Table of Contents

1. POLICY STATEMENT 2

1.2 DEFINITION OF SEXUAL HARASSMENT 3

2. SEXUAL HARASSMENT COMMITTEE 5

3. FUNCTIONS OF THE COMMITTEE 6

4. SEXUAL HARASSMENT COMPLAINTS 7

5. COMPLAINT INVESTIGATION AND RECOMMENDATION 7

6. NON-REPRISAL 9

7. FALSE AND FRIVOLOUS CLAIMS 9

8. ABUSE OF AUTHORITY 9

9. CONFIDENTIALITY 10

10. SANCTIONS AND DISCIPLINARY MEASURES AND RIGHT OF APPEAL

10

11. SENSITIZATION/AWARENESS 11

Sexual Harassment Policy 1

1. POLICY STATEMENT

Sexual harassment in the workplace relates to any form of improper sexual conduct
towards another within the workplace. UGACOF LIMITED (“UGACOF”) has zero
tolerance to any acts of sexual harassment and is committed to creating and maintaining
a work environment free from all forms of sexual harassment which encourages
harmonious, respectful and dignified working relations between the employees. Any
person found to have sexually harassed another will face disciplinary action, up to and
including dismissal from employment and prosecution where applicable. All complaints
of sexual harassment will be taken seriously and treated with respect and in confidence.
No one will be victimized for lodging such a complaint.

1.1.1 Every employee of UGACOF should be aware that:

a) Sexual harassment in the workplace is unacceptable and any person who is found to
have engaged in conduct that contravenes this Policy shall be liable to disciplinary
action.

b) Sexual harassment in the workplace is prohibited both by law and by UGACOF’s

Anti-Sexual Policy Harassment Policy.

c) Sexual harassment in the workplace has an adverse effect on the victims, other
employees, the work place culture and UGACOF’s reputation.

d) Submission of a legitimate complaint or report of sexual harassment will not affect

the complainant’s future employment, performance evaluations or work
assignments.

e) Retaliation against individuals for raising legitimate claims of discrimination or

harassment or for cooperating in an investigation of such a complaint is strictly
prohibited and will not be tolerated.

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1.1.2 UGACOF will take whatever action may be needed to prevent, correct and take any
such action, as deemed necessary, against any employee who perpetrates any such
behavior. All allegations of harassment or discrimination will be investigated and
appropriate corrective action taken to the fullest extent permitted by the law.

1.2 DEFINITION OF SEXUAL HARASSMENT

Sexual harassment means any form of sexual advances, requests for sexual favors, and
other verbal or physical conduct of a sexual nature, which directly or indirectly subjects
the employee to behavior that is unwelcome or offensive to that employee and which
conduct, by its nature or through repetition has a detrimental effect on the employee’s
performance and job satisfaction. Broadly, sexual harassment may refer to the following
instances;

1.2.1 Physical contact includes unwelcome or unwanted physical contact including

patting, pinching, stroking, kissing, hugging, fondling, or inappropriate touching
or any other unsolicited physical contact. It also includes physical violence
including sexual assault and the use of job-related threats or rewards to solicit
sexual favors.

1.2.2 Verbal conduct such as:

a) Unwelcome comments on a worker’s appearance, age, personal life, etc.

b) Vulgar sexual comments, stories and jokes that have the ability of making
employees of either sex uncomfortable.

c) Unwelcome sexual advances such as repeated and unwanted social invitations for
dates or physical intimacy.

d) Requests for sexual favors.

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e) Insults based on the sex of the worker.

f) Offensive flirtation or obscene expressions of sexual interest that are addressed

directly to the person.

g) Condescending remarks such as belittling or undermining an employee’s ability to

do their job based on their sex.

h) Sending sexually explicit messages (by phone, email, social media or any other form
of communication) to another employee.

1.2.3 Non-verbal conduct such as:

a) Unwanted leering (lustful gazing).

b) Unwanted display of sexually explicit or suggestive material.

c) Unwanted sexually-suggestive gestures to another employee or co-worker.

1.2.4 Acts constituting sexual harassment include but are not limited to the following:

1.2.4.1 A direct or implicit request to an employee for sexual intercourse, sexual contact
or any other form of sexual activity that contains;

a) An implied or express promise of preferential treatment in employment.

b) An implied or express threat of detrimental treatment in employment.

c) An implied or express threat about the present or future employment status of the
employee.

