PROTOCOL FOR THE PREVENTION AND ACTION AGAINST SEXUAL HARASSMENT AND HARASSMENT FOR REASONS OF SEX IN THE COMPANY ECOCASTULUM, SL



INDEX

1. COMMITMENT OF ECOCASTULUM, SL IN THE MANAGEMENT OF SEXUAL AND/OR GENDER-BASED HARASSMENT

2. CHARACTERISTICS AND STAGES OF THE PROTOCOL FOR PREVENTION AND ACTION AGAINST SEXUAL HARASSMENT AND/OR HARASSMENT BASED ON SEX

2.1. Preventive protection against bullying

2.1.1. Statement of principles: Zero tolerance for conduct that constitutes sexual harassment and harassment based on sex

2.1.2. Concept and conduct constituting sexual harassment and harassment based on sex

2.1.2.1. Definition and conduct constituting sexual harassment

2.1.2.2. Definition and behaviors constituting harassment based on sex



2.2. The action procedure

2.2.1. Determination of the investigating commission

2.2.2. The beginning of the procedure: The complaint or denunciation

2.2.3. The preliminary phase or informal procedure

2.2.4. The informative file or formal procedure

2.2.5. The resolution of the harassment file

2.2.6. Tracing

3. DURATION, OBLIGATION OF COMPLIANCE AND ENTRY INTO FORCE

4. COMPLAINT OR COMPLAINT MODEL


1. COMMITMENT OF ECOCASTULUM, SL IN THE MANAGEMENT OF SEXUAL AND/OR GENDER-BASED HARASSMENT


With this protocol, ECOCASTULUM, SL, expresses its zero tolerance for the occurrence in its entire organization of conduct constituting sexual harassment or harassment based on sex.


By adopting this protocol, ECOCASTULUM, SL, wants to underline its commitment to the prevention and action against sexual harassment and harassment based on sex in any of its manifestations, informing all personnel who provide services in your organization of its application, whether it is its own staff or from other companies, including people who, not having an employment relationship, provide services or collaborate with the organization, such as people in training, those who carry out non-labor internships or those who volunteer.


Likewise, ECOCASTULUM, SL, assumes the commitment to publicize the existence of this protocol, indicating the need for its strict compliance, to the companies to which its own personnel are posted, as well as to the companies from which the personnel working at ECOCASTULUM, SL Thus, the obligation to observe the provisions of this protocol will be stated in the contracts signed with other companies.


When the alleged harassing person is outside the control of the company management and, therefore, ECOCASTULUM, SL, cannot apply the procedure in its entirety, it will contact the competent company in order to adopt the appropriate measures and, If applicable, penalize the person responsible, warning him that, if he does not do so, the commercial relationship that unites both companies may be extinguished.


The protocol will apply to situations of sexual harassment or harassment based on sex that occur during work, in relation to work or as a result of it:


  1. in the workplace, including in public and private spaces when they are a workplace;
  2. in places where the worker is paid, where he takes his rest or where he eats, or where he uses sanitary or cleaning facilities and in changing rooms;
  3. in commutes, trips, events or social or training activities related to work;
  4. in the framework of communications that are related to work, including those carried out through information and communication technologies (virtual harassment or cyberbullying);
  5. in the accommodation provided by the employer;
  6. on journeys between home and workplace.


This protocol complies with what is required by articles 46.2 and 48 of Organic Law 3/2007, of March 22, for the effective equality of women and men, RD 901/2020 of October 13, which regulates the equality plans and their registration and modifies Royal Decree 713/2010, of May 28, on registration and deposit of collective labor agreements and agreements and article 14 of Law 31/1995, of November 8, on prevention of occupational hazards.


In effect, ECOCASTULUM, SL, by committing to the measures that make up this protocol, expresses and publicizes its express will to adopt a proactive attitude both in the prevention of harassment - awareness and information of behaviors not tolerated by the company -, as well as in the dissemination of good practices and implementation of as many measures as are necessary to manage the complaints and allegations that may be raised in this regard, as well as to resolve as appropriate in each case.


In Linares on January 3, 2022




Signed: Ignacio López Anquela




2. CHARACTERISTICS AND STAGES OF THE PROTOCOL FOR PREVENTION AND ACTION AGAINST SEXUAL HARASSMENT AND/OR HARASSMENT BASED ON SEX


In order to comply with the commitment with which this protocol begins and in the terms exposed so far, the company ECOCASTULUM, SL, implements a procedure for prevention and action against sexual harassment and harassment based on sex, with the intention of establishing a mechanism that establishes how to act comprehensively and effectively in the event of any behavior that may constitute sexual or gender-based harassment. To do this, this protocol combines three types of measures established in section 7 of the Annex to RD 901/2020, of October 13:


1. Preventive measures, with a declaration of principles, definition of sexual harassment and harassment based on sex, and identification of behaviors that could constitute these types of harassment.


