External Diversity, Inclusion
& Anti-Harassment Policy

GrowthInvest is committed to cultivating and preserving a culture of diversity and inclusion.

We embrace our employees’ differences in age, colour, disability, ethnicity, family or marital status, gender identity or expression, language, national origin, physical and mental ability, political affiliation, race, religion, sexual orientation, socio-economic status, veteran status, and other characteristics that make our employees unique.

The Company’s policy is to recruit, retain, develop, reward and promote people without regard to age, race, colour, ethnic or national origins, sex or marital status, disability or any other unlawful criteria unless this cannot be avoided and is legally permitted. We simply want the best person for the job and a genuinely diverse workforce. It is important to us that the workforce of the business is as representative as possible of the community which it serves.

All GrowthInvest employees have a responsibility to treat others with dignity and respect at all times. All employees are expected to conduct themselves in a respectful and appropriate manner at all times during work, at work functions in or outside the office, and at all other company-sponsored and participative events.

Any employee who engages in any inappropriate conduct or behaviour against other employees or applicants or any persons outside of the Company such as associated or subsidiary company personnel, entrepreneurs, contractors, investors and shareholders, suppliers, clients or volunteers (collectively referred to as “Third Parties”), will be subject to disciplinary action, up to and including immediate termination of employment.

Employees who believe they have been subjected to any kind of discrimination, harassment or retaliation or any other conduct that conflicts with the Company’s diversity, anti-harassment, anti-
discrimination or any other policy should immediately report the matter to a Manager, the Managing Director or the Company HR Consultant.

Any Third Party who believes that they have been subjected to any kind of discrimination or harassment or retaliation or any other conduct that conflicts with the Company’s diversity, anti-
harassment, anti-discrimination or any other policy should immediately report the matter to the Company Managing Director or the Company HR Consultant.

The details set out in the remainder of this document detail how the Company deals with any internal discrimination, harassment or retaliation issues.

However, the Company, will endeavour to apply the same process to any similar issues raised by a Third Party, in so far as the specific circumstances and the continued involvement of the Third Party as part of the process allows (for example in helping to establish the facts relating to any issue they may report).

1. Equal opportunities policy

All our managers and employees are required by the Company to ensure that no discriminatory practices occur, and we will strive to ensure that this is indeed the case.

If you have a concern about an equal opportunities issue you should speak to your Manager. If you believe that the matter cannot be dealt with in this way you should speak to the Managing Director or the Company HR Consultant. If the matter cannot be resolved informally, you should use the Company’s grievance procedure.

1.1. Managers’ Responsibilities

If you are a manager, you should:

• Promote equality in the workplace;
• Deal promptly with any complaints, grievances or disciplinary offences;
• Not tolerate unfair discrimination in any form, from any employee or someone who can affect an employee’s work;
• Review your practices and procedures regularly to ensure that you do not unfairly discriminate inadvertently; and
• Make sure that nobody is victimised or treated less favourably due to involvement in a complaint of unfair discrimination of harassment.

2. Employing disabled staff policy

The Company’s policy is to recruit, retain, develop, reward and promote people without regard to race, colour, nationality, ethnic or national origins, sex or marital status, disability, age or any other unlawful criteria, unless this cannot be avoided and is legally permitted.

3. Race discrimination policy

The Company will not permit or condone discrimination whether it be based on race, colour, nationality, ethnic or national origins, sex or marital status, disability, age or any other unlawful criteria, unless this cannot be avoided and is legally permitted. Discrimination is not permitted in any aspect of employment, including (but not limited to) recruitment, selection, promotion, transfer, training, pay and benefits, redundancy, dismissal, and terms and conditions of work.

All employees and other individuals working for the company are expected to take personal responsibility for upholding the company’s standards by treating all job applicants, fellow employees, customers, temporary staff, contract labour and any other individuals associated with the company with dignity and respect.

It is the positive duty of all employees to comply with this policy and appropriate disciplinary action, including dismissal for serious offences, will be taken against any employee who breaches this policy.

All managers have a particular duty to eliminate harassment and discrimination. If a manager fails to do so this may be treated as a disciplinary matter.

3.1. What is Discrimination?

Racial discrimination is unwanted conduct based on a person’s colour, race, nationality or ethnic or national origin. The Race Relations Act is concerned with people’s actions and the effects of their actions, not their opinions or beliefs. Racial discrimination is not the same as racial prejudice or racism.

Prejudice literally means prejudging someone – knowing next to nothing about them but jumping to conclusions because of some characteristic, such as their appearance.

Racism is the belief that some races are superior to others – based on the false idea that different physical characteristics, such as skin colour, or ethnic background make some people better than others.

