1.1 Impact Investment Exchange Pte Ltd (“IIX”) is committed to creating and maintaining a safe and non-discriminatory environment for its employees and stakeholders. This policy details the non-discriminatory and responsive practices and safeguards against any form of gender-based violence with which IIX’s Staff and Stakeholders are expected to comply.
1.2 IIX practices a zero-tolerance policy for gender-based violence. All complaints of gender-based violence are taken seriously and treated with respect and in confidence. Any IIX Staff found to have engaged in or condoned gender-based violence will face disciplinary actions, up to and including dismissal from employment. Any Stakeholder found to have engaged in or condoned gender-based violence will face punitive actions, up to and including termination of relationship.
2. Policy Statement
2.1 This policy applies to all persons working for IIX or on its behalf in any capacity, including employees at all levels, directors, officers, agency workers, seconded workers, volunteers, interns, agents, contractors , external consultants and third-party representatives (collectively referred to as “Staff”), as well as business partners and enterprises IIX works with, including borrowers of the Women’s Livelihood BondTM (WLB) Series (“Borrowers”) (collectively referred to as “Stakeholders”).
2.2 IIX defines gender-based violence and harassment as the continuum of emotional, psychological, economic, physical and sexual abuse, which is experienced disproportionately by women and children and perpetrated predominantly by men. It includes, but is not limited to, domestic abuse, child sexual abuse, rape and sexual assault, sexual harassment, female genital mutilation, forced marriage, so-called “honor” crimes and commercial sexual exploitation through prostitution and pornography. Discrimination in relation to ethnicity, (dis)ability, sexual orientation, poverty, age, migrant or refugee status etc. can increase and intensify vulnerability to abuse.
2.3 IIX’s policy is targeted at preventing gender-based violence and harassment in the workplace. IIX also strongly condemns and forbids domestic abuse, child sexual abuse, female genital mutilation, forced marriage, so-called “honor” crimes and commercial sexual exploitation through prostitution and pornography. IIX recognizes that discrimination in relation to ethnicity, (dis)ability, sexual orientation, poverty, age, migrant or refugee status etc. can increase and intensify vulnerability to abuse.
2.4 Anyone can be a victim of gender-based violence, regardless of their sex and of the sex of the harasser and/or assaulter. IIX recognizes that sexual harassment and/or assault may also occur between people of the same sex. What matters is that sexual and violent conduct is unwanted and unwelcome by the person against whom the conduct is directed.
2.5 IIX recognizes that gender-based violence is a manifestation of power relationships and often occurs within unequal relationships in the workplace, for example, between manager or supervisor and employee. Any member of IIX’s Staff who sexually harasses and/or assaults another will be subject to disciplinary actions in accordance with this policy.
3. Responsibility for the Policy
3.1 The Board of IIX has overall responsibility for ensuring this policy complies with IIX’s legal and ethical obligations, and that all those under IIX’s control comply with it.
3.2 The Chief Operating Officer (“COO”) has primary and day-to-day responsibility for implementing this policy, monitoring its use and effectiveness, dealing with any queries about it and auditing internal control systems and procedures to ensure they are effective in countering gender-based violence.
3.3 All levels of IIX’s management are responsible for ensuring those reporting to them understand and comply with this policy and are given adequate and regular training on it.
4. Compliance with the Policy
4.1 The following obligations shall apply to IIX Staff:
4.1.1 IIX Staff must ensure that they read, understand and comply with this policy.
4.1.2 IIX Staff must refrain from perpetrating gender-based violence or sexual harassment in connection with IIX’s work and their performance of duties for IIX. This applies whether the conduct is directed at another member of Staff, an individual employed by a Stakeholder, a beneficiary or client of a Stakeholder, or otherwise. IIX Staff shall also avoid any activity that might lead to or suggest a breach of this policy.
4.2 The following obligations shall apply to both IIX Staff and Stakeholders:
4.2.1 IIX Staff and Stakeholders are encouraged to raise concerns about any issue or suspicion of gender-based violence in any parts of IIX’s business at the earliest possible stage.
4.2.2 If an IIX Staff or Stakeholder suspects a breach of this policy has occurred or may occur in IIX’s business, the person with the knowledge of such breach must notify the COO in writing as soon as possible.
