703 Sexual and Other Unlawful Harassment and Discrimination
Effective Date: 01/01/2011Revision Date: 01/01/2019
SEATTLE PRIME CAPITAL is committed to providing a workplace that is free from all forms of discrimination, including sexual harassment. SEATTLE PRIME CAPITAL’s policy on sexual harassment is part of its overall efforts to provide a workplace free from discrimination, pursuant to local, state and federal laws prohibiting discrimination based on age, race, color, creed/religion, national origin, honorably discharged veteran and military status, marital status, disability, sexual orientation, gender identity, and sex, or any other characteristic that is protected by law. This policy is also part of SEATTLE PRIME CAPITAL’s commitment to diversity and inclusion, and a workplace that is free from harassment, disrespect, and divisiveness.
Sexual harassment is prohibited by the Civil Rights Act of 1964, as amended in 1991, and the Washington State Law Against Discrimination.
Policy General Provisions
- This policy applies to all employees, applicants for employment, executives, owners, managers, supervisors, interns and volunteers (whether paid or unpaid). For the purposes of this Policy only, this group is referred to as “Workers.”
- This Policy also applies to contractors, vendors, customers and all persons conducting business with SEATTLE PRIME CAPITAL. For the purposes of this Policy only, this group is referred to as “Others.”
- This policy applies to all persons regardless of their immigration status.
- Sexual harassment will not be tolerated. Sexual harassment includes harassment on the basis of sex (including pregnancy, related medical conditions, and breastfeeding), gender identity and expression, sexual orientation, or any other category protected by applicable local, state or federal laws. Any Worker covered by this policy who engages in sexual harassment or retaliation will be subject to corrective action, up to and including termination. Any Other covered by this policy who engages in sexual harassment or retaliation will be subject to corrective action, such as but not limited to: requesting that the Other’s employer take corrective action, up to and including reassignment or termination; suspension or termination of a contract with a vendor or contractor; banning the Other from SEATTLE PRIME CAPITAL’s premises for a specified period of time, or other corrective action intended to keep the harassing conduct from reoccurring.
- Sexual harassment is offensive, is a violation of our policies, can be unlawful, and may subject SEATTLE PRIME CAPITAL to legal liability. Harassers may also be individually subject to liability. Workers who engage in sexual harassment, including owners, executives, managers, and supervisors, will be subject to corrective action for such misconduct. Owners, executives, managers, and supervisors will be subject to corrective action if they fail to take appropriate action when they learn of or observe harassment.
- SEATTLE PRIME CAPITAL has an obligation to investigate and conduct a prompt and thorough investigation that ensures due process for all parties, whenever management receives a complaint about sexual harassment, or otherwise becomes aware of possible sexual harassment occurring. SEATTLE PRIME CAPITAL will keep the complaint and investigation confidential to the extent possible. When sexual harassment is found to have occurred, effective corrective action will be taken. All employees are required to cooperate with any internal investigation of sexual harassment.
- Harassing behavior does not need to be illegal harassment in order for SEATTLE PRIME CAPITAL to take corrective action. SEATTLE PRIME CAPITAL will strive to create a workplace free from disrespect, divisiveness, and inappropriate behavior. Therefore, behavior that could create a harassing environment should the behavior continue or escalate will not be tolerated, and will lead to corrective action.
- Retaliation is prohibited: SEATTLE PRIME CAPITAL will not tolerate retaliation against any Worker or Other who, in good faith, reports or provides information about suspected sexual harassment. Any owner, executive, manager or supervisor who takes retaliatory action against anyone who has reported sexual harassment or who has provided information about possible harassment will be subject to corrective action. SEATTLE PRIME CAPITAL will not tolerate retaliatory harassment by any Worker or Other who has reported harassment or against anyone who has provided information about possible harassment. Any Worker or Other who engages in retaliatory harassment will be subject to corrective action.
- Distribution of policy: This policy will be provided to employees upon hire, will be available on SEATTLE PRIME CAPITAL’s intranet site at https://www.seattleprimecapital.com/wa-hr, shall be posted in cafeterias, and will be posted at all of SEATTLE PRIME CAPITAL’s Washington locations.
- All employees will receive training on this policy and the policy will be made available in a variety of languages when necessary. There will be no barriers to accessing the policy or participating in enforcement.
