWER-G7 programme, funded by the European Union
and jointly implemeneted by the United Nations Entity for Gender Equality and the Empowerment of Women (UN Women) andthe International Labour Organization.

Promoting Economic Empowerment of Women at Work through Responsible Business Conduct in G7 Countries(WE EMPOWER—G7 Programme) is funded by the European Union (EU) and jointly implemented with the International
Labour Organization (ILO). The Programme (2018-2021) will convene stakeholder dialogues in the EU, Canada, Japan andthe US to exchange knowledge, experiences, good practices and lessons learned in the context of the changing world ofwork. Under the Women’s Empowerment Principles (WEPs), WE EMPOWER is working to equip companies to go beyond
making commitments on gender equality and women’s empowerment, to strengthening their implementation, datacollection and reporting on the WEPs.

DISCLAIMER:
The views expressed in this publication are those of the authors and do not necessarily represent the views of the European
Union, UN Women, International Labour Organization or the United Nations and their Member States.
Graphic / Editorial Design: oliver.gantner@unwomen.org

This policy template was prepared through pro bono support from the international law firm, Dentons,
also a signatory to the Women’s Empowerment Principles

12

weps.org@WEPrinciples
empowerwomen.org@Empower_Women

Funded by:

Principle 1

Establish high-level corporate leadershipfor gender equality.

Principle 2

Treat all women and men fairly at work– respect andsupport human rights and nondiscrimination.

Principle 3

Ensure the health, safety and well-being of
all women and men workers.

Principle 4

Promote education, training and professional
development for women.

Principle 5

Implement enterprise development, supply chain
and marketing practices that empower women.

Principle 6

Promote equality through community initiatives
and advocacy.

Principle 7

Measure and publicly report on progressto achieve gender equality.

Produced by:

In support of: