Related policies: Code of Business Conduct, Gender Equality Plan, Whistleblowing Policy, Corporate Policy.
1. Institutional Declaration
At Saporina, we believe that every individual has the right to work in an environment free from intimidation, hostility, and offensive behavior. Our commitment to excellence includes a zero-tolerance policy towards harassment in all its forms.
This declaration formalizes our pledge to prevent, detect, and sanction any conduct that violates the dignity of our employees, collaborators, or partners. It supplements the Saporina Code of Business Conduct, operates in concert with the Whistleblowing Policy, and aligns with the ILO Violence and Harassment Convention 2019 (C190) (opens in a new window), the UK Worker Protection Act 2023 (opens in a new window), and ILO C111 on Discrimination (opens in a new window).
The Equality Agent
Saporina designates an Equality Agent — an independent, trained professional appointed by the Compliance and Audit Committee — responsible for receiving harassment complaints, providing initial guidance to victims, and ensuring investigations are conducted impartially. The Equality Agent operates independently of all business units.
Service-level commitment: Saporina assigns a named Equality Agent within five business days of any complaint, and publishes the role-holder's name and direct contact within 30 days of appointment.
2. Scope of Commitment
This commitment extends beyond the physical walls of our offices. It applies to:
Workplace Interactions
Between colleagues, managers, and subordinates.
Professional Relations
Interactions with suppliers, customers, and manufacturing partners.
Digital Spaces
Communications via email, messaging apps, or social media related to work.
3. Definition of Unacceptable Conduct
Saporina explicitly prohibits the following five categories of conduct. Each is treated as a stand-alone offense; an act may fall under more than one category at once.
How Conduct is Assessed
Saporina applies the “reasonable person in the same circumstances” standard. The subjective experience of the affected person is the starting point; the test asks whether a reasonable person, knowing the full context, would have experienced the conduct as intimidating, hostile, degrading, or offensive.
A complaint is not invalidated by the perpetrator's claim that “they didn't take it that way.” Intent is relevant to sanctioning, not to the question of whether harassment occurred.
3.1 Sexual Harassment — Quid Pro Quo
Absolute Prohibition
Any conduct in which submission to (or rejection of) sexual advances, requests for sexual favors, or other conduct of a sexual nature is used — explicitly or implicitly — as the basis for an employment decision affecting the worker (hiring, dismissal, promotion, assignment, compensation, training, or any other term or condition of employment).
3.2 Sexual Harassment — Hostile Environment
Absolute Prohibition
Any verbal, non-verbal, or physical conduct of a sexual nature that is unwanted and that has the purpose or effect of creating an intimidating, hostile, or offensive working environment. This includes unwanted advances, sexually-explicit jokes or imagery, comments on a person's body or attire, and persistent unwelcome attention — whether in person, online, or through any other channel.
3.3 Harassment Based on Sex / Gender
Absolute Prohibition
Behavior related to a person's sex, gender, or gender identity that violates their dignity or creates an offensive environment — even if not explicitly sexual in nature. Examples include sexist remarks, gendered name-calling, stereotyped job assignments, and exclusion from professional opportunities on the basis of gender.
3.4 Moral Harassment (Mobbing)
Absolute Prohibition
Persistent and systematic abusive behavior (words, acts, or gestures) that degrades the working conditions or psychological integrity of an individual. Examples include sustained belittling in front of colleagues, isolation from team activities, deliberately impossible deadlines used as a punitive tool, and the chronic withholding of information needed to perform the role.
3.5 Harassment Based on Protected Characteristics
Absolute Prohibition
Any unwanted conduct related to a person's race, ethnicity, national origin, religion or belief, disability, age, gender identity, sexual orientation, marital status, pregnancy, or trade-union membership that has the purpose or effect of violating their dignity or creating an intimidating, hostile, degrading, or offensive environment.
4. Our Protocol in Action
Saporina has implemented a specific Protocol for the Prevention and Management of Harassment. Through this protocol, we commit to four operational pillars: prevention, protection, resolution, and non-retaliation.
4.1 Prevention (Proactive)
Proactive Measures
- We do not wait for a complaint to act. We conduct regular sensitivity training to identify “micro-aggressions” and unconscious biases before they escalate.
- We promote a culture where speaking up is treated as alignment with the company's values, not as disruption.
4.2 Protection (Safe Reporting)
A Confidential Reporting Channel is managed by the designated Equality Agent (see Section 1). If you experience or witness harassment, you can report via:
Reporting Channels
Web Platform
Encrypted, web-based intake form — available 24/7. Anonymous submission supported.
saporina.com/ethics-channel
Direct contact with the Equality Agent.
ethics@saporina.com
4.3 Resolution (Decisive Action)
Investigation, Due Process & Sanctions
- Prompt and impartial investigation. All complaints are investigated promptly, impartially, and with absolute confidentiality — led by the Equality Agent and supported by HR / Compliance as required.
- Due process for the accused. The accused will be formally notified of the substance of the complaint, given a meaningful opportunity to respond in writing or in person, and informed of the evidentiary standard applied (preponderance of evidence) before any disciplinary measure is decided. Procedural fairness is guaranteed to the complainant and to the accused.
- Proportionate sanctions. If harassment is proven, Saporina will apply disciplinary measures proportional to the offense, up to and including termination of employment or cancellation of commercial contracts with offending partners. Sanctions follow only after a fair hearing.
- Closure and remediation. Investigations are concluded within 3 months. The complainant receives written notice of the outcome and any remediation steps offered (re-assignment, counseling, training, etc.).
4.4 Guarantee of Non-Retaliation
Zero Tolerance for Retaliation
Saporina guarantees that no employee will suffer adverse consequences for reporting a suspicion of harassment in good faith. Retaliation against a reporter — including demotion, exclusion, harassment, or termination — is itself a serious disciplinary offense and grounds for immediate dismissal of the retaliator, regardless of seniority. This protection extends to employees of our manufacturing and distribution partners.
Burden-of-proof shift. Where a worker reports in good faith and subsequently experiences any adverse treatment within 24 months of the report, Saporina presumes the adverse treatment is retaliatory unless the responsible manager can demonstrate, on the balance of evidence, that the action would have been taken regardless of the report. This shift is aligned with the EU Whistleblowing Directive 2019/1937 (opens in a new window) and the UK Worker Protection Act 2023 (opens in a new window).
5. A Shared Responsibility
Preventing harassment is not just the job of HR; it is the duty of every person at Saporina. We expect our leaders to set the example and our partners to respect our standards.
If You Witness or Experience Harassment
Please do not stay silent. Use our Responsible Channel or contact the Equality Agent directly. Your voice matters — and Saporina will act on it.
6. Contact
For questions about this commitment, or to speak with someone directly:
Contact Channels
Equality Agent
For confidential guidance, questions, or to report harassment directly.
equality@saporina.com
Saporina Ethics & Compliance Channel
Confidential and available 24/7. The web platform supports anonymous submission.
ethics@saporina.com