Thursday, April 25th, 2019

Equal Employment Opportunity, Affirmative Action and Policy Against Discrimination, Harassment (Including Sexual Harassment) and Retaliation

A. Statement of Policy

AI is committed to the principle of equal employment opportunity, and it complies with all applicable laws which prohibit discrimination and harassment in the workplace.  Thus, ACCESS INTELLIGENCE strictly prohibits discrimination or harassment based on race, color, religion, national origin, ethnicity, sex, age, veteran status,  disability, genetic information, or any other characteristic protected by law (see the non-discrimination poster at your work location) in all terms, conditions and privileges of employment, including without limitation, recruiting, hiring, assignment, compensation, promotion, discipline, termination and other general conditions of employment.  This policy covers conduct occurring at AI’s office and all other locations where AI conducts business and to all work-related activities.

As an equal opportunity and affirmative action employer, AI affirms its long-standing commitment to maintain a diverse workforce reflective of the communities in which it operates, strives to maintain a business culture that recognizes the contributions and interests of diverse cultural and social groups, and seeks to maximize employee efforts by understanding individual differences and perspectives.  It is AI’s policy not merely to refrain from employment discrimination as required by federal, state, and local enactments, but to take affirmative action so that women, minorities, individuals with physical or mental disabilities, and veterans are afforded equal employment opportunity.

The Human Resources and Corporate Benefits Manager is also AI's Equal Opportunity/Affirmative Action Officer with responsibility to audit, report, and evaluate activities which pertain to our equal employment opportunity and affirmative action policies and objectives.

Employees interested in reviewing the Affirmative Action Plan for Individuals with Disabilities or the Affirmative Action Plan for Covered Veterans should contact the Human Resources and Corporate Benefits Manager during regular working hours. If you would like to be considered under either or both of these Affirmative Action Plans, please inform the Human Resources Department.  This is completely voluntary, and you will not be subject to adverse treatment whether you request or do not request to be considered.  Information submitted will be kept confidential except where necessary to comply with law.

B. Individuals Covered By This Policy

This policy covers all AI employees and applicants for employment.  AI will not tolerate discrimination or harassment, whether engaged in by fellow employees, supervisors or managers.  Nor will AI tolerate discrimination or harassment engaged in by non-employees who conduct business with AI to the extent that it affects any employee at AI.  While on the job, employees must not engage in any form of discrimination or harassment with respect to anyone, including other employees, customers, visitors, guests, or anyone with whom an employee comes into contact while on the job.  All managers and supervisors are responsible for preventing and eliminating discrimination and harassment at AI.

C. Forms of Harassment

While all forms of discrimination and harassment are prohibited, it is important to understand the types of conduct that may be viewed as harassment and which are not to be engaged in.

1. Non-sexual Harassment.  Forms of harassment that are prohibited include making, displaying or circulating (including through use of AI's computer, telephone, fax or other communications or information systems) epithets or derogatory statements, remarks, comments, jokes or slurs, posters, cartoons, drawings or other written materials that are based on a person's race, color, sex, ancestry, religion, national origin, disability or other protected status.

2. Sexual Harassment.  Sexual harassment includes but is not limited to unwelcome or unwanted sexual advances, requests for sexual acts or favors, offering employment benefits in exchange for sexual acts or favors, lewd or sexually-suggestive remarks, comments or jokes, display or circulation of pictures or written materials of a sexual nature (including through use of AI's computer, telephone, fax or other communications or information systems), actual or threatened retaliation, inappropriate physical contact or other verbal, written or physical conduct of a sexual nature when (i) submission to or rejection of this conduct by an individual is used explicitly or implicitly as a factor in decisions affecting hiring, evaluation, promotion, retention or other aspects of employment; or (ii) this conduct substantially or unreasonably interferes with an individual’s employment or creates an intimidating, hostile or offensive work environment.

D. Compliant Procedure

AI encourages individuals who believe that they are being subjected to discrimination or harassment to notify the offender that his or her behavior is unwelcome.  If for any reason an individual does not want to confront the offender directly, or if this approach does not successfully end the discrimination or harassment, the individual should promptly contact a member of the Human Resources Department, his or her immediate manager or any other managerial employees.  AI cannot act to prevent harassment if it is not made aware of a situation.

E. Protection Against Retaliation

AI prohibits and will not permit retaliation against any individual who makes a complaint under this policy, or anyone who has assisted a person making a complaint or provided information during an investigation under this policy.  Retaliation is a violation of the policy and should be reported immediately.  The same complaint and investigation procedures described herein will also apply to any complaint of retaliation.

F. Investigation

All reports of discrimination, harassment or retaliation will be promptly and thoroughly investigated.  The investigation may include interviews with any person having relevant information, including the complainant, the accused and any witnesses.

To the extent possible, AI will protect the confidentiality of the complaint.  Information concerning the complaint will be limited to those with whom it needs to be shared in order to investigate and respond to the complaint.

G. Disciplinary action

Upon completion of the investigation, appropriate action will be taken, which may include prompt and effective corrective action to stop the discrimination, harassment or retaliation.  Any individual found to have engaged in discrimination, harassment or retaliation will be subject to disciplinary action, up to and including termination.

Employees who have any questions about this policy should contact a member of the Human Resources Department.

H. Disability Accommodation

As an equal opportunity employer, AI does not discriminate on the basis of disability. Accordingly, AI provides reasonable accommodations as required by law to applicants for employment and employees with known disabilities to enable them to apply for employment, to be able to perform the essential functions of their jobs or to enjoy the benefits and privileges of employment.  We encourage applicants and employees to assist us in identifying accommodations that they may need. Any applicant or employee who believes that he or she needs an accommodation should inform a member of the Human Resources Department.  We cannot evaluate a need for an accommodation unless it is brought to our attention.

Any manager or supervisor who receives a request for an accommodation on the basis of a disability must promptly notify a member of the Human Resources Department.