(Implemented June 2018, Updated 2025)

The Gulf Centre for Human Rights (“GCHR”) is committed to providing and maintaining an inclusive, safe, and respectful environment free from sexual exploitation, abuse, discrimination, and harassment. GCHR unequivocally prohibits sexual exploitation, abuse, discrimination or harassment based on a person’s race, colour, gender identity or expression, age, disability, religion or belief, national origin, sexual orientation, ancestry, pregnancy, marital status, familial status, or any other status protected by law.

GCHR also strictly prohibits any form of retaliation, discrimination or harassment on the basis of an individual’s protected activity, such as opposing prohibited discrimination or participating in the statutory complaint process. In addition, GCHR upholds, as a matter of normal business practice, the freedom from harassment provisions of freedom from harassment and equality provisions of applicable statutes across Lebanon, Ireland, and of all other jurisdictions in which it operates (“applicable law”).

GCHR is further committed to ensuring effective prevention, prompt reporting, fair investigation, and accountability mechanisms to address any form of sexual exploitation, abuse, harassment, or discrimination in all its operations, programmes, and partnerships.

This policy applies to everyone who works at GCHR (including all board members, employees, volunteers, and consultants working for GCHR, including contract staff). In addition, for purposes of this policy, the workplace includes any place where GCHR conducts its business or activities, or where GCHR functions occur (for example, at the office, in the course of work assignments outside the office, at work-related conferences or training sessions, during work-related travel, and at social functions supervised by GCHR). It is the responsibility of everyone to whom this policy applies to ensure that their behaviour supports a workplace free from discrimination and harassment, to report any known harassment incident or allegation, and to cooperate with the conduct of related investigations.

Sexual exploitation, abuse, harassment and discrimination prohibited by this policy will not be tolerated. Any individual determined to have violated this policy will be subject to appropriate disciplinary or other action, which, in the case of an employee, may include termination of employment.

GCHR wants to create a safe workspace for everyone who works at or with GCHR. As well, GCHR is trying to build a network that includes women human rights defenders and therefore it is particularly important to ensure that all defenders feel comfortable working with GCHR, a primary goal of this policy. This policy includes sections on Safeguarding and Anti-Retaliation.

This policy is a companion to GCHR’s Diversity, Equity and Inclusion Policy.

A.           Definitions.

Harassment: Prohibited harassment under this policy consists of unwelcome verbal or physical conduct or communication either of a sexual nature or based on an individual’s protected class status that has the purpose or effect of creating an intimidating, hostile, or offensive work environment, that unreasonably interferes with an individual’s work performance. Harassment may occur as a result of one incident or a series of incidents. The behaviour does not have to be directed at a specific person for harassment to occur. Behaviour that tends to ridicule or disparage a group may give rise to a harmful work environment and thus constitutes harassment.

One specific form of prohibited harassment is sexual harassment. Sexual harassment includes unwelcome sexual advances, requests for sexual favours, sexually motivated physical contact, or other verbal or physical conduct or communication of a sexual nature when any of the following conditions are present:

1. Submission to that conduct or communication is made a term or condition, either explicitly or implicitly, of obtaining employment;

2. Submission to or rejection of that conduct or communication by an individual is used as a factor in decisions affecting that individual’s employment; or

3. Such conduct or communication has the purpose or effect of substantially interfering with an individual’s employment or creating an intimidating, hostile or offensive work environment.

4. Finally, it is especially important to be mindful that if you are in a position of power, this may increase the impact of such harassment, and therefore you must take extra care in how you communicate or interact with others.

Sexual Harassment, Assault and Abuse:

Sexual harassment can occur in a variety of situations. The following examples may constitute sexual harassment. While the examples listed below illustrate the kind of conduct prohibited by this policy, this list is not exhaustive and does not exclude complaints about other forms of sexual harassment from being reported:

1. Unwelcome verbal conduct, which may include remarks, jokes, or innuendos related to sex or sexual orientation, suggestive comments, or inappropriate inquiries into personal matters;

2. Unwelcome non-verbal conduct, which may include displaying suggestive objects, pictures, or language that imply offensive behaviours or making suggestive or insulting noises or obscene gestures;

3. Unwelcome touching, which may include pats, pinches, hugs, or any other non-consensual bodily contact;

4. Indecent exposure, stalking or sexual assault (which also constitutes sexual abuse – see below);

5. Making sexual or romantic advances toward an individual and persisting despite the individual’s rejection (expressed in any fashion) of the advances;

6. Refusing to work with people, or to extend work opportunities or other benefits, because of their sex or sexual orientation;

7. Offering or granting employment benefits or opportunities conditioned on an individual’s submission to sexual advances or sexual favours; or

8. Harassment not of a sexual nature directed against an individual due to his or her gender, including persistent unwanted attention.

Other forms of harassment:

More broadly, examples of racial harassment or harassment based on religious belief, may include, but are not limited to:

1. Comment or conduct which disparages or ridicules a person’s race, ethnic origin, colour, language or religion;

2. Insulting gestures or jokes which relate to race, ethnic origin, colour, language or religion;

3. Mimicking a person’s accent, speech or mannerisms;

4. The display or distribution (including use of electronic media) of derogatory materials which relate to race, ethnic origin, colour, language or religion; or

5. Refusing to work with people, or to extend work opportunities or other benefits, because of their race, ethnic origin, colour, language or religious background.

Harassment on other grounds, such as gender, sexual orientation, disability, age, or any other protected characteristic — may follow similar patterns and is equally prohibited

Sexual Exploitation:

Sexual exploitation refers to any actual, attempted, or threatened abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, soliciting, coercing, or otherwise obtaining sexual acts in exchange for monetary, social, or political benefit, or any other advantage.

