Adopted by the EDF Executive Committee, November 2018 – Revised and changes approved by the Executive Committee November 2025.

EDF Commitment

EDF is committed to providing a safe environment for all its employees, members and attendees, free from harassment on any ground in the workplace: the workplace includes online and in person workplaces, including EDF governing body meetings, committees, events, email groups, and project activities.

EDF will operate a zero-tolerance policy for any form of harassment in the workplace, treat all complaints and incidents seriously, and promptly investigate all allegations of harassment. Any person found to have harassed another will face disciplinary action, up to and including dismissal from employment or from EDF’s membership.

Disciplinary action, for breaching this policy includes:

• Verbal warning
• Written warning
• Dismissal, in the case of grave, persistent or repeated offences
• Exclusion from EDF workplace

Points of contact

Internal

Any employee who feels they have been the victim of any form of harassment, whoever the perpetrator, has the right, and is encouraged, to lodge a complaint. This complaint can be made directly to the Executive Director. However, staff can also talk directly with their line manager, the HR manager or another trusted person. If the alleged perpetrator is the Executive Director, then the report can be made to the HR Manager, or directly to the EDF President or Secretary (from the Executive Committee).

External

Victims of any kind of harassment can get help or advice from the Harassment Unit at CESI by completing the following form, or contacting the organisation by phone (+32 2 771 00 25) or email (harcelement@cesi.be).

EDF definition of harassment

In the application of its anti-harassment policy, EDF understands harassment as all forms of behaviours with the purpose or effect to demean, humiliate, or embarass a person in the workplace, including, but not limited to, sexual harassment, bullying and cyber-bullying.

Belgian law

EDF recognises the different definitions of harassment under Belgian law.

• Moral harassment: is defined as “abusive combination of several similar or different conducts, external or internal to the company or institution, which occur over a period of time, and which have the purpose or effect of violating the personality, dignity or physical or psychological integrity of a [person] during the performance of his or her work, to jeopardize his or her employment or to create an intimidating, hostile, degrading, humiliating or offensive environment, manifested in particular by unilateral words, intimidation, acts, gestures or writings.”(art. 32ter, 2°, Law of 4 August 1996 on Well-being);
• Sexual harassment: is defined as “any form of unwanted verbal, non-verbal or physical behavior with a sexual connotation that has the purpose or effect of compromising the dignity or creating a threatening, hostile, abusive, humiliating or hurtful environment” (art. 32ter, 3°, Law of 4 August 1996 on Well-being). The gendered nature of sexual harassment, as a form of harassment affecting predominantly women, is recognised and taken into account by EDF.

EDF understands that harassment can be linked to certain factors in particular, namely:

age, civil status, birth, wealth, religious or philosophical conviction, political conviction, trade union conviction, language, current or future state of health, disability, physical or genetic characteristic, social origin, nationality, alleged race, skin color, ancestry, national or ethnic origin, sex, sexual orientation, gender identity, gender expression, sexual characteristics, pregnancy, childbirth, breastfeeding, maternity, adoption, medically assisted reproduction, sex reassignment, paternity and co-maternity.(art. 32ter, 3°, Law of 4 August 1996 on Well-being).

Workspace regulation

All EDF staff members are bound by the workplace regulation, which they read on signing their employment contracts. Protection from harassment is outlined in article 12 and Annex 2:

 L’employeur, les travailleurs et toutes les autres personnes qui entrent en contact avec les travailleurs lors de l’exécution de leur travail sont tenus de s’abstenir de tout fait de violence, harcèlement moral ou sexuel au travail. La violence et le harcèlement moral ou sexuel font partie intégrale des risques psychosociaux.
À cette fin, les travailleurs doivent s’abstenir de tout acte de violence, harcèlement moral ou sexuel, et conformément à leur formation et aux instructions données par l’employeur contribuer de manière positive à la politique de prévention mise en place dans le cadre de la prévention des risques psychosociaux. Ils doivent également s’abstenir de tout abus de l’intervention psychosociale formelle et informelle décrite ci-dessous et de la procédure interne en particulier [décrite dans ce document]. 

