COPC Handbook April 2025 Q2

3.11 (CONT.)

3.11.2.1 Sexual Harassment Prevention Sexual harassment constitutes discrimination and is illegal under federal, Ohio and local laws. Title VII of the Civil Rights Act of 1964 recognizes two types of sexual harassment: a) quid pro quo, and b) hostile work environment. Sexual harassment may include a range of subtle and not-so-subtle behaviors and may involve individuals of the same or different genders. Depending on the circumstances, these behaviors may include, but are not limited to, unwanted sexual advances or requests for sexual favors; sexual jokes and innuendos; verbal abuse of a sexual nature; commentary about an individual’s body, sexual prowess, or sexual deficiencies; leering, whistling, or touching; insulting or obscene comments or gestures; displays in the workplace of sexually suggestive objects or pictures; and other physical, verbal, or visual conduct of a sexual nature. 3.11.3 Workplace Bullying Prevention COPC defines bullying as repeated inappropriate behavior, either direct or indirect, whether verbal, physical or otherwise, conducted by one or more persons against another or others at the place of work and/or in the course of employment. Such behavior violates the Company’s standards of conduct, which clearly state a minimum expectation that all employees will be treated with civility and respect. The purpose of this policy is to communicate to all employees that the Company will not tolerate behaviors in the workplace which are considered to be of a bullying nature. Any employee who is found to be in violation of this policy may be disciplined, up to and including termination of employment. Bullying may be intentional or unintentional; however, where a complaint of bullying is alleged, the intention of the alleged bully is irrelevant and will not be given consideration when determining appropriate disciplinary action. As in sexual harassment, it is the effect of the behavior upon the individual that will be considered and evaluated. 3.11.4 Individuals and Conduct – Who does the policy apply to? These policies apply to all applicants and employees, whether related to all conduct engaged in by fellow employees or by someone not directly connected to COPC (i.e., outside vendor, consultant, patient).

Sexual harassment may include unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when, for example: ● submission to such conduct is made either explicitly or implicitly, a term or condition of an individual’s employment ● submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting an individual ● 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 COPC considers the following types of behaviors examples of bullying. These are only examples and do not constitute an exhaustive list: ● Verbal bullying: Slandering, ridiculing, or maligning a person or their family; persistent name calling that is hurtful, insulting, or humiliating; using a person as the butt of jokes; abusive and offensive remarks ● Physical bullying: Pushing, shoving, kicking, poking, tripping, assault, or threat of physical assault; damage to a person’s work area or property ● Gesture bullying: Nonverbal threatening gestures or glances that convey threatening messages ● Exclusion: Socially or physically excluding or disregarding a person in work-related activities ● Social media bullying: Posting any threatening messages or forms of harassment or discrimination against another employee, vendor, or patient via social media outlets

Conduct prohibited by these policies is unacceptable in the workplace and in any work- related setting outside the workplace, including, but not limited to, business trips, business meetings, and business-related social events.

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