Anti-Harassment and bullying Policy

Network Merchants, LLC and all its subsidiaries and Affiliates (herewith referred to as NMI, we, our or us) are committed to providing a working environment free from harassment and bullying and ensuring all our employees are treated, and treat others, with dignity and respect. We recognize that harassment and bullying can occur not only among employees but also from Third Parties, and we take such incidents very seriously. 

Purpose

The purpose of this Policy is to set out our commitment to preventing and addressing harassment or bullying may occur by Third Parties such as partners, merchants, vendors, suppliers, visitors to our premises, and any other Third Party involved in our operations (herewith referred to as Third Parties). 

At NMI, we maintain a strict zero-tolerance policy towards harassment or bullying. Harassment, bullying or victimization of any kind will not be tolerated and failure to uphold the dignity and respect of all NMI employees may result in corrective action. All parties are encouraged to report any incident of harassment or bullying involving NMI’s employees. To address and prevent future complaints, we will focus on constructive measures such as providing feedback to customers, collaborating with them to resolve issues, and reporting any serious concerns to the authorities. 

What is Harassment by a third party

Harassment by a Third Party is any unwanted physical, verbal or non-verbal conduct that has the purpose or effect of violating a person’s dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. A single incident can amount to harassment.

It also includes treating someone less favorably because they have submitted or refused to submit to such behavior in the past.

Unlawful harassment may involve sexual harassment (unwanted behaviour of a sexual nature), or it may be related to age, disability, gender reassignment, marital or civil partner status, pregnancy or maternity, race, colour, nationality, ethnic or national origin, religion or belief, sex or sexual orientation. Harassment is unacceptable even if it does not fall within any of these categories.

Harassment may include, but is not limited to:

1. unwanted physical conduct or “horseplay”, including touching, pinching, pushing and grabbing;
2. continued suggestions for social activity after it has been made clear that such suggestions are unwelcome;
3. sending or displaying material that is pornographic or that some people may find offensive (including emails, text messages, video clips and images sent by mobile phone or posted on the internet);
4. unwelcome sexual advances or suggestive behavior (which the harasser may perceive as harmless);
5. racist, sexist, homophobic or ageist jokes, or derogatory or stereotypical remarks about a particular ethnic or religious group or gender;
6. outing or threatening to out someone as LGBTQ+;
7. offensive emails, text messages or social media content; 
8. mocking, mimicking or belittling a person’s disability; or
9. using your position of authority to offer job benefits or promotions in exchange for sexual favors.

A person may be harassed even if they were not the intended “target”. For example, a person may be harassed by racist jokes about a different ethnic group if the jokes create an offensive environment.

A person may be harassed even if the comments or behavior was not intended to cause harm or offense (i.e. if comments were meant to be a joke).

What is Bullying by a third party

Bullying is offensive, intimidating, malicious or insulting behavior involving the misuse of power that can make a person feel vulnerable, upset, humiliated, undermined or threatened. Power does not always mean being in a position of authority, but can include both personal strength and the power to coerce through fear or intimidation.

Bullying may include physical or psychological threats, overbearing and intimidating levels of supervision or inappropriate derogatory remarks about someone’s performance. Please be aware that harassment and bullying can take place in many forms, from face to face encounters to messages via text, social media platforms or through official communication channels or chats.

Preventing Harassment & Bullying

NMI takes a proactive approach to preventing harassment and bullying and as part of those efforts we offer regular training sessions to all employees about harassment and bullying, including what it is, how to recognise it and how to report it.

What should a third party expect

When we receive a report of Third-Party harassment, NMI’s People Team will carefully initiate an investigation to understand the situation fully. This will involve gathering important information, which may include conversations with the person making the report, any witnesses, and any other individual(s) involved in the incident. We will document all findings and consider any relevant evidence.

Once the investigation is complete, we will share the findings with the appropriate parties and take any necessary actions based on the outcome. Throughout this journey, our People Team is dedicated to creating a respectful and safe workplace for everyone.

Third Parties have a responsibility to conduct themselves in a manner that respects the rights and dignity of all NMI employees. If a Third Party is found to have engaged in harassment or bullying, NMI will take appropriate corrective actions, which may include:

• Issuing a formal written warning to the individual or entity. Banning the individual or entity from our premises or events.
• Termination of contracts or business relationships.
• Reporting the behavior to law enforcement authorities if it constitutes a criminal offense.  

In cases where harassment or bullying by a Third Party leads to emotional distress or damages for our employees, NMI reserves the right to seek restitution from the offending party. This may include claims for damages related to lost wages, emotional distress, or any other applicable remedies under the law.

Retaliation against a complainant will not be tolerated and NMI will take appropriate action against anyone who subjects a complainant to retaliatory conduct. NMI will offer the necessary assistance and support to its employees to protect or enforce the complainant’s rights.

Conclusion

NMI is dedicated to maintaining a work environment free from harassment and bullying, including Third Party harassment. By following this policy and working together, we can create a safe and respectful workplace for all employees. This Policy will be reviewed at regular intervals and will be monitored for effectiveness.

For any inquiries related to the policy, or to report an incident of harassment or bullying, please email NMI’s People Team at peopleteam@nmi.com. We’re here to help and ensure you have all the information you need.