SCOPE

The detail below is applicable to ALL VenturePro Staff, Representatives and Clients. No matter what level or perceived level of seniority or celebrity within the public domain. VenturePro operates a ZERO TOLERANCE policy on all forms of harassment.

DEFINITIONS OF HARRASSMENT

DIRECT HARRASSMENT

Harassment is any unwanted behaviour, physical or verbal (or even suggested), that makes a reasonable person feel uncomfortable, humiliated, or mentally / emotionally distressed. This can be on the basis of gender / sexuality, ethnicity, religion or disability.

INDIRECT HARRASSMENT

Indirect harassment occurs when the act was not aimed at the individual but creates a toxic atmosphere, or if, simply put, a secondary victim is offended by an unwelcome conduct. This can manifest in several ways. A person is subjected to indirect harassment if he/she: Overhears an offensive joke or remark. This can be on the basis of gender / sexuality, ethnicity, religion or disability.

PHYSICAL ASSAULT / SEXUAL ASSAULT

Non-consensual physical contact (including groping and rape).

RESPONSE

Where a report of an incident has taken place, this must be escalated to the most senior staff member onsite or if unable to, the most senior person / representative at your location (this includes Freedom to Speak Up Guardians from both staff or clients which is covered later in this framework).

The priority at this stage MUST be:

• The safety of all clients and staff and actions appropriate to facilitate this must take place immediately if required.

• The ongoing, effective support of the victim(s) which may involve medical or specialist assistance / support.

The incident detail will be obtained and statements from the person(s) involved in written format within 12 hours.

The incident detail will then be discussed with the VenturePro Executive Team.

If a crime has occurred, local law enforcement authorities must be called and made aware of the incident and provided with the incident details. This may also facilitate the contacting of law enforcement services in the perpetrators home country. This will be decided and completed by local law enforcement unless a formal request to do so is made by the victim(s).

SUPPORT

VenturePro recognises that an incident can effect not only the victim(s) but also staff, clients and third parties. VenturePro recognises its duty of care to implement a structured support response centred on effective actions and learning. As such, VenturePro has adopted the SHARE framework.

SHARE

• Safe - create a safe environment for those effected to be able to discuss / speak

• Hear - Listen and Hear recollections of those effected in an empathic manner and record

• Assess - Use a collaborative / inclusive manner to assess the information so that we can effectively…

• Respond - Draw up a set of appropriate and agreed actions / desired outcomes from the details of the incident

• Evaluate - Monitor short and long term outcomes from the response to the incident to drive learning that must be shared within the organisation and if required, externally

FREEDOM TO SPEAK UP GUARDIANS (FSG)

At the start of every expedition, a local staff member will be identified to the client groups as their FSG. The option will also be given to the client group to provide 1-2 members to act as an FSG.

The FSG is an alternative reporting / confiding contact within the client and staff group for clients or staff with concerns to speak to regarding any incidents of Harassment. It is recognised by VenturePro that positions of authority may not be considered a desirable first contact and that a peer to peer option would minimise the risk of a victim feeling they are unable / have no one to speak to.

Staff acting as an FSG have attended additional training provided by VenturePro or the local guiding third party in line with incident management requirements. The main objective of the FSG is to listen and escalate in line with the detail above.

TRAINING

VenturePro ensures that all its staff and representatives have been trained in the support principals of the SHARE Framework and the definitions and responses contained in this document.

Third party representatives of VenturePro must provide a yearly signed statement to reflect this training and commitment to the ZERO TOLERANCE policy on harassment in all its forms.