Sexual Harassment Definition
Sexual harassment is defined as unwelcome conduct of a sexual nature, or conduct that is because of sex, when:
- Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive work environment (this can happen even if the complaining party is not the intended target of the sexual harassment);
- Such conduct is made either explicitly or implicitly a term or condition of employment; or,
- Submission to or rejection of such conduct is used as the basis for employment decisions.
Sexual harassment can include derogatory comments, jokes, or statements; sexual advances; sexually explicit language or stories; or visual, verbal or physical conduct of a sexual nature. This definition includes many forms of offensive behavior and includes gender-based harassment of a person even when the harassment is not sexual in nature, but rather is because of the person’s gender. Sexual harassment can include conduct against a person of the same sex as the harasser.
Any sexually harassing conduct will be addressed under this policy.
Examples of Conduct that is Considered Prohibited Harassment
- Physical conduct, such as rape, attempted rape, sexual assault, attempted sexual assault, pinching, patting, kissing, hugging, grabbing, pressing or intentionally brushing up against another employee’s body, poking, or physical intimidation by impeding or blocking someone’s movement or invading their space;
- Visual conduct: leering; making sexual gestures; displaying of sexually suggestive objects, pictures, cartoons, posters, screen-savers, or websites.
- Verbal conduct: making or using sexually derogatory comments, epithets, slurs and jokes; verbal abuse of a sexual nature; graphic verbal commentaries about an individual’s body; sexually degrading words used to describe an individual; derogatory comments related to gender or stereotypical gender roles; subtle or obvious pressure for unwelcome sexual activities; sexually suggestive or obscene letters, notes, emails texts, or invitations; conversations, comments or jokes about a person’s sexuality or sexual experience; questions about a person’s sexuality or sexual experiences;
- Asking a co-worker on a date multiple times if they decline the first request;
- Verbal abuse or joking concerning a person’s gender characteristics such as vocal pitch, facial hair or the size or shape of a person’s body, including remarks implying that a male is too feminine or a woman is too masculine.
- Offering an employment benefit (such as a raise, bonus, promotion, assistance with one’s career or better working conditions) in exchange for sexual favors, or threatening an employment detriment (such as termination, demotion, worse working conditions, or disciplinary action) for an employee’s failure to engage in sexual activity.
- Sending sexually related text-messages, videos or messages via social media.
- Physical or verbal abuse concerning an individual’s actual sex or the perception of the individual’s sex.
- Making or threatening retaliatory action after receiving a negative response to sexual advances.
- Hostile actions taken against an individual because of that individual’s sex, sexual orientation, gender identity, or the status of being transgender, such as:
- Interfering with, destroying or damaging a person’s workstation, tools or equipment, or other interference with the individual’s ability to perform the job;
- Sabotaging an individual's work;
- Bullying, yelling or name calling.
- Degrading comments in the form of sex stereotyping, which occurs when conduct or personality traits are considered inappropriate simply because they may not conform to other people’s ideas or perceptions about how individuals of a particular sex should act or look.
- Other actions not listed above could constitute sexual harassment and/or a violation of this policy and be subject to corrective action.
Conduct That Will Not Usually be Considered Sexual Harassment
Compliments on someone’s attire or new hairstyle; telling someone, “You look nice.”; a single congratulatory pat on the back; a congratulatory hug to someone with whom you are friends and who has expressed acceptance of hugs; or a group of employees joining together after work for a meal or drink, are examples of situations that would not usually be considered to be sexual harassment.
Location and Timing of Behavior
Sexual harassment is not limited to the physical workplace. It can occur during travel, at events sponsored by SEATTLE PRIME CAPITAL, or via phone, email, text, or social media. Such behavior can also occur outside of scheduled work time. Workers and Others who engage in sexually harassing conduct outside of the workplace or outside of work hours will be subject to corrective action.
Workers’ and Others’ Responsibilities
- Each individual Worker and Other has the responsibility to refrain from sexual harassment in the workplace. The harassing Worker will be subject to disciplinary action up to and including termination in accordance with SEATTLE PRIME CAPITAL’s disciplinary policy. Any Other who engages in sexual harassment or retaliation will be subject to corrective action, such as but not limited to: requesting that the Other’s employer take corrective action, up to and including reassignment or termination; suspension or termination of a contract with a vendor or contractor; banning the Other from SEATTLE PRIME CAPITAL’s premises for a specified period of time; or other corrective action intended to keep the harassing conduct from reoccurring.
- Any Worker or Other who believes they have been the target of sexual harassment or witnesses sexual harassment, shall follow SEATTLE PRIME CAPITAL’s Reporting Procedure to report the sexual harassment.
