FEDERAL ANTI HARASSMENT AND DISCRIMINATION POLICY

This policy applies to all work-related settings and activities, whether inside or
outside the workplace, and includes business trips and business-related social
events. Trellis for Tomorrow’s property (e.g. telephones, copy machines, facsimile
machines, computers, and computer applications such as e-mail and Internet
access) may not be used to engage in conduct that violates this policy. Trellis for
Tomorrow’s policy against harassment covers employees and other individuals who
have a relationship with Trellis for Tomorrow which enables the organization to
exercise some control over the individual’s conduct in places and activities that
relate to Trellis for Tomorrow’s work (e.g. directors, officers, contractors, vendors,
partners, program participants, volunteers, etc.).

Discrimination Is Prohibited

      Trellis for Tomorrow (“The Company”), is an equal opportunity organization
and makes all employment/volunteer/program acceptance decisions without regard
to race, religion, color, sex (including pregnancy, sexual orientation, and gender
identity), national origin, disability, age, genetic information, or any other status
protected under applicable federal, state, or local laws. This policy applies to all
terms and conditions of employment/volunteering/program acceptance, including
but not limited to, hiring, placement, promotion, termination, layoff, recall,
transfer, leaves of absence, benefits, compensation, and training. We seek to
comply with all applicable federal, state, and local laws related to discrimination and
will not tolerate the interference with the ability of any of the Company’s employees
and volunteers to perform their job duties on the basis of discrimination.

      The Company makes decisions concerning employment/volunteering based
strictly on an individual’s qualifications and ability to perform the job under
consideration, the comparative qualifications and abilities of other applicants, and
the individual’s past performance within the organization.

      If you believe that a decision has been made that does not conform with the
organization’s commitment to equal opportunity, your complaint will be promptly,
thoroughly, and impartially investigated. There will be no retaliation against anyone
who files a complaint in good faith, even if the result of the investigation produces
insufficient evidence to support the complaint,

Americans with Disabilities Act

      The Federal Americans with Disabilities Act (ADA) prohibits discrimination
against qualified individuals with disabilities in application procedures, hiring, firing,
advancement, compensation, fringe benefits, job training and other terms,
conditions and privileges of employment. The ADA does not alter the Company’s
right to secure the best-qualified applicant, but it does prohibit discrimination
against a qualified applicant or employee/volunteer because of his or her disability,
or because of a perceived disability. As a matter of Company policy, the Company
prohibits discrimination of any kind against people with disabilities.

Disabled Defined

      An applicant or employee/volunteer is considered disabled (as defined by the
Federal Americans with Disabilities Act) if he or she (1) has a physical or mental
impairment that substantially limits one or more major life activities; (2) has a
record or past history of such an impairment; or (3) is regarded or perceived
(correctly or incorrectly) as having such impairment.
       A qualified employee/volunteer or applicant with a disability is an individual
who satisfies the requisite skill, experience, education, and other job-related
requirements of the position held or desired, and who, with or without reasonable
accommodation, can perform the essential functions of that position.

Reasonable Accommodation

      A reasonable accommodation is any change in the work environment (or in
the way things are usually done) to help a person with a disability apply for a job,
perform the duties of a job, or enjoy the benefits and privileges of employment.
     

      Qualified applicants or employees/volunteers/participants who are disabled
should request reasonable accommodation from the Company in order to allow
them to perform a particular job. If you are disabled and you desire such
reasonable accommodation, the request is to be put in writing to the Executive
Director. On receipt of your request a representative of the Company will meet with
you to discuss your disability. The Company may ask for information from your
health care provider(s) regarding the nature of your disability and the nature of
your limitations or take other steps necessary to help us determine viable options
for reasonable accommodation. The Company will then work with you to determine
whether your disability can be reasonably accommodated, and if it can be
accommodated, the Company will explore alternatives with you and endeavor to
implement a mutually agreeable accommodation.

