Anti-Harassment and Discrimination Policy

Sexual harassment is a form of illegal harassment and a violation of this policy. Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and any other verbal or physical conduct of a sexual nature, when:

Unwelcome sexual conduct may include, but is not limited to:

Under the law, it makes no difference if the victim of sexual harassment is of the same or opposite sex as the harasser. Engaging in such conduct through written communications or by originating, forwarding or accessing electronic communications via texting, email or the Internet also is specifically prohibited.

It is a violation of this policy for any team member to engage in unwelcome and offensive conduct on the basis of a team member’s age, race, color, gender, religion, national origin, disability, military service, sexual orientation, genetic information, gender identity, or any other classification protected by law – which has the purpose or effect of interfering unreasonably with another team member’s work performance or creating an intimidating, hostile or offensive working environment. Examples of such conduct include but are not necessarily limited to:

Prohibitions against harassment will also apply to non-team members. Non-team members include applicants or third parties such as vendors or customers. When non-team members are present at our workplace or interact with our team members (including through electronic communications), we expect them to adhere to the same standards of conduct that we expect of our team members. If any team member feels harassed or discriminated against, either sexually or based on membership in a protected class, he/she should use the reporting procedure below. Conversely, we expect our team members to treat non-team members with the same courtesy and respect as co-workers. Harassment or discrimination by NDX team members is strictly prohibited.

NDX strongly encourages good faith reporting of all instances of harassment or discrimination. In addition, NDX encourages team members who believe they are being subjected to such conduct to advise the offender that his/her behavior is unwelcome and request that it be discontinued. Any Manager who becomes aware of possible sexual or other unlawful harassment or discrimination must immediately advise Human Resources or his/her Manager. A team member who feels he/she has been harassed or subjected to discrimination or who has witnessed behavior in violation of this policy must immediately report the alleged violation to his/her:

Because NDX takes allegations of sexual and other unlawful harassment and discrimination seriously, we will respond promptly to complaints and where it is determined that such inappropriate conduct has occurred, we will act promptly to eliminate the conduct and impose such corrective action as is necessary, including disciplinary action where appropriate.

Please note that while this policy sets forth our goals of promoting a workplace that is free of sexual and other unlawful harassment and discrimination, the policy is not designed or intended to limit our authority to discipline or take remedial action for workplace conduct which we deem unacceptable, regardless of whether that conduct satisfies the definition of sexual or other unlawful harassment or discrimination.

A prompt, thorough and impartial investigation will be made. The complaint will be disclosed only to the extent necessary to conduct a thorough investigation or as necessary to take appropriate corrective measures.

Each team member is expected as a condition of employment to cooperate in any such investigation. Failure to cooperate in such an investigation may subject the team member to disciplinary action, up to and including termination of employment. When we have completed our investigation, we will, to the extent appropriate, inform the person filing the complaint and the person alleged to have committed the conduct of the results of that investigation. If it is determined that inappropriate conduct has occurred, we will act promptly to eliminate the offending conduct.

Management will ensure that there is no coercion, retaliation, intimidation, or harassment directed against any team member who makes a good faith report or serves as a witness on behalf of another team member. If any team member feels that he/she has been retaliated against for making a report or participating in the investigation process, the alleged violation should be reported immediately to Human Resources using the procedures previously noted.

Any team member found to have unlawfully harassed or discriminated against another team member will be subject to appropriate discipline, up to and including termination of employment at the sole discretion of the Company. Further, any team member found to have coerced, retaliated against, intimidated or harassed a team member for making a report or for serving as a witness on behalf of another team member, will be subject to appropriate discipline, up to and including termination of employment.

Engaging in bad faith complaints is an equally serious matter. If, following an investigation, it is determined that allegations have been made in a bad faith manner, appropriate discipline, up to and including termination of employment will result.

If there are any questions regarding this policy, you may contact us at NDXEducation@NationalDentex.com