Discrimination occurs when someone is treated less favourably on grounds of their sex, marriage, disability, colour, race, nationality or national or ethnic origin. It is not necessary to prove that someone intended to discriminate; it is sufficient only to show that the outcome of their action was less favourable treatment.

Less favourable treatment may manifest itself by means of unwanted or unwelcome conduct, a hostile or humiliating working environment, or in decisions made affecting employment if based on discriminatory grounds. Less favourable treatment can also include harassment as described below.

3.2. What is Harassment?

Racial harassment includes (but is not limited to):

• Physical contact including bullying or assault based on race;
• Verbal conduct such as offensive remarks, jokes, offensive comments about appearance, dress or origins; and
• Non-verbal behaviour such as the display of offensive pictures, objects or materials.

3.3. Who Does this Policy Apply to?

This policy applies to all employees and other individuals working for the Company and is intended to ensure that this kind of unacceptable behaviour does not occur in the workplace or at any event in direct connection with an employee’s employment e.g. an office party or business trip. The company will also take action against any employee who brings the company’s reputation into disrepute by unacceptable behaviour during out of office hours.

3.4. Positive Action

Selection and recruitment must be on merit although in certain circumstances employees can be given specific encouragement and training to prevent discrimination or to redress a past discrimination.

3.5. What can an employee do if they are aware of or involved in a racial discrimination or harassment issue?

3.5.1. Step 1 – Talk to the alleged perpetrator

It may be that the alleged perpetrator does not realise the impact that their behaviour is having on the recipient and/or a witness to the discriminatory behaviour.

3.5.2. Step 2 – Speak to a Manager

Speak to their Manager, the Managing Director or Company HR Consultant.

If you have a concern about a discrimination/harassment issue that cannot be raised informally, you should speak to your Manager.

If you believe that the matter cannot be dealt with in this way you should speak to the Managing Director or the Company HR Consultant.

3.5.3. Raise the issue formally with their Manager

If an employee raises an issue formally with their Manager, the Managing Director or the Company HR Consultant then he/she will then be obliged to set the company’s grievance procedure in motion. This may involve a formal investigation and disciplinary procedure.

The Company will then investigate the allegations as soon as reasonably possible and may suspend the alleged harasser on full pay whilst the investigation is carried out.

Everyone involved in the investigation will be required to maintain strict confidentiality. A breach of such confidentiality may be a disciplinary offence. Both the employee and the alleged offender may be accompanied by a colleague. If it is reasonably believed that harassment has taken place the company’s disciplinary procedure may be invoked.

4. Sex discrimination policy

Sex discrimination or harassment will not be permitted or condoned.

All employees are expected to take personal responsibility for upholding the company standards by treating all job applicants, fellow employees, customers, temporary staff, contract labour and any other individuals associated with the company with dignity and respect.

4.1. Who the Policy Applies To:

This policy applies to all permanent employees and all individuals who have a personal contract to work in the Company.

4.2. What It Covers

All aspects of employment are covered including recruitment, selection, promotion, transfer, training, pay and benefits, redundancy, dismissal and terms and conditions of work.

4.3. What is Sexual Harassment?

Harassment can:

• Be any unwanted, unreasonable, offensive or unprovoked behaviour by one individual towards another, and which has the impact of making the recipient feel offended, humiliated, threatened or patronised on the grounds of his or her sex.
• Be unintentional. It is not however, the intention of the perpetrator which is the deciding factor, but the impact of the behaviour on the recipient which determines whether or not harassment has occurred. Behaviour that may be regarded as acceptable or tolerable by one individual may be regarded by another individual as harassment. Whether harassment has occurred will depend on all the circumstances including context, cultural differences and social norms.
• Involve persistent conduct or behaviour that continues after the individual receiving it makes it clear that he or she wants it to stop. A single incident can also constitute harassment if it is sufficiently serious.

To intentionally cause a person harassment, alarm or distress on grounds of sex by threatening, abusive or insulting words or behaviour or displaying in writing, sign or other physical representation, which is threatening, abusive or insulting, is ‘intentional harassment’ and may be a criminal offence. Illustrations of what may constitute ‘unacceptable behaviour’ are:

• Physical contact ranging from touching to serious assault.
• Written and verbal harassment through jokes, banter, offensive language and comments, gossip and slander, letters etc.
• Bullying is a form of harassment where a person in authority abuses the power of that position through the use of intimidating, insulting or malicious style.
• Visual display of offensive posters, pictures, calendars or written material (including on personal computer and the email) and graffiti, obscene gestures etc.
• Coercion such as pressure for sexual favours.
• Isolation or non-co-operation at work, exclusion from social activities.

The above is not intended to be an exhaustive list.

