ABC COMPANY

POLICY GUIDE REGARDING INAPPROPRIATE CONDUCT

Manager Guide to Respect and Non-Harassment in the Workplace

ABC Company has a longstanding commitment to a work environment that respects the
dignity and value of each individual. Beyond respecting the differences among us, and
beyond seeking to understand and appreciate the value of diversity in today’s business
environment, the Company wishes to prevent inappropriate behavior in the workplace.
The Company strictly prohibits inappropriate actions, words, jokes or comments based
on an individual’s sex, race, ethnicity, age, religion, disability or any other legally-
protected characteristic. Whether technically lawful or not, inappropriate behavior is
prohibited by this policy guide.

The Company does not put up with unlawful harassment.

As part of seeking to foster an environment of respect for the individual and diversity in
the workplace, the Company will not condone or tolerate unlawful harassment, including
sexual harassment. Sexual harassment occurs when unwelcome conduct of a sexual
nature becomes a condition of employment, affects employment decisions regarding an
employee, or creates an intimidating, hostile or offensive working environment. All
employees are expected to act appropriately towards their fellow employees and third
party customers or vendors.

Don’t be involved in inappropriate behavior.

Let us be clear about what we’re asking. DON’T treat others inappropriately and DON’T
harass someone because of sex, race, ethnicity, age, religion, disability or any other
legally-protected characteristic. That includes:

- Calling people inappropriate names

- Making fun of people because of characteristics like those listed above
- Touching people inappropriately
- Sending inappropriate or sexual e-mails
- Exhibiting sexual pictures, including on your computer
- Assessing pornographic websites
- Taking other inappropriate actions, including sexual behavior

Please report inappropriate behavior immediately.

The Company understands that it can be awkward or uncomfortable to report

inappropriate behavior, including sexual harassment. However, ABC desires to ensure
that such behavior does not occur here and, if it does occur, to take timely and reasonable
steps to solve such problems. The Company cannot respond to inappropriate behavior
unless it knows of such behavior and we truly and sincerely want your assistance in that
regard.
Anyone who believes he or she is being subjected to inappropriate behavior, including
sexual harassment, should immediately notify his or her manager, another member of
management, or Human Resources. Employees also should notify management or
Human Resources if they have been treated inappropriately by a non-Company
employee, vendor or customer. If an employee’s manager is involved in the inappropriate
behavior, the employee should immediately and directly contact Human Resources.
Finally, anyone who witnesses inappropriate behavior, including sexual harassment,
should report that behavior to management or Human Resources.

What will happen after a report is made?

When a concern is reported, a reasonable investigation will be conducted on a timely

basis, with as much confidentiality as can reasonably be maintained in the investigatory
process. The investigation is usually conducted by Human Resources. Violations of this
policy guide will be treated as disciplinary infractions. Offenders are subject to discipline
up to and including termination of employment.

Retaliation also is prohibited.

Retaliation against an employee who raises a concern under this policy guide is also
against Company policy and will not be tolerated. If retaliation occurs, the Company will
take action. Please do not be afraid to raise concerns of retaliation if such concerns arise.

What the Company expects of managers in addition to the above.

As a manager, you have an important responsibility to make sure that the Company
complies with its legal duties regarding harassment claims. To assist you in your
everyday operations, remember the following tips to help keep the Company in
compliance with the law:

(1) Understand the Company’s harassment policy and talk to Company employees if
they raise questions (or direct them to Human Resources);

(2) Make sure you abide by this policy guide;

(3) If a concern is made to you about inappropriate behavior, harassment or

retaliation, contact Human Resources as soon as you reasonably can so that they
can conduct a timely investigation. You must do this even if the employee who is
raising the concern tells you that he or she doesn’t want you to do anything. The
Company’s legal duties may begin upon notice of a concern, even if the employee
asks for no action to be taken;

(4) Coach and, where appropriate, involve Human Resources in dealing with and
potentially disciplining workers who are involved in sexual, racial or other
inappropriate actions and discussions. Don’t wait for someone to complain. If
 you are aware of such issues, deal with them proactively or seek assistance from
Human Resources.

(5) Support Human Resources in investigating and taking prompt and effective
remedial action, where needed;

(6) Follow up to ensure that those remedial actions are working; and

(7) Help ensure that no retaliation occurs regarding employees who raise concerns.