Sexual Harassment, Assault and Discrimination Policy

Sexual Harassment, Assault and Discrimination Policy

Statement of Principles

Garanti BBVA is committed to human rights, the dignity of all people, physical and psychological integrity, the right to honor, privacy and self-image, and the right not to be subject to degrading treatment.

All Garanti BBVA workers must behave in a way that respects all laws and regulations. Through this protocol, the Bank declares that no type of action or conduct representing workplace harassment, in whatever form, will be tolerated, irrespective of the victim or the perpetrator. It undertakes to collaborate proactively, effectively and firmly to prevent, detect, correct and punish any type of conduct constituting harassment, cyberbullying or online harassment through social networks, as many of the behaviors constituting harassment occur in the digital field or through unauthorized processing of personal data in the current work and technological environment.

To achieve this commitment, each and every one of the people who make up Garanti BBVA, especially those with responsibilities for teams, must contribute to eradicating such reprehensible behavior, through prevention, condemnation and zero tolerance, assuming the following responsibilities:

• To treat all people with whom they have relationships for work reasons (colleagues and collaborators, suppliers, customers, external partners, etc.) with respect for their dignity and basic rights.
• To avoid behavior, attitudes and actions that are or may be offensive, humiliating, degrading, annoying or hostile.
• To act appropriately in the face of such behavior, attitudes and actions: not ignoring them and not tolerating them, expressing their opposition, preventing them from being repeated or aggravated, reporting them to the appropriate officers and supporting the people who suffer them.

The workers' representatives undertake to prevent workplace harassment by raising workers' awareness of it and informing the company's management of conduct or behavior of which they become aware that could promote it. In addition to this commitment, it supports its employees in the fight against sexual harassment, assault and discrimination in the workplace with mandatory digital training and communication solutions.

Purpose and Target Group

This practical guide aims to create an environment free from any type of harassment and assault or discrimination based upon gender, sexual orientation, gender identity or any other reason and to specify procedures and principles of such environment.

Garanti BBVA is committed to providing a healthy environment for all its employees.

Exposure to non-consensual behavior of a sexual nature and violence may have negative impact on employee’s both private and work life, emotional and physical health and produce traumatic impact. Harassment and assault is not only a violation of human rights but also a criminal offence.

Through this guide, Garanti BBVA employees accepts and understand that Garanti BBVA will not tolerate harassment under any circumstances.

This guide/policy aims to

• Help to create a sexual harassment and assault free and safe environment that is based on mutual respect and trust in Garanti BBVA, 
• Inform Garanti BBVA employees about harassment, prevent and eliminate any kind of assault,
• Make an effort to eliminate sexist culture,
• Raise awareness regarding gender mainstreaming and prevention of all kind of discrimination and violation based upon gender, sexual orientation and gender identity,
• Establish an efficient mechanism to deal with sexual harassment or assault complaints,
• Support the complainant when a sexual harassment or assault complaint is received,
• Protect complainants, encourage them to report any incident that they have gone or are going through or witnessed in order to stop unwelcome conducts of a sexual nature.

This guide/policy constitutes a reference book for those who want to get information on any type of harassment and assault, think that they are harassed or witnessed such incident.

Garanti BBVA assures that harassment and assault will not be tolerated or ignored under any circumstances and is committed to encourage those employees who think that they are harassed/assaulted or witnessed such incident to take necessary actions. Reporting and complaints are made on a voluntary basis.

Garanti BBVA is committed to maintain confidentiality in all complaints in a way to protect employees’ privacy.

Legal Framework:

This guide has been prepared based on Council of Europe Convention on preventing and combating violence against women and domestic violence1, The United Nations Committee on the Elimination of Discrimination against Women (CEDAW), The United Nations Global Compact2 as well as The Constitution of the Republic of Turkey, Turkish Penal Code, Turkish Labor Law, Occupational Health and Safety Law, Turkish Code of Obligations and Garanti BBVA Code of Conduct3.

Violation of this guide will lead to termination of employment/contractual relationship, legal proceeding and disciplinary action in accordance with applicable labor law and legal obligations.

Definitions of Workplace Harrasment

Harassment refers to any visual/verbal or physical behavior, whether forcible or non-forcible, that humiliates and offends an individual or individuals because of their race, ethnic origin, sexual preference, gender or personal characteristics.

Examples of behaviors that might constitute workplace harassment if they occur systematically include:

• Excluding or ignoring someone.
• Leaving a worker with no effective work or incommunicado continuously, without any reason that justifies this.
• Assigning tasks that are impossible to fulfill or assigning people to tasks that are useless or have no productive value 
• Retaliatory actions against workers who have made complaints, denunciations or claims against the organization, or against those who have collaborated with such claimants.
• Repeatedly insulting or belittling a worker.
• Repeated derogatory criticism of the work done in front of other people.
• Publication or dissemination of derogatory comments and jokes that are offensive or belittle the professional worth of a worker, using instant messaging services or social networks.
• Sending degrading messages or comments using instant messaging services or social networks.
• Use or dissemination of images, photographs or videos that are intended to undermine the dignity of a person and create a humiliating or hostile environment, by any means, including digital channels (especially social networks, apps and instant messaging services).
• Spreading insults or false rumors about someone's work or private life, whether orally or using instant messaging services or social networks.
• Recording degrading images that affect the privacy of workers.
• Unauthorized processing of personal data of any type to deliberately create a hostile working environment for the worker.

