Was that Harassment Report

OUR POLICY AGAINST HARASSMENT

It is the policy and practice of Coltra to maintain and foster a work environment

in which all employees are treated with decency and respect. Accordingly, Coltra has

adopted a zero-tolerance policy toward discrimination and all forms of unlawful

harassment, including but not limited to sexual harassment. This zero-tolerance policy

means that no form of unlawful discriminatory or harassing conduct towards any

employee, client, contractor, or other person in our workplace will be tolerated. Coltra is

committed to enforcing its policy at all levels within Coltra, and any employee who

engages in prohibited discrimination or harassment will be subject to discipline, up to and

including immediate discharge from employment for a first offense.

This policy is equally applicable to Coltra’s members, directors and vendors, and

Coltra reserves the right to preclude such individuals from participation in or doing

business with Coltra to the extent they engage in conduct prohibited by this policy.

Every employee should be aware that all managers and supervisors are absolutely

prohibited from making any decision regarding job assignment or reassignment,

performance evaluation, compensation, promotion or demotion, termination or

commencement of employment, or any other decision involving any tangible

employment action, based in whole or in any part on any person’s exposure to,

submission to, acquiescence in, or complaint about, sexual harassment or any other form

of unlawful harassment or discrimination.

Conduct Covered by this Policy:

This policy applies to and prohibits all forms of illegal harassment and

discrimination, not only sexual harassment. Accordingly, Coltra absolutely prohibits

harassment or discrimination based on sex, age, disability, perceived disability, marital

status, personal appearance, sexual orientation, race, color, religion, national origin,

veteran status or any other legally protected characteristic.

Because confusion often arises concerning the meaning of sexual harassment in

particular, it deserves special mention. Sexual harassment may take many forms,

including the following:

• Offensive and unwelcome sexual invitations, whether or not the employee submits to the invitation, and particularly when a spoken

or implied quid pro quo for sexual favors is a benefit of

employment or continued employment;

• Offensive and unwelcome conduct of a sexual nature, including sexually-graphic spoken comments; offensive comments

transmitted by e-mail or another messaging system; offensive or

suggestive images or graphics whether physically present in the

workplace or accessed over the Internet; or the possession of or use

of sexually suggestive objects; and

• Offensive and unwelcome physical contact of a sexual nature, including the touching of another’s body; the touching or display of

one’s own body, or any similar contact.

Computer Messaging and Information Systems:

Employees are particularly cautioned that the use of e-mail, voice mail, or other

electronic messaging systems, or the Internet, may give rise to liability for harassment.

Employees may not generate, should not receive, and must not forward, any message or

graphic that might be taken as offensive based on sex, gender, or other protected

characteristic. This includes, for example, the generation or forwarding of offensive

“humor” which contains sexually-offensive terms, or terms which are offensive to any

race, religion, national origin group, or other protected group.

Employees receiving offensive messages over Coltra computer equipment, or

receiving other unlawfully offensive messages or graphics over Coltra computer

equipment, should report those messages to their supervisor or other appropriate

manager.

Employees are reminded that Coltra’s computers and the data generated on, stored

in, or transmitted to or from Coltra’s computers remain the property of Coltra for all

purposes. No employee is authorized to use any Coltra computer, computer system,

network, or software for the preparation, transmission, or receipt of sexually offensive

messages or graphics, or for other messages or graphics which might be taken as

offensive based on any other protected characteristic.

Employees are reminded that Coltra retains the right to monitor its computers,

computer systems, and networks to ensure compliance with this requirement.

Mandatory Procedures in Cases of Harassment:

Any Coltra employee who believes that she or he has been subjected to unlawful

harassment of any kind has the responsibility to report the harassment immediately to her

or his supervisor. If the employee is uncomfortable reporting the harassment to her or his

immediate supervisor (whether because the supervisor has committed the harassment, or

for any other reason whatsoever), the employee must report the harassment to the next

higher level of management above the immediate supervisor or, if the employee prefers,

to the [ Human Resources Director, Chief Financial Officer, or President ] of Coltra.

Coltra is committed to taking all reasonable steps to prevent harassment, and will

make every reasonable effort promptly and completely to address and correct any

harassment that may occur. However, Coltra cannot take prompt and effective remedial

action unless each employee assumes the responsibility of reporting any incident of

harassment immediately to an appropriate supervisory employee.

Every report of harassment will be investigated promptly and impartially, with

every effort to maintain employee confidentiality. The complainant and the accused will

be informed of the results of the investigation. If Coltra finds that its policy has been

violated, it will take appropriate corrective and remedial action, up to and including

discharge.

Reporting Without Fear of Retaliation:

No Coltra employee will be retaliated against for reporting harassment. This no-

retaliation policy applies whether a good faith complaint of harassment is well founded or

ultimately determined to be unfounded.

No Coltra manager or supervisor is authorized, or permitted, to retaliate or to take

any adverse employment action whatsoever against anyone for reporting unlawful

harassment, or for opposing any other discriminatory practice in the workplace.

Any employee who feels he or she has been retaliated against in violation of this

no-retaliation policy is responsible for reporting the retaliation to management, in the

same manner as any other form of harassment or discrimination should be reported.

Questions About This Policy:

If you have any questions at all about this policy, about whether you should report

an incident under this policy, or about Coltra commitment to a workplace free of

discrimination and harassment, please speak to your supervisor. If you believe it is

inappropriate for any reason to discuss the matter with your supervisor, please bring your

questions to the Human Resources Director.