Anti-Discrimination | Carter Industrial Company


  1. Introduction and Purpose

Carter Industrial Company's Anti-Discrimination Policy (the "Policy") is grounded in our commitment to promoting equality, inclusivity, and a work environment free from discrimination and harassment. This Policy aligns with relevant national laws, the UN Guiding Principles on Business and Human Rights, Principle 6 of the UN Global Compact, International Labour Organization guidelines, and Carter Industrial Company's Code of Conduct. We strive to ensure that no one, whether internal employees or external candidates, experiences discrimination or harassment during the recruitment, promotion, or employment processes. Our company values individual merit and skills, promoting and supporting equal opportunities. We maintain a zero-tolerance approach towards discrimination and harassment in all work-related activities and interpersonal relationships.




Key Principles

1.   Equality as the Primary Consideration: Carter Industrial Company recognizes that all individuals are born equal, and therefore, equal treatment is paramount. We prioritize equal treatment regardless of factors such as ethnicity, cultural background, sex, gender identity, sexual orientation, religion, disability, age, or any other characteristic.

2.   Zero Tolerance: We maintain a zero-tolerance policy against discrimination, harassment, sexual harassment, and victimization. Any form of discriminatory behaviour or harassment is strictly prohibited within the company.

3.   Respect for Individual Differences: We respect and value the diversity of individuals in terms of ethnicity, sex, gender identity, sexual orientation, culture, religion, and other relevant factors. Embracing these differences fosters an inclusive and supportive work environment.


  1. Applicability of the Policy

The Anti-Discrimination Policy applies to all individuals associated with Carter Industrial Company, including the Board of Directors, management, employees, agency workers, contractors, business partners, and suppliers. This Policy must be communicated to these parties alongside the Code of Conduct, and regular reading and understanding of the Policy are essential to ensure compliance and uphold respect throughout the organization.


This Policy applies to all work-related activities, encompassing but not limited to recruitment and selection processes, employment conditions and benefits, training and promotion opportunities, task allocation, shifts, hours, leave arrangements, workload, and provision of equipment. Additionally, the Policy extends to interpersonal relationships in work-related situations, including travel, events, parties, and after-work gatherings.


  1. Definition of Discrimination
  2. 1. Discrimination

Discrimination, as defined by Carter Industrial Company, refers to any less favourable treatment, differential treatment, or violation of a person's dignity based on factors unrelated to their merits, skills, or job responsibilities. This includes, but is not limited to, less favourable or differential treatment and violations of dignity based on race, ethnicity, sex, gender identity, religion, age, disability, sexual orientation, political opinion, or union status. Discrimination can be either intentional or unintentional, and even actions taken without the intent to discriminate may still be considered acts of discrimination if they put another person at a disadvantage. The following examples illustrate instances of discrimination:


  • Paying an employee a lower salary compared to a colleague of the opposite sex with the same or equivalent tasks.
  • A manager making unwelcome sexual advances.
  • Dismissing a woman due to pregnancy.
  • An employee refusing to cooperate with a colleague based on the colleague's faith.
  • Not offering a job applicant an interview due to their foreign name.
  • Denying a customer with a disability access to company facilities when reasonable accessibility measures have not been implemented.


  1. 2. Harassment

Harassment is a form of discrimination strictly prohibited within Carter Industrial Company. Generally, there are two types of harassment:

1.   Harassment of Improper Behaviour: This includes physical, verbal, or non-verbal misconduct that is related to a person's race, ethnicity, sex, gender identity, religion, age, disability, sexual orientation, political opinion, union status, or any other protected ground. Harassment can involve single or multiple incidents and may cause a person to feel offended, humiliated, or intimidated. Examples of harassment include deliberate insults, physical threats or abuse, unsubstantiated complaints, continued interference with personal workspace, display of offensive material, exclusion from normal work communication, and intrusion into personal life.

2.   Sexual Harassment: This specifically refers to unwelcome sexual advances, requests, verbal conduct, non-verbal conduct, physical conduct, and other forceful or coercive misconduct.


In all cases, it is the victim of harassment who determines what is unwelcome or offensive, and all individuals must carefully consider how certain behaviours are perceived.


  1. 3. Victimization

Victimization encompasses offensive acts directed towards one or several individuals. These acts do not need to be related to any specific characteristic of the individual, such as ethnicity or gender. Examples of victimization include excessive or insufficient workload or demands, bullying, unjustified demotions to positions with lower responsibility, ostracism, defamation, insults, violence, and withholding information. Acts of victimization can cause severe illness and lead to employees being isolated from the workplace community. Carter Industrial Company is committed to fostering an inclusive workplace and does not tolerate any form of victimization.