EDF measures in prevention

1. EDF keeps this policy updated according to the Belgian law and best practice
2. EDF management team must follow mandatory training concerning the prevention of harassment every two years. In the event of a new person joining the team, the training must be followed the first year. The training is open to other staff members who can participate on a voluntary basis.
3. All staff members are reminded annually of the workplace regulations, and who to address in the case of a concern: firstly, the Executive Director or the HR Manager, and if the person prefers, the EDF Secretary (member of the Executive Committee)
4. The EDF Board and membership, and our project partners are made aware of this policy and reminded of its importance
5. All new staff and EDF members are informed of this policy
6. All EDF members, partners and third parties are made aware of the policy as it is published on the EDF website
7. Any staff member who faces, witnesses or is reported harassment should notify the Executive Director/ HR Manager or EDF Secretary- this can be done in strict confidence
8. EDF will ensure that procedures to file a complaint with EDF are accessible (for example, request sign language interpretation where needed)

EDF measures in the case of a complaint

Internal procedure for EDF staff

1. The staff member concerned may request an informal conversation with their line manager, the HR Manager, Executive Director, or the EDF Secretary (in the Executive Committee).
2. The complaint can be documented by the staff member concerned and, in this case, filed by the Executive Director or the HR Manager in a confidential folder.
3. The EDF Secretary (in the Executive), the President and Vice Presidents are informed if the staff member concerned agrees.
4. If a staff member is accused of harassment the accusation is investigated by the Executive Director, the HR Manager or EDF Secretary (in the Executive) in the form of a discussion and email exchanges as needed.
5. In the case that harassment is confirmed, the perpetrator receives a verbal and written warning.
6. If the staff member who has made the complaint agrees, a meeting is organised to discuss the issue and resolve it through dialogue, if possible.
7. If there are persistent breaches of this policy, or repeated or grave episodes of harassment, the staff member concerned may be dismissed.
8. In case of a suspected criminal offence, the police will be informed- this policy should never replace EDF obligation to report a crime.
9. The HR Manager supervises closely and supports the return to work of employees who have declared that they have been subjected to harassment.

As is the case for the Safeguarding reporting procedure, a written and confidential record is kept and the Executive Committee is updated on this topic under the regular risk review in the Executive committee. (in this risk review, the record is anonymised).

Internal procedure concerning EDF members, including elected officials, committee members and project partners

1. EDF members, project partners or anyone participating in an EDF official event, may lodge a complaint for harassment by contacting the HR manager, Executive Director (catherine.naughton@edf-feph.org).
2.  If an EDF member or partner (including EDF elected official or committee members), is accused of harassment, the accusation is investigated by the Executive Director in the form of a discussion and email exchange as needed. For complaint against someone who is not an EDF member or partner (for example external speaker, or contractor), the Executive Director will also investigate, give advice on venue of complaint when necessary, and can take measures to stop future cooperation with the perpetrator.
3. In the case that harassment has taken place, the EDF member or partner will receive a verbal and written warning.
4. If deemed appropriate, a meeting is organised to discuss the issue and resolve it through dialogue if possible.
5. If there are persistent breaches of this policy, or repeated episodes of harassment, the issues will be referred to the Executive who may choose to prevent the member/ partner from attending EDF events and meetings.
6. In case of a suspected criminal offence, the police will be informed- this procedure should never replace EDF obligation to report a crime.

As is the case for the Safeguarding reporting procedure, a written and confidential record is kept and the Executive Committee is updated on this topic under the regular risk review in the Executive committee. (in this risk review, the record is anonymised)

External procedure for EDF staff

The staff member concerned also has the possibility to seek assistance externally:
CESI – Prevention Consultant for Psychosocial Aspects: take contact with an prevention advisor (this is also in strict confidence) via the following link.
They will then follow the procedure outlined in Annex 2 of the work regulations. The internal procedure described here does not replace the external procedure involving CESI.

Other competent agencies

Institute for the Equality of Women and Men: the Institute supports victims of harassment, consults with the prevention advisor and can take the case to court. The measures are taken with the consent of the complainant.

The employees trade union can help facilitate the communication with the employer.

The role of Executive Director, HR Manager or the EDF Secretary

When a designated person receives a complaint of harassment, they will:

• immediately record the dates, times and facts of the incident(s).
• ascertain the views of the complainant as to what outcome they want.
• ensure that the complainant understands the EDFs procedures for dealing with the complaint.
• keep a confidential record of all discussions.
• ensure that the complainant knows that they can lodge the complaint outside of EDF in line with our workplace regulations, including to the police in the case of a criminal offence.
• ensure the complaint is also recorded in an anonymised manner in our overview of risks.

Complaints contact point

For any complaints related to this policy, or other general complaints, please send an e-mail to info@edf-feph.org , with the title of the policy in the Subject field.