Our policy against sexual harassment

Policy Statement

Eastern European Centre for Multiparty Democracy (EECMD) applies a maximum of its efforts to ensure a safe environment for the employees, which will be free from any type of discrimination and harassment in the workplace, including sexual harassment. In case of sexual harassment case identification at the workplace, EECMD will apply a zero-tolerance policy. The organization will seriously consider all incidents and investigate sexual harassment allegations in a timely manner. Any employee, who will be found guilty in sexual harassment against another person will be subject to disciplinary measures, including dismissal from work. All complaints on sexual harassment will be taken seriously and will be subject to a discretionary and respect-based approach. Submission of a complaint will not result in the victimization of the applicant.

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 circumstances, where a person is required to engage in sexual conduct in exchange for employment or other type of labor benefit, as well as situations when hostile, threatening and humiliating environment is created for the purposes of sexual harassment. 

Sexual harassment includes one or more incidents, while sexual harassment-related actions may be of physical, verbal and nonverbal nature. Sexual harassment implies and is not limited to the following actions:

Physical actions:

  • Unwelcome physical contact, including patting, pinching, touching, kissing, hugging, fondling or inappropriate touching; 
  • Coercion, including sexual violence;
  • Use of work-related threats or incentives to gain sexual advantage.

Verbal actions:

  • Comments on someone’s body, age, personal life, and others;
  • Comments, stories, and jokes of sexual nature;
  • Gaining sexual advantage;
  • Recurring and unwelcome invitation to date or proposition of intimacy;
  • Abusing employee of sex grounds;
  • Advantageous and paternalistic comments;
  • Sexually explicit messaging (by phone, e-mail or other means).

Non-verbal actions: 

  • Showing sexually provocative and obscene items;
  • Sexually provocative/vulgar gestures; 
  • whistling;
  • Provocative gazing.

Anyone can become a victim of sexual harassment, regardless of the sex of the victim and the offender. EECMD is of opinion, that sexual harassment may also occur between the people of the same sex. In order to classify an action as sexual harassment, it is sufficient for the action to be deemed unacceptable and unwelcomed by the person towards whom such action is addressed.

EECMD argues, that sexual harassment is a manifestation of power relationships and often occurs in the conditions of unequal workplace relationships, such as between a manager or supervisor and employee. Every human, including EECMD employees, partners, temporary workers, contractors or visitors, who commit sexual harassment against another person in accordance with this internal policy will be subject to sanctions defined hereunder. 

All types of sexual harassment shall be prohibited on and outside the premises of EECMD, including during social events, business visits, conferences, and training sessions organized/financed by EECMD. 

Complaint Procedures

Anyone, who is a victim of sexual harassment should, to the extent possible, inform a person suspected of sexual harassment, that conduct is unacceptable and unwelcome. EECMD recognizes, that sexual harassment may occur in circumstances of unequal relationships (for example a manager and an employee) and that the victim may not be able to inform the person accused in sexual harassment.

If the victim is unable to directly inform the person accused of sexual harassment, then he/she may refer to the employee responsible for receiving complaints of sexual harassment. Application on sexual harassment shall be made on the name of organization CEO or Nana Kalandadze, a member of the supervisory board. 

Once a person in charge of receiving applications on sexual harassment receives complaint, then he/she:

  • shall immediately record incident date, time and fact;
  • Shall familiarize with the victim’s views to understand what is the desired resolution of the victim;
  • shall determine, whether the victim acknowledges the procedures related to claim consideration established in organization;
  • Shall consider and take the following steps: an informal or formal complaint, assuming, that attempt of informal resolution of the matter does not prevent the victim to make a formal complaint if he/she is not satisfied with the outcome;
  • shall keep all conversation records confidential;
  • shall respect the victim’s choice;
  • shall ensure, that the victim is aware of complaint submission mechanisms available outside the organization, in accordance with Georgian legislation.

