Procedure for the prevention and handling of violence, harassment and discrimination – PCSoft
1. Purpose, framework and scope
PCSoft (PC SOFT INFORMATIQUE SAS) ensures the prevention and handling of any situation of violence, harassment or discrimination arising in connection with its WINDEV, WEBDEV and WINDEV Mobile training courses. This procedure meets Indicator 12 of the French National Quality Framework (Référentiel National Qualité), in the version resulting from Decree No. 2026-728 of 1 August 2026 (Official Journal of 4 August 2026), applicable to audits from 1 November 2026.
Text of Indicator 12 (relevant part): "It ensures the prevention and handling of any situation of violence, including sexist and sexual violence, harassment or discrimination in the context of their training."
It is aligned with the training centre's internal rules (revision of 13/10/2026), whose Article 2 bis defines the prohibited conduct and whose Article 3 sets out the applicable disciplinary procedure.
Legal references
- French Labour Code (Code du travail): Art. L. 1132-1 (discrimination), L. 1142-2-1 (sexist conduct), L. 1152-1 (moral harassment), L. 1153-1 and L. 1153-2 (sexual harassment, protection of persons in training), L. 6352-3 et seq. (internal rules of training organisations), R. 6352-3 to R. 6352-8 (sanctions, disciplinary procedure, precautionary measure, informing the employer and funder).
- French Criminal Code (Code pénal): Art. 222-33 (sexual harassment), 222-33-2 (moral harassment in working relationships), 222-33-2-2 (moral harassment, including between trainees or towards a trainee), 225-1 and 225-2 (discrimination), R. 625-8-3 (sexist or sexual insult) and 222-33-1-1 (aggravated sexist or sexual insult).
Scope
- All PCSoft training courses, inter-company and in-company, in person and remote (virtual classrooms, forums, messaging, collaborative tools).
- Certification assessment sessions.
- All persons involved: learners, trainers, administrative staff, speakers, contractors present on site.
- Acts committed by or against a learner during training, breaks, organised meals and online exchanges related to the training.
2. Definitions
| Concept | Definition | Training examples |
|---|---|---|
| Violence | Any physical or psychological harm to a person's integrity: assault, threat, intimidation, insult. | Threatening remarks to a trainer, shoving in the classroom. |
| Sexist and sexual violence (SSV) | Conduct of a sexual nature or based on sex, ranging from insult to sexual assault. | Comments on physical appearance, non-consensual contact, sending sexual images. |
| Sexist conduct | Conduct related to a person's sex, whose purpose or effect is to undermine their dignity or create an intimidating, hostile, degrading, humiliating or offensive environment (L. 1142-2-1). | Demeaning jokes about women developers. |
| Sexual harassment | Repeated remarks or behaviour of a sexual or sexist nature which either undermine the person's dignity because of their degrading or humiliating nature, or create an intimidating, hostile or offensive situation for them (L. 1153-1, 1°). Any form of serious pressure, even if not repeated, exerted with the real or apparent aim of obtaining a sexual act, for the benefit of the perpetrator or a third party, is treated as sexual harassment (L. 1153-1, 2°). | Persistent messages through the virtual classroom messaging. |
| Moral harassment | Repeated conduct whose purpose or effect is a deterioration of training conditions, undermining rights, dignity or health (L. 1152-1). | Repeated mockery of a trainee's level, systematic exclusion. |
| Discrimination | Difference in treatment based on one of the criteria prohibited by Art. 225-1 of the Criminal Code: origin, sex, age, disability, state of health, sexual orientation, gender identity, religion, opinions, family situation, physical appearance, place of residence, etc. | Refusal of registration, denial of access to the certification assessment, lack of adjustments for a candidate with a disability. |
3. Commitments and prevention measures
PCSoft applies a zero-tolerance policy: every reported act is handled, and no person reporting in good faith nor any witness suffers retaliation. Retaliation is itself liable to sanction (internal rules, Art. 2 bis).
| Measure | When | Medium / evidence |
|---|---|---|
| "Violence, harassment and discrimination" clause in the internal rules (Art. 2 bis), with the applicable sanctions (Art. 3) | Before the start of training | Internal rules sent with the course invitation |
| Information for learners: commitment, reporting address referent-vss@pcsoft.com, external resources | Invitation + first-day welcome | Welcome booklet, invitation, session opening slide |
| Display of contacts (referent, emergency numbers) | At all times | Poster in the training room; "Contacts" page of the online area |
| Awareness training for trainers and staff on identifying situations and how to respond | On joining, then annually | Certificate of attendance, attendance list |
| Supervised use of the GoTo chat (technical exchanges: code, links, audio or video issues); the trainer reframes or deletes any inappropriate message | During each virtual class | Reminder of usage rules at the start of the virtual class |
| Dedicated question in the end-of-course evaluation: "During the training, were you a victim of or witness to any sexist, harassing or discriminatory remark or behaviour? Yes / No"; any "Yes" answer is forwarded to the referent | End of session | Satisfaction questionnaire, follow-up of "Yes" answers |
4. Roles and responsibilities
| Party | Responsibilities |
|---|---|
| Referent for sexist and sexual violence, harassment and discrimination: role held by the HR Director or management, reachable at referent-vss@pcsoft.com | Receives reports, acknowledges receipt, listens, provides guidance, conducts the analysis with management, keeps the confidential register. |
| PCSoft management | Approves precautionary measures and sanctions, conducts the disciplinary procedure (internal rules, Art. 3), decides whether to file a complaint or report to the authorities, taking into account the victim's wishes unless legally required, and provides the resources for the system. |
| Trainers | Remind participants of the rules, intervene immediately to stop any behaviour, forward any incident to the referent within 24 hours. |
| Training / administration department | Distributes information documents, updates materials, archives Qualiopi evidence. |
| Quality manager | Monitors the system's indicators, incorporates cases into continuous improvement (Indicator 32), reviews the procedure. |
| Learners | Comply with the internal rules; may report any act of which they are a victim or witness. |
| Learner's employer (in-company / company-funded training) | Informed of any sanction taken against one of its employees (legal obligation, Art. R. 6352-8 of the Labour Code). Informed of the facts themselves only with the victim's consent, unless legally required. |
5. Reporting
Any victim or witness may report an incident by e-mail. A trainer informed orally of an incident forwards it to this address within 24 hours. In case of immediate danger, first call 17 or 112 (section 7).
