Bullying & Harassment Policy

Introduction

This Policy applies to all employees of The ESG Institute Limited ("the Company") and to any worker, contractor, consultant, intern, volunteer, agency worker or job‑applicant who undertakes work on the Company’s behalf. It is issued pursuant to the Equality Act 2017 (Isle of Man), the Employment Act 2006 (Isle of Man), the Health and Safety at Work Act 1974 as applied in the Isle of Man, and associated regulations and codes of practice. Nothing in this document removes or diminishes rights provided by those Acts or by subsequent amendments.

The Company is committed to providing a working environment in which all individuals are treated with dignity and respect and are free from bullying and harassment. Such behaviour can have serious consequences for individuals and for the organisation. Bullying and harassment will not be tolerated under any circumstances and may be treated as gross misconduct.

Policy Statement

Every employee has the right to work in an environment that is free from intimidation, hostility, humiliation or offence. Bullying or harassment undermines dignity at work, destroys confidence and can lead to stress, illness and resignation. The Company therefore adopts a zero‑tolerance approach. Complaints will be taken seriously and investigated promptly, fairly and confidentially. Retaliation against anyone who raises a genuine concern will not be permitted.

Definitions

For the purposes of this Policy, harassment is unwanted conduct related to a protected characteristic—or of a sexual nature—that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment. Bullying is offensive, intimidating, malicious or insulting behaviour, an abuse or misuse of power that undermines, humiliates, denigrates or injures the recipient. Bullying may be obvious, such as persistent criticism or ridicule, or it may be subtle, such as social exclusion or the spreading of malicious rumours. A single incident can amount to bullying or harassment if sufficiently serious.

The behaviour may be face‑to‑face, written, electronic, visual or implied and may occur at or outside the workplace, including work‑related events, travel and social functions. It is the impact on the recipient, not the intention of the perpetrator, that determines whether the behaviour is unacceptable.

Responsibilities

The Executive Leadership Team is accountable for implementation and provides guidance, monitors compliance and reports annually to the Board. Line‑managers must set clear standards of behaviour, address issues promptly and support employees who raise concerns. Every employee must treat colleagues with dignity and respect, refrain from bullying or harassment, and cooperate with investigations.

Raising Concerns

Employees who believe they have been subject to bullying or harassment should, where possible, make the perpetrator aware that the behaviour is unwelcome and must stop. If the employee feels unable to do so, or if the behaviour continues, the matter should be raised with the line‑manager or with People & Culture. Concerns may be raised orally or in writing. Where appropriate, an informal resolution—such as facilitated discussion or mediation—will be explored. If informal methods are unsuitable or unsuccessful, the employee may submit a formal grievance in accordance with the Company’s Grievance Procedure.

Investigation Process

Formal complaints will be acknowledged within five working days. An impartial investigator will be appointed, and both parties will be given the opportunity to provide statements and evidence. The investigation will be conducted as quickly as practicable, consistent with fairness. The complainant and the respondent will be informed of the outcome in writing, subject to confidentiality. Where allegations are upheld, disciplinary action may be taken, up to and including summary dismissal. Support, such as counselling, may be offered to all parties.

Confidentiality and Protection from Retaliation

All complaints will be handled with the utmost discretion. Information will be shared only on a need‑to‑know basis. Retaliation or victimisation against an individual who makes a complaint or who assists in an investigation is prohibited and may itself lead to disciplinary action. Employees who knowingly make false or malicious complaints may also be subject to disciplinary action.

Record‑Keeping

The Company will maintain confidential records of complaints, investigations and outcomes for six years in accordance with the Data Protection Act 2018 (Isle of Man). Aggregated, anonymised data will be reviewed annually to identify trends and to inform preventative measures.

Training and Communication

The Company will provide regular training to ensure that all employees understand what constitutes bullying and harassment, how to prevent it and how to raise concerns. A copy of this Policy is available on the Company website.

Review

This policy is to be reviewed every two years, or earlier if there are significant changes in law or our operations.

Latest update: June 30, 2025.

This Policy is non‑contractual and may be amended at the Company’s discretion.