ANTI-HARASSMENT, DISCRIMINATION, VICTIMISATION AND BULLYING POLICY

1. Introduction
Pathe Productions Limited (“Pathe” which expression shall include any associated and affiliated
companies including any special purpose company incorporated for one of Pathe’s productions) is
proud of its reputation and works with some of the most exceptional talent in the film and television
industries. Pathe’s reputation is dependent on a diverse range of people who contribute to our success.
Core to our values is the commitment to ensuring that everybody who works for and with Pathe and is
associated with Pathe, in any location, can be confident that they will experience an environment
which is collaborative and respectful and not threatening or intimidating. All of us have a responsibility
to treat each other with dignity and respect and consequently, Pathe will not tolerate harassment or
bullying in any form.
This Harassment, Discrimination, Victimisation and Bullying Policy (“Policy”) applies to Pathe’s employees
and all parties engaged on Pathe’s productions and who work with Pathe in any capacity (eg: actors,
heads of department, self-employed freelancers, sub-contractors, agency workers, etc) and under this
Policy, everybody will be treated equally regardless of seniority or the contract type under which they
have been employed or engaged. This Policy does not have contractual effect and is provided for
guidance only and should be read in conjunction with Pathe’s Equality and Diversity Policy.
This Policy is a general statement of the principles which Pathe will apply in relation to allegations of
harassment, discrimination, victimisation or bullying - however, each case will be considered on its own
merits. Pathe expects everyone who works with and for Pathe, and/or is associated with Pathe to be
familiar with its content, to comply with its principles and to be prepared to speak out if any such party
experiences or witnesses behaviour which is not consistent with the Policy and its principles.
2. Concepts
All workers have the right to a working environment free from all forms of harassment, discrimination,
victimisation or bullying. Pathe will not permit or condone any form of such behaviour and is committed
to providing a workplace free from unlawful behaviour. Pathe will investigate all complaints of
harassment, discrimination, victimisation and/or bullying.
For the purposes of this Policy:
(a) “Discrimination” will be considered conduct which, intentionally or unintentionally, amounts to
less favourable treatment of the recipient and which is based on their gender (including gender
reassignment), sexual orientation, marital or civil partner status, pregnancy or maternity, race (to include
colour, nationality (including citizenship), national or ethnic origin), religion or belief, disability or age or
other discriminatory ground.
(b) “Harassment” will be considered unwanted conduct which is related to a protected
characteristic of the Equality Act 2010 (age, sex, disability, gender reassignment, marriage and civil
partnership, pregnancy and maternity, race, religion or belief, and sexual orientation), which has the
purpose or effect of violating a person’s dignity, or creating for that person an intimidating, hostile,
degrading, humiliating or offensive environment.
(c) “Victimisation” will be considered conduct where a person is treated less favourably or
subjecting them to a detriment because they have: (i) brought proceedings for discrimination on any
grounds; (ii) given evidence or information in connection with any such proceedings; (iii) otherwise done
anything in relation to the discrimination; or (iv) made allegations in good faith of unlawful discrimination
or harassment on any grounds.
(d) “Bullying” will be considered any offensive, intimidating, malicious or insulting behaviour, an
abuse or misuse of power through means that undermine, humiliate, denigrate or injure the recipient. It
may be a pattern of behaviour rather than isolated instances, involving negative behaviour targeted
at an individual, or individuals, repeatedly and persistently over time.
The terms above are useful categories within which to understand certain types of behaviour, but are
not exhaustive and behaviour which contravenes any one of the categories above may also
contravene others (and may, in addition, be unlawful).
3. Responsibility for Conduct
All parties are responsible for ensuring that their conduct towards their colleagues and third parties is
not open to misinterpretation. Pathe will not accept the argument that "it was only a bit of fun" or similar
defences to allegations of harassment, discrimination, victimisation or bullying.
4. Procedures
Pathe has in place for its employees (and will implement on its productions) informal and formal
procedures to deal with any allegations of harassment, discrimination, victimisation or bullying.
5. Confidentiality
All complaints of harassment, discrimination, victimisation or bullying can be made to Pathe in strictest
confidence. If any party alleging such behaviour wishes to preserve their anonymity then Pathe will
attempt as far as is practicable to pursue the matter without disclosing their identity. However, in order
to enable a proper investigation of allegations to take place and in fairness to the alleged harasser,
Pathe will follow due process and allow such party to be given the opportunity to give their own version
of events (and witnesses may have to be questioned).
Anyone reporting such behaviour honestly and in good faith will be fully supported and not be subject
to any disciplinary measure, sanction or discrimination resulting from such alert.
6. Consequences
Pathe will treat harassment, discrimination, victimisation or bullying very seriously and act upon any
behaviour which it reasonably believes, after a proper investigation, to be harassment, discrimination,
victimisation or bullying. The same applies to anyone making untrue allegations of harassment,
discrimination, victimisation or bullying in bad faith.
As with all Pathe’s policies, this Policy will be reviewed and updated and amended from time to time to
comply with any applicable laws and best practice.