Discrimination and Harassment Policy

Purpose

The company is committed to providing equal employment opportunity to all individuals applying for employment and to all employees. The purpose of this policy is to help ensure that unlawful discrimination, including all forms of harassment, does not occur. Discrimination against any individual on the basis of race, sex, national origin, religion, age, marital status, height, weight, veteran status, familial status or disability, or any other status protected under federal, state, or local law or ordinance will not be tolerated. All complaints of discrimination or harassment will be investigated promptly and thoroughly, with the company taking the appropriate remedial action, up to and including termination, against the offending party.

Definitions

UNLAWFUL DISCRIMINATION occurs when an employer, either knowingly or unknowingly, treats similarly situated individuals or a protected class differently based on unlawful considerations, such as race, sex, age, marital status, height, weight, or disability.

HARASSMENT refers to behavior that interferes with an individual’s work performance or creates an intimidating, hostile, or an offensive work environment.

Guidelines

All employees and management, in particular, are responsible for providing and maintaining a work environment that is free from unlawful discrimination, including harassment. A number of state and federal laws, such as Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act, and the Americans with Disabilities Act prohibit unlawful discrimination and harassment, in the workplace.

An employer may violate anti‐discrimination laws in one of three ways:

1. Disparate treatment—treating similarly situated employees differently based on an unlawful consideration.

2. Intentional discrimination—being predisposed to discriminate against a protected class and acting on that predisposition.

3. Disparate impact—using a neutral criterion or test data that has an adverse impact on a protected class.

Employers are also prohibited from engaging in unlawful harassment and have a duty to prevent unlawful harassment by others in the workplace, including co-workers, customers, and vendors. Unlawful harassment, including any form of sexual, racial, ethnic, or religious harassment, occurs when an employee engages in an activity which creates a hostile work environment, or subjects another employee to a quid pro quo arrangement as either an explicit or implicit condition of their employment, or their employment opportunity.

The company is in full agreement with the intent of these laws and is committed to maintaining a workplace that is free from unlawful discrimination and harassment. Any employee who believes that he or she has been unlawfully discriminated against or harassed; or who witnesses the unlawful discrimination or harassment of another, shall immediately notify his or her supervisor or Human Resources staff member of the occurrence. There will be no corrective action against an employee who makes a complaint with the reasonable belief that unlawful discrimination or harassment has occurred.

The penalty for retaliatory behavior against an employee reporting an occurrence of unlawful discrimination or harassment will be severe. However, any employee making a complaint against another employee that is unfounded, and in which there is no reasonable basis to believe that unlawful discrimination or harassment has occurred, will be subject to corrective action up to and including termination of employment.

All parties involved in investigating the complaint must remain aware of the need to maintain confidentiality to the greatest degree possible and not to unnecessarily disclose the complaint or the identities of the persons affected.