POLICY FOR PREVENTION OF SEXUALHARASSMENT OF WOMEN

Prevention of Discrimination and Harassment

I. OBJECTIVE

IRMEPL strives to create and maintain a work environment in which people are treated with dignity, decency and respect. The environment of the company should be characterized by mutual trust and the absence of intimidation, oppression and exploitation. IRMEPL will not tolerate unlawful discrimination or harassment of any kind. Through enforcement of this policy and by education of employees, IRMEPL will seek to prevent, correct and discipline behaviour that violates this policy.

All employees, regardless of their positions, are covered by and are expected to comply with this policy and to take appropriate measures to ensure that prohibited conduct does not occur. Appropriate disciplinary action will be taken against any employee who violates this policy. Based on the seriousness of the offense, disciplinary action may include verbal or written reprimand, suspension, or termination of employment.

Managers and supervisors who knowingly allow or tolerate discrimination, harassment or retaliation, including the failure to immediately report such misconduct to human resources (HR), are in violation of this policy and subject to discipline.

II. SCOPE

This policy applies to all employees of the organization and prohibits harassment by any employee towards other IRMEPL employees including supervisors, outside vendors, and customers.

III. PROHIBITED CONDUCT UNDER THIS POLICY

IRMEPL, in compliance with all applicable federal, state and local anti‐discrimination and harassment laws and regulations, enforces this policy in accordance with the following definitions and guidelines:

Discrimination

It is a violation of IRMEPL's policy to discriminate in the provision of employment opportunities, benefits or privileges; to create discriminatory work conditions; or to use discriminatory evaluative standards in employment if the basis of that discriminatory treatment is, in whole or in part, the person's race, color, national origin, age, religion, disability status, gender, sexual orientation, gender identity, genetic information or marital status.

Discrimination in violation of this policy will be subject to disciplinary measures up to and including termination.

HARASSMENT

IRMEPL prohibits harassment of any kind, including sexual harassment, and will take appropriate and immediate action in response to complaints or knowledge of violations of this policy. For purposes of this policy, harassment is any verbal or physical conduct designed to threaten, intimidate or coerce an employee, co‐worker, or any person working for or on behalf of IRMEPL.

The following examples of harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

  • Verbal harassment includes comments that are offensive or unwelcome regarding a person's national origin, race, color, religion, gender, sexual orientation, age, body, disability or appearance, including epithets, slurs and negative stereotyping.
  • Nonverbal harassment includes distribution, display or discussion of any written or graphic material that ridicules, denigrates, insults, belittles or shows hostility, aversion or disrespect toward an individual or group because of national origin, race, color, religion, age, gender, sexual orientation, pregnancy, appearance, disability, sexual identity, marital status or other protected status.

Sexual Harassment

Sexual harassment is a form of unlawful employment discrimination and is prohibited under IRMEPL's anti‐harassment policy.

Sexual harassment occurs when unsolicited and unwelcome sexual advances, requestsfor sexual favors, or other verbal or physical conduct of a sexual nature:

  • Is made explicitly or implicitly a term or condition of employment.
  • Is used as a basis for an employment decision.
  • Unreasonably interferes with an employee's work performance or creates an intimidating, hostile or otherwise offensive environment.

Sexual harassment may take different forms. The following examples of sexual harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

  • Verbal sexual harassment includes innuendoes, suggestive comments, jokes of a sexual nature, sexual propositions, lewd remarks and threats; requests for any type of sexual favor (this includes repeated, unwelcome requests for dates); and verbal abuse or "kidding" that is oriented toward a prohibitive form of harassment, including that which is sexual in nature and unwelcome.
  • Nonverbalsexual harassment includesthe distribution, display or discussion of any written or graphic material, including calendars, posters and cartoons that are sexually suggestive or show hostility toward an individual or group because of sex; suggestive or insulting sounds; leering; staring; whistling; obscene gestures; content in letters, notes, facsimiles, e‐mails, photos, text messages, tweets and Internet postings; or other forms of communication that are sexual in nature and offensive.
  • Physical sexual harassment includes unwelcome, unwanted physical contact, including touching, tickling, pinching, patting, brushing up against, hugging, cornering, kissing, fondling, and forced sexual assault.

Courteous, mutually respectful, pleasant, noncoercive interactions between employees that are appropriate in the workplace and acceptable to and welcomed by both parties are not considered to be harassment.

IV. What to do: Incase subject to Harassment/Discrimination

Anyone at work, on Company business, or at any Company sponsored function engages in conduct that makes you feel uncomfortable, we encourage you to tell that person that the conduct is unwelcome, that you find it Offensive and that you request that it stop immediately.

V. RETALIATION

No hardship, loss, benefit or penalty may be imposed on an employee in response to:

  • Filing or responding to a bona fide complaint of discrimination or harassment
  • Appearing as a witness in the investigation of a complaint.
  • Serving as an investigator of a complaint.

Lodging a complaint will in no way be used against the employee or have an adverse impact on the individual's employment status. However, filing groundless or malicious complaints is an abuse of this policy and will be treated as a violation.

Any person who is found to have violated this aspect of the policy will be subject to discipline up to and including termination of employment.

Confidentiality

All complaints and investigations are treated confidentially to the extent possible, and information is disclosed strictly on a need‐to‐know basis. The identity of the complainant is usually revealed to the parties involved during the investigation, and the HR head will take adequate steps to ensure that the complainant is protected from retaliation during and after the investigation. All information pertaining to a complaint or investigation under this policy will be maintained in secure files within the HR department.

VI. COMPLAINT PROCEDURE

IRMEPL has established the following procedure for lodging a complaint of harassment, discrimination or retaliation. The company will treat all aspects of the procedure confidentially to the extent reasonably possible.

  • Complaintsshould be submitted assoon as possible after an incident has occurred, preferably in writing. The HR team may assist the complainant in completing a written statement or, in the event an employee refuses to provide information in writing, the HR team will dictate the verbal complaint.
  • Upon receiving a complaint or being advised by a supervisor or manager that violation of this policy may be occurring, the HR head will notify senior management and review the complaint with the company's legal counsel.
  • The HR head will initiate an investigation to determine whether there is a reasonable basis for believing that the alleged violation of this policy occurred.
  • If necessary, the complainant and the respondent will be separated during the course of the investigation, either through internal transfer or administrative leave.
  • During the investigation, the HR head, together with legal counsel or other management employees, will interview the complainant, the respondent and any witnesses to determine whether the alleged conduct occurred.
  • Upon conclusion of an investigation, the HR head or other person conducting the investigation will submit a written report of his or her findings to the company. If it is determined that a violation of this policy has occurred, the HR head will recommend appropriate disciplinary action. The appropriate action will depend on the following factors:
    • the severity, frequency and pervasiveness of the conduct;
    • prior complaints made by the complainant;
    • prior complaints made against the respondent; and
    • the quality of the evidence (e.g., first‐hand knowledge, credible corroboration).

    If the investigation is inconclusive or if it is determined that there has been no violation of policy but potentially problematic conduct may have occurred, the HR head may recommend appropriate preventive action.

  • Senior management will review the investigative report and any statements submitted by the complainant or respondent, discuss results of the investigation with the HR head and other management staff as appropriate, and decide what action, if any, will be taken.
  • Once a final decision is made by senior management, the HR head will meet with the complainant and the respondent separately and notify them of the findings of the investigation. If disciplinary action is to be taken, the respondent will be informed of the nature of the discipline and how it will be executed.