2. Proactive or procedural measures to act against harassment to channel complaints or reports that may arise and applicable precautionary and/or corrective measures.


3. Identification of reactive measures against harassment and, where appropriate, the disciplinary regime.


2.1. PREVENTIVE PROTECTION AGAINST HARASSMENT


2.1.1. Statement of principles: Zero tolerance for conduct that constitutes sexual harassment and harassment based on sex


The company ECOCASTULUM, SL, formalizes the following declaration of principles, in the sense of underlining how the relations between company personnel and behaviors that are not tolerable in the organization should be.


This harassment protocol is applicable to all behavior constituting sexual harassment or for reasons of sex that may manifest itself in ECOCASTULUM, SL


ECOCASTULUM, SL, by implementing this procedure, assumes its commitment to prevent, not tolerate, combat and prosecute any manifestation of sexual harassment or harassment based on sex in its organization.


Harassment is, by definition, a multi-offensive act that affects various legal interests, among which the dignity of the worker stands out as a positivization of the right to life and to physical, mental and moral integrity. The affectation to dignity, however, does not prevent an act of these characteristics from also generating damage to other different legal interests such as equality and the prohibition of discrimination, honor, one's own image, privacy, health, etc. . but even and with this it will always be by definition contrary to dignity. Sexual harassment and harassment based on sex always affects the dignity of those who suffer it and constitutes discrimination based on sex.


Within the scope of ECOCASTULUM, SL, conduct that may constitute sexual or gender-based harassment in any of its manifestations will not be allowed or tolerated. The company will penalize both whoever engages in offensive conduct and whoever promotes, encourages and/or tolerates it. All company personnel have the obligation to respect the fundamental rights of all those who make up ECOCASTULUM, SL, as well as those who provide services in it. In particular, they will refrain from conduct that is contrary to dignity, privacy and the principle of equality and non-discrimination, always promoting respectful conduct.


Notwithstanding the foregoing, if they understand that they are being harassed or become aware of a situation of sexual or gender-based harassment, any worker will have the possibility, through a complaint or complaint, to activate this protocol as an internal, confidential procedure. and fast for the sake of its eradication and repair of effects.


Once the corresponding information file has been filed, if the concurrence of sexual harassment or harassment based on sex is confirmed, ECOCASTULUM, SL, will sanction whoever corresponds, committing to use all its management and sanctioning power to guarantee a work environment free of violence, of sexist and gender-based discriminatory behaviors and appropriate to the principles of safety and health at work.


2.1.2 Concept and conduct constituting sexual harassment and harassment based on sex


2.1.2.1. Definition and conduct constituting sexual harassment

Definition of sexual harassment


Without prejudice to the provisions of the Penal Code, for the purposes of this protocol, sexual harassment constitutes any behavior, verbal or physical, of a sexual nature that has the purpose or produces the effect of violating the dignity of a person, particularly when it is creates an intimidating, demeaning or offensive environment.


Any sexual harassment will be considered discriminatory.


Conditioning a right or an expectation of a right to the acceptance of a situation constituting sexual harassment will also be considered an act of discrimination based on sex.


By way of example and without intention of being exclusive or limiting, the behaviors described below could constitute sexual harassment:


Verbal behaviors:

  • Alleged sexual advances, propositions, or pressure for sexual activity;
  • Offensive flirtations;
  • Suggestive, indirect or obscene comments;
  • Unwanted phone calls or contacts through social networks;
  • Jokes or comments about sexual appearance.


Non-verbal behaviors:

  • Display of sexually suggestive or pornographic photos, objects or writings, impudent glances, gestures;
  • Letters or emails or messages on social networks of an offensive nature and with clear sexual content.


Physical Behaviors:

  • Deliberate and unsolicited physical contact, unwanted hugging or kissing, excessive and unnecessary physical closeness.