Reporting channel
- Dedicated e-mail: referent-vss@pcsoft.com, monitored by the HR Director or management.
Useful content of a report: date, place or tool (room, virtual classroom, chat), description of the facts, persons involved and witnesses, available evidence (screenshots, messages). Keeping such evidence for the purpose of a report is not covered by the recording prohibition in the internal rules (Art. 2). An incomplete report is still handled.
Guarantees
- Acknowledgement of receipt within 72 hours.
- Confidentiality: information is shared only with those strictly necessary to handle the report.
- No retaliation against anyone reporting in good faith or against witnesses.
- A deliberately false report may lead to sanctions (internal rules, Art. 2 bis).
6. Handling of reports
Each report is closed within a maximum of 60 calendar days, unless legal proceedings are under way.
| Step | Time limit | Responsible | Content |
|---|---|---|---|
| 1. Ensuring safety | Immediate | Trainer / anyone present | Stop the acts, separate the people involved, call emergency services if necessary (17, 112, 15). |
| 2. Acknowledgement of receipt | 72 h | Referent | Written confirmation to the person reporting, opening of a record in the register. |
| 3. Listening interview | 5 working days | Referent | Collect the victim's account, inform them of their rights and external resources, signed report of the interview. |
| 4. Precautionary measures | From the interview if needed | Management | Change of group or session, switch to remote training, postponement of a certification assessment without penalty, immediate temporary precautionary exclusion of the person implicated (internal rules, Art. 3; Art. R. 6352-7 of the Labour Code). |
| 5. Adversarial analysis | 15 working days | Referent + management | Hearing of the person implicated and witnesses, collection of evidence, written conclusion: facts established, not established or undetermined. This analysis does not replace the disciplinary interview in step 6. |
| 6. Decision | At the end of the analysis | Management | If a sanction is being considered: procedure under Art. 3 of the internal rules (grounds notified in writing, summons against signed receipt, interview with possible assistance, written and reasoned decision taken at least one clear day and at most 15 days after the interview). Sanctions: warning, temporary or permanent exclusion. Employer and funder informed of the sanction taken (Art. R. 6352-8 of the Labour Code). Where applicable, report of a crime or offence to the Public Prosecutor, by decision of management and taking into account the victim's wishes, unless legally required. |
| 7. Support | Until the end of the course | Referent | Referral to external resources, adaptation of the course, continuation of training in good conditions. |
| 8. Closure and lessons learned | 60 days max. | Referent + quality manager | Informing the parties of the outcome, archiving, improvement action (Indicator 32). |
Where the person implicated is a PCSoft employee, management concurrently applies the internal disciplinary procedure provided for by the Labour Code. Where they are a speaker or contractor, management may suspend their involvement as a precautionary measure and applies the terms of the service contract (suspension or termination). Filing a criminal complaint remains the victim's right, independently of these procedures.
7. Contacts and external resources
| Resource | Contact | Use |
|---|---|---|
| PCSoft referent | referent-vss@pcsoft.com (HR Director / management) | All reports |
| Police / gendarmerie | 17 | Immediate danger |
| European emergency number | 112 | Immediate danger |
| SAMU (emergency medical service) | 15 | Medical emergency |
| Emergency by SMS (deaf or hard-of-hearing people, or people unable to speak) | 114 | Immediate danger |
| Violences Femmes Info | 3919 (free, anonymous, 24/7) | Listening and guidance for victims of violence |
| France Victimes | 116 006 | Victim support |
| Défenseur des droits (Defender of Rights) | 3928 – defenseurdesdroits.fr | Discrimination, including racism, antisemitism, homophobia and transphobia |
| SOS homophobie | sos-homophobie.org | Listening and support for victims of homophobia, lesbophobia, biphobia and transphobia |
| DILCRAH (Interministerial Delegation for the Fight against Racism, Antisemitism and Anti-LGBT Hatred) | dilcrah.gouv.fr/annuaire | Directory of associations supporting victims of racism, antisemitism and anti-LGBT hatred |
| PHAROS | internet-signalement.gouv.fr | Reporting hateful online content (racist, antisemitic, homophobic) |
| Platform for reporting sexual and sexist violence | arretonslesviolences.gouv.fr | Online reporting, chat with a police officer or gendarme |
| Labour Inspectorate – DDETS de l'Hérault (Departmental Directorate for Employment, Labour and Solidarity) | 615 boulevard d'Antigone, CS 19002, 34064 Montpellier Cedex 2 – labour law information: 0806 000 126 (local call rate), ddets-droit-du-travail-renseignements@herault.gouv.fr | PCSoft employees concerned |
| Occupational health service | EnSanté – Centre de Montpellier Parc Euromédecine, 525 rue de la Croix Verte, 34094 Montpellier Cedex 5 – 04 67 84 76 40 – ensante.fr | PCSoft employees concerned |
Done at Montpellier on 12/10/2026 — last revised on 12/10/2026
This English version is a translation provided for information purposes. In the event of any discrepancy, the French version shall prevail.