      Reasonable accommodation may take many forms and it will vary from one
employee/volunteer/participant to another. Please note that according to the ADA,

the Company does not have to provide the exact accommodation you want, and if
more than one accommodation works, the Company may choose which one to
provide. Furthermore, the Company does not have to provide an accommodation if
doing so would cause undue hardship to the Company.

Harassment

      The Company is committed to providing an environment that provides
employees/volunteers equality, respect, and dignity. In keeping with this
commitment, the Company has adopted a policy of “zero tolerance” with regard to
harassment. Harassment is defined under federal law as unwelcome conduct that is
based on race, color, religion, sex (including pregnancy, sexual orientation, and
gender identity), national origin, age (40 or older), disability or genetic information.
Harassment becomes unlawful where: (1) enduring the offensive conduct becomes
a condition of continued employment/volunteering; or (2) the conduct is severe or
pervasive enough to create an environment that a reasonable person would
consider intimidating, hostile, or abusive.

      Depending on the circumstances, the following conduct may constitute
discriminatory harassment: (1) epithets, slurs, negative stereotyping, jokes, or
threatening, intimidating, or hostile acts that relate to a protected characteristic;
and (2) written or graphic material that denigrates or shows hostility toward an
individual or group because of a protected characteristic and that is circulated in the
workplace, or placed anywhere in Trellis’ premises such as on an employee’s desk
or workspace or on the organization’s equipment, bulletin boards, internal
applications, social media, website, or other. Other conduct may also constitute
discriminatory harassment if it falls within the definition of discriminatory
harassment set forth above.

      This policy applies to all terms and conditions of
employment/volunteering/program participation. Harassment of any other person,
including, without limitation, fellow employees/volunteers, contractors, visitors,
participants, partners, clients or customers, whether at work or outside of work, is
grounds for immediate termination. The Company will make every reasonable effort
to ensure that its entire community is familiar with this policy and that all are aware
that every complaint received will be promptly, thoroughly and impartially
investigated and resolved appropriately. The Company will not tolerate retaliation
against anyone who complains of harassment or who participates in an investigation.

Sexual Harassment

      Sexual harassment is prohibited by federal, state and local laws, and applies
equally to men and women. Federal law defines sexual harassment as unwelcome
sexual advances, requests for sexual favors and other verbal or physical conduct of
a sexual nature when the conduct: (1) explicitly or implicitly affects a term or condition of an employee’s/volunteer’s company relationship; (2) is used as the
basis for decisions affecting the employee/volunteer; or (3) unreasonably interferes
with an employee’s/volunteer’s work performance or creates an intimidating, hostile
or offensive environment.

      Such conduct may include but is not limited to: subtle or overt pressure for
sexual favors; inappropriate touching; lewd, sexually oriented comments or jokes;
foul or obscene language; posting of suggestive or sexually explicit posters,
calendars, photographs, graffiti, or cartoons; and repeated requests for dates.
Company policy further prohibits harassment and discrimination based on sex
stereotyping. (Sex stereotyping occurs when one person perceives a man to be
unduly effeminate or a woman to be unduly masculine and harasses or
discriminates against that person because he or she does not fit the stereotype of
being male or female.)

Depending on the circumstances, the following conduct may also constitute sexual
harassment:

      (1) use of sexual epithets, jokes, written or oral references to sexual
conduct, gossip regarding one’s sex life; (2) sexually oriented comments on an
individual’s body, about an individual’s sexual activity, deficiencies, or prowess; (3)
displaying sexually suggestive objects, pictures, and/or cartoons; (4) unwelcome
leering, whistling, or deliberate brushing against the body in a suggestive manner;
(5) sexual gestures or sexually suggestive comments; (6) inquiries into one’s
sexual experiences; or (7) discussion of one’s sexual activities.

      While such behavior, depending on the circumstances, may not be severe or
pervasive enough to create a sexually hostile work environment, it can nonetheless
make co-workers uncomfortable. Accordingly, such behavior is inappropriate and
may result in disciplinary action up to and including termination, regardless of
whether the behavior is deemed to be unlawful.