Quid pro quo sexual harassment or sexual blackmail


Among the behaviors constituting sexual harassment, one can differentiate between “quid pro quo” sexual harassment or sexual blackmail, which consists of forcing the victim to choose between submitting to sexual requirements, or losing or seeing certain benefits or working conditions harmed, which affect access to professional training, continued employment, promotion, remuneration or any other decision in relation to this matter. To the extent that it involves an abuse of authority, the harassing person will be the one who has power, either directly or indirectly, to provide or withdraw a benefit or work condition.


environmental sexual harassment


In this type of sexual harassment, the harasser creates an intimidating, hostile, degrading, humiliating or offensive environment for the victim, as a consequence of unwanted attitudes and behaviors of a sexual nature. They can be carried out by any member of the company, regardless of their position or status, or by third parties located in some way in the work environment.



2.1.2.2. Definition and behaviors constituting harassment based on sex

Definition of sexual harassment

Harassment by reason of sex constitutes any behavior carried out based on a person's gender with the purpose or effect of violating their dignity and creating an intimidating, degrading or offensive environment.


Any harassment based on sex will be considered discriminatory.


In order to appreciate that a situation that can be classified as harassment based on sex actually occurs in a specific reality, the concurrence of a series of elements that make up a common denominator is required, among which the following stand out:


  1. Harassment, understanding as such any intimidating, degrading, humiliating and offensive behavior that originates externally and is perceived as such by the person who suffers it.
  2. Objective attack on the dignity of the victim and subjectively perceived by the latter as such.
  3. Multi-offensive result. The attack on the dignity of those who suffer harassment for reasons of sex does not prevent the concurrence of damage to other fundamental rights of the victim, such as the right not to suffer discrimination, an attack on mental and physical health, etc.
  4. That it is not an isolated event.
  5. The reason for these behaviors must have to do with the fact of being women or due to circumstances that biologically can only affect them (pregnancy, maternity, breastfeeding); or that have to do with reproductive and care functions that are presumed to be inherent to them as a result of social discrimination. In this sense, harassment based on sex can also be suffered by men when they perform functions, tasks or activities related to the role that has historically been attributed to women, for example, a male worker who is harassed for dedicating himself to caring for minors or dependents.


Conditioning a right or an expectation of a right to the acceptance of a situation constituting harassment on grounds of sex will also be considered an act of discrimination on grounds of sex.


Conduct constituting harassment for reasons of sex

By way of example, and without excluding or limiting intentions, the ones that follow are a series of specific behaviors that, fulfilling the requirements stated in the previous point, could even constitute harassment based on sex at work if it occurs repeatedly.


Attacks with organizational measures

  1. Judging the person's performance offensively, hiding their efforts and abilities.
  2. Questioning and overruling the person's decisions.
  3. Not assign any homework, or assign meaningless or demeaning homework.
  4. Deny or hide the means to carry out the work or provide erroneous data.
  5. Assign jobs that are much higher or much lower than the person's skills or qualifications, or that require a much lower qualification than the one possessed.
  6. Contradictory orders or impossible to comply with.
  7. Theft of belongings, documents, work tools, deleting files from the computer, manipulating work tools causing harm, etc.
  8. Threats or pressure to the people who support the harassed.
  9. Manipulation, concealment, return of correspondence, calls, messages, etc., of the person.
  10. Denial or difficulties in accessing permits, courses, activities, etc.


Actions that seek to isolate the recipient

  1. Changing the person's location by separating them from their peers (isolation).
  2. Ignore the person's presence.
  3. Do not speak to the person.
  4. Restricting colleagues from speaking with the person.
  5. Do not allow the person to express themselves.
  6. Avoid all eye contact.
  7. Eliminate or restrict the means of communication available to the person (telephone, email, etc.).


Activities that affect the physical or mental health of the victim

  1. Threats and physical attacks.
  2. Verbal or written threats.
  3. Shouting and/or insults.
  4. Scary phone calls.
  5. Provoke the person, forcing him to react emotionally.
  6. Intentionally causing expenses to harm the person.
  7. Causing damage to the workplace or their belongings.
  8. Require the person to perform work that is dangerous or harmful to their health.


Attacks on privacy and personal or professional reputation

  1. Manipulating personal or professional reputation through rumor, denigration and ridicule.
  2. Implying that the person has psychological problems, trying to get them to undergo a psychiatric examination or diagnosis.
  3. Teasing about gestures, voice, physical appearance, disabilities, nicknames, etc.
  4. Criticism of nationality, political or religious attitudes and beliefs, private life, etc.


