Sexual Harassment Policy

Policy statement

The Company is committed to a workplace free of harassment. It is our policy to prohibit harassment of any employee, applicant, intern, or contractor based on a protected characteristic — including race, color, religion, sex, pregnancy, sexual orientation, gender identity or expression, national origin, age, disability, genetic information, veteran status, or any other characteristic protected by law. This policy applies to everyone, including managers, employees, and non-employees such as vendors, clients, and visitors.

What harassment is

Harassment is unwelcome conduct based on a protected characteristic that:

• makes submission to the conduct an explicit or implicit term or condition of employment;
• makes employment decisions affecting a person depend on submitting to or rejecting the conduct; or
• has the purpose or effect of unreasonably interfering with work or creating an intimidating, hostile, or offensive work environment.

It can take several forms:

• Verbal — slurs, jokes, derogatory or suggestive comments, threats, repeated unwelcome requests.
• Visual / written — offensive images, gestures, emails, messages, graffiti, or social-media posts.
• Physical — unwanted touching, blocking movement, or assault.

Sexual harassment is one form and is prohibited regardless of the genders of the people involved.

Reporting

Anyone who experiences or witnesses harassment should report it promptly. You may report to:

• your manager or supervisor;
• any other member of management; or
• Human Resources.

You never have to report to the person you are complaining about. If that person is your manager, take your report to another manager or Human Resources.

Investigation, confidentiality, and no retaliation

The Company will investigate reports promptly and impartially, and keep the matter as confidential as practical given the need to investigate. Retaliation is prohibited — no one will be punished for raising a good-faith concern or participating in an investigation. Anyone found to have violated this policy is subject to discipline, up to and including termination.

Manager responsibilities

Managers and supervisors must model appropriate conduct and immediately report any harassment they observe or that is reported to them to Human Resources — they may not sit on a complaint or handle it informally on their own (see the Manager's Guide to Preventing and Handling Harassment).