      The Company encourages reporting of all perceived incidents of sexual
harassment, regardless of who the offender may be. Every employee is encouraged
to raise any questions or concerns with the Executive Director.

Supervisors’ Responsibilities

      All managers are expected to ensure a work environment free from sexual and
other Harassment. They are responsible for the application and communication of
this policy within their work area. Managers should:
        • Create a work environment where sexual and other harassment is not
permitted.

        • Encourage employees to report any violations of this policy before the
harassment becomes severe or pervasive.

Procedures for Reporting and Investigating Harassment

      Employees/Volunteers/Program Participants should report incidents of
inappropriate behavior or sexual harassment as soon as possible after the
occurrence. Regardless of whether the offensive act was committed by a manager,
co-worker, vendor, visitor, fellow volunteer, or client, you should notify the offender
that his or her behavior is unwelcome; or, notify the Executive Director. The
Executive Director will then attempt to resolve the situation as promptly and
discretely as possible. If the complaint is against the Executive Director, the
employee should contact the President of the Board of Directors.

      Every claim of harassment will be treated seriously, no matter how trivial it
may appear. All complaints of harassment, sexual harassment, or other
inappropriate sexual conduct will be promptly, thoroughly, and impartially
investigated by the Company.

      There will be no retaliation for filing or pursuing a harassment claim. To the
extent possible, all complaints and related information will remain confidential
except to those individuals who need the information to investigate, educate, or to
take action in response to the complaint.

      All employees/volunteers are expected to cooperate fully with any ongoing
investigation regarding a harassment incident. Employees/volunteers who believe
they have been unjustly charged with harassment can defend themselves verbally
or in writing at any stage of the investigation.

      To protect the privacy of persons involved, confidentiality will be maintained
throughout the investigatory process to the extent practicable and appropriate
under the circumstances. Investigations may include interviews with the parties
involved, and where necessary, individuals who may have observed the alleged
conduct or who may have relevant knowledge.

      At the conclusion of a harassment investigation, the complainant and the
“alleged harasser” shall be informed of the determination. Where appropriate, the
“harasser” and the “victim” may be offered mediation or counseling.

Penalties for Violation of Anti-Harassment Policy

      If it is determined that inappropriate conduct has occurred, the Company will
act promptly to eliminate the offending conduct, and take such action as is
appropriate under the circumstances. Such action may range from counseling to
termination of employment/volunteer arrangement, and may include such other
forms of disciplinary action, as the Company deems appropriate under the
circumstances and in accordance with applicable law.

      While it is not the purpose of this Policy to regulate an employee’s personal
morality, the Company considers harassment, discrimination, or retaliation to be an
act of misconduct and subject to appropriate disciplinary action, up to and including
termination of employment. False and malicious complaints of harassment,
discrimination or retaliation may be the subject of appropriate disciplinary action.
On the other hand, an employee will not be disciplined merely because the
complaint is found to be without merit. Trellis for Tomorrow does not condone
retaliation against any employee for making a report in good faith under this Policy.

Approved May 2021

PARTICIPANT RIGHTS AND GRIEVANCE PROCEDURES

As a participant in a federally funded program, you are guaranteed certain rights by law. You
should receive the same fair and equal treatment as any other person participating in a similar
work or training situation. If you feel your rights to equal employment are being denied, you are
encouraged to discuss this with your immediate Case Manager or Program Instructor. In
particular, you should immediately report any discriminatory action taken against you on the
basis of your race, creed, color, national origin, sex, religion, age, political affiliation or belief or
handicap.

If, after you have done this, you do not feel the situation has been corrected, you should contact
the EO/AA Officer of the Chester County Department of Community Development, the local
Workforce Development Area Office at (610) 344-6900. The EO/AA Officer will review the
situation and, if necessary, assist you in filing a formal grievance. In the event that you don’t
feel comfortable contacting the EO/AA Officer, you should contact your Program Instructor,
DCD Case Manager, CAO Caseworker or the DCD Deputy Director for further assistance.

