The Company is committed to providing a workplace that treats all employees with dignity and respect and is free from all forms of harassment, discrimination, and retaliation. Harassment, discrimination, and retaliation are inconsistent with the Company’s philosophy, undermine employee morale, and interfere with productivity. Conduct under this policy that is harassing or discriminatory based on a person’s actual or perceived race, religious creed, color, national origin, ancestry, immigration or citizenship status, age, physical disability, mental disability, medical condition, genetic information, marital status, family status, caregiver status, sex (including pregnancy status, childbirth, breastfeeding, and related medical conditions, as well as sex stereotyping), gender, gender identity, gender expression, sexual orientation, sexual and reproductive health decisions, reproductive health decision making, hair texture or hairstyles, height, weight, military or veteran status, political affiliation, arrest or conviction record, union membership, unemployment status, credit history, status as a victim of domestic violence, stalking, or sexual offenses, or any other legally protected characteristic (collectively the “Protected Characteristics”) may violate federal, state and/or local laws. The Company does not tolerate such harassment or discrimination by managers, supervisors or co-workers, and will attempt to prevent and address any harassment or discrimination by non­ employees (including independent contractors, vendors, consultants, and other non-employee third parties who provide services to the Company). The Company also does not tolerate retaliation against any employee for engaging in protected activity as defined below or under applicable law. The Company prohibits such harassment, discrimination, and retaliation against job applicants, employees, interns, volunteers, and other non-employee third parties with whom you interact in the workplace (including independent contractors, vendors, and consultants).

Keep in mind that your workplace may at times extend beyond the Company’s premises, including, for example, to Company-sponsored meetings or events relating to the Company’s business conducted away from the Company’s premises. Also, conduct that may not be unlawful (e.g., because it is not unwelcome or does not rise to the legal standard of being unlawful) may nevertheless violate this policy.

Harassment: The Company prohibits harassment based on the Protected Characteristics in any form, including verbal, visual, or physical harassment. Conduct that may violate this policy includes:

  • Verbal conduct: using demeaning, derogatory, degrading, obscene, or threatening terms; making comments, epithets, slurs, or jokes; offering or denying employment benefits in exchange for sexual favors; making or threatening reprisals after receiving a negative response to a sexual advance; making unwanted sexual advances or flirtations, lewd or suggestive sexual comments or innuendos, or jokes of a sexual nature; making comments about an individual’s appearance, body, or physical attributes, or style of dress; teasing someone because of their actual or perceived gender; calling someone offensive nicknames; persistent or repeated compliments or requests for dates; engaging in abusive or humiliating behavior, including shouting at or targeting an individual in public or private settings;
  • Visual conduct: displaying or forwarding demeaning, derogatory, degrading, obscene, or pornographic letters, notes, emails, instant messages, text messages, screen savers, images, invitations, statements, or pictorial depictions, including sexually explicit, violent, or offensive pictures, videos, objects, cartoons, posters, or other material of a similar nature; leering or making sexual or obscene gestures; and
  • Physical conduct: assaulting another person; impeding or blocking movements; unwanted touching, including of a sexual nature (e.g., massaging someone’s shoulders or intentionally brushing up against another person’s body).

Sexual harassment is specifically prohibited under this policy and is unlawful under federal, state, and local laws. Sexual harassment includes the conduct described above, and also situations where: (i) submission to the conduct is made a term or condition of employment, including continued employment or promotion opportunities; (ii) submission to or rejection of the conduct is used as the basis for threatening or taking any employment decisions; or (iii) the conduct has the purpose of interfering or tends to interfere with work performance or tends to create an intimidating, hostile, or offensive working environment. Conduct need not be directed at a particular individual to constitute sexual harassment. Sexual harassment also does not need to be motivated by sexual desire to violate this policy, and is not limited to opposite genders.

Discrimination: The Company prohibits discrimination (i.e., treating someone differently or less favorably) based on the Protected Characteristics and is committed to adhering to and enforcing its obligations under applicable non-discrimination laws. The Company recruits, hires, trains, transfers, promotes, compensates, and terminates employees without regard to any Protected Characteristic unless allowable under applicable law (e.g., certain convictions when all relevant circumstances have been considered).

Retaliation: The Company prohibits retaliation for engaging in protected activity, including opposing harassment or discrimination, requesting an accommodation, making a complaint under this policy, or participating in an investigation, proceeding, or hearing conducted by the Company, the Equal Employment Opportunity Commission (“EEOC”), or any other federal, state, or local governmental agency.

