Anti-Discrimination Policy

1 About this Policy

1.1 Overview

The r2p Group is proud to be an equal opportunity employer and will not tolerate or accept any form of discrimination or harassment amongst its employees, whether by reason of gender, sexual orientation, race, nationality, ethnic origin, colour, religion or ability.

Our Anti-Discrimination Policy explains how to prevent discrimination and protect our employees, customers and stakeholders from offensive and harmful behaviours. This Policy supports our overall commitment to create a safe and happy workplace for everyone.

This Policy is available to all team members on ONEr2p, and to contractors via e-mail. New team members will be given a copy of this Policy at their induction and their consent will be documented. Managers and supervisors will remind team members of this Policy from time to time.

1.2 Application of this Policy

This Policy applies to all individuals working for the r2p Group at all levels and grades, including senior managers, officers, directors, consultants, contractors, trainees, homeworkers, full time, part time, fixed-term, maximum-term, casual, permanent and temporary employees and agency staff. All team members have a responsibility for ensuring they take the time to read and understand this Policy.

1.3 Non-compliance with this Policy

The r2p Group takes very seriously its commitment to providing a positive, safe and productive workplace for all staff. All team members are expected to comply with this Policy.

A failure to comply with this Policy may have disciplinary consequences.

Any contractor, including a subcontractor, who is found to have breached this Policy may have their contract with the r2p Group terminated or not renewed.

If you are suspected of committing a breach of this Policy, you will be required to cooperate with any investigation in relation to this matter. A failure to comply with such a direction may in itself result in disciplinary action, including termination of employment or engagement.

If an investigation finds unlawful discrimination or unlawful harassment or inappropriate workplace behaviour has not occurred or cannot be substantiated, the r2p Group may still take appropriate action to address any workplace issues leading to the discrimination or harassment report.


2 Our stance against Discrimination and Harassment

r2p will not tolerate or accept any form of discrimination, harassment, victimisation or vilification as described in the sections below, in the workplace or whilst representing the company.

2.1 Definition of Discrimination

Discrimination occurs when a person is treated less favorably in their employment because of a protected characteristic or attribute. A person can still treat another person less favourably, and unlawfully discriminate against them on one of the grounds below, even if they did not intend to do so.

2.1.1 Grounds of Discrimination

It is unlawful to discriminate against or harass a person based on a prohibited ground of discrimination. These protected grounds differ between countries, but typically include any of the following: disability, disease or injury, including work-related injury, parental status or status as a carer, skin or hair colour, descent, national origin, ethnic background, age, sex, membership in a union, religion, pregnancy and breastfeeding, sexual orientation, intersex status or gender identity, marital status, political opinion, social origin, medical record and an association with someone who has, or is assumed to have, one of these characteristics, such as being the parent of a child with a disability.

2.1.2 Examples of Discrimination

Examples of discrimination include:

  1. failing to offer training to an older employeebecause it is assumed they will retire soon
  2. failing to give a female team member a promotion because she has children or is pregnant
  3. racial or culturally insensitive jokes or racial nicknames
  4. offensive comments about a person's sexuality
  5. teasing a person about their disability
  6. excluding or isolating a person because of their religion.
  7. indirectly, when an unreasonable requirement, condition or practice is imposed that has, or is likely to have, the effect of disadvantaging people with a personal characteristic protected by law.

2.2 Definition and Examples of Harassment and Sexual Harassment


Harassment is unwanted, unwelcomed and uninvited behaviour that demeans, threatens or offends the victim and results in a hostile environment for the victim. Physical harassment can involve direct threats of intent to harm, destroying property or physical attacks like hitting or pushing someone. Psychological harassment can involve isolating someone or spreading rumours. Harassment is against the law wherever and whenever it occurs.

Sexual harassment is unwanted conduct of a sexual nature. It has the purpose or effect of violating the dignity of a person, or creating an intimidating, hostile, degrading, humiliating or offensive environment for them. Sexual harassment is not behaviour that is based on mutual attraction, flirtation or friendship. If the behaviour is mutual, consensual, welcomed and reciprocated it is not sexual harassment. Sexual harassment can be physical or non-physical, for example: written or verbal comments of a sexual nature, such as remarks about an employee’s appearance, questions about their sex life or offensive jokes, displaying pornographic or explicit images, e-mails with content of a sexual nature, sending rude or offensive e-mails.

The r2p Group will not tolerate or accept any form of harassment, in the workplace or in any work-related context such as conferences, work functions and business trips. All employees are responsible for their own behaviour and may be held criminally liable if they engage in harassment.


