Anti-Harassment
Policy

Harassment based on protected classes will not be tolerated. These classes include, but are not necessarily limited to race, color, religion, sex, age, sexual orientation, national origin or ancestry, disability, medical condition, marital or civil union status, veteran status, or any other protected status defined by law.

1. What Is Harassment?
Workplace harassment can take many forms. It may be, but is not limited to, words, signs, offensive jokes, cartoons, pictures, posters, e-mail jokes or statements, pranks, intimidation, physical assaults or contact, or violence. Harassment is not necessarily sexual in nature. It may also take the form of other vocal activity including derogatory statements not directed to the targeted individual but taking place within their hearing. Other prohibited conduct includes written material such as notes, photographs, cartoons, articles of a harassing or offensive nature, and taking retaliatory action against an employee for discussing or making a harassment complaint.

2. Responsibility
All Company employees, and particularly supervisors, have a responsibility for keeping our work environment free of harassment. Any employee, who becomes aware of an incident of harassment, whether by experiencing or witnessing the incident or being told of it, must report it to their immediate supervisor or any management representative with whom they feel comfortable. When management becomes aware of the existence of harassment, it is obligated by law to take prompt and appropriate action, whether or not the victim wants the company to do so.

3. Reporting
While the Company encourages you to communicate directly with the alleged harasser, and make it clear that the harasser’s behavior is unacceptable, offensive or inappropriate, it is not required that you do so. It is essential, however, to notify your supervisor or any management representative with whom you feel comfortable, promptly, even if you are not sure the offending behavior constitutes harassment. All reports will be promptly investigated with due regard for the privacy of everyone involved. However, confidentiality cannot be guaranteed. Any employee found to have harassed a fellow employee or subordinate will be subject to disciplinary action, up to and including termination. The Company will also take any additional action necessary to appropriately remedy the situation. Retaliation of any sort will not be permitted. No adverse employment action will be taken for any employee making a good faith report of alleged harassment.

4. Policy Statement on Sexual Harassment
Sexual harassment may include unwelcome sexual advances, requests for sexual favors, or other verbal or physical contact of a sexual nature when such conduct creates an offensive, hostile and intimidating working environment and prevents an individual from effectively performing the duties of his or her position. It also encompasses such conduct when it is made a term or condition of employment or compensation, either implicitly or explicitly and when an employment decision is based on an individual’s acceptance or rejection of such conduct. It is important to note that sexual harassment crosses age and gender boundaries and cannot be stereotyped. Among other perceived unconventional situations, sexual harassment may even involve two women or two men.

The Company prohibits any employee from retaliating in any way against anyone who has in good faith raised any concern about sexual harassment or discrimination against himself/herself or another individual. The Company will investigate any complaint of sexual harassment and will take immediate and appropriate disciplinary action, up to and including termination, if sexual harassment has been found to have occurred within or in connection with the workplace. Any employees, including supervisors, involved in discriminatory practices will be subject to appropriate disciplinary action, up to and including termination.

Published January 2018