Complaint and Grievance Procedure

Within one year (except for fraud or criminal activity) from the alleged commission of a violation
(180 days for complaints alleging discrimination because of a handicap), any WIOA or TANF
Program Participant, staff member, subcontractor, or other interested party shall have the right
to file a complaint with the DCD and receive fair and impartial processing of the complaint,
according to the following procedures:

Filing of Complaints: Any aggrieved party shall first be required to meet with the designated
representative of the subcontractor, their Case Manger, CAO Caseworker, or Program
Instructor.

If this fails to resolve the issue, within five days, the complainant shall submit the complaint in
writing to the DCD, to the attention of the AA/EO Officer or Deputy Director and request an
informal conference. At a minimum the written complaint should include:

-the name and address of the complainant,

-the name and address of the person/agency charged with the violation,

-the reason for the complaint, and

-the date and time of the violation.

Within forty-eight (48) hours of the receipt of a written complaint, the EO/AA Officer will inform
the person(s) or agency charged, of the receipt of the complaint.

Opportunity For An Informal Conference: Within ten (10) days of the receipt of the written
request for an informal conference, the AA/EO Officer will convene the conference. During this
meeting the AA/EO Officer will attempt to resolve the issue informally. The AA/EO Officer’s
findings will be submitted to the complainant no later than ten (10) days following the
conference.

Opportunity For A Hearing: If the complainant is not satisfied with the results of the informal
conference, he/she must inform the AA/EO Officer (within five (5) days of receiving the AA/EO
Officer’s findings), and may request a hearing, (to be held within thirty (30) days from the date
the complaint was filed), before an impartial judge, to be appointed by the DCD. Those
individuals involved will be notified in writing of the date, time and place of the hearing. Both
parties may utilize legal counsel and may produce appropriate witnesses and records. Within
sixty (60) days of the filing of the complaint, a written decision will be issued by the hearing
officer.

Notice Of Recourse: If the complainant is still dissatisfied, within ten (10) days of the receipt of
the hearing officer’s written decision, he/she may request a review by the appropriate state
agency:

Pennsylvania Department of Labor and Industry,
Bureau of Workforce Development Partnership
Harrisburg, PA

and/or

Department of Public Welfare
Harrisburg, PA
Either of these agencies will review the case and issue a decision within thirty (30) days. Their
decision will be final.

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Chester County Workforce Development Board
Government Services Center
601 Westtown Road, Suite 365
PO Box 2747
West Chester, PA19380-0990
phone (610) 344-6900fax    (610) 344-6925
email: ccdcd@chesco.org
website: www.chesco.org/ccdcd

Federal Acknowledgement of Sexual Harassment Policy

I herby certify that I have received, read and understand the sexual harassment policy and my
rights as a Participant of the program and acknowledge so with my signature.

All Career Corps Program staff and program participants must be aware of the individual assigned the
responsibility for ensuring that the work place and program locations are free from sexual harassment
and responsible for investigating complaints of sexual harassment. Program participants can find this
information in their participant handbook.

Complaints may be filed with your local contact listed below:

• Lila Singleton, Chester County WIOA, Chester County Department of Community Development,
601 Westtown Road, Suite 365, West Chester, PA 19380, Phone number: (610) 344-6900:
Extension: 6914

      Additionally, complaints may be filed with any of the agencies listed below:

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Chester County Workforce Development Board
Government Services Center
601 Westtown Road, Suite 365
PO Box 2747
West Chester, PA19380-0990
phone (610) 344-6900fax    (610) 344-6925
email: ccdcd@chesco.org
website: www.chesco.org/ccdcd

Acknowledgement of Participant Civil Rights

I herby certify that I have received, read and understand my “Civil Rights” as a
Participant of the program and acknowledge so with my signature.