2.3 Definition of Victimisation

Victimisation is where a person is treated less favourably or detrimentally because they have either lodged a complaint, intend to lodge a complaint, or are involved in a complaint of unlawful conduct (including appearing as a witness).

Examples of victimisation may include:

  1. excluding someone because they have made a complaint
  2. dismissing, demoting or failing to promote a person because they have lodged a complaint
  3. otherwise treating a person less favourably because they have made a complaint.

2.4 Definition of Vilification

Vilification is the public act of saying or writing unpleasant things about someone or something, in order to cause other people to have a bad opinion of them. This may involve comments regarding their race, sex, religion, sexuality or sexual identity.

Conduct that may constitute vilification includes:

  1. offensive material on the internet, including e-forums, blogs, social networking sites and video sharing sites
  2. offensive comments or images published in a publication such as a leaflet, flyer, internal message board or workplace intranet
  3. offensive speeches at public events, work functions or in the workplace


3 Rights and responsibilities

3.1 Rights of team members

To meet the objectives of this Policy, teammembers at all levels should understand what their rights and responsibilities are. Every teammember has the right to:

  1. make inquiries and complaints in a reasonable and respectful manner without being victimised;
  2. recruitment and selection decisions based on merit and not affected by irrelevant personal characteristics;
  3. work free from unlawful discrimination and unlawful harassment, including sexual harassment; and
  4. reasonable flexibility in working arrangements, where needed to accommodate their family responsibilities, disability, religious beliefs or culture.

3.2 Responsibilities of team members

Each team member is required to:

  1. familiarise themselves with this Policy and comply with its terms at all times;
  2. treat everyone with dignity, courtesy and respect;
  3. report early of any conduct they believe to be unlawful discrimination or unlawful harassment, whether to them or someone else;
  4. offer support to people who experience discrimination or harassment, including providing information about how to make a complaint; and
  5. treat complaint resolution procedures confidentially.

3.3 Rights and responsibilities of managers and supervisors


Managers and supervisors will take all reasonable steps to ensure team members do not engage in unlawful conduct and are not subject to unlawful conduct in terms of this Policy. Where total elimination is not possible or practical, management encourages early, confidential intervention to minimise the occurrence and seriousness of inappropriate workplace behaviour.

Supervisors and managers are responsible for promoting acceptable and appropriate workplace behaviour, including modelling appropriate behaviour and disseminating information to team members about acceptable and unacceptable behaviours with reference to this Policy.

It is the positive responsibility of all supervisors and managers to take reasonable steps to prevent harassment and discrimination in the workplace or in connection with employment.




4 Handling complaints

4.1 Raising complaints


If you have a complaint about workplace discrimination or harassment you should seek advice from your direct supervisor or the People, Culture & Brand Department.

Any reports of workplace discrimination or harassment will be treated seriously and confidentially. The r2p Group will deal with the complaint in a timely and efficient manner. A person making a complaint and/or who is a witness to workplace discrimination or harassment may not be victimised.

Any complaint made under this Policy must be made in good faith. That is, it should not be made in a malicious or reckless manner or where it is known that the complaint is false or misleading. A person making a misleading or malicious complaint may be subject to disciplinary action, including termination of employment.


4.2 Investigating complaints


The investigation may require the assistance of other members of the staff. All team members involved in a complaint procedure are required to maintain strict confidentiality. If a team member breaches confidentiality, they may be subjected to disciplinary action up to termination of employment or engagement. Spreading rumours or gossip may also expose a team member to a defamation claim.

Where a complaint appears serious or where unlawful conduct may have occurred, the r2p Group may disclose information to external persons or entities for the purposes of investigation. In this case, the r2p Group will ask any external party to keep confidentiality as far as possible.


4.3 Appealing the decision

If the concerned colleague is unhappy with the outcome of the internal investigation, they may appeal this decision to the Global Head of People & Culture (s. 4.4), explaining their reasoning. Any appeal should be raised promptly and will be conducted by the Global Head of People & Culture and an appropriate independent r2p Director. The outcome of the appeal will be final.

4.4 Contacts and queries about this Policy


There are a number of persons within the r2p Group who have been designated to deal with any concerns or questions about this Policy. You should contact your direct supervisor in the first instance and if you have any further queries, please contact your designated HR contact or the r2p Group PC&B department people(at)

You should also contact your direct supervisor or your designated HR contact if:


  1. you are unsure whether your behaviour may breach this Policy; or
  2. you are unsure whether the behaviour of others may breach this Policy.