COPC Handbook December 2023 Q4

3.10 (CONT.)

3.10.2.1 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. 3.10.3 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. 3.10.4 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

3.10.5 Reporting an Incident of Harassment, Discrimination, Retaliation or Bullying COPC strongly encourages the reporting of all perceived incidents of discrimination, harassment, sexual harassment, retaliation, and/or bullying regardless of the alleged offender’s identity or 3.10.5.1 Complaint Procedure COPC strongly encourages the prompt reporting of complaints and/or concerns in order to quickly and effectively take actions which ultimately will resolve the complaint. Employees who feel they have either witnessed or been subjected to incidents of unwelcome or illegal harassment, sexual harassment, discrimination, bullying, or retaliation should report the incident to either their direct supervisor or to Human Resources. All reported allegations of harassment, discrimination, retaliation, or bullying will be promptly investigated. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have relevant knowledge with which to aid in the investigation. COPC will fully maintain confidentiality throughout the investigatory process to the extent that is possible, consistent with ensuring a thorough

position. Individuals who believe they have been the victim of such conduct should discuss these concerns with their Direct Supervisor or a member of the Human Resources Department.

investigation and appropriate corrective action. Confidentiality cannot be guaranteed in all instances, however, and is dependent upon the severity of the situation and the steps required to resolve the issue. Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of a claim of harassment or discrimination is a serious violation of this policy and, like harassment or discrimination itself, is subject to disciplinary action, up to and including termination of employment. Acts of retaliation should be reported immediately and will be promptly investigated and addressed. Employees who make false or malicious complaints of harassment, discrimination, or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) may be the subject of appropriate disciplinary action, up to and including termination of employment.

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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Questions and concerns can be directed to your immediate supervisor, Human Resources (614) 304-2080 or the Compliance Hotline (866) 539-5813

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