WHAT TO DO IF YOU BELIEVE YOU HAVE EXPERIENCED DISCRIMINATION
If you think that you have been subjected to discrimination under a WIA Title I-financially assisted
program or activity, you may file a complaint within 180 days from the date of the alleged violation with
either:

• The recipient’s Equal Opportunity Officer (or the person whom the recipient has designated for
this purpose); or
• The Director, Civil Rights Center (CRC), U.S. Department of Labor, 200 Constitution Avenue NW,

Room N-4123, Washington, DC 20210. Voice: (202) 693-6502 TTY (202) 693-6515
If you file your complaint with the recipient, you must wait either until the recipient issues a written Notice
of Final Action, or until 90 days have passed (whichever is sooner), before filing with the Civil Rights
Center (see address above)

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35 Hall Street, Suite 302, Phoenixville, PA 19460 | 610-886-4900 | www.trellis4tomorrow.org

It is the policy of TRELLIS FOR TOMORROW (hereafter TRELLIS) to treat all participants and their families (“participant”) with fairness and professionalism, in an environment that ensures that participant rights are protected, and to strive for excellence in providing services to participants. Staff is trained in confidentiality, and the policies and procedures of TRELLIS. TRELLIS’s policy provides participants and their families with the opportunity to express a problem or grievance related to the quality of services.  If you feel you have been treated unfairly, unprofessionally or feel that your rights have been breached, the following procedure should be used. This policy does not apply to employees, since TRELLIS has specific policies to address employee concerns, nor does it prevent any TRELLIS participant from utilizing the TANF grievance policy.

A grievance is defined as any written complaint regarding the quality of service that a participant would like someone in charge to be aware of and do something about.  A grievance is also defined as a written account of events leading up to a possible wrongful removal from the program for violation of the rules.  Examples of grievances could include a participant who is dissatisfied with services received or with a particular employee, provider, policy, procedure, practice, decision, etc.

TRELLIS’s grievance procedure is designed to provide a means for participants involved in TRELLIS’s programs to bring a complaint to the attention of TRELLIS and to reach a speedy resolution. TRELLIS has a strict policy prohibiting retaliation in any form against anyone who files a grievance.

Even in the best situations, misunderstandings may cause a participant to feel she/he has been treated unfairly. If you are in disagreement with a policy or how you are treated you may file a grievance. A grievance is defined as any situation or condition that a participant thinks is unfair, unjust, or inequitable. In addition, if a participant merely states they want to file a grievance, a grievance should be completed.  Under this Participant Grievance Procedure, you should submit a grievance in the following sequence:

Step 1:  Informal.  If you have a grievance, the concern can be discussed with a member of TRELLIS staff or the Executive Director. Honest discussion usually will clear up the misunderstanding and resolve the problem.  It is the responsibility of staff to provide an atmosphere that is conducive to mutually satisfactory conflict resolution.   If you decide to speak to a staff member and an agreement cannot be reached, you should proceed to the next step of this grievance procedure.  You can also file a grievance without any discussion and proceed to the next step.

Step 2:  Formal.  Step 2 is filing a grievance in writing.  Grievance forms can be found at the following:

1.  The TRELLIS website under Programs or

1.  You can request the form from any staff member.

Once notified in writing, the Executive Director will review the grievance and take one of the following two steps:

1. Give the participant a written response which will indicate the final disposition or
2. Call a meeting for the parties involved in the incident(s). The final disposition will be issued within five working days of the meeting.

Step 3:  If for any reason you are unsatisfied with the results, or your complaint is with the Executive Director, you may proceed with the complaint within five (5) business days of receipt of the Step Two decision by submitting your complaint to the Board of Directors for review.  A meeting with the participant, the President of the Board of Directors and/or his/her designate(s), and the Executive Director will generally be held within five (5) business days of the receipt of the complaint.   The Board of Directors should be advised of the meeting and its outcome, and the Board of Directors designate will issue a final written decision on behalf of TRELLIS, generally within five (5) business days of the meeting.

