Purpose
To inform that this policy applies to all employees and U.S. expatriates, outside vendors and clients.
Policy and Enforcement
TCRL has a zero tolerance policy that endorses the right of all employees to work in an environment free from discriminatory and harassment. Violation of this policy is prohibited for any employee, regardless of status or position; whether a manager, supervisor or co‐worker, to harass or discriminate against another person based on the individual’s preferences to sex, gender, race, color, religion, national origin, creed, citizenship status, age, disability, sexual orientation, veteran status, social-economic status or any category protected by either federal or state law. Any such acts or behaviors will not be tolerated and violators will be prosecuted.
Discrimination and harassment in any form; quid pro quo sexual harassment or hostile work environment, or discrimination against any individual based upon any protected group status will not be tolerated by TCRL or any of its subsidiaries. Discriminatory conduct is a violation of the law and can subject the firm and individuals within the firm to civil liability and punitive damages. Discrimination is not only incompatible with organizational values, but also counterproductive to our mission and goals.
Unwelcome sexual advances, requests for sexual favors and other verbal, written or physical conduct of a sexual nature are prohibited whether made either explicitly or implicitly to a term or condition of an individual employment. Submission to or rejection of such conduct by an individual used as the basis for employment decisions are forbidden. Conduct with the purpose or effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment is prohibited. Sexual harassment can occur between either sex as well as the same sex.
All members and associates of TCRL have a legal obligation to act on any reported or unreported incident of harassment or discrimination. All employees are strongly encouraged to report incidents as outlined.
1. If/When an employee feels they are being harassed, observes harassment or discriminated against, they may choose to tell the person to stop, however the employee is not required to do so.
2. The employee should report the incidents to their chain of authority or contact the Office of the Compliance Officer immediately.
3. If the employee’s manager is the harasser or demonstrating discriminatory conduct, the employee should report the incidents to their Human Resources or Equal Opportunity Advisor or use the establish organizational protocol.
4. Any employee who experiences harassment or discrimination by a non‐employee or who observes
harassment or discrimination of an employee by a non‐employee should report such harassment or
discrimination to their immediate supervisor or to Human Resources.
5. Once a complaint has been reported, an investigation will be undertaken. Notification and involvement of the complainant’s manager will take place at the discretion of Human Resources and the Office of General Counsel.
6. Information to consider when reporting allegations of harassment, discrimination or retaliation:
- Basis for allegation.
- Details of the complaint (dates, locations and specific details) and relationship with respondent.
- Witnesses, documents or supporting evidence.
- Scheduled work time missed as a result of the action(s).
- Number of allegations against respondent(s) and recommended remedy on behalf of plaintiff.
7. All employees are protected under federal and state law against retaliatory behavior directed against them by the harasser or others as a result of filing a harassment or discrimination complaint. Employees are not required by law to confront a harasser. However, in the event an employee chooses to do so, the following actions are recommended:
- Clearly and firmly tell the harasser to stop the harassing activity.
- Inform the harasser that more serious action will be taken if the behavior does not cease immediately.
- Maintain detailed records of the harassment, including dates, times and places, as well as the names of witnesses and other relevant information.
- Store records in a safe place outside the work environment.
- One confronted, report whether the harassment continues.
Accountability and Disciplinary Action
All complaints, consistent with the law and TME responsibility will result in full investigate and attempt to resolve the situation and the appropriate disciplinary actions recommended or taken. Harassment and discrimination constitute a severe infraction of policies and grounds for disciplinary action including dismissal.
Mandatory Training
All new employees must complete sexual harassment training. All current employees must renew their training on sexual harassment annually, unless otherwise required by law.
