Prevention of Sexual Harassment Policy

Veramed recognises it is the right of every person who works for or on behalf of the Company to be able to attend work and perform their duties without being subjected to any form of sexual harassment.

Equally, every person who works for or on behalf of Veramed has an obligation and responsibility to ensure that the workplace is free from sexual harassment. This policy seeks to prevent sexual harassment, and is one component of our commitment to an inclusive and discrimination free working environment.

Policy

This policy applies to all employees, contractors, temps, interns and third parties, and anyone else working on behalf of or representing the Company.

Veramed will not tolerate sexual harassment under any circumstances. Responsibility lies with every employee and representative of Veramed, to ensure that sexual harassment does not occur.

This policy covers:
• Behaviour that takes place in the workplace
• Conduct during work-related activities such as conferences, work functions, social events or at client and supplier locations or events.
• Online behaviour or incidents outside of work that affect the work environment and/or relationships
• Third party sexual harassment, including by clients, suppliers or other external
stakeholders

What is sexual harassment?
Sexual harassment is a specific form of harassment that involves unwanted conduct of a sexual nature. It is unlawful under the Equality Act 2010 and can occur between individuals of the same or different genders. Examples of sexual harassment may
include, but are not limited to:
• Unwanted sexual advances, propositions or invitations
• Displaying sexually explicit materials such as images, posters or videos in the workplace
• Lewd comments, gestures or innuendos
• Intrusive questions about a person’s private or sexual life
• Repeated and unwelcome sexual advances or physical conduct, such as touching, hugging, massaging or kissing
• Sending or displaying sexually explicit messages, emails or social media content
• Spreading sexual rumours
• Making degrading comments about someone’s appearance
• Offering benefits in return for sexual favours, or making threats for refusal

Employer responsibilities
Veramed is committed to taking proactive and responsive steps to prevent and address sexual harassment. The following outlines our responsibilities:

Preventative measures
• The expectations of this policy will be clearly communicated to all employees, contractors, and third parties of Veramed
• Sexual harassment awareness training will be integrated into onboarding materials for all new hires
• We will implement comprehensive training on sexual harassment prevention for all employees and managers. This includes understanding what constitutes sexual harassment, how to report it, and how to intervene when witnessing inappropriate behaviour
• We will encourage managers and leadership to model appropriate behaviour and hold them accountable for maintaining a safe and respectful work environment. Managers will be given specific training to help them identify and prevent sexual harassment in their teams
• We will conduct regular risk assessments of the workplace to identify areas where sexual harassment risks may be higher (e.g., isolated working environments, offsite events) and take measures to reduce those risks

Reporting and investigation of sexual harassment
• We will provide employees with accessible channels for reporting sexual harassment, including the option to report anonymously
• We will ensure that all reports of sexual harassment are dealt with promptly, confidentially, and impartially. Employees who report sexual harassment will not face any form of retaliation
• We will assign neutral investigators to handle complaints. Investigations will be impartial and will aim to be resolved within a reasonable timeframe
• We will protect the confidentiality of those involved in sexual harassment investigations. Information will only be shared with those who need it to understand and address the complaint.

Support for victims of sexual harassment
• We will offer support services, such as counselling, to employees who experience sexual harassment through our Employee Assistance Program (EAP)
• We will make workplace adjustments for victims of sexual harassment where necessary (e.g., temporary changes to reporting lines or work locations) to ensure they feel safe and supported
• The employee’s line manager, or another appropriate person, will follow up with the affected employee after the resolution of the case to ensure their well-being and to monitor the continued safety of their work environment

Disciplinary action and accountability
• We will assume a zero tolerance approach and will take disciplinary action against individuals who are found to have committed sexual harassment. This may include verbal or written warnings, suspension, or termination of employment, depending on the severity of the misconduct
• We will ensure that line managers or leaders who fail to address or report known incidents of sexual harassment are also held accountable
• If the behaviour is deemed criminal, the Company will cooperate fully with law enforcement

Creating a safe reporting environment
• We will enforce a strict no-retaliation policy for employees who report sexual harassment. Retaliation against those who come forward will be treated as a serious disciplinary offence and may lead to dismissal
• We will encourage employees to report sexual harassment, even if they are not the direct victims. Bystanders who witness inappropriate conduct should feel empowered to report it without fear of retribution

Preventing and addressing sexual harassment by third parties
• We will ensure that clients, customers, suppliers, and other third parties who interact with the Company understand that sexual harassment of our employees will not be tolerated. Posters will be displayed in the offices where appropriate, and third parties will be informed of our zero-tolerance policy
• In cases of sexual harassment by third parties, the Company will take appropriate
action, which may include issuing warnings, banning the individual from the premises, or terminating contracts with the offending party
• Employees harassed by third parties will be provided with the same level of support and access to reporting channels as if the harassment were committed by an internal party

Complaints procedure
Sexual harassment can occur at any level of the organisation, can be experienced by any individual, and may involve a colleague, consultant, line manager, client, or any other person working on behalf of, or for Veramed.

Informal resolution
Where appropriate, employees who experience sexual harassment may choose to address the behaviour informally. This could, if the employee is comfortable doing so, involve speaking directly with the perpetrator to explain that their behaviour is unwanted and must stop. Employees may also seek support from their line manager or HR to resolve the issue informally through mediation or a facilitated conversation.

Formal complaints procedure
If an informal resolution is not appropriate or unsuccessful, employees are encouraged to file a formal complaint. Victims of sexual harassment can make a complaint by contacting a member of the HR team, their own line manager, via another Veramed line manager or senior member of staff. Reports can be made in person, remotely, or by email. All reports will be dealt with sensitively and confidentiality.

Investigation process
All complaints will be handled in a timely and impartial manner, and the process will include:
• Appointment of a neutral investigator to review the complaint
• Interviews with the complainant, the alleged perpetrator, and any witnesses
• Collection and examination of any relevant documentation (e.g., emails, text messages, or other evidence)
• Providing both parties with information about the outcome of the investigation

Criminal Conduct
Some forms of sexual harassment may constitute criminal conduct. Whilst Veramed is committed to treat most sexual harassment complaints at a company level as far as possible, this type of conduct is not appropriate for internal resolution.

Disciplinary action
If the investigation concludes that sexual harassment has occurred, the HR department will refer to the Disciplinary Policy to determine a recommended course of action. This may include:
• Verbal or written warnings
• Suspension of the perpetrator
• Termination of employment, depending on the severity of the behaviour

All records relating to complaints of sexual harassment will be stored securely and access restricted to members of the HR department, and members of senior management, if appropriate.

False or malicious complaints
Whilst the Company takes all complaints seriously, any employee found to have made a malicious or false complaint will be subject to disciplinary action, up to and including termination of employment.

Responsibilities of Employees
All employees are responsible for:
• Treating colleagues, clients, and third parties with respect and refraining from any form of bullying, harassment, or sexual misconduct
• Reporting any incidents of bullying, harassment, or sexual harassment they experience or witness
• Cooperating with investigations by providing honest and accurate information

Unfavourable treatment
Employees or representatives of Veramed who make a complaint of sexual harassment will not be treated less favourably.

Disciplinary action may be taken against anyone who victimises or retaliates against a person who has complained of sexual harassment, or against any employee or representative of Veramed who has been alleged to be a harasser.

Dated: 1st April 2025