Workplace Harassment

PROTOCOL FOR THE PREVENTION AND RESPONSE TO SEXUAL HARASSMENT AND GENDER-BASED HARASSMENT AT PERINOX, S.A.

1. INTRODUCTION

PERINOX, S.A. states that employees Melanie Torres Senabre (ID: 44387996C) and Caridad Notario Lopez (ID: 74511568D) have completed the course: “Development of a Workplace Harassment Prevention Protocol.”

Aligned with its values, PERINOX, S.A. expresses its commitment to prevent, avoid, resolve, and penalize incidents of workplace or sexual harassment, as an essential requirement to ensure dignity, integrity, and equal treatment and opportunities for all workers.

All employees have the right and duty to interact with courtesy, respect, and dignity. Site managers must ensure a harassment-free work environment. Everyone, especially team managers, must report behaviors violating this policy. Cooperation is essential to prevent such conduct.

The Management is committed to investigating all harassment reports confidentially, following the procedure outlined in accordance with the European Framework Agreement on Harassment and Violence at Work (April 26, 2007).

Employees have the right to use this procedure without fear of intimidation, unfair treatment, or discrimination. The protocol must be disclosed internally and to third-party companies where PERINOX staff may be assigned. It also applies to:

• The workplace (including public and private spaces used for work);
• Areas for payment, breaks, meals, restrooms, and changing rooms;
• Travel, events, or training related to work;
• Work-related communications, including digital (cyber harassment);
• Employer-provided accommodations;
• Commutes between home and workplace.

This protocol affirms the company’s commitment to eliminate all forms of harassment and establishes procedures and remedies.

2. PERSONAL SCOPE

This policy applies to all PERINOX, S.A. employees, regardless of contract type, including interns and temporary agency staff. Contracts with third-party companies must reflect this obligation.

3. OBJECTIVE

PERINOX, S.A. commits to taking necessary measures to ensure a psychosocially healthy, harassment-free work environment.

This protocol aims to:

• Provide a procedure for workers who believe they are victims of harassment to seek clarification and action;
• Prevent recurrence by establishing mechanisms to address such issues effectively.

4. PREVENTIVE ACTIONS

To prevent harassment, measures based on dignity, privacy, and non-discrimination will be implemented, as per section 7 of Annex of RD 901/2020:

• Communication: Promote awareness of this protocol and reporting procedures;
• Training: Include anti-harassment education in training plans, especially for supervisors;
• Commitment: All employees are responsible for maintaining a respectful environment. Supervisors must prevent and act against harassment.

5. DEFINITIONS

Harassment involves behaviors creating an intimidating, degrading, or offensive environment. It infringes on dignity and may harm other legal rights (e.g., equality, health, honor).

• Sexual Harassment: Verbal or physical behavior of a sexual nature, undesired and offensive, including inappropriate remarks, contact, suggestive media, or messages.
• Gender-Based Harassment: Behavior based on a person’s sex, aiming to demean, intimidate, or discriminate.
• Workplace Harassment (Mobbing): Systematic, prolonged psychological pressure aimed at degrading or excluding an employee, including social isolation, demeaning tasks, or public humiliation.

Conflicts lacking intentionality or duration, or arising from routine supervision or disagreements, are excluded.

6. HARASSMENT PREVENTION DECALOGUE

1. Respect: Promote dignity and respectful conduct.
2. Communication: Avoid behaviors that isolate or silence colleagues.
3. Reputation: Prohibit defamation or ridicule.
4. Discretion in Reprimands: Conduct feedback privately.
5. No Arbitrary Assignments: Avoid abusive work distribution.
6. Fair Monitoring: Apply controls uniformly.
7. Ban on Sexual Conduct: Forbid any lewd acts or comments.
8. Unwanted Gifts: Discourage inappropriate gestures.
9. Gender Harassment: Forbid targeting for exercising legal rights.
10. Equal Opportunities: Ensure fair training and promotion.

7. CONFLICT RESOLUTION PROCEDURE

Victims should immediately inform the harasser to stop. If this fails, they must notify HR. Witnesses may also report.

Complaints can be verbal (followed by written confirmation) or written, identifying the accused, the victim, and detailed facts.

• HR assigns a numeric code to protect identities.
• An investigation starts within 2 working days and concludes in 10 days.
• Interviews are confidential; both parties may have a confidant.
• Precautionary measures may be applied based on severity.
• A final report is issued within 5 days.
• Management decides on actions within 3 days.
• Disciplinary measures may include relocation, suspension, promotion limits, or dismissal.

If inappropriate conduct is found, even if not classified as harassment, corrective actions will be recommended.

Retaliation against complainants or participants is prohibited. Full cooperation during investigations is mandatory.

8. FALSE ACCUSATIONS

Employees have the right to presumption of innocence. False accusations or testimonies will result in disciplinary action.

9. MONITORING

The Equality Commission, with company and employee representation, will monitor harassment incidents and suggest improvements. PERINOX, S.A. will:

• Evaluate psychosocial risks;
• Implement surveillance to prevent harassment;
• Prevent recurrence by sanctioned individuals;
• Provide psychological and social support;
• Adjust working conditions with victim consent;
• Offer training after extended leave;
• Conduct awareness and prevention sessions.

Follow-ups will be conducted within 30 calendar days of case closure.

10. BIBLIOGRAPHY

• Directive 2006/54/EC on equal treatment of men and women in employment;
• Organic Law 3/2007 for effective equality between women and men;
• ILO Convention C190 on violence and harassment (2019);
• Law 31/1995 on occupational risk prevention.

ANNEX 1: HARASSMENT REPORT FORM

Personal Information

• Name:
• ID:
• Address:
• Direct Supervisor:

Statement

Reports harassment committed by Mr./Ms. [Name].

Type:

• Workplace
• Sexual
• Gender-Based

Is there a hierarchical relationship with the accused? [Yes/No]

Description of Facts
(Include dates, witnesses, phrases, and other relevant details)

The complainant requests that the report be processed and investigated according to the workplace and sexual harassment prevention protocol.

Signature
Date: ____________