General Information

The time limits above are subject to modification on a case-by-case basis due to operational requirements, travel, in-depth investigations, etc. The Board of Directors shall have final authority to resolve any disputes regarding the implementation of this Participant Grievance Procedure, including determination of the appropriate decision makers.

GRIEVANCE REPORTING FORM

This form is to be completed if you wish to make or file a grievance or complaint.  You may also ask someone else who is acting with your knowledge and consent to write or express the grievance.   (You may file this report anonymously, without your name, however it may make it more difficult for TRELLIS to address the matter.)

When completed, please submit to:

Executive Director, Jennifer Anderson at janderson@trellis4tomorrow.org

OR

Board President, Bob Prachar, at bprachar@comcast.net

OR

To either of the above by mail to 35 Hall Street, Suite 302, Phoenixville, PA 19460

THIS INTERNAL POLICY DOES NOT PREVENT ANY TRELLIS PARTICIPANT FROM UTILIZING THE TANF GRIEVANCE POLICY. 

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35 Hall Street, Suite 302, Phoenixville, PA 19460 | 610-886-4900 | www.trellis4tomorrow.org

ANTI HARASSMENT AND DISCRIMINATION POLICY

This policy applies to all work-related settings and activities, whether inside or outside the workplace, and includes business trips and business-related social events. Trellis for Tomorrow’s property (e.g. telephones, copy machines, facsimile machines, computers, and computer applications such as e-mail and Internet access) may not be used to engage in conduct that violates this policy. Trellis for Tomorrow’s policy against harassment covers employees and other individuals who have a relationship with Trellis for Tomorrow which enables the organization to exercise some control over the individual’s conduct in places and activities that relate to Trellis for Tomorrow’s work (e.g. directors, officers, contractors, vendors, partners, program participants, volunteers, etc.).

Discrimination Is Prohibited

Trellis for Tomorrow  (“The Company”),  is an equal opportunity organization and makes all employment/volunteer/program acceptance decisions without regard to race, religion, color, sex (including pregnancy, sexual orientation, and gender identity), national origin, disability, age, genetic information, or any other status protected under applicable federal, state, or local laws. This policy applies to all terms and conditions of employment/volunteering/program acceptance, including but not limited to, hiring, placement, promotion, termination, layoff, recall, transfer, leaves of absence, benefits, compensation, and training. We seek to comply with all applicable federal, state, and local laws related to discrimination and will not tolerate the interference with the ability of any of the Company’s employees and volunteers to perform their job duties on the basis of discrimination.

The Company makes decisions concerning employment/volunteering based strictly on an individual’s qualifications and ability to perform the job under consideration, the comparative qualifications and abilities of other applicants, and the individual’s past performance within the organization.

If you believe that a decision has been made that does not conform with the organization’s commitment to equal opportunity, your complaint will be promptly, thoroughly, and impartially investigated. There will be no retaliation against anyone

who files a complaint in good faith, even if the result of the investigation produces insufficient evidence to support the complaint.

 Americans with Disabilities Act

The Federal Americans with Disabilities Act (ADA) prohibits discrimination against qualified individuals with disabilities in application procedures, hiring, firing, advancement, compensation, fringe benefits, job training and other terms, conditions and privileges of employment. The ADA does not alter the Company’s right to secure the best-qualified applicant, but it does prohibit discrimination against a qualified applicant or employee/volunteer because of his or her disability, or because of a perceived disability. As a matter of Company policy, the Company prohibits discrimination of any kind against people with disabilities.  

Disabled Defined

An applicant or employee/volunteer is considered disabled (as defined by the Federal Americans with Disabilities Act) if he or she (1) has a physical or mental impairment that substantially limits one or more major life activities; (2) has a record or past history of such an impairment; or (3) is regarded or perceived (correctly or incorrectly) as having such impairment.