- A Worker or Other who believes that they have been the target of sexual harassment is encouraged to inform the harassing person that such conduct is unwelcome and offensive and must stop, if they can safely do so. However, this step is not necessary in order for an investigation and corrective action to take place.
- Workers shall familiarize themselves with this Policy and the Reporting Procedure, and attend all required sexual harassment trainings.
SEATTLE PRIME CAPITAL Responsibilities
- SEATTLE PRIME CAPITAL, including owners, executives, managers, and supervisors, are ultimately responsible for maintaining a workplace free from sexual harassment.
- Owners, executives, managers and supervisors must take a harassment complaint or an observed incident of sexual harassment seriously, and take prompt action. The parties should be separated to the extent possible, without any negative impact on the complaining party. A report should immediately be made to the Human Resources Director unless the Human Resources Director is the subject of the complaint, in which case the report should be made to the Operation Manager. All management and supervisory personnel will cooperate with the investigation.
- Managers and supervisors are required to report all complaints that they receive, or any harassment that they observe, to the Human Resources Director unless the Human Resources Director is the subject of the complaint, in which case the report should be made to the Operation Manager. This applies even when an employee tells the manager or supervisor about behavior that constitutes sexual harassment but does not want to make a formal complaint, or when the complaining party changes their mind and retracts the complaint.
- Retaliation against those who report sexual harassment or who participate as a witness to a complaint will not be tolerated. If a supervisor or manager sees any retaliation or retaliatory harassment toward a Worker or Other, they must report this conduct to the Human Resources Director unless the Human Resources Director is the subject of the complaint, in which case the report should be made to the Operation Manager. If an owner, executive, supervisor, or manager engages in retaliation, they will be subject to corrective action.
- Owners, executives, managers, and supervisors shall familiarize themselves with this Policy and the Reporting Procedures, and attend sexual harassment training. Owners, executives, managers, and supervisors shall be able to understand and recognize sexual harassment, and should be able to provide information and direction to employees regarding sexual harassment, the Policy, and the Reporting Procedures.
Reporting Methods
Reporting sexual harassment is everyone’s responsibility. SEATTLE PRIME CAPITAL will not be able to prevent or correct sexual harassment unless it is aware.
- All Workers and Others should report any harassment or behaviors that violate this Policy. Reports of harassment should be made to the Human Resources Director unless the Human Resources Director is the subject of the complaint, in which case the report should be made to the Operation Manager. Workers and Others are encouraged to make complaints in writing. However, a complaint of sexual harassment, including a verbal complaint, will still be investigated even if the complaint is not in writing.
- If a Worker or Other feels that they are being sexually harassed in violation of this policy by another employee, owner, executive, manager, supervisor, or third party doing business with SEATTLE PRIME CAPITAL, or witnesses sexual harassment, they are encouraged to immediately contact:
- Reporting information will be prominently posted in all Washington work locations in selected areas where Workers gather, and will be available on line at https://www.seattleprimecapital.com/wa-hr Methods of reporting and this Policy and Reporting Procedures will be distributed and displayed in multiple languages when necessary.
- The Human Resources Director at 425-248-2811
- The Operation Manager at 425-248-2829
- An employee can make an anonymous report. Anonymous reports will be investigated with the same procedure and timeliness as other reports. However, SEATTLE PRIME CAPITAL’s ability to investigate and respond to allegations and to provide feedback may be limited depending on the information provided in the complaint.
External process
Reporting harassment to SEATTLE PRIME CAPITAL does not stop a Worker or Other from also making a complaint in a different forum. They have a right to file a discrimination, harassment, and/or retaliation complaints with outside agencies, such as the Washington State Human Rights Commission (WSHRC) and the United States Equal Employment Opportunity Commission (EEOC). There may also be applicable local laws and agencies. A complaint with WSHRC must be filed within 6 (six) months of the incident of sexual harassment. A complaint with EEOC must be filed within 300 days of the incident.
WSHRC www.hum.wa.gov
1-800-233-3247
EEOC www.eeoc.gov
1-800-669-4000, 1-844-234-5122 (ASL Video Phone)
Retaliation
Retaliation is unlawful under federal, state and local law. The Washington State Law Against Discrimination (RCW 40.60) protects any individual who has engaged in “protected activity”. Protected activity occurs when a person has:
- Made a complaint of sexual harassment, either internally, with an administrative anti-discrimination agency, or filed a lawsuit about harassment;
- Provided information, testified or assisted in a proceeding involving sexual harassment;
- Opposed sexual harassment by making a verbal or informal complaint to management, or by simply informing a supervisor or management of harassment; or
- Reported that another Worker or Other has been sexually harassed.