During the process of complaint, the victim is entitled to receive consultations within or outside the organization. EECMD will designate several advisors/consultants and ensure their training in order to support victims of sexual harassment. If organization employees will fail to provide consultations, then EECMD will hire qualified and professional consultants. EECMD recognizes, that sexual harassment may occur in circumstances of unequal relationships and accordingly, the victim is often unable to openly speak about the harassment case. EECMD recognizes the necessity to support victims in the process of complaint submission.

Informal Complaint Mechanisms

If the victim wishes to resolve the matter in an informal manner, then the responsible person: 

  • shall allow the person accused of sexual harassment to respond to the complaint;
  • shall ensure, that the person accused of sexual harassment is familiar with complaint mechanisms;
  • shall conduct a dialogue between the parties to resolve the matter in an informal manner to ensure, that the complainant is satisfied, or shall engage the organization;s internal mediator in order to achieve the acceptable situation for the victim;
  • shall maintain confidential records on development of the matter;
  • shall monitor complaint mechanism outcomes in order to determine whether the unwelcome conduct has ceased;
  • shall ensure, that al the above-mentioned procedures are implemented in a timely manner and within 5 days after submission of the complaint.

Formal Complaint Mechanisms

If the victim wishes to submit a complaint or the outcome of an informal complaint is not satisfactory for the victim, then formal mechanisms of complaint shall be applied in order to resolve the matter.

Formal investigation will be carried out by a responsible person, who has initially received the complaint. Responsible persons shall consider the case in person or shall refer the matter to an internal or external investigator, or in accordance with this policy refer to a committee composed of three other persons.

Investigator shall:

  • individually interview the victim, as well as the person accused of harassment;
  • individually interview third party related to the matter;
  • determine, whether incident(s) of sexual harassment has occurred;
  • prepare detailed report, findings, and recommendations on the investigation;
  • if the fact of sexual harassment is confirmed, then consult with the victim in order to define outcomes of corrective measures acceptable to the victim (for example, apology, amendment of work structure, promotion of the victim in case of sexual harassment resulted in demotion of the victim, training for sexual harassment practitioners, disciplinary measures, temporary release, termination);
  • in order to implement recommendations, eliminate unwelcome conduct and facilitate victim’s desired outcomes monitor further development of the process;
  • even if the fact of sexual harassment is not confirmed issue recommendations to ensure the proper functioning of the workplace;
  • maintain records on all steps taken;
  • ensure confidentially of all records related to the matter; 
  • ensure, that the process is carried out in a timely manner, no later than 5 days after submission of the complaint.

Sanctions and Disciplinary Measures

All individuals, who in accordance with this policy will be confirmed to participate in the act of sexual harassment against another person shall be subject to the following sanctions:

  • verbal or written warning; 
  • negative evaluation of work activity;
  • salary reduction; 
  • transfer;
  • demotion;
  • temporary termination;
  • termination. 

The nature of the above-mentioned sanctions depends on the scale and severity of the harassment. Relevant restraining sanctions will be used in order to prevent inadequate response to harassment incidents. Severe cases, which along with other forms of sexual harassment include physical violence, which will result in immediate termination of the employment contract of the offender.

Implementation of this Policy

EECMD will ensure, that this policy is provided to all relevant individuals. It will become a part of the organization’s guidelines. As a part of the organization’s familiarization process, training on the content of the sexual harassment policy will be facilitated for all new employees. Once in three years, all employees of EECMD will be required to participate in updated training courses on the content of this policy.

It is the responsibility of all managers to ensure, that each subordinate employee is adequately informed on the sexual harassment policy. It is the responsibility of all new employees to carefully familiarize with this policy.

Monitoring and Evaluation

EECMD recognizes the importance of “Policy Against Sexual Harassment” monitoring and will anonymously collect statistics and data in order to ensure its application and determine the effectiveness of the policy.

Leaders, managers, and employees working on the cases of sexual harassment will provide annual reports on compliance with this policy, including information on a number of incidents, response to such incidents and elaborated recommendations. Based on the report, the organization will evaluate the effectiveness of this policy and make relevant changes as required.