2.2. ACTION PROCEDURE


Schematically, the phases and maximum deadlines for carrying out the action procedure are the following:


fases protocolo acoso

new paragraph


2.2.1.- Determination of the investigating committee for cases of harassment


An investigative and follow-up commission is set up for cases of sexual harassment and for reasons of sex that is made up of three people[one]:


  1. Chief Executive Officer
  2. Chief Learning Officer
  3. Administration Department


In the event of absence due to vacation, illness or any other legal cause, you may act as a substitute for any of the holders:


  • Chief Technology Officer


In order to guarantee the maximum confidentiality of this procedure, the people who are members of this commission will be permanent.


The commission will last four years. The indicated people who make up this investigative commission, will exhaustively comply with impartiality with respect to the affected parties, so in the event of some type of relationship by consanguinity or affinity with one or more of the people affected by the investigation, close friendship , manifest enmity with the people affected by the procedure or direct or indirect interest in the specific process, they must refrain from acting. In the event that, despite the existence of these causes, abstention does not occur, any of the persons affected by the procedure may request the recusal of said person or persons from the committee.


Additionally, this commission, either by its own agreement or at the request of one of the affected persons, may request the hiring of an external expert who may accompany them in the investigation of the procedure.


This commission will meet within a maximum period of 3 working days from the date of receipt of a complaint, denunciation or knowledge of inappropriate behavior, in accordance with the procedure established in this protocol for its presentation.


Within the commission, any claim, communication, complaint or report on behavior that could be considered sexual or gender-based harassment will be immediately and thoroughly investigated. Complaints, reports and investigations will be treated in an absolutely confidential manner, consistent with the need to investigate and adopt corrective measures, taking into account that it may directly affect the privacy and honor of people.



2.2.2. The beginning of the procedure: The complaint or denunciation


At ECOCASTULUM, SL, the Administration Department is in charge of managing and processing any complaint or denunciation [2] that, in accordance with this protocol, can be filed by the people who provide services in this organization.


The workers of ECOCASTULUM, SL, should know that, except for fraud or bad faith, they will not be penalized for activating the protocol. In case of doing so, when filing any claim, it will have a presumption of veracity and will be managed by the department to which reference has just been made.


The complaints will be secret, but they cannot be anonymous, ECOCASTULUM, SL, will guarantee the confidentiality of the affected parties.


In order to guarantee the confidentiality of any complaint, denunciation or communication of a situation of harassment, ECOCASTULUM, SL enables the email account canaldenuncias@ecocastulum.com to which only the person in charge of processing the complaint and the people who make up the investigating commission will have access, and whose purpose is solely and exclusively the presentation of this type of complaint or complaint. All this without prejudice to being able to also accept complaints or reports that may be submitted secretly, not anonymously, in writing and in a sealed envelope addressed to the person in charge of processing the complaint. In order to protect the confidentiality of the procedure, the person in charge of processing the complaint will give a numerical code to each of the affected parties.


Upon receipt of a complaint in either of the two indicated modalities, the person in charge of processing the complaint will immediately inform the management of the company and the other people who make up the investigating commission.


The model that appears in this protocol is made available to the workers of the company for the formalization of the complaint or complaint. The presentation by the victim of the situation of sexual harassment or for reasons of sex, or by any worker or worker who has knowledge of it, of the corresponding form by email at the address provided in this regard or by internal registry reporting a situation of harassment, will be necessary for the initiation of the procedure in the terms stated in the following section.



2.2.3. The preliminary phase or informal procedure


This phase is optional for the parties and will depend on the will expressed by the victim in this regard. The aim of this preliminary phase is to resolve the harassment situation urgently and efficiently in order to interrupt the harassment situations and reach a solution accepted by the parties.


Once the complaint or denunciation has been received, the investigating commission will interview the affected person, and may also interview the alleged aggressor or both parties, request the intervention of expert personnel, etc.


This informal procedure or preliminary phase will have a maximum duration of seven working days from the receipt of the complaint or denunciation by the investigating commission. Within that period, the investigating commission will conclude this preliminary phase, assessing the consistency of the complaint, indicating whether or not the purpose of the procedure has been achieved and, where appropriate, proposing the actions it deems appropriate, including the opening of the information file. . The entire procedure will be urgent and confidential, protecting the dignity and privacy of the people affected. The file will be confidential and only the aforementioned commission may have access to it.


Notwithstanding the foregoing, the investigating committee, given the complexity of the case, may skip this preliminary phase and proceed directly to the processing of the information file, which it will communicate to the parties. Likewise, the information file will be processed if the harassed person is not satisfied with the solution proposed by the investigating commission.


