Code of Conduct to Prevent Harassment or Sexual Harassment

The Policy Statement 

Ctl Eurocollege is committed to providing a safe environment for all its staff and students free from discrimination on any ground and from harassment including sexual harassment. 

Ctl Eurocollge will operate a zero tolerance policy for any form of sexual harassment in the workplace, treat all incidents seriously and promptly investigate all allegations of sexual harassment. Any person found to have sexually harassed or harassed in any other way another will face disciplinary action, up to and including dismissal from employment or expulsion. 

All complaints of harassment and sexual harassment will be taken seriously and treated with respect and in confidence. No one will be victimised for making such a complaint. 

Definition of harassment 

Harassment is unwanted conduct related to a relevant protected characteristic that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for that person. The unwanted conduct can be physical, verbal or non-verbal.

Definition of sexual harassment 

Sexual harassment is unwelcome conduct of a sexual nature which makes a person feel offended, humiliated and/or intimidated. It includes situations where a person is asked to engage in sexual activity as a condition of that person’s employment, as well as situations which create an environment which is hostile, intimidating or humiliating for the recipient. 

Sexual harassment can involve one or more incidents and actions constituting harassment may be physical,   verbal   and   non-verbal.   Examples   of   conduct   or   behaviour   which   constitute   sexual harassment include, but are not limited to: 

Physical conduct 

• Unwelcome physical contact including patting, pinching, stroking, kissing, hugging, fondling, or inappropriate touching
• Physical violence, including sexual assault
• The use of job-related threats or rewards to solicit sexual favours 

Verbal conduct 

• Comments on appearance, age, private life, etc.
• Sexual comments, stories and jokes
• Sexual advances
• Repeated and unwanted social invitations for dates or physical intimacy
• Insults based on the sex of the individual
• Condescending or paternalistic remarks
• Sending sexually explicit messages (by phone or by email) 

Non-verbal conduct 

• Display of sexually explicit or suggestive material
• Sexually-suggestive gestures
• Whistling
• Leering 

Anyone can be a victim of harassment, regardless of their sex and of the sex of the harasser. Ctl Eurocollege recognises that any form of harassment may also occur between people of the same sex. What matters is that the sexual conduct is unwanted and unwelcome by the person against whom the conduct is directed. 

Anyone who sexually harasses or harasses in any other form another will be reprimanded in accordance with this internal policy. 

All types of harassment is prohibited whether it takes place within the Institution’s premises or outside, including at social events, recreational activities, business trips, training sessions,   conferences, visits sponsored by Ctl Eurocollege. 

Complaints procedures 

Anyone who is subject to any form of harassment should, if possible, inform the alleged harasser that the conduct is unwanted and unwelcome. 

The victim can approach the designated persons responsible for receiving complaints of any form of harassment. The designated persons are: 

1. The Quality Assurance Officer
2. The Academic Dean
3. The Student Counselor 

When the designated person receives a complaint of any form of harassment, he/she will: 

• immediately record the dates, times and facts of the incident(s)
• ascertain the views of the victim as to what outcome he/she wants
• ensure that the victim understands the procedures for dealing with the complaint
• discuss and agree the next steps: either informal or formal complaint, on the understanding that choosing to resolve the matter informally does not preclude the victim from pursuing a formal complaint if he/she is not satisfied with the outcome
• keep a confidential record of all discussions
• respect the choice of the victim
• ensure that the victim knows that they can lodge the complaint outside of the Institution
• follow the relevant legal framework
• request the Disciplinary Committee to meet in case of a formal complaint 

Throughout the complaint procedure, a victim is entitled to be helped by a counsellor or a person he/she wants to be accompanied within the Institution. Ctl Eurocollege nominated a clinical psychologist to assist victims of sexual or any other form of harassment. Ctl Eurocollege recognises that because harassment often occurs in unequal relationships, victims often feel that they cannot come forward. Ctl Eurocollege understands the need to support victims in making complaints. 

Informal complaints mechanism 

If the victim wishes to deal with the matter informally, the designated person will:

• give an opportunity to the alleged harasser to respond to the complaint
• ensure that the alleged harasser understands the complaints mechanism
• facilitate discussion   between both parties to achieve an informal resolution which is acceptable to the complainant, or refer the matter to a designated mediator within the Institution to resolve the matter
• ensure that a confidential record is kept of what happens
• follow up after the outcome of the complaints mechanism to ensure that the behaviour has stopped
• ensure that the above is done speedily and within two (2) days of the complaint being made 

Formal complaints mechanism 

If the victim wants to make a formal complaint or if the informal complaint mechanism has not led to a satisfactory outcome for the victim, the formal complaint mechanism should be used to resolve the matter. 

The designated person who initially received the complaint will refer the matter to the Disciplinary Committee. 

The person(s) carrying out the investigation will:

 interview the victim and the alleged harasser separately

• interview other relevant third parties separately
• decide whether or not the incident(s) of harassment took place
• produce a report detailing the investigations, findings and any recommendations
• if the harassment took place, decide what the appropriate remedy for the victim is, in consultation with the victim
• follow up to ensure that the recommendations are implemented, that the behaviour has stopped and that the victim is satisfied with the outcome
• if   it   cannot   determine   that   the   harassment   took   place,   he/she   may   still   make recommendations
• keep a record of all actions taken
• ensure that the all records concerning the matter are kept confidential
• ensure that the process is done as quickly as possible and in any event within ten 10 days of the complaint being made 

Outside complaints mechanisms

 A person who has been subject to harassment of any form can also make a complaint outside of the Institution through the police. 

Sanctions and disciplinary measures 

Anyone who has been found to have harassed or sexually harassed another person under the terms of this policy is liable to any of the following penalties: 

• Verbal warning
• Maximum two (2) written warnings
• Dismissal 

In case of student harasser 

Penalties imposed may be: 

• Exclusion from activities
• Exclusion from using facilities
• Reduction of grade
• Expulsion for a period of time
• Permanent expulsion from College 

The nature of the sanctions will depend on the gravity and extent of the harassment. Suitable deterrent sanctions will be applied to ensure that incidents of sexual harassment are not treated as trivial. Certain serious cases, including physical violence, will result in the immediate dismissal of the harasser. 

Implementation of this policy 

Ctl Eurocollege ensures that this policy is widely disseminated to all relevant persons. It will be included in the staff and students handbook. All new employees must be trained on the content of this policy as part of their induction into the company.

Every year, Ctl Eurocollege will require all employees to attend a refresher training course on the content of this policy. 

It is the responsibility of the College to ensure that all employees and students are aware of the policy. 

Monitoring and evaluation 

Ctl Eurocollege recognises the importance of monitoring this harassment policy and will ensure that it anonymously collects statistics and data as to how it is used and whether or not it is effective. 

Those responsible for dealing with any form of harassment cases will report on compliance with this policy, including the number of incidents, how they were dealt with, and any recommendations made. This will be done on a yearly basis. As a result of this report, the company will evaluate the effectiveness of this policy and make any changes needed.