Purpose

PATH4 Group is committed to providing a safe, inclusive and respectful work environment in which all employees, contractors and temporary employees are treated with dignity and fairness. This policy sets out our commitment to Equal Employment Opportunity (EEO) and our zero‑tolerance approach to discrimination, harassment and bullying.

Scope

This policy applies to:

• All PATH4 Group employees
• Temporary employees, contractors and agency workers
• Managers, directors and representatives of PATH4 Group
• All work-related activities, including recruitment, training, promotion, work placements, meetings, work travel and social events connected to work

Equal Employment Opportunity (EEO)

PATH4 Group is committed to equal employment opportunity for all people. Employment decisions are based on merit, skills, experience and business needs.

Unlawful discrimination will not be tolerated in any aspect of employment, including:

• Recruitment and selection
• Terms and conditions of employment
• Training, promotion and career development
• Performance management
• Termination of employment

Discrimination

Discrimination occurs when a person is treated less favourably, or is disadvantaged, because of a protected personal characteristic.

Protected characteristics include, but are not limited to:

• Sex, gender identity or gender expression
• Sexual orientation
• Marital or relationship status
• Pregnancy, breastfeeding or parental/carer status
• Age
• Race, colour, nationality, ethnic or social origin
• Religion or belief
• Political opinion
• Disability or physical features
• Industrial activity
• Personal association with a person who has any of the above attributes

Direct and indirect discrimination are both prohibited.

Harassment

Harassment is any unwelcome, uninvited or offensive behaviour—verbal, written, visual or physical—that creates an intimidating, hostile or humiliating work environment.

Harassment may be a single incident or repeated behaviour and may relate to any protected characteristic listed above.

Sexual harassment, in particular, is strictly prohibited and includes any unwanted conduct of a sexual nature that makes a person feel offended, humiliated or intimidated.

Bullying

Workplace bullying is repeated, unreasonable behaviour directed at an individual or group that creates a risk to health and safety.

Examples of bullying or harassment may include:

• Offensive jokes, comments, images or videos
• Insulting, mocking or mimicking behaviour
• Aggressive or intimidating language or gestures
• Unfair, excessive or unreasonable criticism
• Deliberate exclusion or isolation

Reasonable management action, carried out in a fair and lawful manner, does not constitute bullying. This includes setting performance goals, providing feedback, managing performance or addressing misconduct.

Zero Tolerance & Responsibilities

PATH4 Group has zero tolerance for discrimination, harassment or bullying.

All workers are responsible for:

• Treating others with respect
• Complying with this policy
• Not engaging in, encouraging or ignoring inappropriate behaviour

Managers and leaders have an additional responsibility to:

• Model appropriate behaviour
• Act promptly on complaints or observed misconduct
• Ensure a safe and inclusive workplace

Reporting & Complaints

Any person who experiences or witnesses discrimination, harassment or bullying is encouraged to report it as soon as possible.

Reports can be made to:

• A PATH4 Group representative
• A manager or supervisor
• Human Resources (where applicable)

Complaints will be:

• Taken seriously
• Handled promptly, fairly and sensitively
• Investigated in a confidential manner, as far as reasonably possible

Non‑Retaliation

PATH4 Group strictly prohibits victimisation or retaliation against any person who:

• Makes a complaint in good faith
• Assists in an investigation
• Exercises their rights under this policy

Any retaliation will result in disciplinary action.

Disciplinary Action

If discrimination, harassment or bullying is substantiated, PATH4 Group will take appropriate corrective action. This may include:

• Education or counselling
• Formal warnings
• Reassignment or removal from duties
• Termination of employment or contract

Confidentiality

All reports and investigations will be handled with discretion and confidentiality, subject to legal and procedural requirements.

Policy Review

This policy will be reviewed regularly to ensure compliance with applicable legislation, industry standards and best practice.