1. PURPOSE

Policy for the Prevention and Elimination of Harassment in the Workplace

PRO CONECT Group, an organization with over 550 employees, supports and promotes a working environment based on equality, respect and dignity. We are committed to preventing and eliminating all forms of discrimination in the workplace, contributing to the maintenance of a healthy, fair and inclusive professional climate.

This policy reflects the firm commitment of PRO CONECT Group to promoting equal opportunities and treatment, regardless of race, gender, age, sexual orientation, religion, disability, political opinion, social status or any other differentiating criterion.

2. SCOPE OF APPLICATION

This policy applies to:

• All employees of PRO CONECT Group (directors, managers, specialists, operators, support staff, etc.);

• Collaborators, consultants, volunteers and any other persons working on behalf of or for the company;

• Throughout the entire professional relationship cycle: recruitment, onboarding, development, evaluation, promotion, termination of employment contract.

3. REFERENCE AND RELATED DOCUMENTS

This policy is grounded in and correlated with the following legislative acts and internal documents:

3.1. Legislative documents (reference)

3.1.1. Labour Code – Law no. 53/2003, republished, with subsequent amendments and additions;

3.1.2. Law no. 202/2002 on equal opportunities and treatment for women and men;

3.1.3. Government Decision no. 262/2019 for the approval of the Methodological Norms for the implementation of Law 202/2002;

3.1.4. Government Ordinance no. 137/2000 on the prevention and sanctioning of all forms of discrimination;

3.1.5. Law no. 167/2020 on the prevention and sanctioning of moral harassment in the workplace;

3.1.6. Charter of Fundamental Rights of the European Union – Articles 21 and 23;

3.1.7. ILO Convention no. 111 concerning discrimination in respect of employment and occupation.

3.2. Internal documents (related)

3.2.1. Anti-harassment policy in the workplace – PRO CONECT Group;

3.2.2. Code of professional conduct – PRO CONECT Group;

3.2.3. Internal procedure for resolving reports regarding inappropriate behaviour (Whistleblowing);

3.2.4. Internal regulations of PRO CONECT Group;

4. Definitions

• Direct discrimination: different and unfavourable treatment of a person based on a protected criterion;

• Indirect discrimination: the application of apparently neutral practices, policies or criteria that disadvantage a particular category of persons;

• Victimisation: the sanctioning or intimidation of a person who has reported discriminatory behaviour;

• Equal opportunities: ensuring fair access to rights and opportunities, without barriers.

5. Employer Obligations

PRO CONECT Group:

• Periodically informs and trains staff on non-discrimination;

• Includes anti-discrimination clauses in internal policies and individual/collective contracts;

• Ensures mechanisms for reporting and investigating acts of discrimination;

• Does not tolerate retaliation against complainants or witnesses;

6. Reporting and Resolution Mechanisms

Any person who believes they have been subjected to discriminatory treatment may:

• Submit a written complaint to their line manager or HR;

• Contact the Equal Opportunities Officer;

Complaints will be handled confidentially, impartially and promptly. 

Internal investigations will be conducted in accordance with the specific procedure, and complainants will be protected against retaliation.

7. Disciplinary Sanctions

Depending on the severity and nature of the act, the following may be applied:

• Warnings;

• Disciplinary Sanctions;

• Reduction of benefits;

• Dismissal for serious misconduct;

• Referral to the National Council for Combating Discrimination (NCCD), where applicable;

• Request assistance through the confidential internal reporting channel (Whistleblowing) – email address etica@ops.proconect.ro;

• All complaints will be handled with maximum confidentiality and impartiality.

8. Documents Related to the Discrimination Policy

No.	Document Name	Document Type	Retention Period	Storage Location	Archiving Regime
1	Policy for the Prevention and Elimination of Discrimination	Internal Policy	Permanent	HR	Organisation archive – permanent
2	Report regarding discriminatory behaviour	Individual Document	5 years from resolution	HR	Secured archive
3	Internal Investigation Report	Internal Report	5 years	Disciplinary Committee / HR	Organisation archive
4	Sanctioning Decision Following Discrimination	Official Decision	10 years	HR / Personal File	Personal file archive
5	Acknowledgement Declarations of the Policy	Written Declaration	3 years after termination of IEC	HR / Personal File	Personal file archive
6	Minutes of the Disciplinary Committee	Official Document	5 years	HR / Legal	Organisation archive

• Confidentiality is essential: documents containing personal data or sensitive information must be kept in secure locations (physical and digital);

• Digitalisation is recommended, but GDPR regulations and the Archives Law must be observed;

• Upon expiry of the retention period, documents may only be destroyed with a formal record approved by the archive officer and the organisation management.

 9. Investigation of Complaints

The company will initiate a prompt, objective and confidential investigation. Persons accused will have the right to a defence, and any retaliation against complainants will be prohibited.

10. Duration of Application and Review

This policy is valid for an indefinite period and is reviewed annually or whenever necessary, depending on legislative changes or changes to the organisational structure.

11. Company Commitment

Our organisation has zero tolerance for harassment and is committed to protecting the rights and integrity of every employee.