47G — Employee Handbook
Chapter 4 of 16

Anti-Harassment, Anti-Discrimination & Reporting

[4.1]Anti-Discrimination Policy

[4.1.1]Prohibited Discrimination

47G prohibits discrimination in any aspect of employment based on race, color, religion, sex, pregnancy, childbirth or related medical conditions, sexual orientation, gender identity, national origin, age, disability, veteran status, genetic information, citizenship status, or any other status protected by applicable federal, state, or local law.

This policy applies to all employment decisions and workplace conduct, including recruitment, hiring, placement, compensation, promotion, transfer, training, discipline, termination, benefits, assignments, scheduling, and participation in workplace programs or events.

47G’s mission depends on trust, professionalism, and disciplined execution. Discrimination undermines that standard and has no place in the organization.

[4.1.2]Examples of Discriminatory Conduct

Discriminatory conduct may include treating an employee or applicant less favorably because of a protected characteristic, making employment decisions based on stereotypes or assumptions, denying work opportunities for unlawful reasons, applying policies inconsistently based on protected status, or creating conditions that interfere with equal access to employment.

Discrimination may occur through direct action, indirect conduct, written communication, verbal statements, digital communication, employment decisions, exclusion from opportunities, or failure to act when unlawful conduct is known or reasonably should be known.

Employees are expected to recognize that intent does not eliminate impact. Conduct that violates this policy may result in corrective action even if the employee did not intend harm.

[4.1.3]Reporting Channels

Employees who believe they have experienced, witnessed, or become aware of discrimination should report the concern promptly.

Reports may be made to a supervisor, Human Resources, authorized leadership, or any other reporting channel identified by 47G. Employees are not required to report concerns to the person involved in the conduct, and employees may bypass a supervisor if the supervisor is involved in the concern or if the employee is uncomfortable reporting to that supervisor.

47G encourages early reporting so concerns can be reviewed and addressed with appropriate care. Delayed reporting does not prevent 47G from reviewing a concern, but early reporting strengthens the organization’s ability to gather accurate information and respond effectively.

[4.2]Anti-Harassment Policy

[4.2.1]Workplace Harassment

47G prohibits workplace harassment based on any protected characteristic or any other conduct that violates applicable law or organizational policy.

Harassment may include unwelcome verbal, physical, visual, written, or digital conduct that is based on a protected characteristic and that creates an intimidating, hostile, or offensive work environment, interferes with an employee’s work performance, or affects employment opportunities.

Harassment may come from supervisors, managers, coworkers, contractors, vendors, members, visitors, public officials, event participants, or other individuals encountered through work. 47G expects employees to conduct themselves professionally in all work-related settings, including offices, events, meetings, travel, conferences, digital platforms, and partner engagements.

[4.2.2]Sexual Harassment

47G prohibits sexual harassment in any form.

Sexual harassment may include unwelcome sexual advances, requests for sexual favors, or other verbal, physical, visual, written, or digital conduct of a sexual nature when submission to the conduct is made a condition of employment, when employment decisions are based on acceptance or rejection of the conduct, or when the conduct creates an intimidating, hostile, or offensive work environment.

Sexual harassment may occur regardless of the gender, sexual orientation, gender identity, position, or seniority of the individuals involved.

47G will not tolerate sexual harassment in the workplace or in any work-related environment.

[4.2.3]Verbal, Physical, Visual, and Digital Harassment

Harassment may occur through many forms of conduct.

Verbal harassment may include slurs, insults, jokes, comments, threats, repeated unwanted questions, or degrading remarks related to a protected characteristic.

Physical harassment may include unwanted touching, blocking movement, intimidation, physical interference with work, or threatening gestures.

Visual harassment may include offensive images, symbols, cartoons, objects, clothing, screensavers, posts, or other visual materials that target or demean a protected characteristic.

Digital harassment may include inappropriate emails, text messages, social media messages, chat messages, shared images, online comments, video calls, or other electronic communications connected to work or the workplace.

Employees are responsible for maintaining professional standards across all communication channels. Digital conduct carries the same responsibility as conduct in a meeting room.

[4.2.4]Examples of Prohibited Behavior

Prohibited harassment may include offensive jokes or comments about a protected characteristic; repeated unwanted remarks about a person’s appearance, body, accent, religion, culture, age, disability, pregnancy, gender identity, sexual orientation, race, national origin, veteran status, or family status; unwanted sexual comments or advances; displaying offensive material; mocking religious or cultural practices; using slurs or demeaning language; threatening or intimidating another person; or interfering with an employee’s ability to work.

