Anti-Harassment Policy

CONEXXUS, INC.
ANTI-HARASSMENT POLICY
REVISED DECEMBER  21, 2017

Conexxus expressly prohibits any form of employee discrimination or employee harassment, including any form of unlawful employee harassment based on race, color, religion, sex, national origin, age, disability, status as a Vietnam-era or special disabled veteran, or status in any group protected by state or local law.

Sexual Harassment

With respect to sexual harassment, Conexxus prohibits the following:

  1. Unwelcome sexual advances, requests for sexual favors; and all other verbal or physical conduct of a sexual or otherwise offensive nature, especially where:
    • Submission to such conduct is made either explicitly or implicitly a term or condition of employment
    • Submission to or rejection of such conduct is used as the basis for decisions affecting an individual’s employment, or
    • Such conduct has the purpose or effect of creating an intimidating, hostile, or offensive working environment
  2. Offensive comments, jokes, innuendos, and other sexually oriented statements.

Examples of the types of conduct expressly prohibited by this policy include, but are not limited to, the following:

  • Touching, such as rubbing or massaging someone’s neck or shoulders, stroking someone’s hair, or brushing against another’s body
  • Sexually suggestive touching
  • Grabbing, groping, kissing, fondling
  • Violating someone’s “personal space”
  • Offensive whistling
  • Lewd, off-color, sexually oriented comments or jokes
  • Derogatory comments or jokes about any person’s race, religion, ethnicity, sexual orientation, and the like
  • Foul or obscene language
  • Leering, staring, stalking
  • Suggestive or sexually explicit posters, calendars, photographs, graffiti, cartoons
  • Unwanted or offensive letters or poems
  • Sitting or gesturing sexually
  • Offensive e-mail or voice-mail messages
  • Sexually oriented or explicit remarks, including written or oral references to sexual conduct, gossip regarding one’s sex life, body, sexual activities, deficiencies, or prowess
  • Questions about one’s sex life or experiences
  • Repeated requests for dates
  • Sexual favors in return for employment rewards, or threats if sexual favors are not provided
  • Sexual assault or rape

Responsibility for Compliance

Each member of management is responsible for creating an atmosphere free of discrimination and harassment, sexual or otherwise.  Further, employees are responsible for respecting the rights of their co-workers.

Filing of Complaints

If an employee experiences any job related harassment based on one’s sex, race, national origin, disability, or another factor, or believes he/she has been treated in an unlawful, discriminatory manner, the incident should be promptly reported to the Vice President of Human Resources or another designated organization Harassment Officer.  This policy applies to all incidents of alleged discrimination or harassment, including those which occur off-premises, or off-hours, where the alleged offender is a supervisor, co-worker, or even a non-employee with whom the employee is involved, directly or indirectly, in a business or potential business relationship.

Should the alleged discrimination or harassment occur at a time other than one’s normal business hours, a complaint should be filed as early as practicable on the first business day following the alleged incident.

Please understand that Conexxus takes complaints of discrimination and harassment very seriously.  Consequently, there is no need to follow any formal chain of command when filing a complaint or when discussing or expressing any issue of concern regarding alleged discrimination or harassment; an employee may bypass anyone in one’s direct chain of command and file a complaint or discuss or express any issue of concern with any member of management.  Conexxus will undertake an investigation of any complaints.  All employees have a duty to cooperate with Conexxus in connection with any such investigation.

Confidentiality

All complaints will be kept confidential to the maximum extent possible.

Disciplinary Action

If Conexxus determines that an employee is guilty of discriminating against or harassing another individual, appropriate disciplinary action will be taken against the offending employee, up to and including termination of employment.

No Retaliation

Conexxus prohibits any form of retaliation against any employee for filing a complaint under this policy or for assisting in a complaint investigation.

However, if after investigating any complaint of harassment or unlawful discrimination, Conexxus determines that the employee knowingly made a false complaint or that an employee has provided false information regarding the complaint, disciplinary action may be taken against the individual who filed the complaint or who gave the false information.

If you have any questions concerning this policy, please contact the Vice President of Human Resources or another designated organization Harassment Officer.