Behaviour policy

1. Introduction

GLSS aims to provide top-quality, consistent, and accessible services for the benefit of its distributors, partners, auditors, trainers, invigilators, and clients, as well as creating and maintaining a positive work environment which ensures safety and well-being of its staff, and holds the dignity, respect and human rights of its staff in high regard. The purpose of this policy is to ensure that GLSS is managing unacceptable behavior of Partners or Clients in an impartial, confidential, fair, and timely manner.

2. Application and Scope
This policy applies to i) all Partners or Clients, and ii) all GLSS staff that interacts with a Partner or a Client, while carrying out their duties or services for GLSS or on behalf of GLSS.

3. Purpose
The purpose of this policy is to ensure that GLSS is managing unacceptable behavior of Partners or Clients in an impartial, confidential, fair, and timely manner.
The objectives of the policy are to:
– Inform GLSS staff, Partners or Clients what types of behavior that are deemed unacceptable
by GLSS
– Define the roles and responsibilities internally at GLSS in dealing with unacceptable behavior
– Informing Partners or Clients of how unacceptable behavior will be managed by GLSS

4. Defining Unacceptable Behavior
What is deemed to be unacceptable behavior often differs depending upon the individuals involved, the culture in which the Partner or Client operates and the particular circumstances of the interaction with GLSS. However, any behavior that is reasonably likely to be expected to make a member of the GLSS staff feel threatened, harassed, frightened, offended, or physically at risk is considered unacceptable.

Schedule A provides further examples of what will generally be considered unacceptable behavior.

5. Roles and Responsibilities in Managing Unacceptable Behaviors
a) Individual employees are responsible for and expected to deliver excellent service to Partners
or Clients and to avoid any potentially difficult situations arising by displaying a professional
attitude at all times. Should they experience unacceptable behavior from Partners or Clients,
GLSS staff must immediately and adequately warn the Partner or Client that they deem their
behavior unacceptable, while remaining professional in their conduct. In the event that the
unacceptable behavior occurs during a phone call, the GLSS staff is authorized to notify the
Partner or Client that they will hang up the call if the unacceptable behavior continues following
such warning and do so if the Partner or Client does not stop immediately to display the
unacceptable behavior. The individual employee must report the incident as soon as possible to
their Supervisor or Director, but shall consider any such information as confidential information
of GLSS and will not disclose same to any person other than such Supervisor or Director.

b) Supervisors and Directors have to ensure that this policy is properly communicated and
enforced within their department. Supervisors and Directors shall maintain accurate written
records of all incidents reported by the GLSS staff under this policy. If Supervisors or Directors
deem it necessary that further actions should take place, they should contact the Managing
Director.

c) The Managing Director is responsible to properly communicate this policy with all Partners
or Clients. The Managing Director, or another person appointed by the Managing Director, shall
investigate the incident further and ask for additional information or evidence, as required, and
depending on its assessment of the behavior send a formal notification informing the Partner
or Client that an incident has been reported and requiring change in its behavior. If the Partner
or Client fails to comply with the formal notice requirements, the Managing Director must raise
the issue with the Board of Directors.

d) The Board of Directors is responsible for making the final decision upon the further actions to
be taken, including without limitation regarding the way they will manage future communications
and contacts with such Partners or Clients. If it considers it appropriate, it will refer the issue
to the Legal Department. Actions following the review process may include one or more of the
following actions:

a. Limit future contact to a particular form (e.g., written form only);
b. Arrange for a single, named member of staff to deal with all future calls or
correspondence from the respective Partner or Client;
c. Record all the phone calls and personal contacts (ensuring that GDPR and other
relevant requirements are met);
d. Terminate all contact(s) if the Partner or Client is a complainant;
e. Terminate the relevant contract with such Partner or Client, and such termination will
be deemed to be a termination for cause;
f. Take legal action, such as apply for an injunction or court order to prohibit contact and
ensure the cessation of such unacceptable behavior or request damages.
The actions taken shall be communicated to the Partner or Client in a written form by an
authorized representative of GLSS.

e) The Legal Department is responsible to deal with the legal aspects and to initiate legal
procedures regarding the unacceptable behavior, as applicable.

6. Monitoring and Reporting
GLSS will monitor this policy to ensure that it is being applied in a fair, reasonable, and consistent manner

SCHEDULE A

EXAMPLES OF UNACCEPTABLE BEHAVIOUR

7.1. Aggressive Behavior
This type of behavior is violent and may result in physical harm. This behavior also includes violent language used towards GLSS staff, whether written or verbal, which is threatening in its nature and simulates aggressive acts.

7.2. Abusive Behavior
Abusive behaviors are considered behaviors that may be verbal and intimidating.
a. Verbal — this includes rudeness, derogatory remarks, inflammatory statements, and
unsubstantiated allegations. This type of behavior also includes offensive language or shouting
towards GLSS staff via phone calls or any correspondence (email, letter, etc.).
b. Intimidating – This includes behavior that makes GLSS staff feel afraid and threatened.

7.3. Vexatious Behavior
This type of behavior is manifested generally through different comments, actions or gestures which are hostile or unwanted and such behavior affects the dignity or psychological integrity of a GLSS employee.
Moreover, this type of behavior is manifested when a Partner or Client is seeking to cause unnecessary aggravation or annoyance to the GLSS employees through groundless complaints.
7.4. Discriminatory Behavior
This type of behavior is displayed towards someone because of their disability, gender identity, race, religion, or sexual orientation.

7.5. Defamation
A Partner or Client must operate with integrity and shall not defame or disparage GLSS or its staff. A Partner or Client is prohibited from making false or misleading statements regarding GLSS or its products and services.

7.6. Persistent Behavior
A Partner or Client’s actions may be considered as persistent behavior when after all internal review mechanisms have been exhausted, the Partner or Client still continues to challenge the decision of GLSS relating to their complaint or dispute. This persistent behavior is unacceptable because it may take up a disproportionate amount of time and resources. The following are some examples of persistent behavior:

a. Persistently refusing to follow the proper procedures explained to them by GLSS in order to
pursue their issue;
b. Continuously making excessive and unnecessary number of phone calls or visits to GLSS
offices;
c. Continuously contacting GLSS on the same issues without presenting any new information;
or
d. Falsely using names to contact and access GLSS offices to raise the same issue.

7.7. Extreme Behavior

Extreme behaviors threaten the immediate safety and well-being of the GLSS staff and should be regarded with critical importance.

7.8. Unauthorized Recordings
Any unauthorized filming or sound recording of face-to-face, phone communication, or meetings are prohibited without the prior agreement and knowledge of all parties involved.

7.9. Deliberate Damage
Unacceptable behavior can also include deliberate physical damage caused by a Partner or Client to GLSS office premises.

Version: 1.0 | Approval date: 09.04.2021