Prohibited conduct may also include pressuring an employee for dates or personal contact after the employee has declined, sending inappropriate images or messages, making employment opportunities dependent on personal or sexual attention, or retaliating against someone for rejecting unwelcome conduct.

This list is not exhaustive. 47G may determine that other conduct violates this policy based on the facts, applicable law, and the organization’s workplace standards.

[4.3]Anti-Bullying Policy

[4.3.1]Verbal Bullying

47G prohibits bullying that undermines a respectful, safe, and productive workplace.

Verbal bullying may include repeated insults, ridicule, humiliation, yelling, name-calling, hostile sarcasm, public shaming, threats, or aggressive communication that is intended to intimidate or demean another person.

47G expects direct communication, not personal attacks. Employees may disagree, challenge ideas, and address performance concerns, but they must do so with professionalism and control.

[4.3.2]Physical Bullying

Physical bullying may include pushing, blocking movement, invading personal space in a threatening manner, damaging personal property, using physical intimidation, or engaging in any conduct that creates fear for personal safety.

Any act or threat of physical harm must be reported immediately. 47G may take urgent action when necessary to protect employees, visitors, partners, and the workplace.

[4.3.3]Gesture-Based Bullying

Gesture-based bullying may include threatening gestures, mocking gestures, obscene gestures, hostile facial expressions used to intimidate, or other nonverbal conduct that demeans or threatens another person.

Employees are expected to maintain professional composure in meetings, events, office settings, digital calls, and all other work-related environments.

[4.3.4]Exclusion or Intimidation

Bullying may include deliberate exclusion from work-related communication, meetings, information, or opportunities when the exclusion is intended to isolate, embarrass, or undermine an employee.

Bullying may also include intimidation, coercion, repeated hostile treatment, misuse of authority, or behavior that interferes with an employee’s ability to perform their work.

This policy does not prohibit appropriate performance management, coaching, accountability, operational direction, or corrective action. Leaders are expected to address performance and conduct issues directly, but they must do so with professionalism, fairness, and respect.

[4.4]Workplace Violence Prevention

[4.4.1]Threats

47G prohibits threats of violence, whether direct or indirect, verbal or written, physical or digital.

Threats may include statements, gestures, messages, images, or conduct that would cause a reasonable person to fear harm to themselves, another person, or property. Threats made jokingly, casually, or in frustration may still violate this policy.

Employees must report threats immediately to a supervisor, Human Resources, authorized leadership, or emergency services when immediate danger exists.

[4.4.2]Intimidation

47G prohibits intimidation that creates fear, disrupts work, or interferes with the safety and confidence of employees or others in the workplace.

Intimidation may include aggressive confrontation, stalking, repeated unwanted contact, hostile surveillance, coercive behavior, threatening posture, or conduct intended to pressure another person through fear.

Employees are expected to address conflict through appropriate workplace channels, not intimidation or coercion.

[4.4.3]Physical Violence

47G prohibits physical violence in any workplace or work-related setting.

Physical violence may include hitting, pushing, shoving, grabbing, fighting, throwing objects, damaging property, using weapons, or any other conduct that causes or threatens physical harm.

Employees who engage in workplace violence may be subject to immediate corrective action, up to and including termination of employment. 47G may also contact law enforcement or take other action necessary to protect safety.

[4.4.4]Reporting Safety Concerns

Employees must report safety concerns, threats, violence, weapons concerns, stalking, domestic violence spillover into the workplace, or other conduct that may create risk to employees, partners, visitors, or the public.

If there is an immediate threat to life or safety, employees should contact emergency services first and then notify 47G leadership as soon as it is safe to do so.

47G will respond to safety concerns based on the seriousness of the matter, available information, applicable law, and the organization’s responsibility to maintain a safe workplace.

[4.5]Complaint Reporting Procedure

[4.5.1]Multiple Reporting Options

47G provides multiple reporting options so employees can raise concerns through a channel that is appropriate to the circumstances.

Employees may report concerns to their direct supervisor, another supervisor, Human Resources, authorized leadership, or any reporting channel designated by 47G. Employees are not required to follow the chain of command when reporting discrimination, harassment, retaliation, violence, safety concerns, ethical concerns, or other serious misconduct.

Employees should report concerns as soon as possible and provide all relevant information available, including dates, locations, individuals involved, witnesses, documents, messages, and any prior steps taken.

[4.5.2]Supervisor Responsibilities

Supervisors have a responsibility to take reports seriously and act promptly.

A supervisor who receives a complaint or becomes aware of possible discrimination, harassment, retaliation, bullying, violence, or other serious misconduct must promptly report the matter to Human Resources or authorized leadership. Supervisors should not attempt to handle serious complaints alone or promise confidentiality beyond what 47G can reasonably provide.

