This policy aims to maintain and foster a work environment in which all employees are treated with decency and respect. We have adopted a zero-tolerance policy toward discrimination and all forms of unlawful harassment, including but not limited to sexual harassment. This zero-tolerance policy means that no form of unlawful discriminatory or harassing conduct towards any employee, client, contractor, or another person in our workplace will be tolerated. The company is committed to enforcing its policy at all levels and any employee who engages in prohibited discrimination or harassment will be subject to discipline, up to and including immediate discharge from employment for a first offense

This policy is equally applicable to all members, directors and vendors, and the company reserves the right to preclude such individuals from participation in or doing business with the company to the extent they engage in conduct prohibited by this policy.

Conduct Covered by this Policy:

• This policy applies to and prohibits all forms of illegal harassment and discrimination, not only sexual harassment. Accordingly, the company absolutely prohibits harassment or discrimination based on sex, age, disability, perceived disability, marital status, personal appearance, sexual orientation, race, color, religion, national origin, veteran status or any other legally protected characteristic.

• Because confusion often arises concerning the meaning of sexual harassment in particular, it deserves special mention. Sexual harassment may take many forms, including the following:

 Offensive and unwelcome sexual invitations, whether or not the employee submits to the invitation, and particularly when a spoken or implied quid pro quo for sexual favors is a benefit of employment or continued employment;

 Offensive and unwelcome conduct of a sexual nature, including sexually-graphic spoken comments; offensive comments transmitted by e-mail or another messaging system; offensive or suggestive images or graphics whether physically present in the workplace or accessed over the Internet; or the possession of or use of sexually suggestive objects; and

 Offensive and unwelcome physical contact of a sexual nature, including the touching of another, ’s body; the touching or display of one’s own body, or any similar contact.

Computer Messaging and Information Systems:

• Employees are particularly cautioned that the use of e-mail, voice mail, or other electronic messaging systems, or the Internet, may give rise to liability for harassment. Employees may not generate, should not receive, and must not forward, any message or graphic that might be taken as offensive based on sex, gender, or other protected characteristic. This includes, for example, the generation or forwarding of offensive “humor” which contains sexually-offensive terms, or terms which are offensive to any race, religion, national origin group, or another protected group.
• Employees receiving offensive messages over the company’s computer equipment, or receiving other unlawfully offensive messages or graphics over the company’s computer equipment, should report those messages to their supervisor or another appropriate manager.
• Employees are reminded that the company’s computers and the data generated on, stored in, or transmitted to or from the company’s computers remain the property of the company for all purposes. No employee is authorized to use any company computer, computer system, network, or software for the preparation, transmission, or receipt of sexually offensive messages or graphics, or for other messages or graphics which might be taken as offensive based on any other protected characteristic.
• Employees are reminded that the company retains the right to monitor its computers, computer systems, and networks to ensure compliance with this requirement.

Mandatory Procedures in Cases of Harassment:

• Any employee who believes that she or he has been subjected to unlawful harassment of any kind has the responsibility to report the harassment immediately to her or his supervisor. If the employee is uncomfortable reporting the harassment to her or his immediate supervisor (whether because the supervisor has committed the harassment, or for any other reason whatsoever), the employee must report the harassment to the next higher level of management above the immediate supervisor or, if the employee prefers, to the [ Human Resources Director, Chief Financial Officer, or President ] of the company.

• The company is committed to taking all reasonable steps to prevent harassment and will make every reasonable effort promptly and completely to address and correct any harassment that may occur. However, the company cannot take prompt and effective remedial action unless each employee assumes the responsibility of reporting any incident of harassment immediately to an appropriate supervisory employee.

• Every report of harassment will be investigated promptly and impartially, with every effort to maintain employee confidentiality. The complainant and the accused will be informed of the results of the investigation. If the company finds that its policy has been violated, it will take appropriate corrective and remedial action, up to and including discharge.

Reporting Without Fear of Retaliation:

• No employee will be retaliated against for reporting harassment. This no-retaliation policy applies whether a good faith complaint of harassment is well founded or ultimately determined to be unfounded.
• No manager or supervisor is authorized, or permitted, to retaliate or to take any adverse employment action whatsoever against anyone for reporting unlawful harassment, or for opposing any other discriminatory practice in the workplace.

• Any employee who feels he or she has been retaliated against in violation of this no-retaliation policy is responsible for reporting the retaliation to management, in the same manner as any other form of harassment or discrimination should be reported.

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