Response Plan in case of harassment or bullying at GunHil

GunHil has implemented an equality and equal pay policy. In connection with this policy, this action plan is established, based on Article 38 of Act No. 46/1980 on conditions, hygiene and safety at work, and regulation no. 1009/2015 on measures against bullying, sexual harassment, gender-based harassment and violence at work.

It is GunHil’s policy that employees work in a spirit of collaboration and thus always show their colleagues courtesy and respect in their communications. Bullying, sexual harassment, gender- based harassment and violence will under no circumstances be tolerated. Employee co- dependency in such cases is also condemned.



GunHil’s definition of bullying, sexual harassment, gender-based harassment and violence at work is in accordance with regulation no. 1009/2015. There says in Article 3:

Bullying: Repetitive behaviour that generally causes distress to the affected person, such as belittling, insulting, hurting, intimidating, or alarming the affected person. Differences of opinion or difference due to divergent interests are not covered here.

Gender-based harassment: Behaviour related to the gender of the affected person is disapproving of that person and has the purpose or effect of violating that person’s dignity and creating situations that are threatening, hostile, degrading, humiliating or offensive to that person.

Sexual harassment: Any sexual behaviour which, in the displeasure of the affected person, has the purpose or effect of violating that person’s dignity, particularly when the behaviour leads to an intimidating, hostile, degrading, humiliating or offensive situation. The behaviour can be verbal, symbolic and/or physical.

Violence: Any behaviour that leads to, or could lead to, physical or psychological harm or suffering to an affected person, including the threat of such, coercion, or arbitrary deprivation of liberty.

Furthermore, the following definitions are used:

Victim: The person who is subjected to bullying, sexual or gender- based harassment. Until the investigation of a case is completed, the term “alleged victim” is used.

Perpetrator: The person who uses bullying, sexual or gender-based harassment. Until the investigation of a case is completed, the term “alleged perpetrator” is used.


All complaints of bullying, sexual and gender-based harassment or violence shall be investigated as soon as possible and the need for professional support for both the victim and the perpetrator shall be assessed. It is very important that the company records and stores all relevant data.

GunHil is committed to activate the response plan for bullying, harassment, or violence no later than five working days after receiving the complaint. If the complaint is verbal, the manager must record it and define its nature. A manager who fails to perform his duty to such a complaint can expect to be granted a warning or even suspension if the case is grave.


Management is responsible for ensuring that the basic principles of communication in the workplace are respected and that new employees are made aware of this GunHil policy and response plan at the very beginning of work. The supervisor will take action against employees who violate the policy, e.g. by reprimanding, transferring or termination. Serious incidents may be reported to authorities after consultation with the victim. The perpetrator will be held accountable.

GunHil’s management has an obligation to create working conditions that do not offer the risk of bullying, harassment, or violence. They are responsible for implementing the equality policy and this response plan and that all employees are aware of it.

Management is also obliged to address issues in accordance with this response plan when they arise and seek the assistance of the Human Resources Manager and/or the Managing Director of GunHil.


Employees are prohibited from bullying other employees or managers in the workplace, harassing them and/or subjecting them to violence in the workplace.

An employee who believes they have experienced bullying, sexual harassment, gender-based harassment or violence in the workplace, or who have reasonable suspicion or knowledge of such behaviour in the workplace, shall inform the Human Resources Manager or Managing Director of GunHil. The employee shall also be prepared to clarify his case.


An employee who believes he or she has been bullied, harassed or violate against, or has reasonable suspicion or knowledge of such behaviour in the workplace, must contact the Human Resources Manager or Managing Director of GunHil as soon as possible and report the incident.

If the immediate supervisor is the perpetrator or if supervisor does not react on the complaint, emphasis is placed on the employee turning to the employee confidant or if that does not work, seek assistance from his/her union.

When a manager or employee confidant of the organisation becomes aware of bullying, harassment or violence, they shall take action according to this response plan:

Care must be taken to ensure that the working conditions of the victim during the procedure are such that the victim is not further exposed, overloaded with work, is supported and feels safe in the workplace.

All data collected in cases shall be kept in a secure place and accessible only to those investigating the case.


Information is sought from both the victim and the perpetrator separately and also discussed with the other parties if necessary. Both the victim and the perpetrator should be assisted by a supervisor, chief of staff and/or a safety committee foreman to resolve the case (mediation) and, in addition, the need for external assistance in the form of psychological assistance or counselling shall be assessed. Others than those concerned within the workplace are not informed about the case. The counsellor shall ensure that direct parties to a case are supported and safeguarded by ensuring suitable tasks.


  • A formal procedure will be supervised by a trained external counsellor in every case.
  • An impartial examination of the facts is made. Talk to the victim, the perpetrator and others who can provide information about the case. It is important to seek information about the timing and obtain any data, such as e-mails, SMS messages or otherwise.
  • A solution is sought that may include changes in the workplace, work methods or work organisation. The case is then followed up and discussed with its parties after a certain period of time and their communications are monitored.
  • If bullying, harassment, or violence is confirmed after examination, the perpetrator will receive a written warning. He/she will receive guidance and may be terminated from his/her job depending on the seriousness of the case.
  • The victim and perpetrator are offered psychological support as appropriate and needed.
  • Failure to stop his behaviour and continuing harassing, the perpetrator’s employment will be terminated.


It is necessary to pursue the case whether an informal or formal approach is taken. Follow-up includes:

  • Monitor the well-being and social status of the perpetrator and victim.
  • Provide appropriate support to the perpetrator and/or victim.
  • Evaluate the effectiveness of an intervention.
  • Review interventions if warranted.

Follow-up is aimed at ensuring improved well-being of the victim and preventing a recurrence of alleged bullying, harassment, or violence.

If a case evaluation reveals that it is not involving bullying, harassment or violence, consideration must nevertheless be given to the workplace culture and communications that led to this notification.

At all stages of a case, from the first notification, GunHil’s management can consult experts and delegate proceedings on behalf of the company.


The Chief of Staff and/or the Managing Director shall be responsible for implementing the policy and this response plan. Divisions and departments managers are also responsible for ensuring that all provisions of the response plan are implemented. The policy and this response plan shall be presented to all employees, and they guided where they can go with individual cases.

The implementation and review of the programme shall be monitored by the Director of Staff and/or the Managing Director and evaluated and reviewed every two years. Suggestions and suggestions concerning the programme shall be forwarded to them.

Approved by the Board of Directors of GunHil ehf.

GunHil ehf

Hlíðarfæti 13

102 Reykjavík



Response Plan GunHil ehf. v.1 – September 2023

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