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1.2.4.2 Use of language whether (written or verbal) of a sexual nature such as unwelcome

verbal advances, sexual oriented comments, requests for sexual favors, jokes of a

sexual nature, offensive flirtation or obscene expressions of sexual interest that are

addressed directly towards another employee.

1.2.4.3 Use of visual material (of whatever nature) of a sexual nature such as display of
sexually suggestive pictures, objects or written materials or sexual suggestive
gestures.

1.2.4.4 Showing physical behavior of a sexual nature such as unwanted and unwelcome
touching, patting, pinching or any other unsolicited physical contact.

2. SEXUAL HARASSMENT COMMITTEE

2.1 The Committee shall include four (4) members: one (1) employee representative,
two (2) managerial representatives and one (1) Chairperson who shall be
appointed by the Managing Director or his/her designee. Each Committee member
shall at all time have an alternate appointed through the same process to ensure
that the Committee shall always be competent to perform its functions envisaged
hereunder.

2.2 All Committee members shall be knowledgeable and sensitive to gender and sexual
harassment issues. It shall be the responsibility of UGACOF to where necessary
facilitate/conduct the necessary trainings to equip all staff more so the Committee
members with the relevant knowledge.

2.3 UGACOF will periodically and publicly notify all employees as and when details
about the Committee and/or Committee members change on an annual basis to
ensure uninterrupted lodging of complaints.

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3. FUNCTIONS OF THE COMMITTEE

3.1 The Committee shall;

a) Receive and register complaints of sexual harassment as described in this policy.

b) Initiate and conduct internal investigations into complaints.

c) Keep a record of the nature of sexual harassment offences, proceedings, documents,

information and action taken.

d) Respond to complaints within 14 days from the date of lodging the complaint with
recommendations to management for appropriate action, or such longer time as
would be necessitated by the circumstances of each case.

e) Review the provisions of the Policy to convey a responsive and supportive attitude
that builds faith and trust.

f) Prepare and provide reports under the complaint’s procedure to the Commissioner
for labour or labour officer; and carry out any other duties as may arise for the
prevention of sexual harassment with the support of the Employee Relations
Department in the home office.

3.2 In the conduct of its functions set out above, the Committee shall in as far as
practicable, having regard to the circumstances of each case, maintain
confidentiality in respect of any sexual harassment claim and the parties involved.
Nothing in this clause shall however be interpreted to prohibit disclosure where the
same is necessary for the purpose of investigating the complaint, reporting the
complaint to the Authorities or taking disciplinary measures in relation thereto.

Sexual Harassment Policy 6

4. SEXUAL HARASSMENT COMPLAINTS

Lodging a sexual harassment complaint;

4.1 An employee who believes that s/he has been subjected to sexual harassment by
anyone in the work place is encouraged to promptly make a complaint in this
regard.

4.2 All cases of sexual harassment must be reported in writing or verbally to any
member of the Committee. Where a complaint is reported verbally, the Committee
member to whom the complaint has been lodged shall record the complaint in
writing in the presence of the complainant, read it back to the complainant for
purposes of ensuring that the same is an accurate record of the complaint.
The complaint statement shall be signed by the employee indicating the same as a
true and accurate record of the complaint and the same countersigned by the
committee member. Upon receipt of a sexual harassment complaint, the Committee
member shall immediately notify the Chairperson of the Committee of such
complaint.

5. COMPLAINT INVESTIGATION AND RECOMMENDATION

5.1 Initiating investigations: Upon receipt of a report or complaint alleging sexual

harassment, the Chairperson shall immediately authorize an investigation which
will be conducted by the Committee members. The Chairperson shall also ensure
that the victim understands UGACOF procedures for dealing with the complaint.

5.2 Form of investigations: The investigation may consist of personal interviews, with
the complainant, the individual(s) against whom the complaint is filed and such
other persons as the Committee deems relevant in the circumstances of each case
as well as review of any documents and communications as the Committee deems
relevant to the complaint.

Sexual Harassment Policy 7

 The investigations may also consist of any other methods as the Committee may
deem fit to apply.

