An Example

Equal Opportunity Policy states that all managers must ensure equal opportunity in the conduct of all our business activities without regard to an individual's race, color, religion, sex, national origin, veteran status, or handicap. Included in this commitment is that there will be an environment free of harassment. The Equal Employment Opportunity Commission has issued specific guidelines concerning sexual harassment. Essentially, these guidelines state that "unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature" will be considered harassment when"

• "Submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment."

Or

• "Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting an individual."

Or

• "Such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile or offensive working environment."

The Company is in full agreement with the intent of these guidelines and is committed to maintaining a workplace where each employee's privacy and personal dignity are respected and protected from offensive or threatening behavior.

If any employee believes that he or she has been subjected to conduct which may constitute sexual harassment, that employee should immediately report the offensive conduct to his or her immediate supervisor or manager. If a complaint arises because of the complaint of the employee's supervisor or manager, the employee should contact the local EEO Coordinator who, in turn, will advise the employee and consult with the appropriate level of local management to resolve the issues surrounding the complaint. It is important that all parties involved in a complaint remain aware of the need to maintain confidentiality to the greatest extent possible while the complaint is being investigated and evaluated.

After a prompt investigation of the employee's complaint has been concluded, the employee will be advised of the results of that investigation. Based on a finding of reasonable evidence that sexual harassment has occurred, the Company will take the necessary and appropriate action against the offending party. Employees are assured that there will be no retaliation against any employee who makes a complaint with the reasonable belief that sexual harassment has occurred. Managers and supervisors have a responsibility to communicate the Company's position on sexual harassment to all employees and will be held accountable for ensure compliance with these guidelines in their area of responsibility. Managers and supervisors are also encouraged to consult with the local EEO Coordinator in seeking assistance in complying with the requirements of these guidelines and other matters relating to equal employment opportunity.

(Howard Parker - Chicago)

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