Sexual Harassment Policy

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SEXUAL HARASSMENT POLICY

A. Policy of No Sexual Harassment

It is the policy of The Company that there shall be no harassment of any employee on account of an employee's sex. The Company will not tolerate sexual harassment of its employees by anyone - supervisors, other employees, clients, or customers. Persons harassing others will be dealt with swiftly and vigorously. Anyone who violates this policy will be subject to disciplinary action up to and including discharge.

B. Definition of Sexual Harassment

Sexual harassment is behavior of a sexual nature which is unwelcome and personally offensive to its recipients.

Unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature constitute "sexual harassment" when:

submission to such conduct is made explicitly or implicitly a condition of an individual's employment;

submission to or rejection of such conduct is used as a basis for an employment decision affecting the employee; or

the harassment has the purpose of effect of unreasonably interfering with the employee's work performance or creating an environment which is intimidating, hostile or offensive to the employee.

The following are examples of unlawful harassment:

1. Unwelcome sexual advances. This means patting, pinching, brushing up against, hugging, kissing, fondling, or any other similar physical contact considered unwelcome by another individual

2. Requests for demands for sexual favors. This includes subtle or blatant pressures or requests for any type of sexual favors accompanied by an implied or stated promise of preferential treatment or negative consequence concerning one's employment status.

3. Verbal abuse or kidding that is sex-oriented and considered unwelcome by another individual. This includes commenting about an individuals body or appearance where such comments are beyond mere courtesy, telling 'dirty jokes," that are clearly unwelcome and considered offensive by others or any other tasteless, sexually-oriented comments, innuendoes or actions that offend others.

4. Engaging in any type of sexually-oriented conduct that would reasonably interfere with another's work performance. This includes extending unwanted sexual attention to someone that reduces personal productivity or time available to work at assigned tasks.

5. Creating a work environment that is intimidating, hostile or offensive because of unwelcome sexually-oriented conversations, suggestions, requests, demands, or physical contacts.

C. Complaint Procedure

Any employee who feels that he or she has been sexually harassed should immediately report the matter to his or her supervisor. If that person is unavailable or the employee believes that it would be inappropriate to contact his or her supervisor, the employee should contact the Human Resources Director.

Any supervisor or manager who becomes aware of any possible sexual harassment should immediately advise the Human Resources Director who will handle such matters in a lawful manner to ensure that such conduct does not continue. All complaints of sexual harassment will be investigated in as discreet and confidential a fashion as possible. No person will be adversely affected in employment with the Company as a result of bringing complaints of sexual harassment.

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