In the case of not proceeding to the processing of the informative file, the minutes of the solution adopted in this preliminary phase will be drawn up and the management of the company will be informed.


Likewise, the legal representation of workers, the person responsible for occupational risk prevention and the monitoring commission of the equality plan will be informed, who must keep confidentiality regarding the information to which they have access. In any case, in order to guarantee confidentiality, no personal data will be given and the numerical codes assigned to each of the parties involved in the file will be used.



2.2.4. The informative file


In the event that the preliminary phase is not activated or when the procedure cannot be resolved despite having been activated, the information file will be given way.


The investigative commission will carry out an investigation [3] , in which it will be resolved regarding the occurrence or not of the reported harassment after hearing the affected persons and witnesses who are proposed, holding meetings or requesting as much documentation as necessary, without prejudice to the provisions on the protection of character data. reserved personnel and documentation.


The people who are required must collaborate with the greatest possible diligence.


During the processing of the file, at the proposal of the investigating committee, the management of ECOCASTULUM, SL, will adopt the necessary precautionary measures leading to the immediate cessation of the situation of harassment, without these measures being able to suppose permanent and definitive damage to working conditions. of the people involved. Apart from other precautionary measures, the management of ECOCASTULUM, SL, will separate the alleged harasser from the victim.


In the development of the procedure, the victim will be given a hearing first and then the person denounced. Both parties involved may be assisted and accompanied by a person they trust, whether or not they are the legal and/or union representative of the workers, who must keep confidentiality regarding the information to which they have access.


The investigation commission may, if it deems it appropriate, request external advice on harassment and equality and non-discrimination during the investigation of the procedure. This external expert person is obliged to guarantee the maximum confidentiality with respect to everything of which he may have knowledge or to which he may have access for being part of the conflict resolution commission in question, and will be linked to the same causes of abstention and recusal. than the members of the investigation commission.


Once the investigation is over, the commission will draw up a record that will include the facts, the testimonies, evidence carried out and/or collected, concluding whether or not, in its opinion, there are indications of sexual harassment or harassment based on sex.


If evidence of harassment can be deduced from the test carried out, in the conclusions of the minutes, the investigating commission will urge the company to adopt the appropriate sanctioning measures, and may even, in the event of being very serious, propose the disciplinary dismissal of the company. aggressor person.


If from the evidence carried out no indications of harassment are found, the commission shall record in the minutes that the evidence expressly carried out does not show the presence of sexual or gender-based harassment.


If, even if there is no harassment, any inappropriate action or a situation of violence that may be punished is found, the commission investigating harassment will likewise urge the management of ECOCASTULUM, SL, to adopt measures that are considered pertinent in this regard.


Within the harassment investigation commission, decisions will be made by consensus, whenever possible and, failing that, by majority.


The procedure will be agile, efficient, and will be protected, in any case, the privacy, confidentiality and dignity of the people affected. Throughout the entire procedure, strict confidentiality will be maintained and all internal investigations will be carried out tactfully, and with due respect, both for the complainant and/or the victim, who in no case may receive unfavorable treatment. For this reason, as well as the defendant, whose proof of guilt requires the concurrence of evidence in the terms provided in the labor regulations in case of violation of fundamental rights.


All the people involved in the process will have the obligation to act with strict confidentiality and to keep secrecy and professional secrecy regarding all the information to which they have access.


This formal development phase must be carried out within a period not exceeding ten working days. If there are reasons that require a longer term, due to their complexity, the investigating committee may agree to extend this term without, in any case, exceeding another three more working days.



2.2.5. The resolution of the harassment file


The management of ECOCASTULUM, SL, once the conclusions of the investigating committee have been received, will adopt the decisions it deems appropriate within a period of 3 working days, being the only one qualified to decide on the matter. The decision adopted will be communicated in writing to the victim, the person denounced and the investigating commission, who must keep confidentiality regarding the information to which they have access.


Likewise, the decision finally adopted in the file will also be communicated to the monitoring commission of the equality plan and to the person responsible for occupational risk prevention. In these communications, in order to guarantee confidentiality, no personal data will be given and the numerical codes assigned to each of the parties involved in the file will be used.