5.3 Interim measures: Pending the completion of the investigations, the Chairperson
of the Committee may, at his/her discretion take immediate/interim steps, to
protect the complainant, customers and other employees including but not limited
to temporary transfer, reassignment, requiring any complainant or perpetrator to
take a paid leave of absence for the duration necessary to conclude the
investigations. Similar action may be taken to protect the complainant from the
person in respect of whom the sexual harassment claim is lodged.

5.4 Consideration in the conduct of investigations: In determining whether any alleged

conduct consists of sexual harassment, the Committee will have consideration to
the circumstances surrounding the allegations and the context in which the alleged
incidents occurred including but not limited to: (i) the nature of the alleged sexual
advances, (ii) the relationships between the parties involved, and (iii) conduct of
the parties in and outside the work environment.

5.5 Completion of investigations: The Committee shall be required to complete its

investigations within 14 days following the receipt of a complaint and submit its
written report to the Managing Director or his/her designee. Where the Committee
is, for any reason, unable to submit an investigative report within 14 days following
the receipt of a complaint, the Committee shall notify the Managing Director or
his/her designee, giving reasons for the same.

5.6 Nature of report: The report of the Committee following the conduct of
investigations into a sexual harassment claim shall contain details of the complaint,
details of the nature of investigations conducted, findings of the Committee and
recommendations including counselling of the complainants and disciplinary
action in respect of any employee who is found to have conducted themselves in a
manner which contravenes this Policy.

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5.7 Update to the complainant: The result of the investigation of each complaint filed
under the above procedures will be reported in writing to the complainant by the
Committee Chairperson and the report will document any action taken as a result
of the complaint.

6. NON-REPRISAL

6.1 The Chairperson will recommend for disciplinary action any individual who
retaliates against any person who reports alleged sexual harassment or who
retaliates against any person who testifies assists or participates in an investigation,
proceeding or hearing relating to sexual harassment complaint.

Retaliation includes, but is not limited to any form of intimidation, reprisal or

harassment, termination; denial of promotion; demotion in title or duties; transfer
to a less favorable position or location; involuntary placement on leave; hostile or
abusive treatment; decreasing remuneration or benefits; coercion; threats; and
intimidation.

7. FALSE AND FRIVOLOUS CLAIMS

7.1 Staff shall not knowingly raise a false and frivolous claim of sexual harassment.
Disciplinary action will be taken against any member of staff who raises a false
claim.

8. ABUSE OF AUTHORITY

8.1 Abuse of authority refers to the improper use of position of influence, power or
authority by an individual against another colleague or group of colleagues. This is
worsened when an individual misuses his/her influence, power or authority to
negatively influence the career or employment conditions (including appointment,
assignment, contract renewal, performance evaluation or promotion) of another.

Sexual Harassment Policy 9

 It may include a one-off incident or a series of incidents. Abuse of authority may
also include misuse of power that creates a hostile work environment which
includes the use of intimidation, threats, blackmail or coercion.

9. CONFIDENTIALITY

9.1 All information received when handling sexual harassment complaints shall be
confidential and such information shall only be used for the purpose of
determining or resolving the complaint and its disclosure shall be limited to
persons involved in the complaint handling.

9.2 Subject to any statutory and or contractual disclosures which may be applicable,
all confidentiality on information received while handling a sexual harassment
complaint shall continue to exist after the termination of the employment
relationship howsoever caused.

10. SANCTIONS AND DISCIPLINARY MEASURES AND RIGHT OF APPEAL

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

a) Verbal or written warning

b) Adverse performance evaluation
c) Transfer
d) Demotion
e) Suspension
f) Dismissal

10.2 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.

Sexual Harassment Policy 10

10.3 Any person who is aggrieved by UGACOF’s disciplinary decision of the Committee
in any sexual harassment matter shall have a right to appeal to the Managing
Director or his/her designee. The Managing Director or his/her designee will
review the Committee’s decisions. The Managing Director or his/her designee will
review the investigations of alleged sexual harassment which were conducted to
determine whether or not the Sexual Harassment Policy was violated and if the
outcome was satisfactory.

10.4 Upon conclusion of the review process, the Managing Director may subject to
his/her findings vary or affirm the decision of the Committee

11. SENSITIZATION/AWARENESS

All employees shall be given a copy of this policy and training conducted on the various
aspects of this Policy.

Signed this Monday 3rd day of October 2022 by

Joe Hage-Chahine _______________________

Managing Director - Ugacof

Aidah Nabasirye _______________________

Human Resource Manager- Ugacof

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