Date of Implementation: July 1st, 2023
The Company is committed to providing a safe, respectful, and lawful workplace that promotes equality and is free of any form of discrimination, harassment, and retaliation. In furtherance of this commitment, the Company has implemented this Policy Prohibiting Discrimination, Harassment, and Retaliation (the “Policy”).
This Policy prohibits all discrimination and harassment, including, but not limited to: discrimination or harassment on the basis of sex (including pregnancy, childbirth or related medical condition, or breastfeeding), gender, gender identity or expression (including transgender identity or expression), sexual orientation, race, religious creed, color, national origin, ancestry, physical disability, mental disability, protected medical condition (including genetic characteristics), genetic information, marital status, age, military or veteran status, citizenship status, and any other category protected by applicable state or federal law.
The Company does not permit any instance of harassment, discriminatory conduct, or retaliation by or towards anyone.
This Policy applies to all employees, including managers, officers, and directors, as well as, if applicable, temporary staff, volunteers, or interns (all listed here will be collectively referred to as “employees”). Employees are prohibited from harassment, discrimination, or retaliation towards other employees, independent contractors, vendors, suppliers, or any others doing business with the Company. Any employee in violation of this Policy will be subject to immediate and severe disciplinary action, up to and including termination.
The Company also prohibits third parties doing business with the Company from engaging in harassment, discriminatory conduct, or retaliation against its employees. Employees who believe that they have been the victim of discrimination, harassment, or retaliation from any third party doing business with the Company, such as the Company’s independent contractors, vendors, suppliers, or others, should contact their immediate supervisor as soon as possible. Any complaints made in this regard will be dealt with in a prompt and confidential manner.
Sexual Harassment: Sexual harassment includes a range of conduct that is unwelcome and offensive. Sexual harassment is conduct that is so pervasive or offensive that it interferes with an employee’s performance. Sexual harassment is also conduct that 2/4 creates an intimidating or hostile environment.
Sexual harassment can be based on sex, gender, gender identity or expression, and sexual orientation. Sexual harassment may include in-person interactions or those that occur via text message or the Internet, and violations of this Policy are not only those which occur on the Company’s physical premises or during working hours. Sexual harassment can be physical or psychological.
A single instance of conduct that may, on its own, not be considered sexual harassment can become so if several incidents are perpetrated against the same individual by the same person or persons.
Sexual harassment can include any of the following examples (sexual harassment can also be conduct that is not on the below list, which are intended as non-exhaustive examples only):
- Unwanted sexual comments, sexual advances, or propositions
- “Quid pro quo” requests offered in exchange for benefit or advancement
- Non-verbal conduct, such as sexual gestures or displaying suggestive visuals
- Threatening an employee for rejecting sexual advances
- Sending sexually suggestive or derogatory text messages, videos, emails, or social media posts
- Making degrading remarks about an individual, their body, or their gender, gender identity, or gender expression
- Sexual assault, including touching or groping
How to Make a Complaint: Employees who feel they have been subject to harassment or discrimination are encouraged to document such conduct and should immediately report the incident to their supervisor or, if the complaint is concerning their supervisor, to a superior supervisor. Those acting on behalf of employer who have received a report of such conduct are advised to document everything thoroughly.
Employees can also file a complaint with a government agency or in court under federal, state or, local anti-discrimination laws.
If employees are not comfortable bringing a complaint to their supervisor or someone directly above their supervisor, employees may report to any senior member of the 3/4 Company they feel comfortable with. Employees should be aware, however, that the senior member they report to may bring the complaint to employee’s direct supervisor or other senior employees in the Company.
The Company encourages all employees to report violations of this Policy, no matter against whom. No individual member of the Company is exempt from this Policy.
Investigation: The Company will promptly and thoroughly investigate all complaints reported under this Policy. The investigation will be completed in a timely manner. Investigations may involve interviews, examination of physical evidence, and the involvement of qualified personnel to assist, such as Human Resources or Legal Counsel. The investigation will be kept confidential and disclosed only on a need-to know basis. Please note, however, that the respondent may be made aware of the complainant’s identity. The Company will also keep a record of the investigation, including documenting all interviews and evidence, so that the complainant may track its progress.
Upon completion of the investigation, the Company will take any action deemed fit, based on the evidence collected, including termination of the offending employee or reports to law enforcement.
If the Company finds that the behavior does not rise to the level of legally-actionable discrimination or harassment, but may do so if left unchecked, the Company will respond appropriately.
If any employee reporting a complaint under this section believes the Company’s response has not been adequate, that employee may involve law enforcement as they deem necessary in their sole and exclusive discretion. Employees may also make complaints to the Equal Employment Opportunity Commission (EEOC), in their sole and exclusive discretion.
Anti-Retaliation Policy: The Company prohibits retaliation against any employee who has reported a violation under this Policy, any employee who has participated in an investigation that came about as a result of a reported violation, or the family member of any such employee. Retaliation is prohibited for the following (by way of example only):
- Filing a complaint with the Company
- Filing a complaint with a government agency
- Testifying in any capacity 4/4
- Cooperating or participating in a government agency’s investigation
Communication: It is critical that all Employees communicate with the Company regarding any instances of discrimination, harassment, or retaliation. We are only able to assist Employees if we are made aware of the problem. It is your responsibility to bring these concerns to us.
No Limitation: Nothing in this Policy is designed to replace or limit any legal rights employees may have to seek remedies under applicable law or rule.