Sexual Harassment Policy

1. Introduction

Welcome2Africa International Limited recognises that all persons interacting with the Company are entitled to be treated with dignity, respect, and professionalism in an environment free from sexual harassment.

The Company is committed to maintaining a safe and respectful workplace and business environment in which employees, consultants, stakeholders, partners, investors, contractors, vendors, clients, and other third parties can carry out activities free from intimidation, coercion, humiliation, or unwelcome sexual conduct.

Welcome2Africa International adopts a zero-tolerance approach to sexual harassment. Any form of sexual harassment is strictly prohibited and shall be addressed promptly and appropriately in accordance with this Policy.

 

2. Scope

This Policy applies to:

1. all employees of Welcome2Africa International Limited and its subsidiaries, including executives, directors, interns, and volunteers;
2. consultants, contractors, secondees, and temporary staff;
3. business partners, investors, vendors, suppliers, clients, and service providers; and
4. stakeholders and any third parties interacting with the Company in the course of business activities.

This Policy applies to conduct occurring:

1. within Company premises;
2. outside Company premises where connected to Company activities;
3. during official meetings, conferences, trainings, work travel, networking events, and social engagements; and
4. through electronic communication, including email, messaging platforms, video calls, social media, and other digital channels.

 

3. Definition of Sexual Harassment

Sexual harassment means any unwelcome conduct of a sexual nature, whether verbal, non-verbal, physical, written, visual, or electronic, that violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment.

Sexual harassment may occur regardless of gender and may occur between employees, supervisors and subordinates, colleagues, clients, consultants, vendors, partners, or any other persons connected with Company activities.

 

4. Conduct Constituting Sexual Harassment

Sexual harassment includes, but is not limited to:

• Physical Conduct

1. unwanted touching, patting, hugging, pinching, rubbing, or brushing against another person;
2. invasion of personal space in a sexual manner; and
3. unwanted physical contact of a sexual nature.
   • Verbal Conduct
4. unwelcome sexual advances;
5. repeated requests for dates, meetings, or personal relationships after refusal;
6. sexually suggestive remarks, comments, or jokes;
7. comments about a person’s body, appearance, or dress that are sexual in nature; and
8. sexual propositions or pressure for sexual activity.
   • Non-Verbal or Visual Conduct
9. staring, leering, or suggestive gestures;
10. circulation or display of sexually suggestive materials;
11. sharing inappropriate pictures, videos, memes, or messages; and
12. making facial expressions or gestures of a sexual nature.
    • Digital or Electronic Conduct
13. sending sexually suggestive emails, messages, images, emojis, or content;
14. repeated unwelcome communication of a sexual nature; and
15. online harassment through social media or electronic platforms connected to Company activities.

 

5. Responsibility
   • Human Resources shall be responsible for:
6. receiving complaints;
7. acknowledging complaints promptly;
8. conducting fair and confidential investigations;
9. maintaining records relating to complaints and outcomes; and
10. escalating matters to the Disciplinary Committee where necessary.
    • The Disciplinary Committee shall:
11. review investigated complaints;
12. make findings based on available evidence; and
13. impose appropriate sanctions.

 

6. Duty to Report
   • Employees and persons covered under this Policy are encouraged to report any observed or suspected sexual harassment.
   • Managers and supervisors who become aware of incidents shall promptly notify Human Resources.

 

7. Confidentiality

All complaints and investigations under this Policy shall be treated confidentially and disclosed only on a need-to-know basis for investigation, resolution, and legal compliance purposes.

 

8. Protection from Retaliation

No individual shall be subjected to intimidation, victimisation, discrimination, threats, adverse treatment, or retaliation for:

1. making a complaint;
2. participating in an investigation; and
3. supporting another person’s complaint.

Any retaliatory conduct shall constitute a violation of this Policy.

9. False or Malicious Complaints
   • False or malicious complaints shall constitute misconduct and may result in disciplinary action.
   • Failure to substantiate an allegation alone shall not automatically constitute a false complaint.
10. Complaint Procedure
    • Complaints shall be submitted to Human Resources through official reporting channels.
    • The complaint should contain:
11. details of the incident;
12. names of parties involved;
13. dates and locations;
14. names of witnesses, where applicable; and
15. supporting evidence where available.
    • Upon receipt of a complaint, Human Resources shall:
16. acknowledge receipt;
17. notify the Respondent;
18. conduct investigation;
19. take interim measures where necessary to prevent further harm; and
20. refer the matter to the Disciplinary Committee.

 

11. Disciplinary Action

Any person found to have violated this Policy shall be subject to disciplinary action.

Depending on severity, disciplinary measures may include:

1. verbal or written warning;
2. mandatory counselling or training;
3. suspension;
4. termination of employment or engagement;
5. termination of contractual relationships with vendors, partners, consultants, or third parties; or
6. referral to law enforcement authorities where necessary.

 

12. Policy Review

This Policy shall be reviewed by the legal department every two (2) years or earlier where legal, regulatory, or organisational requirements necessitate amendment.