COPC Handbook August 2025 Q3

3.11

Discrimination, Harassment and Sexual Harassment, and Bullying Prevention Policies and Complaint Procedure

3.11.1 Retaliation COPC requires the reporting of all perceived incidents of discrimination or harassment. It is the policy of COPC to investigate such reports promptly and thoroughly. COPC prohibits 3.11.2 Harassment Prevention Harassment based on any protected characteristic is strictly prohibited. Under this policy, harassment is verbal, written, or physical conduct that degrades or shows hostility or aversion toward an individual because of their race, color, religion, sex, sexual orientation, gender identity, transgender identity or expression, national origin, age, disability, pregnancy, marital status, citizenship, genetic information, protected veteran status or any other characteristic protected by law, or that of their relatives, friends or associates, and that: a) has the purpose or effect of creating an intimidating, hostile or offensive work environment, b) has the purpose or effect of unreasonably interfering with COPC is committed to a work environment in which all individuals are treated with respect and civility. Every individual has the right to work in a professional environment which promotes equal employment opportunities and prohibits unlawful discriminatory practices, including the prevention of discrimination, harassment and sexual harassment, and bullying. This means actions and words which may be construed as harassing, degrading, and/or offensive will not be tolerated. COPC has developed this policy to ensure all employees work in an environment free from sexual harassment, unwelcome or unlawful harassment, discrimination, and/or retaliation. COPC will make every reasonable effort to

ensure that all concerned are familiar with these policies and are aware that all complaints will be investigated and resolved promptly. These policies should not and may not be used as a basis for excluding or separating individuals of any protected class (as outlined in section 1.4 Equal Opportunity Employer ) from participating in business or work-related social activities or discussions. In other words, no one should make the mistake of engaging in discrimination or exclusion to avoid allegations of harassment. The law and the policies of COPC prohibit disparate treatment based on any protected class with regards to terms, conditions, privileges, and advantages of employment.

retaliation against any individual who reports discrimination or harassment or who participates in an investigation of such reports.

an individual’s work performance, or c) otherwise adversely affects an individual’s employment opportunities. Harassing conduct includes, but is not limited to, epithets, slurs, or negative stereotyping; threatening, intimidating or hostile acts; degrading jokes; and written or graphic material that degrades or shows hostility or aversion toward an individual or group that is placed anywhere on COPC’s premises or circulated in the workplace, on Company time or using Company equipment by e-mail, phone (including voice messages), text messages, social networking sites, or other means.

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