A qualified employee/volunteer or applicant with a disability is an individual who satisfies the requisite skill, experience, education, and other job-related requirements of the position held or desired, and who, with or without reasonable accommodation, can perform the essential functions of that position.

Reasonable Accommodation

A reasonable accommodation is any change in the work environment (or in the way things are usually done) to help a person with a disability apply for a job, perform the duties of a job, or enjoy the benefits and privileges of employment.

Qualified applicants or employees/volunteers/participants who are disabled should request reasonable accommodation from the Company in order to allow them to perform a particular job. If you are disabled and you desire such reasonable accommodation, the request is to be put in writing to the Executive Director. On receipt of your request a representative of the Company will meet with you to discuss your disability. The Company may ask for information from your health care provider(s) regarding the nature of your disability and the nature of your limitations or take other steps necessary to help us determine viable options for reasonable accommodation. The Company will then work with you to determine whether your disability can be reasonably accommodated, and if it can be accommodated, the Company will explore alternatives with you and endeavor to implement a mutually agreeable accommodation. 

Reasonable accommodation may take many forms and it will vary from one employee/volunteer/participant to another. Please note that according to the ADA, the Company does not have to provide the exact accommodation you want, and if more than one accommodation works, the Company may choose which one to provide.  Furthermore, the Company does not have to provide an accommodation if doing so would cause undue hardship to the Company.

Harassment

The Company is committed to providing an environment that provides employees/volunteers equality, respect, and dignity. In keeping with this commitment, the Company has adopted a policy of “zero tolerance” with regard to harassment. Harassment is defined under federal law as unwelcome conduct that is based on race, color, religion, sex (including pregnancy, sexual orientation, and gender identity), national origin, age (40 or older), disability or genetic information. Harassment becomes unlawful where: (1) enduring the offensive conduct becomes a condition of continued employment/volunteering; or (2) the conduct is severe or pervasive enough to create an environment that a reasonable person would consider intimidating, hostile, or abusive. 

            Depending on the circumstances, the following conduct may constitute discriminatory harassment: (1) epithets, slurs, negative stereotyping, jokes, or threatening, intimidating, or hostile acts that relate to a protected characteristic; and (2) written or graphic material that denigrates or shows hostility toward an individual or group because of a protected characteristic and that is circulated in the workplace, or placed anywhere in Trellis’ premises such as on an employee’s desk or workspace or on the organization’s equipment, bulletin boards, internal applications, social media, website, or other. Other conduct may also constitute discriminatory harassment if it falls within the definition of discriminatory harassment set forth above.

This policy applies to all terms and conditions of employment/volunteering/program participation. Harassment of any other person, including, without limitation, fellow employees/volunteers, contractors, visitors, participants, partners, clients or customers, whether at work or outside of work, is grounds for immediate termination. The Company will make every reasonable effort to ensure that its entire community is familiar with this policy and that all are aware that every complaint received will be promptly, thoroughly and impartially investigated and resolved appropriately. The Company will not tolerate retaliation against anyone who complains of harassment or who participates in an investigation.

Sexual Harassment

Sexual harassment is prohibited by federal, state and local laws, and applies equally to men and women. Federal law defines sexual harassment as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when the conduct: (1) explicitly or implicitly affects a term or condition of an employee’s/volunteer’s company relationship; (2) is used as the basis for decisions affecting the employee/volunteer; or (3) unreasonably interferes with an employee’s/volunteer’s work performance or creates an intimidating, hostile or offensive environment.

Such conduct may include but is not limited to: subtle or overt pressure for sexual favors; inappropriate touching; lewd, sexually oriented comments or jokes; foul or obscene language; posting of suggestive or sexually explicit posters, calendars, photographs, graffiti, or cartoons; and repeated requests for dates. Company policy further prohibits harassment and discrimination based on sex stereotyping. (Sex stereotyping occurs when one person perceives a man to be unduly effeminate or a woman to be unduly masculine and harasses or discriminates against that person because he or she does not fit the stereotype of being male or female.)