Even if the alleged harassment does not rise to the level of a violation of law or of this Policy, the individual is protected from retaliation if the person engaged in protected activity believed in good faith that the practices were unlawful or a violation of policy. However, those who knowingly make a false complaint of harassment are not protected.
Examples of retaliation include but are not limited to:
•Termination or demotion;
• A decrease in hours for the employee;
• Being given more work, more difficult work, or undesirable tasks;
• Isolation;
• Hyper scrutiny by a supervisor or manager;
• Threatening messages sent via social media for reporting;
• Retaliatory harassment by supervisors or managers, or by co-workers when the harassment is reported to or witnessed by a supervisor or manager. Retaliatory harassment can include:
- Leaving the person out of meetings or work-related events;
- Refusing to communicate with the person;
- Spreading rumors about the person;
- Interacting with the person in a hostile manner that is different from interactions prior to the complaint;
• Disciplinary action based on pretextual reasons;
• Transfer to a less desirable location or;
• Giving a bad reference.
Retaliation that violates this policy is defined as any action that could discourage a Worker or Other from coming forward to make or support a sexual harassment claim. Adverse action need not be job-related or occur in the workplace to constitute unlawful retaliation (e.g., threats of physical violence for reporting via social media or outside of work hours). Workers and Others will be protected from retaliation and retaliatory harassment from owners, executives, managers, supervisors, and co-workers.
What is Not Retaliation
A negative employment action is not retaliatory merely because it occurs after the Worker engages in protected activity. Workers continue to be subject to all job requirements and disciplinary rules after having engaged in such activity. Changes in work duties, job site, or hours due to a legitimate business need are not retaliation. Similarly, an action that negatively impacts an Other is not retaliatory merely because it occurs after the Other engages in protected activity. Others continue to be subject to all contractual requirements (such as contractors and vendors), expectations for conduct (in the case of customers and others who interact with SEATTLE PRIME CAPITAL’s Workers), and changes in SEATTLE PRIME CAPITAL’s legitimate business needs are not retaliation.
Contacting Law Enforcement
If the harassing conduct involves or attempts rape, assault, unwanted touching, or confinement, the conduct could be a crime. The victim of such conduct is encouraged to call 911 or the local police department. Unless criminal behavior also occurred against SEATTLE PRIME CAPITAL, SEATTLE PRIME CAPITAL will not contact law enforcement on the victim’s behalf without the victim’s permission. The decision to do so or not will be left to the victim, but SEATTLE PRIME CAPITAL will support the victim if law enforcement is involved.
SEATTLE PRIME CAPITAL Sexual Harassment Reporting Procedures
Introduction
These procedures shall be used when dealing with sexual harassment issues that arise in the workplace, whether you are an employee, owner, executive, manager, or supervisor, or the designated individual who receives and investigates complaints of such issues. These procedures should be used in combination with the Sexual Harassment Policy. Please review that Policy and definition of sexual harassment found within it. All references to “sexual harassment” in this document are based on that definition.
The Reporting Procedure covers employees, applicants for employment, executives, owners, interns and volunteers (whether paid or unpaid) (collectively, “Workers”), and contractors, vendors, customers and all persons conducting business with SEATTLE PRIME CAPITAL (collectively, “Others”). “Policy” refers to SEATTLE PRIME CAPITAL’s Sexual Harassment Policy.
Reporting Methods
Reporting sexual harassment is Everyone’s responsibility. SEATTLE PRIME CAPITAL will not be able to prevent or correct sexual harassment unless it is aware.
1. If a Worker or an Other feels that they are being sexually harassed or witnesses sexual harassment in violation of the Policy by a Worker or third party doing business with SEATTLE PRIME CAPITAL, they should immediately contact one of the following to make a complaint:
- The Human Resources Director at 425-248-2811
- The Operation Manager 425-248-2829
- An employee can make an anonymous report. Anonymous reports will be investigated with the same procedure and timeliness as other reports. However, SEATTLE PRIME CAPITAL’s ability to investigate and respond to allegations and to provide feedback may be limited depending on the information provided in the complaint.