  1. Reporting Incidents

If an employee at Carter Industrial Company experiences discrimination or harassment, they should promptly report the incident to their local Human Resources department at their site. If anyone is under immediate threat or danger, it is important to notify the local police as well. However, if site HR management is involved in the incident, the employee should directly contact Group HQ HR.


The victim's preference for interpretation should be respected, and each case should be treated seriously. Victims have the right to request additional external aid, such as counseling, medical assistance, or involving the police. If requested by the victim, witnesses to the incident can be involved in the investigation. It is crucial for both the person responsible for the discrimination and the victim to be cooperative and honest throughout the process. Victims must feel safe to report discrimination and harassment without fear of reprisals from management.


The following four-step procedure should be followed when addressing reported cases of discrimination and/or harassment:


1.   Investigate the Discrimination/Harassment Incident: The site HR department should conduct an immediate investigation to determine the severity of the incident.

2.   Analyse Causes and Risks: The site HR department should evaluate the underlying causes and potential risks associated with the incident.

3.   Perform Corrective and Preventative Actions: Based on the investigation's findings, appropriate corrective and preventative actions should be taken to address the situation effectively and prevent future occurrences.

4.   Follow-up and Evaluate Actions: The site HR department should ensure that the actions taken are followed up on and evaluated to assess their effectiveness in resolving the issue.


After the incident is reported to the site HR department, the following steps should be taken in order:


1.   The site HR department should promptly initiate an investigation to determine the severity of the incident.

2.   The site HR department should contact Group HQ HR to conduct a detailed investigation.

3.   In severe cases, with agreement between Group HQ HR and site HR, a third party may be brought in for mediation or further investigation if requested.

4.   If necessary, the involved parties should be released from work duties during the investigation to ensure a fair and unbiased process.

5.   Group HQ HR and site HR should collaborate to determine appropriate disciplinary actions, which may include verbal warnings, written warnings, counselling, separating involved parties into different functions, shifts, or tasks, temporary suspension, or permanent dismissal in severe cases.

6.   Upon completion of the investigation, the site HR department should arrange individual or group meetings with the involved parties, depending on the case, to discuss the findings and proposed actions.

7.   The site HR department is responsible for implementing and following up on the disciplinary actions as decided by Group HQ HR and site HR.


  1. Implementation and Compliance

The Anti-Discrimination Policy of Carter Industrial Company aims to ensure that all employees understand and adhere to the principles and rules outlined in this policy. If you have any doubts or questions about how to act or behave in accordance with the policy, it is important to discuss these issues with your direct manager or the site HR department.


  1. 1. Implementation and Additional Guidelines

This policy, along with other separate policies and our Code of Conduct, has been developed to establish internal standards and guidelines. They are not intended to be legally binding or create any guarantees or warranties. Therefore, individuals cannot claim any legal rights derived from these policies or the Code of Conduct.


Carter Industrial Company intends to conduct internal mapping every two years to identify and address any hidden cases of discrimination or harassment.

All employees are obligated to regularly update themselves on any changes or additions to our policies without being specifically requested to do so.


This policy serves as a framework document that complements the local housekeeping rules and policies of each Carter Industrial Company site. Employees working at any site are required to follow and understand the local rules and policies in addition to this policy.


  1. 2. Compliance

This policy is a resource that provides guidance on ethical behaviour towards one another. It clearly outlines our values and how we can achieve a positive work environment free from misconduct and inappropriate behaviour.


Retaliation against anyone who reports a known or suspected case of discrimination or harassment is strictly prohibited.


  1. 3. Employee Responsibility

Every employee of Carter Industrial Company has a responsibility to act honestly and ethically. The policy and Code of Conduct provide the framework to put our values into action. It is our collective responsibility to act with integrity, comply with applicable laws and regulations, and honour the Code of Conduct.


Employees are responsible for knowing, understanding, and complying with all company policies and procedures. However, it is important to note that national laws or local collective bargaining agreements always take precedence over the policy. By committing to these responsibilities, we can maintain the expected standards of interpersonal relationships with integrity and good behaviour.


  1. 4. Managers’ Responsibility

Managers play a crucial role in setting an example for employees. In relation to this policy, managers are expected to:


  • Embrace the policy and act as role models.
  • Foster a workplace environment that supports the principles outlined in the policy.
  • Educate employees on the meaning and application of the policy.
  • Enforce the policy consistently and fairly.


  1. Our Commitment to Prevent Retaliation

Ethical values and integrity are of utmost importance to Carter Industrial Company, and it is vital that individuals feel comfortable raising concerns or reporting suspected breaches of the policy, other company policies, or the law. We assure you that if you raise a concern in good faith, there will be no retaliation against you. Any employee found engaging in retaliation will be subject to disciplinary action. If you believe you have experienced retaliation, you should report it as a suspected misconduct.


June 30, 2023

Carter Industrial Company

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