Depending on the circumstances, the following conduct may also constitute sexual harassment:

            (1) use of sexual epithets, jokes, written or oral references to sexual conduct, gossip regarding one’s sex life; (2) sexually oriented comments on an individual’s body, about an individual’s sexual activity, deficiencies, or prowess; (3) displaying sexually suggestive objects, pictures, and/or cartoons; (4) unwelcome leering, whistling, or deliberate brushing against the body in a suggestive manner; (5) sexual gestures or sexually suggestive comments; (6) inquiries into one’s sexual experiences; or (7) discussion of one’s sexual activities.

            While such behavior, depending on the circumstances, may not be severe or pervasive enough to create a sexually hostile work environment, it can nonetheless make co-workers uncomfortable. Accordingly, such behavior is inappropriate and may result in disciplinary action up to and including termination, regardless of whether the behavior is deemed to be unlawful.

The Company encourages reporting of all perceived incidents of sexual harassment, regardless of who the offender may be. Every employee is encouraged to raise any questions or concerns with the Executive Director.

Supervisors’ Responsibilities

All managers are expected to ensure a work environment free from sexual and other Harassment. They are responsible for the application and communication of this policy within their work area. Managers should:

• Create a work environment where sexual and other harassment is not permitted.
• Encourage employees to report any violations of this policy before the harassment becomes severe or pervasive.

Procedures for Reporting and Investigating Harassment

Employees/Volunteers/Program Participants should report incidents of inappropriate behavior or sexual harassment as soon as possible after the occurrence. Regardless of whether the offensive act was committed by a manager, co-worker, vendor, visitor, fellow volunteer, or client, you should notify the offender that his or her behavior is unwelcome; or, notify the Executive Director. The Executive Director will then attempt to resolve the situation as promptly and discretely as possible. If the complaint is against the Executive Director, the employee should contact the President of the Board of Directors.

 Every claim of harassment will be treated seriously, no matter how trivial it may appear. All complaints of harassment, sexual harassment, or other inappropriate sexual conduct will be promptly, thoroughly, and impartially investigated by the Company.

There will be no retaliation for filing or pursuing a harassment claim. To the extent possible, all complaints and related information will remain confidential except to those individuals who need the information to investigate, educate, or to take action in response to the complaint.

All employees/volunteers are expected to cooperate fully with any ongoing investigation regarding a harassment incident. Employees/volunteers who believe they have been unjustly charged with harassment can defend themselves verbally or in writing at any stage of the investigation.

To protect the privacy of persons involved, confidentiality will be maintained throughout the investigatory process to the extent practicable and appropriate under the circumstances. Investigations may include interviews with the parties involved, and where necessary, individuals who may have observed the alleged conduct or who may have relevant knowledge.

            At the conclusion of a harassment investigation, the complainant and the “alleged harasser” shall be informed of the determination. Where appropriate, the “harasser” and the “victim” may be offered mediation or counseling.

Penalties for Violation of Anti-Harassment Policy

If it is determined that inappropriate conduct has occurred, the Company will act promptly to eliminate the offending conduct, and take such action as is appropriate under the circumstances.  Such action may range from counseling to termination of employment/volunteer arrangement, and may include such other forms of disciplinary action, as the Company deems appropriate under the circumstances and in accordance with applicable law.

While it is not the purpose of this Policy to regulate an employee’s personal morality, the Company considers harassment, discrimination, or retaliation to be an act of misconduct and subject to appropriate disciplinary action, up to and including termination of employment. False and malicious complaints of harassment, discrimination or retaliation may be the subject of appropriate disciplinary action. On the other hand, an employee will not be disciplined merely because the complaint is found to be without merit. Trellis for Tomorrow does not condone retaliation against any employee for making a report in good faith under this Policy.