Based on these previous results, the management of ECOCASTULUM, SL, will proceed to:


  1. Archive the proceedings, drawing up minutes in this regard.
  2. adopt as many measures as it deems appropriate based on the suggestions made by the commission investigating the harassment procedure. By way of example, the following can be mentioned among the decisions that the company can adopt in this regard:
  3. physically separate the alleged aggressor from the victim, through a change of position and/or shift or schedule. In no case will the victim of harassment be forced to change their position, hours or location within the company.
  4. Without prejudice to what is established in the previous point, if applicable, and based on the results of the investigation, the aggressor will be sanctioned by applying the table of infractions and sanctions provided for in the collective agreement applicable to the company or, in its case, in article 54 ET.


Among the sanctions to be considered to apply to the aggressor, the following will be taken into account:


  1. the transfer, displacement, change of position, day or location;
  2. suspension of employment and salary;
  3. the temporary limitation to ascend;
  4. disciplinary dismissal.


In the event that the sanction to the aggressor is not the extinction of the contractual link, the management of ECOCASTULUM, SL, will maintain an active duty of vigilance with respect to that worker when he reincorporates (if it is a suspension), or in his new job in case of a change of location. But always and in any case, the fulfillment of eradicating harassment will not end with the mere adoption of the change of position measure or with the mere suspension, its subsequent monitoring and control being necessary by the company.


The management of ECOCASTULUM, SL, will adopt the necessary preventive measures to prevent the situation from happening again, will reinforce the training and awareness actions and will carry out actions to protect the safety and health of the victim, among others, the following:




2.2.6. Tracing


OR Once the file is closed, and within a period not exceeding thirty days s natural, the investigating commission will be obliged to follow up on the agreements adopted, that is, on their compliance and/or result of the measures adopted. From the result of this follow-up, the appropriate record will be drawn up that will include the measures to be adopted in the event that the events causing the procedure continue to occur and it will also be analyzed if the proposed preventive and sanctioning measures have been implemented. The minutes will be sent to the management of the company, to the legal and/or union representation of the workers, to the person responsible for occupational risk prevention and to the monitoring commission of the equality plan, with the precautions indicated in the procedure. regarding the confidentiality of the personal data of the affected parties.



3. DURATION, OBLIGATION OF COMPLIANCE AND ENTRY INTO FORCE


The content of this protocol is mandatory, entering into force on the date provided in the equality plan of ECOCASTULUM, SL, on January 3, 2022 or failing that, from its communication to the company's staff, through its publication on the company website [4] , remaining in force for four (4) years.


Likewise, the protocol will be reviewed in the cases and deadlines determined in the equality plan in which it will be integrated once it is prepared.



This procedure does not impede the victim's right to file a complaint, at any time, with the Labor and Social Security Inspection, as well as with the civil, labor or criminal courts.



4. COMPLAINT OR COMPLAINT MODEL IN THE COMPANY ECOCASTULUM, SL


I. Person reporting the facts


II. Data of the person who has suffered the harassment


Name:

Surnames:

ID:

Position:

Type of contract/Employment relationship:

Phone:

E-mail:

Domicile for the purpose of notifications:

III. Data of the aggressor


Name and surname:

Professional group/category or position:

Workplace:

Company name:

IV. Description of the facts


Include an account of the reported facts, attaching the numbered pages that are necessary, including dates on which the facts took place whenever possible :

V. Witnesses and/or evidence


If there are witnesses, indicate their names and surnames:

Attach any means of proof that you consider appropriate (indicate which ones):

V. Application


The complaint or denunciation of harassment (INDICATE IF IT IS SEXUAL OR BY REASON OF SEX) is considered filed against (IDENTIFY PERSON OF THE AGGRESSOR) and the procedure established in the protocol is initiated:

Location and date :


Signature of the person concerned :

To the attention of the Investigative Commission of the complaint procedure against sexual and/or gender harassment in the company ECOCASTULUM, SL




[one] In order to preserve confidentiality, it is recommended that the investigating commission be made up of 3 people, with a maximum of 5 if necessary, and among its members is the person in charge of the company or person in charge of human resources, representative/s of the workers, an equality technician from the company and/or an occupational risk prevention technician. For their appointment, their training and/or experience in matters of equality between women and men and specifically in sexual and gender-based harassment will be preferably taken into account, and it is also recommended that these people be known by all company personnel and/or or the organization. In companies in which there is legal representation of the workers, the representation of the company and that of the workers will participate equally in the investigative committee.


[2] This person will form part of the protocol's investigative committee.


[3] The investigation must be fast, confidential and based on the principles of contradiction and orality. Any complaint, denunciation or claim that is raised will have a presumption of truthfulness.

[4] It may be through email, publication on the company's intranet, publication on the bulletin board or in writing or any other means that serves for said purpose.

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