Anti-Harassment Policy

Anti-Harassment Policy and Complaint Procedure

Carter & Carter is committed to a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore, Carter & Carter expects that all relationships among persons in the office will be business-like and free of bias, prejudice and harassment.

Carter & Carter seeks to maintain a workplace free of ethnic, racial, religious or other discriminatory harassment. The physical or verbal harassment of another based on that person’s race, creed, color, national origin, religion, gender, citizenship status, age, marital status, pregnancy, sexual orientation, gender identity, disability, genetic information, ancestry or status as a covered veteran, or any other classification protected by Federal, State or Local law is unlawful and will not be tolerated. Improper interference with the ability of Carter & Carter employees to perform their expected job duties is absolutely not tolerated.

Carter & Carter encourages reporting of all perceived incidents of discrimination or harassment. It is the policy of Carter & Carter to promptly and thoroughly investigate such reports. Carter & Carter prohibits retaliation against any individual who reports discrimination or harassment or who participates in an investigation of such reports.

Definitions of Harassment

Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal, written or physical conduct that denigrates or shows hostility or aversion toward an individual because of his/her race, color, religion, gender, sexual orientation, national origin, age, disability, marital status, citizenship, genetic information or any other characteristic protected by law or that of his/her 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 an individual’s work performance; or c) otherwise adversely affects an individual’s employment opportunities.

Harassing conduct includes epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion toward an individual or group and that is placed on walls or elsewhere on the employer’s premises or circulated in the workplace, on Carter & Carter time or using Carter & Carter equipment via e-mail, phone (including voice messages), text messages, tweets, blogs, social networking sites or other means.

Individuals and Conduct Covered

These policies apply to all applicants and employees, whether related to conduct engaged in by fellow employees or someone not directly connected to Carter & Carter (e.g., an outside vendor, consultant or customer).

Conduct prohibited by these policies is unacceptable in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events.

Any employee who violates this Anti-Harassment Policy and harasses, disrupts, or interferes with an employee’s work performance or who creates an intimidating, offensive, or hostile work environment will be subject to disciplinary action up to and including termination.

Sexual Harassment Policy

Carter & Carter is committed to creating and maintaining a working environment
free of all forms of discrimination, including sexual harassment.

Sexual harassment constitutes discrimination and is illegal under federal, state and local laws. For the purposes of this policy, sexual harassment is defined, as in the Equal Employment Opportunity Commission Guidelines, as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when, for example

1. Submission to such advances, requests or conduct is made either implicitly or explicitly a term or condition of an individual’s employment;
2. Submission to or rejection of such advances, requests or conduct is used as a basis for employment decisions affecting the individual;
3. Such advances, requests or conduct have the purpose of effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive work environment.

Sexual harassment may include a range of subtle and not-so-subtle behaviors and may involve individuals of the same or different gender including continuing to express sexual or social interest in another employee after being told that the interest is unwelcome. Depending on the circumstances, these behaviors may include unwanted sexual advances or requests for sexual favors; sexual jokes and innuendo; verbal abuse of a sexual nature; commentary about an individual’s body or dress, sexual prowess or sexual deficiencies; leering, suggesting or insulting noises, or touching; insulting or obscene comments or gestures; display in the workplace of sexually suggestive objects or pictures; and other physical, verbal or visual conduct of a sexual nature. Sexual innuendoes or jokes of a sexual or gender specific nature may contribute to a sexually hostile work environment and must be avoided.

Sexual harassment may include prohibited harassing conduct by members of the same gender.

Any employee who engages in sexual harassment is subject to disciplinary action, up to and including termination.

Harassment and Discrimination Reporting Procedure

Individuals who believe they have been the victims of conduct prohibited by this policy statement or who believe they have witnessed such conduct should discuss their concerns with their immediate supervisor, Human Resources or any member of management.

If the harassment involves the employee’s supervisor, then the harassment should be reported to Human Resources.

Any supervisor/manager who receives a report, or has knowledge of, harassment must promptly inform Human Resources.

When possible, Carter & Carter encourages individuals who believe they are being subjected to such conduct to promptly advise the offender that his or her behavior is unwelcome and request that it be discontinued. Often this action alone will resolve the problem. Carter & Carter recognizes, however, that an individual may prefer to pursue the matter through complaint procedures listed above.

Carter & Carter encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken before relationships become irreparably strained. Therefore, although no fixed reporting period has been established, early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment.

Any reported allegations of harassment, discrimination or retaliation will be investigated promptly. 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 other relevant knowledge.

Confidentiality will be maintained throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action.

Retaliation Prohibited

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, will be subject to disciplinary action. Acts of retaliation should be reported immediately and will be promptly investigated and addressed.
Misconduct constituting harassment, discrimination or retaliation will be dealt with appropriately.

If a party to a complaint does not agree with its resolution that party may appeal to Carter & Carter’ President.

False and malicious complaints of harassment, discrimination or retaliation may be the subject of appropriate disciplinary action up to and including termination.