Harassment Policy

As of ______________________

Scope

1. Covered Individuals
   

   The Policy applies to all employees, both supervisory and non-supervisory, and all other persons whom the Employer and its employees come into contact or interact with at work, including but not limited to clients, customers, suppliers, applicants, and visitors (the "Individuals").

2. Application of Policy
   

   This Policy applies to all kinds of harassment that occurs in the workplace. A workplace is defined as any location used for work-related activities, including physical offices, retail spaces, warehouses, remote or virtual offices, client sites, and other locations where business is conducted, during or beyond normal work hours.
   
   This Policy also applies to harassment that takes place in online and electronic communication channels and at work-sponsored events, such as social gatherings or corporate parties.

3. Definition of Harassment
   

   Harassment refers to any unwelcome conduct towards another person based on their status (e.g. race, color, religion, national origin, age,  disability, genetic information, or any other status protected by federal, state, or local law). It may also involve behavior that affects another’s ability to perform their job or duties, creates a hostile, abusive, or intimidating work environment, or results in an adverse employment decision against an employee.
   
   Harassment also includes sexual harassment which is defined as unwelcome sexual advances, requests for sexual favors, and other verbal or physical harassment of a sexual nature when submission to such conduct is imposed as a prerequisite for employment, influences employment opportunities, interferes with work, or contributes to an environment that is intimidating, hostile, or offensive.
   
   Behavior or conduct that constitutes harassment includes, but is not limited to:

   • any offensive language, including jokes, insults, racial or ethnic slurs, or derogatory remarks, that targets a person's protected status;
     
   • improper or unwelcome physical contact, which may be of an aggressive or sexual nature (e.g. touching, hugging, patting);
     
   • physical or sexual assaults or attempts to commit these assaults;
     
   • displaying, distributing, or sending sexually suggestive messages, images, or other forms of multimedia;
     
   • bullying, stalking, or intimidating others in person or online;
     
   • intentionally undermining or damaging another person's work;
     
   • spreading rumors or gossip about another person;
     
   • teasing or belittling someone because of their physical or mental disabilities;
     
   • mocking or ridiculing someone for their religious or cultural beliefs or practices;
     
   • imposing one’s religious or political beliefs on another as a condition of hiring or continuous employment; and
     
   • any other form of behavior, including verbal, physical, or visual actions, that could be considered discriminatory or constitutes harassment.
     

Reporting Procedure

1. Internal Complaints
   
   1. Filing Complaints
      

      Any person who feels that they have been harassed, discriminated against, or have witnessed any harassment, should take the following actions:

      • Confront the Harasser
        

        If they feel safe and comfortable, directly communicate to the alleged harasser that their behavior is not welcome and must stop.
        
        This approach is appropriate if the conduct is not considered serious or habitual, such as petty slights or annoyances, and/or if the behavior only involves Individuals employed by the Employer within the same organization level.
        
        Individuals who choose this approach are advised to record the specifics of their interaction with the alleged harasser. This documentation will be helpful in case the behavior persists or the issue is revisited in the future.
        

      • Report to the Immediate Supervisor
        

        If the conduct is serious, persistent, or if additional employees or non-employees are involved, the complainant must report the behavior to their immediate supervisor.
        
        Supervisors who receive complaints or reports of harassment are required to immediately report the matter to the Human Resources Department so an investigation can be promptly conducted.

      • Report to Another Supervisor or the Human Resources Department
        

        If the complainant’s immediate supervisor is involved or unavailable, the complainant must report the behavior to another supervisor they feel comfortable with or to the Human Resources Department.
        
        If the complainant feels uncomfortable or unsafe communicating with the alleged harasser or their immediate supervisor, or if they are unsure if the conduct they experienced or witnessed violates the Policy, the complainant can directly escalate the matter to the Human Resources Department. This option is available regardless of the severity of the behavior or the identity of the persons involved.

      Complaints addressed to the Human Resources Department must be submitted to ___________________ at ____________________________.

   2. Investigating Complaints
      
      • Opportunity To Be Heard
        

        The Employer is committed to conducting the investigation of the complaint in a fair, prompt, and thorough manner.
        
        The Employer will ensure that the persons assigned to investigate the complaint are unbiased and have no prior involvement in the matter. In cases where internal impartiality cannot be assured, the Employer may engage an external, independent investigator to handle the matter.
        
        The investigator will give all relevant parties the opportunity to be heard. This includes providing oral or written accounts of the incident(s), submitting any relevant documentation (e.g. copies of e-mails, photographs of injuries, etc.), and introducing witnesses who can contribute to the full understanding of the incident(s).
        

      • Confidentiality
        

        The Employer takes all harassment complaints seriously and will take all reasonable measures to ensure that the identities of the complainant, the alleged harasser, and any witnesses, as well as the details of the complaint are treated with the highest level of confidentiality consistent with a comprehensive and fair investigation. Information will only be disclosed on a need-to-know basis to facilitate the investigation and resolution process, or as required by law.
        
        All parties involved in a harassment complaint are expected to maintain confidentiality. Any employee who discloses confidential information related to a complaint without authorization may be subject to disciplinary action, up to and including termination.