Bystander Intervention: The Company strongly encourages bystanders who witness inappropriate conduct to take reasonable and prudent steps to see that the conduct immediately ceases. Bystander intervention refers to safe and appropriate actions that may be taken to prevent or lessen harm where there is a risk of discrimination, harassment, or retaliation of others. Such actions may include: (1) speaking up, such as confronting the person engaging in the inappropriate conduct in the moment or addressing their behavior with them afterwards; (2) stepping in, such as causing a distraction to help a victim get out of harm’s way; and/or (3) offering other assistance, such as acknowledging and listening to the victim and suggesting they make a complaint. Do not intervene in a way that puts yourself or others at risk of physical harm.

Procedure for Addressing Harassing, Discriminatory or Retaliatory Conduct: In all cases in which you believe you have experienced or witnessed harassment, discrimination, or retaliation, including as a bystander, you must immediately report the facts and the names of the individuals involved to a manager in the Company’s Human Resources Department. If you are uncomfortable reporting your complaint to Human Resources, you must contact an attorney in the Company’s Legal Department, who will identify an appropriate person to address your complaint. Members of management who learn of harassing, discriminatory, or retaliatory conduct from any source are required to immediately inform a manager in the Human Resources Department. If a manager is uncomfortable reporting the complaint to Human Resources, they must report it to an attorney in the Company’s Legal Department.

You are encouraged to report concerns under this policy using the Complaint Form that may be found at Appendix B to the Company’s Employee Handbook.

In addition to the above, you may also report concerns under this policy via the Company’s “Alertline.” Reports made through the Alertline may be made anonymously. The telephone number for the Alertline is 844-809-9347; you may also access the Alertline online at

Investigation: Reported incidents of harassment, discrimination, and retaliation will be investigated in a fair, complete, and timely manner by impartial, qualified personnel, with due process given to all parties involved and due consideration given to the surrounding circumstances. Steps that may be taken during an investigation include:

  • The investigator will promptly review the allegations and take any interim actions as appropriate. If the incident is reported verbally, the investigator will provide the individual the opportunity to document the incident in writing. If the individual declines, the investigator will document the incident based on the oral reporting.
  • If documents, emails, phone records, or other evidence is relevant to the investigation, the investigator will take steps to collect and preserve such evidence, including requesting it from the person making the report or any relevant witnesses, or obtaining such evidence independently.
  • The investigator will interview the person making the report and all other relevant witnesses, including the subject of the report.
  • Investigations will be documented for progress as appropriate; such documentation will be preserved in accordance with the Company’s Records Management policy.
  • The Company will maintain the confidentiality of the investigation to the extent possible, including the identity of the person making the report and the witnesses interviewed during the investigation. However, depending on circumstances of the allegations (e.g., when the alleged conduct involves only two individuals and there are no other witnesses), maintaining such confidentiality may not be possible.

All employees have an obligation to participate truthfully, accurately, and completely in all Company investigations. Without your full cooperation, the Company’s efforts to investigate and address reported incidents may be hindered. If the Company reasonably determines that a violation of this policy has occurred based on the investigation it has undertaken, the Company will take appropriate remedial action, up to and including immediate termination of employment. At the end of the Company’s investigation, the investigator will notify the person making the report that the investigation is completed and conclusions they have reached (e.g., whether the reported concerns have been substantiated). For privacy reasons, however, and consistent with applicable law, the investigator may be unable to provide specific information regarding remedial action taken as a result of the investigation.

The EEOC, Analogous State and Local Agencies, and Law Enforcement: Job applicants and employees who believe they have been unlawfully harassed, discriminated or retaliated against may file a complaint with the EEOC, which enforces Title VII of the 1964 Civil Rights Act and other federal anti-discrimination laws. The EEOC has the authority to endeavor to end unlawful employment practices it determines to have occurred by conference, conciliation, or persuasion, as well as the authority to seek remedies on behalf of employees or job applicants, including back pay and other monetary damages, fines, and orders relating to hiring or reinstatement, promotion, and/or changes to an employer’s policies or practices. For more information, please contact the EEOC at

In many states and cities there are government agencies that are analogous to the EEOC. These agencies are charged with enforcing state and/or local anti-discrimination laws, and usually have authority similar to the EEOC. For more information, please contact the government agency in your city and state, which contact information can be found on the Internet.

In addition to reporting conduct to federal, state, and/or local agencies, aggrieved individuals may also file private lawsuits in state and/or federal courts to enforce the protections afforded to them under the laws that prohibit unlawful harassment, discrimination, and retaliation.

Finally, certain conduct that may violate this policy may also violate state or local criminal laws, including conduct that involves unwanted touching (whether of a sexual nature or not), coerced confinement, or coerced sex acts. Under such circumstances, you may also file a complaint with your local police department.