Directive on protection against discrimination, sexual harassment, bullying and abuse on

workplace DONGWON SK, s.r.o.


(1) Discrimination, harassment, bullying and other forms of abuse represent a serious problem for organizations, companies or movements. The action has now significantly ended, especially for the affected person, but they also damage the organization internally (disrupting internal relations) as well as externally (the performance and motivation of the affected individuals and thus the entire organization decreases, while disclosure occurs mainly against the good name of the entire organization).

(2) For this reason, it is necessary to take measures with the aim of eliminating discrimination, harassment, bullying and abuse, regardless of whether it is labor law, commercial law, relations of superiority and subordination, or relations at the collegial level.

This is the only way to ensure a positive atmosphere in the entire organization and thus improve work results and the work of all people.

(3) Considering that cases of discrimination, harassment, bullying and abuse in many cases occur in a hidden form and the persons concerned are often afraid to report suspicions of such conduct, each organization should adopt a guideline aimed at ensuring that:

a) to retrospectively identify the potentially affected persons listed;

b) they are not afraid to report these negative phenomena;

c) cases of suspicion were independently investigated and

d) in the case of their confirmation, measures were taken to remove and sanction them.

(4) In order to fulfill the goals and tasks of DONGWON SK, s.r.o. this Directive is accepted as a document expressing the commitment of DONGWON SK, s.r.o. to protect its employees, volunteers and other persons who cooperate with the foundation in the workplace.

DONGWON SK, s.r.o., Továrenská 1, 018 41 Dubnica nad Váhom

(5) Amendments to the generally binding legal regulations of the Slovak Republic and international treaties to which the Slovak Republic is bound take precedence over this report.


Purpose of the directive

(1) This directive aims to ensure high standards of protection against discrimination, sexual harassment, bullying and abuse in the workplace at DONGWON SK, s.r.o.

(2) The policy of DONGWON SK, s.r.o. a workplace without similar phenomena is supported. Every individual has the right to work in a professional environment that promotes equal opportunity and demonstrates discriminatory practices, including sexual harassment.

(3) In DONGWON SK, s.r.o. possible discrimination, bullying, sexual harassment, whether verbal or physical, is not acceptable and will not be tolerated under any circumstances.

(4) This directive regulates the basic features, forms and manifestations of discrimination, sexual harassment, abuse and bullying and the possibilities of preventive action and subsequent resolution of the mentioned negative phenomena, primarily through internal means based on a report submitted by an authorized reporter.

(5) The aim of this directive is, given the seriousness of the mentioned negative phenomena, to provide basic information to all potentially affected persons about the forms of their manifestations, proposals for solutions, methods of their preventive prevention and about the need for notification and cooperation in solving the mentioned problems.

(6) The directive regulates the recommended prevention and the recommended procedure for:

(a) giving notices;

(b) checking notifications and related authorizations of the responsible person;

(c) maintaining the confidentiality of the whistleblower's identity;

(d) recording notices;

(e) informing the notifier of the result of the verification of his notification;

(f) processing of personal data specified in the notification.

(7) These principles apply to all employees of DONGWON SK, s.r.o..

DONGWON SK, s.r.o. will not tolerate or allow sexual harassment, whether it involves co-workers, superiors, volunteers, external persons or other employees who work with DONGWON SK, s.r.o. DONGWON SK, s.r.o. recommends reporting all cases of sexual harassment regardless of who the perpetrator may be.

(8) All workers are responsible for excluding all forms of sexual harassment, discrimination, bullying. Any management personnel (foundation administrator, board of directors, managers) who are informed of sexual harassment and fail to take corrective action in accordance with this policy will be subject to disciplinary action.

(9) DONGWON SK, s.r.o. encourages individuals who believe they are being harassed to firmly and promptly inform the offender that their behavior is inappropriate and unwelcome. It also recognizes that differences in power and status between the harassed person and the perpetrator may cause the harassed person not to confront the perpetrator. In case such informal direct communication between individuals is ineffective or impossible, it is necessary to contact the HR manager of DONGWON SK, s.r.o. using the procedures below or a member of HR. DONGWON SK, s.r.o. will not punish a person who reports sexual harassment, nor will it allow any supervisor or employee to do so. Any penalty against such a person constitutes a serious violation of this policy and should be reported immediately.

(10) A whistleblower is a natural person who, in good faith, reports suspicions of discrimination, harassment, bullying or harassment to the responsible person established pursuant to this directive. The condition for any notification is that it be made in good faith, that is, that a person who, given the circumstances known to him and the knowledge he has at the time of notification, reasonably believes that the stated facts are true. If a person does not act in good faith, he is not entitled to protection. In case of doubt, the action is considered to be in good faith, until proven otherwise.



Definitions of terms

(1) For the purposes of these principles, sexual harassment is defined as unwanted sexual favors, requests for sexual favors and other verbal or physical behavior of a sexual nature, especially when:

(a) submission to such conduct is expressly or impliedly a condition of the individual's employment, promotion, salary increase or other benefit; (b) the individual's compliance with or rejection of such conduct is used as a basis for employment decisions affecting the individual;

(c) the purpose or effect of such conduct is to unduly interfere with the individual's work performance or to create an intimidating, hostile or offensive work environment.

(2) Examples of sexual harassment include, but are not limited to: unwanted sexual practices; soliciting sexual favors in exchange for favorable treatment or additional employment; repeated sexual jokes; flirting; verbal abuse of a sexual nature; graphic, verbal commentary about an individual's body, sexual prowess or sexual deficiencies; whistling, touching or pinching; suggestive, offensive or obscene comments or gestures of a sexual nature; and displaying sexually suggestive objects or images in the workplace.