2. Workers and Others are encouraged to make complaints in writing. However, a complaint of sexual harassment, including a verbal complaint, will still be investigated even if the complaint is not in writing.
Receiving a Complaint
1. Any Owner, Executive, Manager, or Supervisor can receive a complaint of sexual harassment.
2. When an individual receives a complaint of sexual harassment, that complaint must be taken seriously, and the reporting party treated with respect.
3. Every effort should be taken to separate the alleged harassment victim from the alleged harasser. They should be placed on different shifts or different locations, or one should be placed on administrative leave during the investigation. However, to avoid the appearance of retaliation, the alleged harasser should be the individual moved, put on a different shift, or put on leave, unless the alleged victim specifically requests a move or to be put on leave. This request should be put in writing and signed by the alleged victim.
4. The individual receiving the complaint shall make a written record of the name of the complaining party, the nature of the allegations, the date, and the next steps taken.
5. The individual receiving the complaint, shall immediately forward the complaint and any related information to the Human Resources Director. However, if the subject of the Complaint is the Human Resources Director, the complaint should be forwarded to the Operation Manager.
6. The individual receiving the complaint, unless that individual is the Human Resources Director or someone else who has been assigned to investigate the Complaint, shall not make their own determination about whether or not the alleged conduct is a violation of the Policy.
Responsibilities of the Human Resources Director (or Operation Manager, if the Human Resources Director is the subject of the complaint)
General Responsibilities
1. The Human Resources Director (or Operation Manager, if the Human Resources Director is the subject of the complaint) must ensure that all parties to the complaint are physically safe, and that the alleged victim receives information about supportive resources.
2. The Human Resources Director (or Operation Manager, if the Human Resources Director is the subject of the complaint) shall either investigate the complaint themselves or delegate the investigation to appropriately trained staff or an outside investigator.
3. The investigator must remain neutral. If for whatever reason, the investigator cannot remain neutral, or has a conflict of interest, the investigator must recuse themselves as the investigator.
4. The investigator shall not presume that the alleged harasser is guilty.
5. The investigator shall not assume that the person making the complaint is not telling the truth or is mistaken or overreacting.
6. The investigator shall inform all parties and witnesses that the complaint and investigation will be kept confidential to the fullest extent possible, but that depending on what is found and what happens with the complaint, this might not always be possible.
7. The investigator should use a neutral interpreter when the complaining party, the accused, or a witness does not speak English or is more comfortable speaking in another language.
8. The investigator shall thoroughly document the investigation in a manner that is intended for review by a third party.
9. Investigations into complaints of harassment must be conducted even if the person making the complaint does not wish to pursue the complaint or withdraws the complaint; if the person making the complaint is no longer an employee; or when the alleged harasser is no longer an employee.
Investigation Process and Procedures
1. The investigator shall begin the investigation with interviewing the complaining party. The interview will include the following:
• An assurance that the complaint is being taken seriously and will be investigated.
• An explanation of retaliation that includes: (1) assuring the complaining party that retaliation is prohibited, (2) providing examples of common retaliation conduct, and (3) encouraging the complaining party to report retaliation in the same manner as violations of the Sexual Harassment Policy.
• A summary of the general investigation process and a review of possible outcomes from the investigation.
• An interview focused on the alleged conduct using the following guidelines:
- The interview uses open-ended questions beginning with “Who, What, Where, When, Why, How”;
- Ask follow up questions to develop key events and clarify details;
- All details can be relevant during this interview; seemingly unimportant details can be used later to evaluate credibility when few or no witnesses are available;
- If possible, have the interviewee write a timeline or written statement with as much detail as possible regarding the alleged conduct;
- Identify likely witnesses to include both eyewitnesses and witnesses that the interviewee spoke to shortly after the incident regarding the alleged conduct; and
- Identify corroborating documentation (i.e. emails, texts, social media posts, etc.).
• End the interview by asking the complaining party what they want to have happen to address the alleged conduct, while making clear this is not a promise that any action will be taken.
• Thank the complaining party for coming forward.
2. After the initial interview, the investigator will promptly interview the alleged harasser.[1] The interview will include the following:
• An overview of the allegations in the complaint;
• Inform the interviewee that the complaint is being taken seriously and will be investigated;
• An assurance to the interviewee that they are not “presumed guilty” unless a completed investigation supports that a violation of the Policy occurred;
• An explanation of the general investigation process and a review of possible outcomes from the investigation;
• An interview focused on the alleged conduct using the following guidelines:
- Use open-ended questions, if possible (Who, What, Where, When, Why, How);
- Can use leading questions to obtain key information or if the interviewee is reluctant to provide information or to give direct answers; and
- Ask follow up questions to develop key events and clarify details.
