SEXUAL HARASSMENT PREVENTION POLICY:

1. Institutional Commitment

INNOVSURGERY, S.L. is committed to creating and maintaining a safe, inclusive, and respectful work environment, free from any form of sexual harassment or harassment based on sex. The company enforces a zero-tolerance policy toward any conduct that violates the dignity, equality, or integrity of its employees. To this end, this protocol establishes an effective, confidential procedure with full legal guarantees for the management, investigation, and resolution of complaints related to sexual or sex-based harassment. Furthermore, INNOVSURGERY, S.L. is committed to implementing ongoing training, awareness, and best practice programmes to prevent any form of harassment and to promote a corporate culture based on respect and equality.

2. Definitions of Harassment

Sexual Harassment
Unwanted verbal, nonverbal or physical conduct of a sexual nature that undermines a person’s dignity, particularly when creating an intimidating, hostile, degrading, humiliating or offensive environment. Examples include:

• Unsolicited sexual comments, innuendos, or propositions
• Spreading rumors or information about a person’s sexual life or identity
• Inappropriate gestures, looks or display of sexual material
• Unwanted or excessive physical contact, such as touching or hugging
• Cyberharassment with sexual content
• Blackmail or abuse of power linked to sexual favours

Sex-Based Harassment
Includes any discriminatory, offensive, or violent conduct based on sex, gender, gender identity, or gender expression that undermines dignity and creates a hostile or discriminatory work environment.

3. Rights and Responsibilities

Employees’ Rights

• The right to work in an environment free from harassment and discrimination
• The right to file internal complaints or report to authorities without fear of retaliation
• The right to receive appropriate psychological, legal, and medical support
• The right to confidentiality and protection throughout the entire process

Employees’ Responsibilities

• Maintaining professional and respectful conduct in all interactions
• Reporting any incident of harassment, whether experienced or witnessed
• Cooperating honestly and proactively in investigations

4. Reporting Procedure

Reporting Channels
Employees may submit complaints via:

• Confidential email: naiara.raengo@innovsurgery.com
• Telephone: +34 676 603 094
• Anonymous form available on the corporate intranet

All complaints will be treated with strict confidentiality and without prejudice.

Investigation Process

• Receipt: Confirmation and guarantee of confidentiality
• Investigation: An impartial team will conduct an objective investigation, collecting testimonies and evidence
• Resolution: A report will be issued and suitable disciplinary measures imposed, ranging from warnings to dismissal, depending on severity

5. Support for Victims

INNOVSURGERY, S.L. will provide comprehensive assistance resources for victims, including:

• Internal counselling by trained professionals in conflict resolution
• Access to external psychological support and legal advice, at company expense
• Implementation of interim measures to protect the victim (e.g., shift changes, remote working), subject to informed consent

6. Training and Awareness

INNOVSURGERY, S.L. will implement an ongoing training and awareness programme that includes:

• Mandatory, periodic training for all employees on sexual and sexbased harassment
• Targeted training for managers and supervisors on detection and management
• Internal awareness campaigns to foster a respectful work culture
• Annual evaluation of the protocol’s impact and training effectiveness

7. Frequently Asked Questions (FAQs)

What should I do if I’m a victim of harassment?
Report it through the designated channels and trust the investigative process.

Is confidentiality guaranteed?
Yes. Information will be handled with strict confidentiality and limited access.

What if the complaint is false?
An objective investigation will be carried out; malicious claims may result in disciplinary action.

What sanctions can be applied?
From minor disciplinary actions to dismissal, depending on severity.

Who is protected?
All staff, including temporary workers, interns and collaborators.

8. Applicable Legislation

This policy complies with current regulations, including:

• Organic Law 10/2022 on the Comprehensive Guarantee of Sexual Freedom
• Workers’ Statute
• Organic Law 3/2007 on Effective Equality between Women and Men
• Occupational Health and Safety regulations

Contact for Questions and Complaints:
Email: naiara.raengo@innovsurgery.com
Tel: +34 676 603 094