Policy of Reykjavík Arts Festival on Bullying, Sexual Harassment, Gender-Based Harassment and Violence in the Workplace

This policy is established in accordance with Article 38 of the Icelandic Act No. 46/1980 on working environment, health and safety, and regulation No. 1009/2015 on measures against bullying, sexual harassment, gender-based harassment and violence in the workplace.

Objective

The objective of this policy is to prevent bullying, harassment and violence in the workplace and to ensure that appropriate measures are in place if employees believe they have been subjected to such conduct.

Definitions of Terms

·      Bullying: Repeated behaviour that is generally likely to cause distress to the person affected, such as belittling, insulting, hurting or threatening the individual, or causing fear. Differences of opinion or conflicts arising from differing interests are not considered bullying.

·      Gender-based harassment: Behaviour related to a person’s gender that is unwanted and has the purpose or effect of violating the person’s dignity and creating an intimidating, hostile, degrading, humiliating or offensive environment.

·      Sexual harassment: Any form of sexual behaviour that is unwanted and has the purpose or effect of violating the person’s dignity, particularly when the behaviour creates an intimidating, hostile, degrading, humiliating or offensive environment. Such behaviour may be verbal, non-verbal and/or physical.

·      Violence: Any behaviour that results in, or could result in, physical or psychological harm or suffering.

Guiding principles

Bullying, gender-based or sexual harassment, and violence are prohibited by law and will not be tolerated in the workplace.

·      Employees must not engage in bullying, gender-based or sexual harassment, or violence towards others.

·      All employees share responsibility for preventing bullying and other inappropriate behaviour, both through their own actions and by reporting incidents to designated parties in accordance with the response plan.

·      Individuals may not always be aware that their behaviour is inappropriate. It is therefore important that employees set boundaries and express if they find certain behaviour unacceptable, with or without the assistance of management, and report the matter where appropriate.

·      This applies to interactions between colleagues as well as interactions between employees and others they engage with in the course of their work.

This applies to interactions that take place in the workplace, including any environment, whether indoors or outdoors, where employees are present or required to go for work purposes. It also applies to communication via email, phone or other electronic means, as well as social events connected to work and business travel. Reykjavík Arts Festival may also address conduct that occurs outside the workplace if it is considered likely to affect workplace relations.

·      All cases are handled in accordance with the response plan.

·      False accusations of bullying, harassment or violence will be addressed.

·      Employees who believe they have been subjected to, or have witnessed, bullying, harassment or violence are encouraged to report it so that appropriate action can be taken.

·      Complaints or reports should be directed to the Managing Director. If the complaint concerns the Managing Director, it may be directed to the Artistic Director. If it concerns the Artistic Director, it may be directed to the Chair of the Board.

·      The Managing Director is responsible for the implementation of the response plan of Reykjavík Arts Festival.

This policy was approved at a board meeting of Reykjavík Arts Festival on September 24, 2025 and shall be reviewed annually.

Response Plan on Bullying, Sexual Harassment, Gender Based Harassment and Violence

This plan is based on the policy of Reykjavík Arts Festival on bullying, sexual harassment, gender based harassment and violence in the workplace.

Initiation of the Process

Information or a report is received by the responsible party in accordance with the policy.

The responsible party gathers the following information from the reporting individual:

·      Who the alleged perpetrator is

·      Description of the behaviour

·      When and where the behaviour took place, and who was present, if applicable

The responsible party ensures that all reports are assessed by an external professional and that documentation is properly maintained.

Informal Process

If the alleged victim requests confidentiality and does not wish to initiate a formal process, an external professional must assess whether this is possible. If the professional considers that the case should proceed, the alleged victim is provided with professional support and the case is formally investigated.

If the professional considers that the case may proceed informally, the alleged victim is still offered support. The identity of the alleged perpetrator is not formally recorded, and no one other than the responsible party is informed.

Formal Process

Investigation

The responsible party prepares the investigation, assesses whether there are reasonable grounds, develops an interview plan and gathers relevant information.

Interviews

The responsible party works with a professional to conduct the assessment and interviews, or conducts them independently with professional support.

Interviews with the alleged victim and witnesses: The alleged victim and witnesses are interviewed. All interviews and their content are confidential. Participants are not permitted to disclose information or discuss the case with the alleged victim or the alleged perpetrator.

Interviews with the alleged perpetrator: The alleged perpetrator is informed of the case. A summary of interviews and information is presented without conclusions. The individual is asked to provide their own account of the behaviour, time and place, and whether there are witnesses. Additional information is requested as relevant. It is assessed whether further interviews are needed, including follow up interviews with the alleged victim, witnesses, and the alleged perpetrator. All parties are offered professional support if the process causes distress or strain.

Assessment

Once the investigation is complete, an assessment is made and a conclusion reached. The outcome is presented to both the alleged victim and the alleged perpetrator. The outcome includes an action plan with a timeline. Where appropriate, both parties are offered an agreement on the action plan or are informed of the measures.

If the behaviour does not constitute bullying, harassment or violence:

·      The action plan includes measures to improve communication

·      Clear guidance is provided on how communication should be improved

·      Monitoring and follow up are carried out in accordance with the plan

·      The parties are informed that the case is considered closed but remains under follow up

If the behaviour does constitute bullying, harassment or violence:

·      The plan includes decisions on consequences for the perpetrator:

o   Warning or termination, where appropriate

o   Mediation, where appropriate, supported by clear expectations for improved communication, monitoring and follow up

o   Clear guidance is provided on improved communication

o   Monitoring and follow up are carried out in accordance with the plan

o   The parties are informed that the case is considered closed but remains under follow up

Follow up

Support is provided to the parties involved, and their wellbeing and progress are monitored. The effectiveness of the action plan is evaluated, and consideration is given to whether further measures are required, such as changes to roles, work organisation or other adjustments.

This response plan was approved at a board meeting of Reykjavík Arts Festival on September 24, 2025 and shall be reviewed annually alongside the policy on bullying, sexual harassment, gender based harassment and violence in the workplace.