Sexual Abuse:

Sexual abuse encompasses the actual, attempted, or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. “Sexual abuse” includes rape, sexual assault, and all sexual activity with a child. Sexual activity is physical contact of a sexual nature. “Physical intrusion” is understood to mean “sexual activity”. Sexual activity is physical contact of a sexual nature. All sexual activity with a child is sexual abuse.

Discrimination:

Any distinction, exclusion, restriction, or preference based on race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth, disability, age, sexual orientation, gender identity, or any other status, which has the purpose or effect of nullifying or impairing the recognition, enjoyment, or exercise, on an equal basis, of human rights and fundamental freedoms in any field of public or private life.

B.           Reporting Sexual Exploitation, Abuse Discrimination or Harassment.

Any individual who feels that she or he has been the victim of sexual exploitation, abuse, discrimination or harassment, or who knows of or suspects the occurrence on discrimination or harassment, is responsible promptly for immediately reporting the incident to the person she or he feels most comfortable contacting, whether the Executive Director, any member of the Advisory Board including the Chairperson, or the Finance Manager, who is responsible for human resources. It is not sufficient to report a complaint of harassment or discrimination to persons other than those designated above.

Anyone else connected to GCHR who receives a complaint, including contractors, volunteers, or partners, must remind the complainant of their responsibility to contact one of the aforementioned people above.Any supervisor or manager who fails to comply with these provisions may be subject to disciplinary action, up to and including termination of employment.

GCHR encourages the reporting of all occurrences of harassment or discrimination under the procedures set forth in this policy, and strictly prohibits retaliation taken against people making complaints or participating in investigations in good faith. (See section D below).

GCHR will announce the policy during all events and workshops, both at the beginning of the event and during the evaluation process, so that participants know whom to contact if they have a complaint.

GCHR will also ensure that reporting channels are accessible, confidential, and communicated clearly to all participants and staff, including through event materials and orientation sessions.

C.           Investigation and Action.

Upon receipt of a complaint about sexual exploitation, abuse, discrimination or harassment, GCHR will investigate and work to resolve all complaints in a fair, confidential, timely, and thorough manner. While complete confidentiality cannot be guaranteed during the course of an investigation, every attempt will be made to use confidential information sensitively and with respect for all parties involved. (See section D on No Retaliation below.)

Cooperation with any investigation is required of all employees as part of their job responsibilities. Any employee who fails to cooperate in an investigation may be subject to disciplinary action, up to and including termination of employment.

If the investigation of a reported or suspected occurrence of sexual exploitation, abuse, discrimination or harassment reveals that an individual has not engaged in any prohibited conduct, management will inform both the individual and the complaining party (if their identity is known) that an investigation has been conducted and that no evidence supports the report or suspicion.

In the event an investigation reveals evidence that sexual exploitation, abuse, discrimination or harassment has occurred, management will take whatever steps it deems necessary and appropriate to prohibit further acts of discrimination or harassment, up to and including terminating the employment of an offending employee. These steps will be determined on a case by case basis commensurate with the situation, while considering confidentiality and safety of those involved. GCHR may also seek legal redress, including attorneys’ fees and costs, against any employee or other person who causes GCHR to incur any expense or liability as a result of prohibited behaviour.

Disciplinary action, up to and including termination of employment, may also be taken against any employee who witnesses sexual exploitation, abuse, discrimination or harassment and does not report it as described above, including any manager who fails to report a complaint of sexual exploitation, abuse, discrimination or harassment or fails to take corrective action after being informed of a hostile work environment or other incident involving harassment.

Please see also GCHR’s Diversity, Equity and Inclusion Policy for the reporting mechanism for any form of abuse or harassment:

D.          No Retaliation.

GCHR is committed to maintaining an environment in which individuals feel free to report all incidents of sexual exploitation, abuse, harassment or discrimination. GCHR encourages the reporting of all occurrences of harassment or discrimination under the procedures set forth in this policy. No retaliatory action shall be tolerated against any person who, in good faith, reports conduct that they reasonably believe violates this policy. Similarly, no retaliatory action shall be taken against any individual who, in good faith, assists with, or participates in, an investigation, proceeding, or hearing related to a complaint of sexual exploitation, abuse, harassment, or discrimination.. Any person who violates these provisions may be subject to discipline, up to and including termination of employment or contract as applicable.

While a complaint is pending, the person who is the subject of the complaint has been made shall not participate in any formal or informal evaluations of the person who has made the complaint. Any attempt to do so constitutes a separate violation of this policy that may result in disciplinary action, up to and including termination of employment or contract as applicable.

Retaliation includes, but is not limited to, intimidation, threats, adverse employment actions, social exclusion, or any behavior that discourages or penalizes a person for making or supporting a complaint in good faith.

E.           Consenting Sexual or Romantic Relationships.

GCHR discourages consensual sexual or romantic relationships between employees when there is any direct or indirect reporting relationship between them. Any employee acting in a supervisory capacity who enters into such a relationship with a subordinate employee must promptly inform the Executive Director or Financial Manager of such relationship. Any employee acting in a supervisory capacity who fails to notify the Executive Director or Financial Manager may be subject to disciplinary action, up to and including termination of employment.

GCHR is fully committed to complying with all applicable laws protecting employees from discrimination based on marital, partnership and other protected relationship status, and this policy is in no way intended to interfere with, nor to be applied in violation of, such protections.

Employees are encouraged to exercise sound judgment and maintain professional boundaries at all times to avoid conflicts of interest or the appearance of favoritism.