Policy on detection and prevention of sexual harassment, sexual violence, and exploitation of the Private Agricultural Enterprise “Ukraina”

1.Purpose

These guidelines provide a safe, healthy and supportive work environment for all employees of Private Agricultural Enterprise Ukraine (from now on referred to as the Company). The main objectives include:

• Preventing sexual harassment, violence and exploitation: Develop and implement effective mechanisms to avoid any form of sexual harassment in the workplace.
• Support for victims: Ensuring appropriate support and protection for individuals who are victims of sexual harassment or violence.
• Ensuring compliance with the law: Complying with applicable laws and standards to protect against sexual harassment and violence in the workplace.
• Raising awareness: Educating employees on sexual harassment, violence and exploitation to ensure that they are aware of and respect the corporate policy.

2. Scope of application

These guidelines apply to all employees of the Company, including:

• Administrative Staff
• Specialists of all levels
• Permanent and temporary employees
• Contractors and unauthorised persons who are on the Company’s premises

The guidelines apply to all aspects of the work environment, including but not limited to

• Office premises and production sites
• Mobile work teams and offsite events
• Interaction via email and other digital communication tools
• Social and professional events organised by the company

The application of these guidelines is mandatory for all levels of management and personnel, and each employee must comply with the established norms and procedures to ensure safety and well-being in the workplace.

The company is committed to creating a safe and supportive working environment for all employees. In this regard, the company implements these guidelines to prevent and combat sexual harassment, sexual violence and exploitation.

3. Definitions of terms

To ensure a clear understanding and proper application of these guidelines, the following terms and their definitions are provided:

Sexual harassment

Sexual harassment is any form of unwelcome or unwanted sexual behaviour that has the purpose or effect of creating a hostile, degrading or intimidating work environment. This may include, but is not limited to:

• Inappropriate sexual comments, jokes or questions.
• Unwelcome sexual advances or requests.
• Inappropriate physical touching or approaching.

Sexual violence

Sexual violence refers to any form of violence that involves sexual acts without the survivor’s voluntary consent. This may include, but is not limited to:

• Sexual acts that are forced or threatened.
• Extortion of sexual services through force, threat or manipulation.
• Other forms of forced sexual contact.

Sexual exploitation

Sexual exploitation involves the use of sexual acts or advances to take advantage of or manipulate a person. This may include, but is not limited to:

• Coercion to provide sexual services in exchange for work privileges or promotion.
• Using personal or professional relationships to obtain sexual services.
• Sexual manipulation or exploitation in a professional or personal relationship.

Violations

A violation is any act or omission that contravenes these guidelines and may include sexual harassment, abuse or exploitation.

Affected person

A survivor is anyone who has been subjected to sexual harassment, abuse or exploitation, whether or not they have filed a complaint.

Immediate response

An immediate response is a quick and effective response to incidents of sexual harassment, violence or exploitation that includes reporting to the appropriate individuals or departments, investigating and taking the necessary steps to protect the survivor and restore safety in the workplace.

Reference person

A focal point is a person designated to provide assistance and support to employees in matters of sexual harassment, violence and exploitation, and to receive and address complaints.

4. Company policy

Zero tolerance policy

The company proclaims a zero-tolerance policy towards any form of sexual harassment, sexual violence and exploitation. Our goal is to provide a safe and supportive work environment in which every employee can work without fear of discrimination or violence. We are committed to:

• Prevent sexual harassment and violence: conduct preventive measures, training and awareness raising to raise awareness and prevent potential incidents.
• Respond to violations: respond immediately to any incidents of sexual harassment, violence or exploitation, taking the necessary steps to investigate and ensure justice.
• Protect the rights of survivors: provide survivors with support and protection, including the ability to report violations anonymously and receive counselling and assistance.

Confidentiality and data protection

Confidentiality is a fundamental principle when dealing with cases of sexual harassment, abuse or exploitation. We are committed to:

• Maintain confidentiality: information relating to complaints and investigations will be treated confidentially and will only be made available to those directly involved.
• Protect personal data: ensure that the personal data of affected individuals and all participants in investigations are protected by applicable law.

Rights and obligations of employees

Employees have the right to:

• To safety: to a safe and free from sexual harassment environment.
• To support: to receive support and protection if they are victims of sexual harassment, violence or exploitation.

Employees have an obligation to:

• Comply with the policy: to strictly adhere to this policy and corporate standards related to sexual harassment and violence.
• Report Violations: Immediately report any incidents of sexual harassment, violence or exploitation and cooperate with investigations.

Responsibilities of the management

Management is responsible for:

• Implementing the policy: ensuring that the policy is implemented and adhered to at all levels of the organisation.
• Training: organising regular training events to raise awareness of the policy and procedures among employees.
• Controlling and monitoring: regularly monitoring the effectiveness of the policy and procedures to improve them.

Response measures

In the event of a violation of this policy, the company will take the necessary measures, including:

• Investigation: conducting a thorough investigation of all incidents of harassment or violence.
• Disciplinary action: applying disciplinary sanctions to individuals who violate the policy, including possible dismissal for serious violations.

This policy is the basis for ensuring the safety and dignity of each employee of the Company and contributes to the formation of a healthy corporate environment.

5. Notification procedure

Filing a complaint

Any person who witnesses or is a victim of sexual harassment, violence or exploitation has the right to file a complaint. To do so, you should

• Contact the Compliance Officer by sending an email to mm.savytska@dubnoinvest.com.
• The complaint may be submitted in writing or orally in any form. A written complaint should include details of the incident, including dates, times, locations and a description of the events.

Acknowledgement of receipt of the complaint

Upon receipt of a grievance, the responsible person shall:

• Immediately acknowledge receipt of the complaint and provide information on the next steps in the investigation process.
• Explain to the complainant what steps will be taken to investigate and protect them.

6. Responding to a complaint

Assessment of the situation

• Immediately conduct an initial assessment of the complaint to determine its severity and the need for urgent action.
• Take interim measures to prevent further sexual harassment or violence, such as changing working conditions or suspending the person suspected of the violation.

Investigation

• Appoint an investigation committee or individuals to conduct the investigation, consisting of representatives from relevant business units.
• Conduct a comprehensive investigation, including gathering evidence, interviewing witnesses and engaging experts if necessary.
• Document all stages of the investigation, keeping records of incidents, interviews and decisions.

Results of the investigation

• Based on the results of the investigation, prepare a report with conclusions and recommendations for further action.
• Ensure the protection of the victim’s rights and interests, including the possibility of providing support and advice.

Taking action

• Take appropriate disciplinary action against the individual who violated the policy, including possible dismissal or other sanctions.
• Based on the results of the investigation, review and improve procedures and policies to prevent similar incidents in the future.

Feedback

• Provide feedback to all parties involved on the results of the investigation and actions taken.
• Evaluate the effectiveness of the measures taken and make adjustments as necessary.

Support for victims

• Provide affected individuals with the necessary support and assistance in their recovery and return to work.

7. Control and monitoring

Control and monitoring are key elements to ensure the effectiveness of the implementation of the policy of combating sexual harassment, violence and exploitation in the Company.

8. Final provisions

This Policy is an integral part of the Company’s development strategy and is subject to regular review. We undertake to regularly evaluate and improve this Policy, taking into account trends and relevant legislative changes. The Company strives to be an example for other organisations in implementing and supporting the principles of gender equality at all levels of activity.

This Policy comes into force from the moment of its approval and is binding on all employees of the Company.