Third-Party Harassment & Sexual Harassment Policy

Our Core Value: We Value Everyone At Boulder Developments Ltd (including our sub-brands SuperFOIL Insulation and Treefloor), people are at the heart of what we do. Every person is important to us, and we are dedicated to making that clear by providing a safe, friendly, respectful, and inclusive working environment where everyone is treated with dignity and respect.

1. Policy Statement

The Company is committed to providing a working environment free from harassment and sexual harassment. Boulder Developments Ltd does not tolerate the harassment or sexual harassment of its staff, contractors, or partners by any third party, and we strictly encourage the reporting of any concerns. We will thoroughly investigate such reports and, where appropriate, take decisive action to protect our workforce.

2. Who is a “Third Party”?

A third party is anyone who is not a direct employee or worker of Boulder Developments Ltd. In the context of our operations, this includes (but is not limited to):

3. What is Harassment?

Harassment under UK discrimination law is any unwanted conduct related to a protected characteristic—including age, disability, gender reassignment, race (colour, nationality, ethnic or national origin), religion or belief, sex, or sexual orientation—which has the purpose or effect of:

It also includes treating someone less favourably because they have submitted to, or rejected, unwanted conduct of a sexual nature, or conduct related to sex or gender reassignment in the past.

Key Principles of Harassment:

Note: Aligned with our core values, the Company also prohibits any conduct that has a similar negative impact, such as bullying, aggressive behaviour, or intimidation, even if it is not linked to a protected characteristic.

4. What is Sexual Harassment?

Sexual harassment occurs where a perpetrator engages in unwanted conduct of a sexual nature that has the purpose or effect of violating the victim’s dignity or creating an intimidating, hostile, degrading, humiliating, or offensive environment.

Examples of Unwanted Conduct of a Sexual Nature:

5. Management Action & Commercial Remedies

When a staff member reports concerns of third-party harassment or sexual harassment, Boulder Developments Ltd will act immediately, handling the matter with the utmost sensitivity and confidentiality.

Stage
Action Taken by Management
1. InvestigationHR or an appointed manager will conduct a prompt, fair, and impartial investigation. This may involve notifying and interviewing the employer or professional association of the third party.
2. ProtectionTemporary supportive adjustments (e.g., changing schedules, relocating tasks, or reallocating accounts) may be implemented to prevent further contact between parties during the process.
3. ResolutionWhere a complaint of third-party harassment is upheld, the Company will take definitive steps to address the issue and prevent it from happening again.

Potential Action Against Harassers:

Commercial and legal steps taken by the Company may include (but are not limited to):

Proactive Safeguarding: We proactively communicate our zero-tolerance policy to staff, clients, and suppliers. Clear signage is placed in public areas across our sites to actively remind all visitors of our conduct expectations. Furthermore, disclosures relating to sexual harassment are explicitly recognized as qualifying disclosures and are fully protected under our Whistleblowing Policy.

6. Reporting and Questions

If you have any questions about this policy, or if you experience or witness any form of third-party harassment, please raise it immediately with your line manager, the HR Team, or directly to our Chief Happiness Officer:

Email Support: [email protected]

Contact: Kate Bown (Chief People & Culture Officer)

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