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Anti-Harassment Policy

March 09, 2008

The Anti-Harassment Policy states that the Company will investigate any report of harassment to obtain details of the conduct. It also states the interview procedure that will be followed and who will be part of the investigation team, as well as discipline measures.

Subject: Investigation of Harassment

Organization: Anonymous

Example of: Standard

Investigation of Harassment

Interview the employee to obtain the details of the conduct. (Two members of management should be present. Ideally, one manager will be a member of the protected group alleging harassment.) Determine or do the following:

1. What was the frequency of the conduct?

2. Dates of occurrence.

3. Circumstances of each occurrence.

4. Context of each occurrence (e.g., at work, on a break, off-duty).

5. What was the effect on the employee who is complaining (e.g., economic, psychological)?

6. Are other persons who are not members of the protected group subject to the same conduct?

7. What is the relationship of the harasser to the company (e.g., supervisor, hourly employee, customer, supplier)?

8. Did the employee’s supervisor know of the harassment?

9. Should the supervisor have known of the harassment?

10. Did the employee complain to anyone about the harassment before now?

11. Review the personnel files of the employee and the person accused of the harassment for any evidence supporting or refuting the claim.

12. If appropriate, obtain a written statement from the employee.

13. Are there any witnesses to the conduct?

14. Interview the witnesses. (Two members of management should be present.) If appropriate, obtain written statements from any witnesses.

15. Interview the person accused of the harassment. (Two members of management should be present.)

16. If appropriate, obtain a written statement from the accused.

17. If unlawful harassment occurred, take immediate steps to remedy the situation.


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