4.3 The following obligations shall apply to IIX Stakeholders:
4.3.1 For Stakeholders which are organizations, their respective management shall ensure that their employees are apprised of their organization’s commitment to complying with this policy. For Stakeholders which are individuals, the Stakeholder must ensure that they read, understand and comply with this policy.
4.3.2 Stakeholders are expected to take reasonable steps to prevent any form of gender-based violence in their operations.
4.3.3 If a Stakeholder is unsure about whether a particular act, the treatment of workers or their working conditions constitute gender-based violence, the Stakeholder is encouraged to raise the matter with IIX’s COO.
4.4 IIX, as Portfolio Manager of the WLB Series, shall ensure that Borrowers sign a statement certifying that they understand IIX’s gender-based violence policy and that they will comply with said policy to the extent that it applies to Stakeholders.
4.5 IIX shall deal with any complaints received in relation to gender-based violence in its operations fairly, with sensitivity and respect, and in confidence for all parties concerned.
4.6 IIX takes note that under Singapore law, a person who has been subject to sexual harassment has legal recourse through the Penal Code and Protection from Harassment Act (POHA), which provide measures that protect victims against two common forms of sexual harassment: (1) Non-physical (e.g., taking of “upskirt” photos/videos, verbal and visual forms of sexual harassment, among others) and (2) Physical (e.g., stalking, molestation, sexual assault and rape). Generally, under the Penal Code and the POHA, someone who has experienced sexual harassment at work may choose to pursue one or more of the following actions: (1) Pursue criminal sanctions against the offender by lodging a police report; (2) Apply before the Court a Protection Order; or (3) Sue the offender in court for monetary damages as part of a civil lawsuit.
4.7 In many jurisdictions outside Singapore, there are similar laws, and IIX encourages its Staff and Stakeholders operating outside of Singapore to familiarize themselves with such local laws relating to gender-based violence. Staff and Stakeholders are required to follow such laws to the extent relevant, in addition to this policy.
5. Communication and Awareness of this Policy
5.1 IIX shall ensure that this policy is widely disseminated to all relevant persons and that this will be included in the IIX staff handbook.
5.2 Training on this policy, and on the risk IIX’s business faces from gender-based violence forms part of the induction process for all individuals who work for IIX and is provided as necessary.
5.3 Every year, IIX will require all its employees to attend a refresher training course on the content of this policy. Every IIX manager is responsible for ensuring that all IIX employees/contractors reporting to them are aware of this policy.
5.4 IIX’s commitment to addressing the issue of gender-based violence in its business is regularly communicated to all Stakeholders at the outset of its business relationship with them and reinforced as appropriate thereafter.
6. Breaches of the Policy
6.1 All formal complaints must be made in writing to the COO.
6.2 IIX shall not retaliate against, terminate or discipline any Staff for reporting in good faith concerns about workplace-related incidents of gender-based violence, including an allegation that the act was perpetrated by a fellow Staff or person in a management capacity. Prohibited acts of retaliation include, but are not limited to, demotion or withholding of earned pay, as well as acts of personal retaliation. Any Staff who believes he or she has been subjected to adverse action for making a report pursuant to this policy should immediately contact the COO or IIX’s Chief Executive Officer or Board of Directors. Any allegations of violations of this provision will be promptly investigated.
6.3 Following reporting and/or complaint of cases of violence and harassment, appropriate measures will be taken in relation to the perpetrator(s).
6.3.1 In cases of harassment, IIX may take specific actions, e.g., redeploy or relocate the harasser to avoid future conflicts; monitor the harasser after the incident so that he/she does not repeat the act; monitor the well-being of the affected Staff; provide coaching and counselling for both harasser and the harassed.
6.3.2 Any IIX Staff who has harassed and/or assaulted his/her co-worker or has participated in an act of harassment or encouraged such conduct by others shall face disciplinary action up to, and including, dismissal for misconduct or gross misconduct, based on senior management’s assessment of the case. For severe cases, a police report may be made.
6.3.3 If the harassment involves an external Stakeholder, IIX shall take appropriate actions to prevent recurrence. IIX reserves the right to terminate its relationship with a Stakeholder if they breach this policy.