Definition of harassment based on sexual orientation or gender identity

Harassment based on sexual orientation or gender identity is any behavior based on a person's sex, sexual orientation or gender identity, with the purpose or effect of infringing their dignity and creating an intimidating, degrading, humiliating or offensive environment.

The following are illustrative examples of behavior that may constitute cases of harassment due to sexual orientation or gender identity:

• Having sexual conversations, making sexual jokes or compliments of sexual nature or using obscene language
• Unusually persistent behavior for flirting;
• Displaying or sending pornographic materials;
• Forcing someone to have sexual contact or intercourse by threatening him/her to use or disseminate his/her audio, video recordings without his/her consent;
• Recording, sharing or disseminating recordings of a person’s sexual activity or nudity without his/her consent;
• Asking questions or spread rumors about a person’s sex life;
• Behaviors of a sexual nature accompanied by threat, blackmail or insult;
• Stalking;
• Unwelcome gestures, looks, staring;
• Sending sexually explicit messages or demands or insinuations of a sexual nature by phone, email, or social media platforms,
• Insisting on having sexual intercourse.

Measures to be taken in case of harassment

As specified in Garanti BBVA’s Code of Conduct 1, Employees of Garanti BBVA should act with integrity and transparency in accordance with the applicable law and regulations, be prudent and professional aligned with social impacts of finance industry and maintain the trust of Garanti BBVA shareholders and customers.

Those employees of Garanti BBVA who think that they are sexually harassed or assaulted or suspect that another person is being harassed may take the following steps to report such incident:

Report the harassment to your superior, Human Resources Corporate Integrity Team or your HR Business Consultant.

For any reason, if you think that this option is not suitable for you or not the most appropriate way to solve the issue,

You may send an e-mail to etikbildirim@garanti.com.tr or call Garanti BBVA Integrity Hotline at +(90) 216 662 5156. For any reason, if you think that this option is not suitable for you or not the most appropriate way to solve the issue,

Compliance will deal with, examine and solve promptly and thoroughly all complaints reported in accordance with management procedures of Integrity Hotline. Complaints will be treated fairly, objectively and confidentially. Complainant’s identity will be kept confidential; it will only be revealed to those parties involved in the process during the investigation period.

Any behavior that may offend the complainant again and harm dignity and trust of the parties involved should be avoided and special attention should be paid in order to prevent such behaviors.

Accusatory and incredulous attitude, talks, insinuations which may exacerbate suffering of the victim should be avoided during support process.

Necessary measures and actions will be taken and communicated to concerned parties in accordance with the Bank Disciplinary Committee/Rules once the investigation is completed.

The matter may be forwarded to the Disciplinary Board for the necessary evaluation and implementation of administrative sanctions against those responsible for any kind of illtreatment, discrimination or harassment, as well as actions to conceal such behavior. The Disciplinary Board may decide to impose administrative sanctions (written warning, censure, termination etc.) depending on the nature and severity of the faulty action and the direct or indirect role of the personnel who caused the action.. As a result of the investigation, necessary precautions are taken in accordance with the Bank Disciplinary Board/Rules and shared with the parties.

Frequently Asked Questions

1. How do I know that a behavior, joke or speech qualifies as harassment? To consider following aspects may give you a clue in order to find out if it is a harassment or not:

• Is such relationship appropriate in the workplace?
• Would other employees find acceptable such behavior? In other words, how would those people whom you respect react? • Would I be embarrassed if my family and friends witness my behavior?
• Would I feel uncomfortable if someone I know has been exposed to such behaviors?
• Is this situation can be misconceived by others?
• Do I ignore and pretend not to see explicit or implicit negative reactions of those around me?

2. What can a person do if he/she realizes that his/her behavior disturb others?

• He/she may apologize as soon as he/she realizes that his/her behavior is improper.
• He/she avoids consciously such behaviors.
• He/she does not ignore the incident or underestimates the importance of the incident.
• He/she does not follow others’ advice to ignore the incident or underestimate the importance of the incident.
• If there is a hierarchical relationship between, if possible, the superior transfers to another person all his/her responsibilities related with the other person.

3. What can a person do if he/she thinks that he/she is sexually harassed?

• A person who feels that he/she is being sexually harassed must know that he/she is not and will not left alone.
• If he/she chooses to have a direct conversation with the other person, this conversation needs to have a clear and consistent message.
• Sharing the incident with someone he/she trusts will help to eliminate misunderstandings and take necessary steps. 
• It is preferable to react directly instead of evading incident by using an ineffective and evasive method. For example; instead of “Thank you for inviting me to dinner but I am busy on Monday”, you may say “Thank you but I only go on a date with colleagues that I have an equal relationship”
• He/she may ask for support by following the steps specified in Garanti BBVA’s Practical Guide on Prevention of Sexual Harassment and Discrimination.