      • Preventive Measures
        

        The Employer will take necessary preventive measures while the investigation is pending to prevent any continuation of the alleged harassment and ensure the complainant feels safe in the workplace, such as temporarily transferring or re-assigning the alleged harasser. The Employer may also provide the complainant with supportive measures, such as counseling or other types of assistance, to help them cope with the experience.
        
        The Employer may place the alleged harasser in preventive suspension if the Employer believes that they pose a serious imminent threat to the life or property of the complainant, the Employer, or other employees.

   3. Resolving Complaints
      

      Upon completion of the investigation, the Employer will immediately provide the complainant with a detailed report of the findings and the next steps of the resolution process, including any corrective measures the harasser is required to undertake or disciplinary actions they will face.
      
      If the allegation of harassment is proven, the Employer will make sure that the harassment will no longer continue and that the harasser will be subjected to disciplinary action, up to and including termination.
      
      All records relating to the investigation, including reports, interview notes, and findings will be stored in a secure and confidential location, in accordance with the Employer's record-keeping policies and applicable federal, state, and local laws.

2. External Complaints
   

   Individuals are encouraged but not required to wait for the outcome of the investigation of their complaints before they pursue other available remedies under federal, state, or local law. Individuals may file their complaints with appropriate agencies should they feel the Employer has not acted promptly or effectively in addressing or correcting the situation.
   
   Individuals who work for employers with at least 15 employees may lodge their complaints with the US Equal Employment Opportunity Commission (EEOC) federal office or the nearest EEOC field office. Individuals may also file their complaints with their local Fair Employment Practice Agency (FEPA) or any other relevant local agencies that are near and available to them.
   

   • Equal Employment Opportunity Commission (federal office)
     131 M Street, NE
     Washington, DC 20507
     www.eeoc.gov
     www.eeoc.gov/field-office
     1-800-669-4000 / 1-800-669-6820 (TTY) / 1-844-234-5122 (ASL Video Phone)
     info@eeoc.gov

   • District of Columbia Office of Human Rights
     441 4th Street NW, Suite 570 North
     Washington, DC 20001
     www.ohr.dc.gov
     ohr.intake@dc.gov
     (202) 727-4559

3. False or Frivolous Complaints
   

   If, after the investigation, the Employer finds that an employee has reported a harassment complaint that is false or frivolous, lodged in bad faith, or accompanied by misleading or untrue information, the employee will be subjected to disciplinary action, up to and including termination.

Retaliation

The Employer does not tolerate any form of retaliation and will take all reasonable measures to protect Individuals who report or assist in the investigation of harassment or discrimination.

Retaliation is defined by the Employer as any intentional action taken by an Individual in response to a report made against them. This includes, but is not limited to, providing negative performance reviews, denying benefits or perks, transferring the complainant to a less desirable work location or assignment, and any other form of punishment or negative treatment.

Any employee who retaliates against another employee will be subject to disciplinary action, up to and including immediate termination.

The Employer will take all retaliation complaints seriously and investigate them promptly and thoroughly. If you feel another Individual has retaliated against you for reporting or participating in the investigation of an incident, please immediately file a complaint with the Human Resources Department.

Disciplinary Action

An employee who violates this Policy will be subjected to disciplinary action based on a range of factors, such as the severity of the offense and the employee’s disciplinary history. Disciplinary action may include, but is not limited to warnings, work suspensions, counseling, re-training, or termination.

The Employer will regularly evaluate an employee who was subjected to disciplinary measures to make sure that they are adhering to the changes outlined in the corrective action plan within the specified time frame and complying with this Policy.

In case the harassment was committed by a non-employee with whom the Employer or its employees interact or do business, the Employer will take appropriate actions to address and correct the situation. This includes conducting a thorough investigation of the complaint, implementing stricter anti-harassment measures, or if warranted, terminating the Employer’s business relationship with the harasser.

All disciplinary actions will be administered in accordance with federal, state, and local laws to ensure lawful and fair treatment of all employees.

Policy Review and Updates

This Policy will be reviewed and updated every year to accommodate any changes in applicable laws, regulations, and industry best practices relating to harassment and discrimination. The updates will also incorporate feedback from employees to ensure this Policy remains effective in fostering a respectful work environment.

Any changes to the Policy will be communicated to employees in a timely manner.

Related Company Policies

This Policy must be read together with the Employee Handbook, Code of Conduct, and other relevant company policies to guarantee a comprehensive understanding of workplace expectations, responsibilities, and behaviors, as well as compliance with organizational standards.

Governing Law

This Policy will be construed in accordance with and governed by the laws of the District of Columbia.

Inquiries

If you have any questions about the Policy, please contact ___________________________________, ____________________________, at _________________ or _________________________________.

ACKNOWLEDGMENT AND ACCEPTANCE FORM

I acknowledge that I received a copy of the Policy and that I understand I am fully responsible for reading the contents of the Policy.

I acknowledge that the Policy will not be interpreted as an employment contract, or an inducement for employment, nor will it guarantee my employment for any period of time.

I understand that by signing this Acknowledgement and Acceptance Form, I am agreeing to follow the Policy.