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Zero -Tolerance Harrassment Policy

CLP prohibits any type of harassment that creates an intimidating, hostile, or offensive work environment, including, but not limited to, verbal, visual, or physical conduct that discriminates on the basis of sex, race, national origin, color, religion, age, disability or veteran’s status, all as defined and protected by applicable law. Employees of CLP are prohibited from engaging in unwelcome sexual advances, requests for sexual favors and any other forms of harassment based on any of the above criteria.

If you believe you have been treated in a discriminatory manner, promptly report the incident to your office or the Human Resources Department. Any employee who is found to have displayed inappropriate behavior against another employee will be appropriately disciplined which may include termination. This policy applies to all CLP employees. Harassment by any CLP employee, as described below, toward any employee, will not be tolerated.

SEXUAL HARASSMENT

Sexual harassment has been defined generally as including unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature, whenever (1) Submission of the conduct is either an explicit or implicit term or condition of employment; (2) An employee’s reaction to the conduct is used as a basis for employment decisions affecting that employee; or (3) The conduct has the purpose or effect of interfering with the employee’s work performance or creating an intimidating, hostile or offensive work environment.

No employee or applicant should be subjected to unsolicited and unwelcome sexual overtures, nor should any employee or applicant be led to believe that an employment opportunity or benefit would in any way depend upon “cooperation” of a sexual nature. Sexual harassment is not limited to demands for sexual favors. It also may include such actions as: (1) Sexually oriented verbal “kidding,” “teasing” or jokes; (2) Repeated offensive sexual flirtations, advances or propositions; (3) Continued or repeated verbal abuse of a sexual nature; (4) Graphic or degrading comments about an individual or his or her appearance; (5) The display of sexually suggestive objects or pictures; (6) Subtle pressure for sexual activity; and (7) Physical contact or blocking movement. Sexual harassment does not refer to occasional compliments of a socially acceptable nature or consensual personal and social relationships without a discriminatory employment effect. It refers to behavior which is not welcome and which is personally intimidating, hostile, or offensive.

UNLAWFUL HARASSMENT

Other prohibited forms of harassment include jokes, verbal abuse and epithets, degrading comments, the display of objects and pictures and other offensive conduct relating to an individual’s sex, race, national origin, color, religion, age, disability or veteran’s status, all as defined and protected by applicable law.

Any CLP employee who is found to have engaged in prohibited harassment will be subject to appropriate disciplinary action, up to and including termination of employment, depending on the circumstances.

REPORTING DISCRIMINATORY HARASSMENT

The Company strongly encourages the prompt reporting of all incidents of discriminatory harassment. If you believe you are being harassed or have observed harassment, the Company encourages you to promptly notify your CLP representative or, if you prefer not to advise your representative, contact CLP’s Human Resources Department at 800-216-4934 or the CLP Compliance Alert at www.truebluecompliancealert.com or call 855-70-ALERT. 

COMPLIANCE ALERT

Items to report may include, but are not limited to:

  • Fraud/Deceit and Embezzlement
  • Falsification of Information
  • Unethical Business Practices
  • Violation of Policies/Procedures
  • Harassment
  • Unsafe Workplace
  • Threatening Violence
  • Substance Abuse
  • Discrimination
  • Vandalism
  • Theft

Compliance Alert is a confidential resource to address workplace concerns 24 ours a day, 7 days a week.

INVESTIGATION

When an employee reports harassment as specified above, the Company will undertake a prompt investigation appropriate to the circumstances.  The steps to be taken during the investigation cannot be fixed in advance, but will vary depending upon the nature of the allegations. Confidentiality will be maintained throughout the investigative process to the extent practicable and consistent with the Company’s need to undertake a full investigation.

RESOLVING THE MATTER

Upon completion of the investigation, appropriate remedial action will be taken, if necessary and supported by the facts. Remedial action may include oral or written counseling, referral to formal counseling, disciplinary suspension, or discharge from the Company.

NON-RETALIATION

An individual who reports incidents that the employee, in good faith, believes to be in violation of this policy, or who is involved in the investigation of harassment, will not be subject to reprisal or retaliation.  Retaliation is a serious violation of this policy and should be reported immediately. The report and investigation of allegations of retaliation will follow the procedures set forth in this policy. Any person found to have retaliated against an individual for reporting discriminatory harassment or participating in an investigation of allegations of such conduct will be subject to appropriate disciplinary action.

COMMUNICATION

This policy is part of CLP’s overall commitment to open communication. The Company encourages any employee with workplace concerns of any nature (including, but not limited to, any alleged discrimination) to bring those concerns to the attention of the office staff.

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