Heritage Malta is committed to provide a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore, Heritage Malta expects that all relationships among persons will be free of explicit bias, prejudice and harassment.
Heritage Malta has developed this policy to ensure that all its employees can work in an environment free from unlawful harassment, discrimination and retaliation. The Agency will make every reasonable effort to ensure that all concerned are familiar with these policies and are aware that any complaint in violation of such policies will be investigated as stipulated in the Discipline Code of the Agency`s Collective Agreement.
Any employee who has any questions, queries or concerns about these policies should liaise with the Manager (Human Resources).
This policy should not, and may not, be used as a basis for excluding or separating individuals of a particular gender, or any other protected characteristic, from participating in business or workrelated social activities or discussions. In other words, no one should make the mistake of engaging in discrimination or exclusion to avoid allegations of harassment. This policy prohibits disparate treatment based on sex or any other protected characteristic, concerning terms, conditions, privileges and perquisites of employment. The prohibitions against harassment, discrimination and retaliation are intended to complement and further those policies, not to form
the basis of an exception to them.
Equal employment opportunity
It is the policy of Heritage Malta to ensure equal employment opportunity without discrimination or harassment based on race, colour, religion, sex, sexual orientation, gender identity or expression, age, disability, marital status, citizenship, national origin, genetic information, or any other characteristic protected by law. Heritage Malta prohibits any such discrimination or harassment
The Agency encourages reporting of all perceived incidents of discrimination or harassment. It is the policy of Heritage Malta to promptly and thoroughly investigate such reports. The Agency prohibits retaliation against any individual who reports discrimination or harassment or participates in an investigation of such reports.
Sexual harassment constitutes discrimination and is illegal under the laws of Malta. For this policy, “sexual harassment” is defined, as unwelcome sexual advances, requests for sexual favours and other verbal or physical conduct of a sexual nature when, for example, a) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment, b) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or c) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.
Sexual harassment may include a range of subtle and not-so-subtle behaviours and may involve individuals of the same or different gender. Depending on the circumstances, these behaviours may include unwanted sexual advances or requests for sexual favours; sexual jokes and innuendo; verbal abuse of a sexual nature; commentary about an individual’s body, sexual prowess or sexual deficiencies; leering, whistling or touching; insulting or obscene comments or gestures; display in the workplace of sexually suggestive objects or pictures; and other physical, verbal or visual conduct of a sexual nature.
Harassment based on any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal, written or physical conduct that denigrates or shows hostility or aversion toward an individual because of his or her race, colour, religion, sex, sexual orientation, gender identity or expression, national origin, age, disability, marital status, citizenship, genetic information, or any other characteristic protected by law, or that of his or her relatives, friends or associates, and that: a) has the purpose or effect of creating an intimidating, hostile or offensive work environment, b) has the purpose or effect of unreasonably interfering with an individual’s work performance or c) otherwise adversely affects an individual’s employment opportunities.
Harassing conduct includes epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion toward an individual or group that is placed on walls or elsewhere on the employer’s premises or circulated in the workplace, on company time or using company equipment by email, phone (including voice messages), text messages, social networking sites or other means.
Individuals and conduct covered
This policy applies to all applicants and employees, whether related to conduct engaged in by fellow employees or by someone not directly connected to Heritage Malta (e.g., an outside vendor, customers and contractors including their employees).
Conduct prohibited by these policies is unacceptable in the workplace and any work-related setting outside the workplace, such as during business trips, business meetings and businessrelated social events.
Reporting an incident of harassment, discrimination or retaliation
The Agency encourages reporting of all perceived incidents of discrimination, harassment or retaliation, regardless of the offender’s identity or position. Individuals who believe that they have been the victim of such conduct should discuss their concerns with their immediate supervisor, the Manager (Human Resources) or the Chief Executive Officer. In addition, the Agency encourages individuals who believe they are being subjected to such
conduct to promptly advise the offender that his or her behaviour is unwelcome and to request that it be discontinued. Often this action alone will resolve the problem. Heritage Malta recognizes, however, that an individual may prefer to pursue the matter through complaint procedures
Heritage Malta encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken. Early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment. Any reported allegations of harassment, discrimination or retaliation will be investigated promptly; the procedure is outlined in the Discipline Code of the Agency’s Collective Agreement.
The Agency will maintain confidentiality throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action. The Agency shall keep records of all employees in line with GDPR.
Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of a claim of harassment or discrimination is a serious violation of this policy and, like harassment or discrimination itself, will be subject to disciplinary action. Acts of retaliation should be reported immediately and will be promptly investigated and addressed.
False and malicious complaints of harassment, discrimination or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) may be the subject of appropriate disciplinary action.
Communicating the Policy
This policy is explained to all employees as part of the Induction Meeting. This policy is uploaded on the Agency’s Intranet and will be accessible to all employees.