4.4. What to do if you are aware of or involved in a discrimination or harassment issue

GrowthInvest has both an informal and formal process for exploring and resolving concerns related to this policy. Before starting a process, we encourage individuals who believe they are being harassed or otherwise discriminated against to tell the offender promptly that his/her/their behaviour is unwelcome and ask that it stop, though we understand that request may not be sufficient to stop the conduct.

Moreover, some individuals may not feel comfortable confronting the offender directly, especially if that person is a supervisor or otherwise in a position of authority over the individual; in such cases, the informal process may be a good option.

4.4.1. Informal Process

In some instances, an individual may seek to discuss matters with her or his Manager, the Managing Director, or the Company HR Consultant; such discussion is encouraged. Under the informal process, the individual is not making a formal complaint against the alleged offender and is not requesting an investigation. Even under the informal process, an individual can request that the Manager, Managing Director or the Company HR Consultant speak to the alleged offender.

Following the informal process, the individual could speak directly to the alleged offender and tell them clearly what the unwanted behaviour is and the impact the behaviour is having. It may be that the alleged offender does not realise the impact that his or her behaviour is having on the recipient.

The individual should make a record of the people involved and the nature of the conversation.

In most cases of an informal process no investigation will be initiated, and no action will be taken against the alleged offender if that is what the person raising the concern desires.

However, the Company may decide independently that it is necessary to take action beyond an informal discussion in order to deal with that situation appropriately. For example, the Company may have a duty to investigate if the situation seems imminently dangerous or if the person may do harm to themselves or someone else. This may be the case if there are multiple reports against someone. The best course of action in any case will depend on many factors and, therefore, the informal procedure will remain flexible.

Everyone should understand that the informal procedure is not a required first step for reporting on any given situation.

4.4.2. Formal Process

Raise the issue with your Manager, the Managing Director or the HR Consultant. This will be treated in confidence. Remember however, that the Company cannot guarantee that the matter will stay totally confidential. In particular, if you describe an issue that the Company considers to be important to act upon, then action will be initiated. For instance, the Company may decide to take disciplinary proceedings against your alleged offender. The Company may also want, or need, to investigate the matter further.

The full process is outlined below.

• Notification of Manager or Senior Team Member
  An individual who believes she or he has been harassed or otherwise discriminated against, or who believes she or he has witnessed such a violation, can initiate a formal complaint with their Manager, the Managing Director, or the HR Consultant. That person will try to respond within two, and not longer than five, business days.
• Timeliness in Reporting
  Complaints can be made at any time. Ideally, the initial complaint should be made promptly so that rapid and constructive action can be taken before relationships become irreparably strained and while memories are fresh as to the events. Early reporting and intervention can often resolve actual or perceived incidents of harassment or discrimination, as well as prevent additional incidents.
• Investigation Process
  Every formal complaint regarding a violation of this policy will be investigated promptly. The investigation may include individual interviews with the parties involved and, where necessary, with others who may have seen or heard the alleged conduct or have other relevant knowledge.
• Confidentiality
  The complaint and investigation will be handled with sensitivity, and confidentiality will be maintained throughout the investigatory process to the extent practicable and appropriate under the circumstances.
• Protection Against Retaliation
  Retaliation against an individual for reporting harassment or discrimination or assisting in providing information relevant to a claim of harassment or discrimination is a violation of this policy and will be treated with the same strict discipline as will the harassment or discrimination itself. Acts of retaliation should be reported immediately and will be investigated promptly.
• Responsive Action
  Misconduct violating this policy or otherwise constituting unlawful harassment or discrimination based on protected characteristics will be dealt with appropriately by GrowthInvest. Responsive action may include, without limitation, the following examples: training, referral to counselling and/or disciplinary action such as warnings, reprimands, or termination of employment, all as GrowthInvest believes appropriate under the circumstances.
• False and Malicious Accusations
  False and malicious complaints of harassment or discrimination are exceedingly rare. They are very different from complaints which are made in good faith but cannot be substantiated or represent a difference of opinion on what’s appropriate conduct. A fabricated and malicious complaint will be the subject of appropriate disciplinary action.

4.4.3. Follow up and tracking

The Company will endeavour to provide appropriate and sufficient support for individuals involved in harassment or discriminatory cases (e.g. access to counsellors or support systems) and will evaluate what is most helpful and appropriate for the individual in question on a case-by-case basis.

The Company will also aim to follow up with individuals 30, 60 and 90 days following any formal complaints, and 30 days after any informal complaints.

Firm points of contact for reporting harassment or discrimination issues or for diversity, inclusion and anti-harassment questions

Internal company contact:

Daniel Rodwell
Managing Director
daniel.rodwell@growthinvest.com

Third party contact:

Michael Brading
HR Consultant
bradingm@gmail.com