NORDISK FILM’s POLICY – NON-HARASSMENT AND NON-DISCRIMINATION

PURPOSE OF THE POLICY

The purpose of this policy is to secure and maintain a healthy, trustful, and safe work environment for all employees and partners working for Nordisk Film. The policy is a supplement to our Code of Conduct, Business Ethics and Whistleblowing Policies.

NORDISK FILM’S POSITION ON OFFENSIVE ACTIONS

Nordisk Film stands for honesty and responsibility.

At Nordisk Film workplace interaction takes place in a professional and respectful way. We share knowledge, listen to each other, and show helpfulness. We communicate openly and with trust in each other. Therefore, we expect all employees, managers, and partners to comply with this policy as it is a prerequisite for well-functioning collaboration and a safe workplace. Nordisk Film does not accept any form of offensive behavior or actions, including harassment, bullying or persecution.

Nordisk Film wants to actively prevent offensive behavior in the best possible way to ensure that each employee and partner can carry out his/her work in a safe, secure and healthy way. We all share the responsibility of maintaining and developing a culture with norms and values that actively prevent offensive behavior and actions.

WHEN IS AN ACTION OFFENSIVE?

An action is offensive when one or more individuals grossly or several times expose one or more other INDIVIDUAL to harassment, sexual harassment, or other humiliating behavior during work. Professional leadership, management, and feedback from one colleague to another may not in itself be considered an offensive action.

An offensive action must be perceived as such by the person/persons exposed, which is why it is the experience of the individual exposed to it that constitutes the basis of the offensive action.

Offensive actions can be both active and passive and may include:

• Slander and exclusion from social life and/or professional communities
• Attacks on or criticism of a person’s private life, for instance due to life values
• Being yelled at, ridiculed, or being exposed to unpleasant teasing.
• Physical abuse or threats thereof
• Hostility or silence in response to questions or attempts at communicating.
• Downgrading of a person’s job, work effort or competencies
• Offensive written messages, SMS’s, photos and videos, including on social media.
• Discrimination due to e.g. age, gender, identity, sexual orientation, color of skin, religion, political belief, disability or ethnic origin.

Sexual harassment exists when unwanted verbal, non-verbal or physical behavior with sexual undertones is exercised with the purpose of or the effect that a person’s integrity is violated and/or intimidated.

Sexual harassment may for instance be:

• Unwanted verbal encouragements to sexual activity
• Sexual jokes and comments
• Non-relevant discussion of sexual topics
• Unwanted touching
• Showing and sharing of pornographic material

Offensive actions or sexual harassment – as described above – may be committed by either employees, managers and partners and may take place both during work hours as well as outside work hours, for instance in connection with work related events/celebrations/parties.

Offensive actions or sexual harassment committed by a manager, an employee, or an external partner with a trusted or visible position will often be experienced particularly stressful by the exposed. This is typically due to the power in the senior position, just as he/she will typically be a role model for young or new colleagues.

The higher and more powerful position an individual has, formal and informal, the more ethically correct such person is expected to act. This applies especially towards children and younger individuals.

WHO HAS A RESPONSIBILITY?

It is the responsibility of the management to secure and support a good physical and mental work environment at Nordisk Film.

If you personally experience an offensive action, you should, if possible, object and tell the person to stop in the situation or shortly after to stop the unwanted action. If this is not possible you should involve your leader, see below.

If you experience that a colleague or a partner is being exposed to an offensive action, you should, if possible, interact and support the target of the offensive action. Collegial support is important to help the person/individual being exposed. It is equally important not to contribute negatively to the offensive behavior, by for instance laughing or staying passive.

WHO SHOULD YOU GO TO?

If you have experienced offensive behavior or witnessed others being exposed to offensive behavior you must inform your leader. If your leader is the offender, you must contact your leader’s superior. If your Managing Director or Finance Director is involved, you must contact your Division Director or the HR Director.

If you experience an offensive action from external partners, such as suppliers, temporary project assigned or creative staff on a film crew, you must immediately say no/stop and notify the nearest manager/producer/responsible person about the course of events for them to follow up. You can always contact Nordisk Film’s HR team personally, write to hr@nordiskfilm.com or to your local HR contact person if you need confidential consultation and support on how to handle the experience.

Nordisk Film encourages you to put your name on the inquiry. Anonymous accusations are weaker and harder to address than non-anonymous inquiries and it will impact the way the process or sanctions can be handled.

HOW WE HANDLE INQUIRIES AND COMPLAINTS OF OFFENSIVE ACTIONS

In Nordisk Film it is HR who handles cases of offensive actions and behavior. Nordisk Film has a clear procedure for uncovering courses of events in to assess the circumstances of the matter in question. If complaints or accusations as described in this Policy arise, HR will intervene.

HR will use the following procedure for investigating the course of events:

• Initiate a dialogue with the complainant to get a thorough description of the course of events, including who, where and when the offensive action took place.
• The description of the incident is presented to the person against whom the complaint/accusation is directed to clarify his/her view of the situation.
• If necessary and possible, witnesses, if any, may be called upon to clarify if an offensive action has taken place.
• The complaint/accusation will be handled as quickly as possible whilst respecting that all parties involved (including the alleged offender) have the right to a fair and objective treatment.
• Where appropriate, mediation between the parties will be attempted. Psychological assistance may be offered during or after the investigation.
• Follow up and communication to the parties involved when the investigation is completed.

In every investigation, per above, the necessary discretion and protection of the involved parties’ dignity and private life is exercised so that no information about the matter is passed on to unauthorized persons.

WHAT ARE POSSIBLE CONSEQUENCES?

Depending on the information available in the case, the course of events and documentation, HR will assess if the offensive action is to have any consequences for the employment of the offender, such as a warning, an organizational move or dismissal with or without notice. This assessment is done together with the director of the business area.

If the person is not employed by Nordisk Film, HR assesses together with the director of the business area if the person’s action should have any contractual consequences, such as termination of contract, claim for compensation etc.

The sanction will be decided in each individual case based on the seriousness and the extent of the offensive action and based on how long it has taken place as well as any other circumstances.

False accusations about offensive actions are of course unacceptable and may also have consequences for the employment or contracts of those presenting them.

WORK ENVIRONMENT ORGANISATION

Nordisk Film makes sure that offensive actions are being investigated with appropriate involvement of the work environment organisation. In the everyday work life, the work environment groups contribute to this Policy being observed within the part of the Nordisk Film organization represented by each group.