Violence and harassment prevention policy

Written by Sim on 1. April 2025. Posted in Allgemein.

CHAPTER I
INTRODUCTION

The aim of the Violence and Harassment Prevention Policy of the Company is to create a
working environment in which an employee or a group of employees will not be subjected to
any hostile, unethical, degrading, humiliating, aggressive, abusive, insulting or offensive actions
which violate the honour and dignity of an individual or a group of employees, or the physical
or psychological integrity of a person, or which are intended to intimidate, embarrass, or reduce
the individual or a group of employees to a defenceless and helpless position.
The Company is guided by the principle that every employee of the Company shall respect the
dignity of another person, shall interact with others in a courteous and respectful manner, and
shall ensure by his/her conduct a working environment in which the other person is not
subjected to any hostile, unethical, degrading, humiliating, aggressive, abusive, insulting or
insulting actions.
All employees of the Company are required to comply with this Violence and Harassment
Prevention Policy (the Policy) in their day-to-day work, and the Company’s employees are
required to play an active role in creating a work environment that is welcoming, respectful of
human dignity, and ensures equal opportunities and non-discrimination.
The policy sets out how to identify violence and harassment, the possible forms of violence and
harassment, the procedures for familiarising people with measures to prevent violence and
harassment, the procedures for reporting and dealing with reports of violence and harassment,
the measures to protect and assist those who report violence and harassment and the assistance
provided to them, and any other information relating to the prevention of violence and
harassment.

CHAPTER II
TERMS USED, WAYS OF RECOGNISING VIOLENCE AND HARASSMENT
Violence and harassment, including psychological violence, gender-based violence and
harassment (violence and harassment directed against persons on the basis of their sex or
disproportionately affecting persons of a certain sex, including sexual harassment) means any
unacceptable behaviour or threat thereof, whether the unacceptable behaviour is aimed at, once
or repeatedly, causing physical, psychological, sexual or economic impact, or whether the
unacceptable behaviour results in, or is likely to result in, a violation of a person’s dignity or
creates an intimidating, hostile, degrading or offensive environment, and/or whether physical,
property and/or non-pecuniary damage has occurred or is likely to occur.
Violence and harassment means unacceptable behaviour by one or more persons, which may
take many forms, some of which are easier to detect than others, and which is behaviour where
one or more managers or employees seek to insult or violate the dignity of an employee, seek to
affect or adversely affect the employee’s emotional health and/or seek to create or create a
hostile working environment.
Violence is defined as the intentional infliction, by act or omission of a person(s) on another
person(s), of physical, mental, sexual or economic harm in connection with work, which causes
or is likely to cause non-material or material damage to the employee.
Harassment is unwanted conduct which, on the grounds of sex, race, nationality, citizenship,
language, origin, social status, religion, belief or opinion, age, sexual orientation, disability,
ethnic origin, religion, is intended to insult or violate the dignity of a person and is intended to
create or creates an intimidating, hostile, degrading or offensive environment.
Harassment can take the form of oral and written harassment, and less often of physical acts.
Harassment can include offensive comments, jokes, humiliation, withholding important
information, isolating the person from colleagues, meetings or briefings, ignoring them,
assigning them to tasks that are not related to their job, etc.
The main difference between violence and harassment is that harassment is a continuous
process, i.e. repeated unacceptable behaviour, while violence is usually a one-off, sudden
(acute) outbreak of abuse.
Sexual harassment is unwanted abusive behaviour of a sexual nature, whether verbal, written or
physical, towards a person, intended to harm that person’s dignity, in particular by creating an
intimidating, hostile, degrading or offensive environment.
Threat is understood as an imminent situation or danger, including a range of threatening events,
where behaviour is not yet considered unacceptable but there is a realistic possibility that it will
be (e.g. verbal attacks by an employer, line manager, other employees or third parties, various
behaviours of concern).
The threat can be imminent to a single employee or to a group of employees, it can be obvious
or not, but the key element is the consequences of the threat. This can include various forms of
violence, punishment, ignoring, isolation, harassment, oppression, bullying, etc.
Violence and harassment are prohibited:
14.1. In workplaces, including public and private places, where the employee is at the
employer’s disposal or performing duties under an employment contract.
14.2. During rest and meal breaks, or when using household, sanitary and hygiene facilities.
14.3. During work-related outings, trips, travel, training, events or social activities.
14.4. During work-related communication, including communication using information and
electronic communication technologies.
14.5. In accommodation provided by your employer.
14.6. On the way to or from work.

