Harassment and Complaint Protocol

Confidentiality

All complaints and investigations are treated confidentially to the extent possible, and information is disclosed strictly on a need-to-know basis. The identity of the complainant is usually revealed to the parties involved during the investigation, and the company will take adequate steps to ensure that the complainant is protected from retaliation during and after the investigation. All information pertaining to a complaint or investigation under this policy will be maintained in secure files.

Complaint procedure

The company has established the following procedure for lodging a complaint of harassment, discrimination or retaliation. The company will treat all aspects of the procedure confidentially to the extent reasonably possible.

1. Complaints should be submitted as soon as possible after an incident has occurred, preferably in writing, to the complainant’s direct report. Should the incident involve the direct report, the complainant should seek out the General Manager, Regional Manager, President or CEO of the company. In the event an employee refuses to provide information in writing, the person investigating will dictate the verbal complaint.

2. Upon receiving a complaint or being advised by a supervisor or manager that a policy violation may be occurring, the person receiving the complaint will notify his/her supervisor and review the complaint together.

3. An investigation will ensue to determine whether there is a reasonable basis for believing that the alleged violation of this policy occurred.

4. If necessary, the complainant and the respondent will be separated during the course of the investigation, either through internal transfer or administrative leave.

5. The investigation will include interviews with the complainant, the respondent and any witnesses to determine whether the alleged conduct occurred.

6. Upon conclusion of an investigation, a written report of findings will be completed. If it is determined that a violation of this policy has occurred, appropriate disciplinary action will be taken. The appropriate action will depend on the following factors:

a) the severity, frequency and pervasiveness of the conduct;

b) prior complaints made by the complainant;

c) prior complaints made against the respondent; and

d) the quality of the evidence (e.g., firsthand knowledge, credible corroboration).

If the investigation is inconclusive or if it is determined that there has been no violation of policy but potentially problematic conduct may have occurred, appropriate preventive action may be recommended.

7. The CEO and/or President will review the investigative report and any statements submitted by the complainant or respondent, discuss results of the investigation with management as appropriate, and decide what action, if any, will be taken.

8. Once a final decision is made the CEO and/or President will determine the appropriate person to meet with the complainant and the respondent separately and notify them of the findings of the investigation. If disciplinary action is to be taken, the respondent will be informed of the nature of the discipline and how it will be executed.

Adopted 09/22/2022