SUBJECT: HARASSMENT
In Foster Wheeler, we constantly emphasize the importance of observing our Code of Business Conduct and Ethics (Code) in the conduct of our business and day-to-day duties. In this memo, I would like to draw your attention to the subject matter of harassment and I urge you to read carefully and understand our Code on this subject. Anyone who violates the Code will be subject to severe disciplinary action.
You are aware that certain actions clearly constitute harassment and are in violation of our Code. However, certain actions or reactions, e.g. verbal statements, physical action, gestures, facial expressions or eye contact, which may be made with no ill intent, may still be perceived as a form of harassment. While these actions or reactions may or may not ultimately constitute harassment, they invite problems and issues such as conflict between and distress for the relevant individuals, prolonged company investigations into the incident and in some cases, involvement by the police, all of which lead to work disruption and unnecessary stress for all concerned. Therefore, I urge you to take extra care and err on the side of being cautious, when acting or reacting to any situation which, if inappropriately handled, could be construed as harassment, so as to avoid unnecessary problems and issues for yourself, your family and the Company.
If you have any questions relating to this, please do not hesitate to contact our Chief Legal Officer, HR Director or Corporate Compliance Officer.