CHAPTER III
FORMS OF VIOLENCE AND HARASSMENT
Violence and harassment can take many forms, such as:
15.1. Unwanted physical contact (e.g. flicking, patting, stroking, fondling, nibbling, reaching
out to kiss, kissing, etc.) or requesting such contact.
15.2. Verbal or written humiliation (offensive jokes and witticism, persistent remarks, hate
speech, talking in an elevated tone, gossip, rumours, slander, etc.).
15.3. Demonstration, publicity, offensive gestures of offensive pictures, notes or other materials.
15.4. Demonstration or transmission by electronic means of pornographic or sexist images,
images or texts.
15.5. Unethical, unwanted comments on appearance, body shape, clothing.
15.6. Intrusive communication, tracking a person or gathering information about an employee
when it is unrelated to the work functions performed, without the employee’s consent or
reasonable grounds.
15.7. Threatening or other intimidating behaviour aimed at restricting a person’s freedom of
self-determination.
15.8. Effect on an employee of the company for the purpose of achieving certain conduct,
services or sexual services unrelated to the performance of their job functions.
15.9. Uneven distribution of work tasks when assessing the workload of other employees
engaged in analogous work or assignment of tasks not related to work functions.
15.10. Unjustified deterioration of working conditions compared to other employees.
15.11. Deliberate isolation or non-communication of the employee in work activities, separation
from social activities.
15.12. Other forms, not covered here, where certain behaviour creates an undesirable,
unpleasant, intimidating, humiliating or offensive working environment.
This list of forms of violence and harassment is not exhaustive and is assessed on a case-by-case
basis.
Harassment, sexual harassment, physical or psychological violence can also manifest itself in
other ways that are not obvious but create an unpleasant, intimidating, humiliating or offensive
environment

CHAPTER IV
RECOMMENDED CONDUCT OF THE COMPANY’S EMPLOYEES TO PREVENT
CASES OF VIOLENCE AND HARASSMENT, PREVENTION MEASURES
The Company’s employees are recommended to comply with the following principles:
18.1. Analyse their behaviour and assess whether it complies with the provisions of the Policy.
18.2. Being aware of, knowing or anticipating potential behaviour that could be considered
harassment, sexual harassment and violence.
18.3. Be considerate and sensitive to other employees of the Company, respect their privacy,
views, beliefs, their physical and mental integrity, to try to understand whether their verbal,
written or physical behaviour may cause unpleasant, undesirable, humiliating consequences,
may interfere with another person in the work environment, which may result in his or her
inability to perform his or her functions properly, for example:
18.3.1. Disrespectful way of greeting.
18.3.2. Compliments unrelated to the employee’s professional qualities.
18.3.3. Comments on the employee’s physical appearance or attire, characteristics of human
identity.
18.3.4. Unethical comments about the employee’s views, weaknesses or strengths, their private
life.
18.3.5. Unethical calls to the employee (e.g. name abbreviations, nicknames, diminutive calls,
etc.).
18.3.6. Jokes or witticism of a sexual nature, offensive or disrespectful to the employee.
18.3.7. Physical touching of an employee of the company, causing physical or psychological
discomfort without observing a respectful physical distance.
18.3.8. Showing intrusive attention to the employee, visual inspection of their physical
appearance.
18.3.9. Tone of speech, sounds and movements which may injure, humiliate, degrade or
sexually intimidate the employee.
18.3.10. Use of visual means that degrade the honour and dignity of the employee (posters,
photos, drawings, objects, etc.).
18.3.11. Sending or otherwise publicising messages, communications or notes of a defamatory
nature, which are derogatory to the honour and dignity of the employee.
18.4. In order to avoid unpleasant and unacceptable behaviour of the employee and the negative
consequences of this behaviour, in case of doubt that certain behaviour may be undesirable or
may make another person feel uncomfortable, degrade their dignity, it is advisable to ask in
advance, discuss with the Company’s employees whether certain behaviour, the form of
communication, is acceptable.
18.5. If an employee of the Company demonstrates, verbally, by actions or lack of response, that
certain behaviour that is unrelated and/or not necessary for the performance of their job
functions is not acceptable to them, they must immediately stop such behaviour and limit
communication to that required for the performance of their job functions.
18.6. Not to be a passive observer of the conduct of an employee in violation of the Policy, but
to take active action to stop such conduct. If such behaviour occurs, do not tolerate it, do not
consider it a jesting remark or a lame joke, do not encourage such behaviour by supporting
smile, laughter or other actions supporting such behaviour.
18.7. If you experience behaviour that appears to be harassment, sexual harassment or violence,
it is advisable to calmly, in a polite tone of voice, tell or inform the person who is behaving in
such a way that the behaviour is unacceptable and must stop. This can also be done by email or
text message. It is advisable to explain which gestures, words, comments, physical behaviour or
other actions are unpleasant, create a humiliating, offensive working or study environment.
18.8. It is advisable to record all acts (behaviour) of harassment, sexual harassment and violence
in lawful ways and means, to record the time, witnesses and other significant circumstances.
18.9. If the harassment, sexual harassment or violence took place against another employee of
the Company, it is advisable to encourage them to speak up about it, to encourage the person
who committed these acts to contact them and to immediately inform them that such behaviour
is unwelcome.
In order to create a safe and friendly environment within the Company, this Policy should be
assessed and implemented in parallel with the Company’s approved Rules of Procedure,
Code of Ethics and Equal Opportunities Policy.
When creating an emotionally favourable work environment for employees, the Company
shall provide training, send and/or demonstrate information materials aimed at awareness,
recognition and intolerance of forms of violence and harassment, as well as the procedure
for submission and examination of reports of violence and harassment.

