Last Technology

Policy Against Harassment, Sexually Inappropriate Conduct, and Bullying

Introduction

LAST fosters an inclusive, respectful, and safe working environment in which every individual—whether internal or external to the organization—can freely express their identity and professionalism.

Inspired by the Universal Declaration of Human Rights and the Company’s Code of Ethics, this Policy sets forth the expected behaviors and the individual and collective responsibilities in preventing and addressing any form of harassment, sexually inappropriate conduct, or bullying.

Such behaviors undermine people’s physical and psychological well-being, the internal climate, the quality of services, and the company’s reputation. LAST ensures support, protection, and attentive listening to anyone reporting incidents related to these issues, and expressly prohibits retaliatory actions against those who contribute to reporting or investigations.

This Policy is subject to periodic review. Violations of its principles may result in disciplinary proceedings, with aggravating circumstances in cases of abuse of power by personnel in positions of hierarchical authority.

Scope of application

This Policy applies to all individuals working for LAST: employees, members of corporate bodies, agency workers, interns, trainees, and external collaborators.

The rules apply both within the physical workplace and in any context connected to professional activity: business trips, events, common areas (locker rooms, parking lots, break areas), use of social media, remote working, and all interactions attributable to the company.

Key external stakeholders are also informed of the Policy’s contents. Reports concerning third parties will be subject to confidential investigation and, if necessary, specific actions.

Harassment

Harassment is defined as any verbal, non-verbal, psychological, or physical behavior that violates a person’s dignity or creates a hostile, degrading, offensive, or intimidating environment.

Even a single incident is considered relevant if it causes discomfort, anxiety, or fear.

Common examples—without claiming to be exhaustive—include:

derogatory comments, humiliating jokes, ridicule or epithets;
threats, intimidation, insults, defamation or circulation of harmful information;
hostility towards personal characteristics (origin, age, gender, gender identity, sexual orientation, health conditions, disability, marital status, etc.);
aggressive behavior, limitations on freedom of expression;
dissemination of inappropriate content via email, chat, or social networks.

Sexually inappropriate behavior

This category includes all unwanted behaviors with sexual connotations, or based on a person’s gender, identity, or sexual orientation, which offend their dignity or harm the professional environment.

They are prohibited regardless of the role or gender of the parties involved.

Among the recurring behaviors (listed as an example):

observations or allusions about physical appearance or body parts;
displaying or sharing sexually explicit or degrading material;
insistent glances, winks or ambiguous attitudes;
advances, pressure or requests of a sexual nature, even when accompanied by promises or threats related to one’s career;
unwanted questions or confidences about your private or sexual life;
sexually explicit gossip, messages, emails, or digital content;
unwanted physical contact (hugs, massages, caresses, kisses);
hostile acts based on sexual stereotypes or prejudices.

LAST bases its professional environment on skills and ethical behavior, not on physical or aesthetic characteristics.

Bullying

Bullying involves repeated and targeted actions aimed at hindering, isolating, intimidating, or discrediting a person in the performance of their work.

Such behaviors can make the person vulnerable, threatened, or humiliated, compromising their professional dignity and emotional well-being.

Among the most commonly encountered practices:

hostile or threatening behavior, even when perceived as such;
yelling, public humiliation or personal attacks;
dissemination of harmful or denigrating information;
ridicule or belittling of skills;
exclusion from communication or work activities;
improper use of social media or chats to offend or isolate;
abuse of hierarchical position to limit growth or training opportunities.

Legitimate professional feedback, constructive criticism, and proper performance management are excluded from this definition.

Prevention and corporate culture

LAST promotes a work environment based on respect, inclusion, and equal dignity.
Prevention involves:

dissemination and constant communication of the Policy;
awareness-raising initiatives;
Dedicated training courses aimed at increasing awareness, interpersonal skills, and the ability to recognize and manage inappropriate behavior.

Report Management

Anyone who experiences or witnesses incidents of harassment, sexually inappropriate behavior, or bullying can contact:

to the Human Resources and Organization Department through the HR Manager;
to the whistleblowing system, according to company procedures.

Each report will be treated confidentially and will be investigated as necessary.

Disciplinary consequences

Violations of the Policy or applicable regulations will result in disciplinary action, commensurate with the seriousness of the conduct, and potentially up to and including dismissal.

Protection of whistleblowers

LAST protects those who report in good faith, even anonymously, by guaranteeing:

confidentiality;
absolute prohibition of any form of retaliation;
timely handling of exposed situations.

Retaliatory or silence-inducing behaviors are themselves serious disciplinary violations.

False reports submitted in bad faith will be subject to specific evaluation and, if necessary, disciplinary action.

Practical information

When you feel like you’re a victim

It is possible:

talk to the person directly about it, explaining the impact of the behavior and setting limits;
contact your HR Manager;
confide in a colleague or manager who can act as a mediator;
submit a formal report through the whistleblowing system.

When you witness an episode

Everyone is required to actively contribute to combating harassment.

These are useful actions:

intervene to interrupt or divert the behavior;
express dissent or call attention to the company’s ethical rules;
offer support to the person involved, even through simple contact or listening;
inform the HR Manager so that the necessary checks can be undertaken.

Prata di Pordenone, May 9, 2025​​​​​

The Management

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