Anti-Harassment & Anti-Discrimination Policy

Comprehensive anti-harassment policy meeting EEOC guidance and state-specific requirements (CA, NY, IL training mandates). Defines prohibited conduct, reporting channels, investigation process, and anti-retaliation protections.

Purpose

• This policy establishes the organization's commitment to a workplace free from harassment, discrimination, and retaliation. It is designed to comply with applicable federal, state, and local employment laws, including **Title VII of the Civil Rights Act of 1964**, EEOC guidance on harassment, and state-specific requirements in California, New York, and Illinois. The policy provides clear standards of conduct, reporting channels, investigation procedures, and corrective action expectations. It also supports a respectful workplace and helps ensure that all employees understand their rights and responsibilities.

Scope

• This policy applies to all employees, applicants, interns, contractors, temporary workers, volunteers, managers, supervisors, and anyone else conducting business on behalf of the organization. It applies to conduct that occurs: - In the workplace - During work-related travel or events - In virtual meetings, messaging platforms, email, and other electronic communications - Off-site when the conduct affects the workplace or employment relationship **California employees:** Additional training, notice, and complaint-handling requirements may apply under the California Fair Employment and Housing Act (FEHA) and related regulations. **New York employees:** Harassment prevention training and policy distribution requirements may apply under the New York State Human Rights Law. **Illinois employees:** Harassment prevention training requirements may apply under the Illinois Human Rights Act and related state rules.

Definitions

• For purposes of this policy: - **Protected class** means a characteristic protected by law, including race, color, religion, sex, pregnancy, sexual orientation, gender identity or expression, national origin, ancestry, age, disability, genetic information, marital status, military or veteran status, citizenship status, or any other status protected by applicable law. - **Harassment** means unwelcome conduct based on a protected class that is severe or pervasive enough to create a hostile work environment, or that results in an adverse employment action. - **Quid pro quo harassment** means a request for sexual favors or other conduct tied to employment benefits, threats, or decisions. - **Hostile work environment** means unwelcome conduct that unreasonably interferes with work performance or creates an intimidating, hostile, or offensive work environment. - **Discrimination** means unfavorable treatment in hiring, compensation, promotion, discipline, termination, assignments, or other terms and conditions of employment because of a protected class. - **Retaliation** means any adverse action taken because a person reported a concern, participated in an investigation, requested a reasonable accommodation, or opposed conduct they reasonably believed violated this policy. - **Good-faith report** means a report made honestly, even if the concern is not ultimately substantiated. - **Bad-faith report** means a knowingly false report made to harm another person or to evade accountability.

Policy Statement

• The organization prohibits harassment, discrimination, and retaliation in any form. All employment decisions must be based on legitimate business reasons and job-related criteria, consistent with applicable law. Prohibited conduct includes, but is not limited to: - Offensive jokes, slurs, epithets, or insults - Unwanted touching, blocking movement, or physical intimidation - Displaying or sharing offensive images, memes, or messages - Repeated unwanted comments about appearance, body, identity, or personal life - Sexual advances, requests for sexual favors, or suggestive conduct - Misgendering, deadnaming, or mocking a person's protected status - Excluding or isolating a person because of a protected characteristic - Retaliating against a person for making a complaint or participating in an investigation This policy applies to conduct by coworkers, supervisors, managers, customers, vendors, clients, and other third parties when the conduct affects the workplace.

Reporting Procedure

• Employees are encouraged to report concerns as soon as possible. Reports may be made verbally or in writing through any of the following channels: - Direct manager or supervisor - Human Resources - Compliance Officer or designated ethics hotline - Any manager in the reporting chain A report should include, when possible: - The names of the people involved - A description of the conduct - Dates, times, and locations - Any witnesses or supporting documents If the complaint involves the employee's direct supervisor, the employee may report to HR, another manager, or the Compliance Officer. Employees are not required to confront the person involved before reporting. The organization will make reasonable efforts to keep reports confidential to the extent possible while still conducting a prompt and thorough investigation. **California employees:** The organization will provide information about available state complaint channels and any required notices. **New York employees:** The organization will distribute the required anti-harassment policy and training materials as applicable. **Illinois employees:** The organization will provide required training and complaint information as applicable.

Investigation Procedure

• The organization will promptly review all complaints and determine the appropriate investigative steps. Investigations will be conducted in a fair, impartial, and documented manner. Investigation steps may include: - Initial intake and risk assessment - Interim protective measures, when necessary - Interviews with the complainant, respondent, and witnesses - Review of documents, messages, recordings, or other evidence - Credibility assessment based on the totality of the facts - Written findings and recommended corrective action Investigations should be completed as quickly as practicable, consistent with the need for a thorough review. The organization may place employees on administrative leave or implement temporary separation measures when appropriate and lawful. The organization will maintain investigation records in accordance with its retention schedule and applicable privacy requirements.

Anti-Retaliation Protections

• Retaliation is strictly prohibited. No employee will be disciplined, demoted, denied opportunities, harassed, or otherwise adversely treated for: - Making a good-faith complaint - Participating in an investigation - Opposing conduct reasonably believed to violate this policy - Requesting a reasonable accommodation - Supporting another employee's complaint Any employee who believes they have experienced retaliation should report it immediately using the reporting channels above. Retaliation may result in disciplinary action up to and including termination.

Training and Prevention

• Managers and supervisors are responsible for maintaining a respectful workplace and escalating concerns promptly. They must not ignore, minimize, or retaliate against complaints. The organization will provide harassment prevention training to employees and supervisors as required by applicable law. Training content may include: - Recognizing prohibited conduct - Reporting obligations and escalation paths - Supervisor duties and response expectations - Anti-retaliation protections - Bystander intervention and respectful workplace behaviors **California employees:** Supervisor and employee training must comply with California FEHA training requirements, including timing and frequency where applicable. **New York employees:** Training must comply with New York State Human Rights Law requirements, including annual training where applicable. **Illinois employees:** Training must comply with Illinois Human Rights Act requirements and any applicable annual training standards.

Compliance / Discipline

• Violations of this policy may result in corrective action up to and including termination of employment, removal from assignments, suspension of access, or other appropriate measures. Discipline will be based on the severity of the conduct, prior history, credibility findings, and the need to prevent recurrence. The organization may also require coaching, counseling, training, a documented warning, or a performance improvement plan (PIP) where appropriate. False or bad-faith reports may also result in discipline. However, a report made in good faith will not be treated as false merely because the allegation is not substantiated.

Roles & Responsibilities

• **Employees** must treat others respectfully, comply with this policy, and report concerns promptly. **Managers and supervisors** must model compliant behavior, respond immediately to complaints, preserve evidence, and escalate issues to HR or Compliance without delay. **Human Resources** is responsible for intake, investigation coordination, documentation, corrective action support, and policy administration. **Compliance Officer / Legal / Designated Investigator** is responsible for oversight of serious or sensitive matters, trend review, and ensuring consistent application of the policy. **Policy holder** is responsible for maintaining the policy, coordinating training, and ensuring periodic review for legal updates.

Review & Revision

• This policy will be reviewed at least annually and updated as needed to reflect changes in law, regulatory guidance, or organizational practices. Any material revisions should be communicated to affected employees, and acknowledgement may be required upon update. Jurisdiction-specific addenda may be issued for California, New York, Illinois, or other locations where local law imposes additional requirements.