CHAPTER V
PROCEDURE FOR SUBMISSION AND EXAMINATION OF REPORTS/COMPLAINTS
ON VIOLENCE AND HARASSMENT, DECISION MAKING
The investigation of a notification or complaint shall be based on the following principles:
21.1. Non-culpability – the Complainant shall be presumed innocent until a decision is made on
the violation of the Policy.
21.2. Promptness – the investigation is carried out within the shortest possible time.
21.3. Immediacy – the victim, the complainant, the witness(es) are given every opportunity to
provide explanations and to give their version of their actions and their interpretation.
21.4. Assistance to the victim – upon receipt of a complaint about a violation of the Policy, safe
working conditions are created.
21.5. Proactive preventive measures – upon detection of a violation, appropriate individual
preventive measures shall be applied, ensuring safe and dignified working conditions for the
Company’s employees.
21.6. Objectivity and impartiality – the investigation is carried out objectively, without
preconditions for the assessment of the circumstances.
Reports/complaints regarding possible cases of violence or harassment are examined by forming
a Commission. The Commission is established in accordance with the procedure set by the
Company only after the registration of the report/complaint and investigates the specific case of
violence or harassment in the workplace.
The Commission is composed of at least 3 members, including one representative from the
employees and one from the employer. Persons with family ties or any potential conflict of
interest cannot be appointed to the Commission. Members of the Commission must be impartial
and objective.
An employee of the Company who believes that they or another person is being harassed,
sexually harassed, or subjected to physical and/or psychological violence has the right to submit
a report or complaint to their direct supervisor. If the accused individual is the direct supervisor,
the report or complaint should be submitted to a higher-level manager. It is recommended that
the report or complaint be submitted as soon as possible after the alleged actions occurred or
were discovered.
A report/complaint can also be submitted via email by sending it to: report@l-experts.com .
Anonymous reports/complaints shall not be dealt with by the Commission.
A received report/complaint must be registered no later than the next working day. Following
this, a Commission is formed in accordance with the procedure established by the Company,
which then initiates the investigation. In the report/complaint, the Company’s employee must
provide the following information:
27.1. Detailed explanations of the event regarding the situation, manifestations and
circumstances of the violence, harassment or sexual harassment suffered.
27.2. Identify potential witnesses.
27.3. Provide any other information (photos, video or audio recordings, etc.) that is available by
lawful means.
Members of the Commission shall be bound to ensure the confidentiality of the investigation.
Members of the Commission shall be prohibited from disclosing any information relating to the
investigation to persons and personnel not involved in the investigation procedure.
When interviewing the victim or complainant, his or her legal representative may also
participate in the interview.
Upon completion of the investigation, the Commission shall evaluate the data obtained during
the investigation and, within 10 working days, prepare and submit to the Company’s manager a
conclusion containing proposals. If the actions or behaviour of the manager of the Company are
appealed against, the conclusion with the proposals shall be submitted accordingly to the higher
management body (board, supervisory board or shareholder) operating in the Company.
The report and/or complaint shall be investigated within the shortest possible time, but not more
than 1 month from the date of receipt of the report/complaint.
The time limit for the investigation of the report and/or complaint may be extended only if due
to justified circumstances (illness, etc.) it is not possible to interview the victim, the complainant
or the witness.
After examining the report/complaint, the Commission may take the following decisions:
32.1. Leave the report/complaint unexamined.
32.2. Declare the report/complaint to be unfounded.
32.3. Acknowledge the report/complaint as justified. In such a case, the Commission shall
submit, together with the decision, proposals on the imposition of sanctions on the complainant
and the need for victim assistance measures.
34.4. The examination of the report/complaint shall be terminated if the lack of information
prevents the investigation or the identification of the persons mentioned in the report/complaint.
The Head of the Company, or, in the case of a complaint against the Head of the Company, the
higher management body of the Company (the Board of Directors, the Supervisory Board or the
shareholder), shall, upon receipt of the Commission’s conclusions with proposals, decide on the
necessity of taking measures of influence on the person complained against and/or the need to
apply protective or assistance measures to the person who is the subject of the complaint. The
victim and the person complained against shall be informed of the decisions taken within no
later than 3 working days. The conclusions and proposals adopted by the Commission to the
Company’s manager are of a recommendatory nature.
The Commission shall take into account the impact of each individual case on the emotional
health of the victim when making proposals for possible protective measures (relocation, job
rotation, granting of leave, etc.) or the provision of possible assistance (individual
interviews, specialist advice, etc.) to the victim.
When making proposals for the imposition of possible sanctions on the complainant, the
Commission shall take into account the malignancy and seriousness of the conduct
complained of, its frequency, the consequences for the victim, etc.

CHAPTER VI
FINAL PROVISIONS
This Policy is binding and applies to all employees of the Company without exception,
regardless of the position they hold or the type of employment contract they have entered
into.
A violation of this Policy will be considered a violation of work duties for which liability is
provided for in the Labour Code of the Republic of Lithuania.
The Company’s employees are informed about the approved Policy through informational
electronic communication channels in accordance with the Company’s established
procedures. This Policy and all its amendments are published on the Company’s intranet
and/or another platform used by the Company.

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