• Identify likely witnesses to include both eyewitnesses and witnesses that the interviewee spoke to shortly after the incident regarding the alleged conduct.
• Identify corroborating documentation (i.e. emails, texts, social media posts, etc.).
• An explanation of retaliation that includes: (1) explaining that retaliation is prohibited, (2) providing examples of common retaliation conduct, and (3) emphasizing that retaliation is prohibited.
• End interview with opportunity and offer for interviewee to provide any additional information they believe is relevant.
3. The investigator then interviews witnesses identified by either party, if any have been identified, or any other individuals known to have relevant information, or who is likely to have relevant information.
• These interviews should be used for three purposes:
- To determine what the witness personally observed related to alleged conduct;
- To determine what the witness was told after the fact about the alleged conduct; and
- To identify other likely witnesses;
• Each interview will include the following:
- Inform the interviewee that the complaint is being taken seriously and will be investigated;
- Inform the interviewee that the “alleged harasser” is not “presumed guilty” unless a completed investigation supports that a violation of the policy occurred;
- An explanation of retaliation that includes: (1) explaining that retaliation is prohibited, (2) providing examples of common retaliation conduct, and (3) encouraging the interviewee to report retaliation in the same manner as violations of the Sexual Harassment Policy;
- An interview focused on the alleged conduct;
• Use open-ended questions, if possible (Who, What, Where, When, Why, How);
• Can use leading questions to obtain key information or if the interviewee is reluctant to provide information or to give direct answers; and
• Ask follow up questions to develop key events and clarify details.
• End Interview with opportunity and offer for interviewee to provide any additional information they believe is relevant.
4. If appropriate, the investigator shall then collect relevant documents or evidence (i.e. pictures, text messages, emails, screen shots, etc.).
5. As needed, the investigator will conduct follow up interviews with parties and witnesses. The follow up will include obtaining any newly identified documents or evidence.
6. At the end of the investigation, the investigator shall draft a summary report documenting the relevant witness testimony and other evidence from the investigation and the investigator’s conclusion of whether the Sexual Harassment Policy was violated. The summary should be written in a manner that is intended to be reviewed by a third party.
7. The investigator shall forward the summary report to the appropriate decision maker for any disciplinary action.
Post-Investigation and Actions Taken
1. Meet with the parties separately to explain the outcome of the investigation.
2. Follow any laws, union contracts and internal policies governing confidentiality of employee information.
3. Inform the parties what steps were completed during the investigation.
4. Explain the outcome of the investigation, and why that decision was reached.
5. If the alleged harasser will be given corrective action, inform the complaining party that “corrective action” was or will be taken regarding the allegations.
6. Remind the parties that retaliation by anyone against the complaining party for bringing this complaint forward, or against witnesses for participating in the investigation, is prohibited. Ask the complaining party to report any retaliation.
7. Thank the complaining party for coming forward.
8. Take disciplinary action as decided upon, if applicable.
Investigations of Anonymous Complaints
1. Workers and Others can make anonymous sexual harassment complaints.
2. When SEATTLE PRIME CAPITAL receives an anonymous complaint, it will be investigated to the fullest extent possible.
3. If the alleged perpetrator is named, interviews will be conducted of that individual’s co-workers and supervisor, and in that individual’s department to determine if additional evidence exists.
4. Any other facts or information in the anonymous complaint will be followed-up on.
5. If evidence of harassment is uncovered, the perpetrator should be interviewed.
6. A summary report will be written detailing the efforts made to gather information on the complaint, and the conclusion reached by the investigation.
7. If the investigation determines that harassment occurred, the perpetrator will be subject to corrective action.
Retaliation
1. All Workers shall review and be familiar with the section of the Sexual Harassment Policy that prohibits retaliation. All Others who make complaints or are involved in investigations as witnesses will be informed of the prohibitions against retaliation.
2. Any violation of the retaliation policy will not be tolerated.
3. Any complaining party or witness who believes that they are being retaliated against should follow the procedures set forth in this document.
4. Any complaint of retaliation will be investigated in the same manner as set forth in this document.
5. Any individual found to have retaliated against a complaining party or witness will be subject to corrective action.