Anti-harassment Policy Guide For Managers

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 legallyprotected 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.