Supervisors are expected to model professional conduct, protect employees from retaliation, document concerns appropriately, and support 47G’s review process.

[4.5.3]Human Resources or Leadership Contacts

Human Resources or authorized leadership is responsible for receiving complaints, determining appropriate next steps, coordinating reviews or investigations, documenting outcomes, and recommending corrective action when warranted.

Employees who are unsure where to report a concern should contact Human Resources or any member of authorized leadership.

If a complaint involves Human Resources, an executive, or another person who would normally receive the report, the employee may report the concern to another authorized leader or another channel designated by 47G.

[4.5.4]Anonymous Reporting, If Available

47G may provide anonymous reporting channels when available and appropriate.

Employees who report anonymously should provide as much detail as possible so the organization can review the concern effectively. Anonymous reports may limit 47G’s ability to ask follow-up questions, verify information, or communicate outcomes, but 47G will review anonymous concerns to the extent reasonably possible.

Employees are encouraged to report concerns in a way that allows 47G to respond thoroughly, while recognizing that some employees may prefer or need to report anonymously.

[4.6]Investigation Process

[4.6.1]How Complaints Are Reviewed

47G will review complaints in a timely, fair, and professional manner.

The review process may include interviews, document review, digital communication review, witness statements, consultation with leadership or legal counsel, interim measures, and other steps appropriate to the nature of the concern.

The scope and timing of an investigation may vary depending on the seriousness of the allegation, the number of individuals involved, availability of information, legal requirements, and operational needs.

47G will make findings based on the information available and will take action it determines to be appropriate under the circumstances.

[4.6.2]Confidentiality Limits

47G will treat complaints and investigations with appropriate discretion.

Information will be shared only with individuals who have a legitimate business or legal need to know, such as those involved in reviewing the concern, responding to the complaint, implementing corrective action, or complying with legal obligations.

47G cannot guarantee complete confidentiality. Some information may need to be disclosed to conduct a meaningful review, provide due process, protect workplace safety, or comply with applicable law.

Employees involved in a complaint or investigation are expected to maintain appropriate confidentiality and avoid unnecessary discussion of the matter.

[4.6.3]Cooperation Expectations

Employees are expected to cooperate honestly and fully in investigations.

Cooperation may include participating in interviews, providing documents or messages, identifying witnesses, preserving relevant information, and answering questions truthfully.

Employees must not interfere with an investigation, withhold relevant information, destroy or alter records, pressure witnesses, retaliate against participants, or provide false information.

Failure to cooperate or dishonest participation in an investigation may result in corrective action, up to and including termination of employment.

[4.6.4]Corrective Action

If 47G determines that policy violations, misconduct, or other concerns occurred, the organization will take corrective action it determines to be appropriate.

Corrective action may include coaching, counseling, training, written warning, reassignment, schedule change, reporting structure change, removal from an event or project, suspension, termination of employment, vendor action, partner restrictions, or other measures appropriate to the circumstances.

Corrective action will be based on the nature and severity of the conduct, prior history, impact on the workplace, applicable law, and the need to protect 47G’s mission, employees, partners, and reputation.

[4.7]Non-Retaliation Policy

[4.7.1]Protection for Good-Faith Complaints

47G prohibits retaliation against any employee who makes a good-faith complaint or report of discrimination, harassment, bullying, workplace violence, safety concerns, ethical concerns, legal concerns, policy violations, or other workplace misconduct.

A good-faith complaint does not require that the concern ultimately be substantiated. It requires that the employee honestly believes the concern may be true and reports it without knowingly providing false information.

Employees who knowingly make false complaints or provide false information may be subject to corrective action. This does not apply to complaints made in good faith that are not substantiated.

[4.7.2]Protection for Participation in Investigations

47G prohibits retaliation against employees who participate in an investigation, provide information, serve as a witness, support another employee’s complaint, request an accommodation, or exercise rights protected by law or policy.

Protected participation includes honest cooperation with internal reviews, external agency proceedings, legal processes, safety inquiries, and other protected workplace matters.

Employees are expected to participate truthfully, professionally, and without interference.

[4.7.3]Consequences for Retaliation

Retaliation may include termination, demotion, reduced hours, pay changes, unfavorable assignments, exclusion from meetings, threats, intimidation, harassment, negative treatment, or any action that would discourage a reasonable employee from making a complaint or participating in a protected process.

Any employee who engages in retaliation may be subject to corrective action, up to and including termination of employment.

Employees who believe they have experienced or witnessed retaliation should report the concern promptly. 47G will review retaliation concerns with the same seriousness applied to the original complaint.

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