(3) According to the Slovak legal system and for the purpose of this directive, discrimination is understood as action contrary to the principle of equal treatment established for the field of labor relations by the Labor Code (Act No. 311/2001 Coll. Labor Code as amended) and the special Act on equal treatment in some areas and on protection against discrimination and on the amendment of certain laws (Act No. 365/2004 Coll. as amended).

(4) Discrimination is primarily, but not exclusively, direct or indirect, aggressive or subtle, violation of the right to equal treatment, and other rights of persons that belong to every human being regardless of gender, religion or belief, race, nationality or ethnic group, disability, age, sexual orientation, marital and family status, skin color, language, political or other opinion, national or social origin, property, gender or other status, or due to reporting criminal or other anti-social activity.

(5) Discrimination manifests itself mainly, but not exclusively, as direct or indirect discrimination, while:

(a) direct discrimination is an act or omission in which a person is treated less favorably than another person in a comparable situation is, has been or could be treated;

(b) indirect discrimination is an outwardly neutral regulation, decision, instruction or practice that puts a person at a disadvantage compared to another person. There is no question of indirect discrimination if such a regulation, decision, instruction or practice is objectively justified by the pursuit of a legitimate interest and is adequate and necessary to achieve such an interest

(6) For the purpose of this directive, bullying means:(a) akýkoľvek incident, počas ktorého dôjde k zneužívaniu, ohrozeniu alebo napadnutiu osoby, a to za okolností súvisiacich s jej činnosťou;

(b) harassing, insulting and excluding from the collective or negatively influencing the work tasks of a certain person;

(c) collective bullying of a selected person with the aim of psychologically harassing him;

(d) repeated abuse or sabotage of a person's activity by other persons so that they cannot complete it, verbal abuse, threats, intimidation or humiliation;

(e) psychological violence, which may include aggressive behavior or harassment with the aim of harming a person, but also less open, even subtle, non-verbal, indirect, and even hidden forms of psychological harassment, coercion, exclusion, insults, slander, name-calling, belittling, trampling , intimidation, including unjustified punishment, as well as incitement to such actions.

(7) The essence of bullying is mainly:

(a) intent to harm another physically or mentally;

(b) aggression of one person or group of persons against another person or persons;

(c) dominance of the aggressor or group of aggressors over the victim.

(8) Bullying can manifest itself:

(a) in a direct form, especially by physical attacks, insults, swearing, mockery, ridicule, orders of the aggressor to do a certain thing against the will of the victim, theft of things, threats, intimidation, blackmail, misuse of personal data, photos, spreading of false information or cyberbullying, or

(b) in an indirect form, in particular by overlooking, ignoring, intentionally setting them apart from the collective or involuntarily exposing them to aggressive situations.

(9) Bullying does not have to be carried out only by a superior against a subordinate, but can also be carried out by a subordinate against a superior or between persons who are not in a relationship of superiority and subordination.

(10) Cyberbullying is a direct form of bullying, which involves the misuse of information and communication technologies (especially telephone, tablet, internet and social networks) to intentionally threaten, harm or intimidate, while it often occurs in connection with other forms of bullying.

Prevention of discrimination, harassment, bullying and abuse as part of effective prevention, it is particularly important to:

(a) create a positive climate in the company environment

(b) clearly define the possibilities to report even the seeds of intentional violence (while maintaining the confidentiality of such reports);

(c) keep written records of the resolution of specific cases of intentional violence;

(d) familiarize potential data subjects with the system for reporting and investigating intentional violence;

(e) raise awareness in this area;

(f) inform potential data subjects what to do if they become aware of intentional violence;

(g) provide education in the field of prevention of intentional violence;

(h) cooperate with experts from the relevant field, or other specialist workplaces of advisory and preventive services.


Procedure for reporting incidents

  1. Notification of an alleged violation of these principles should be immediately sent in writing to the HR manager of DONGWON SK, s.r.o.. If the alleged perpetrator is to be the HR manager, then the notification shall be made to the CEO of DONGWON SK, s.r.o. or to another member, or to another manager of DONGWON SK, s.r.o..

(2) The investigation of the alleged harassment will be conducted confidentially in order to protect the privacy of the persons involved. Throughout the investigation process, confidentiality is maintained to the extent practical and reasonable under the circumstances. During the investigation, the director (or board chair/manager) will try to take into account the wishes of the whistleblower, but will investigate the matter thoroughly in the circumstances. The alleged offender will be informed of the report and given the opportunity to comment, answer questions and call witnesses. The director or manager informs the whistleblower of the status of the investigation. Upon completion of the investigation of the sexual harassment complaint, the director or manager will recommend appropriate action to be taken. If the director or manager determines that harassment has occurred, appropriate disciplinary action will be taken against the offender as outlined below. The complainant will be informed about the disciplinary measures taken.

(3) If harassment cannot be proven, this finding will be communicated to the whistleblower in an appropriately sensitive manner. The whistleblower can provide additional evidence for the investigation at any time.

(4) If any party directly involved in an investigation into sexual harassment, abuse, discrimination or bullying is dissatisfied with the outcome or resolution, that person has the right to appeal the decision. The dissatisfied party should submit written comments to the HR manager in a timely manner.

(5) The conditions of employment of the whistleblower and witnesses will not be adversely affected by the use of this procedure, subject to paragraph 7 below.

(6) Individuals who are found to have committed any of the acts of sexual harassment, abuse, bullying or discrimination will be subject to disciplinary action. Relevant sanctions may include a written warning, termination of employment, if the action fulfills the elements of a criminal offense or misdemeanor, the action will be reported to the competent authority.

(7) If the investigation results in the finding that the whistleblower knowingly or maliciously falsely accused another person of sexual harassment, abuse, bullying or discrimination, an appropriate sanction will be imposed against him, including the possibility of termination of employment.