Sexual and Other Unlawful Harassment

PMG is committed to providing its employees with a work environment that is free from discrimination and harassment of any kind, including harassment based on an individual’s race, religion, color, gender, national origin, age, disability, veteran status, or any other characteristic protected by law. PMG strictly prohibits, and will not tolerate in any fashion, harassment of any employee by another employee (regardless of position or authority). Similarly, PMG will not tolerate harassment of its employees by any client, vendor, supplier, or other third party.

Prohibited harassment occurs when an individual is subjected to verbal or physical conduct that defames or shows hostility toward the individual because of his or her race, color, religion, gender, national origin, age, disability, veteran status, or any other characteristic protected by law, including the fact that such individual has made a complaint of discrimination or harassment, has participated in the investigation of any such complaint, or due to such individual’s association, friendship or relationship with any person protected by applicable law. Prohibited harassment also includes conduct that (i) creates or is intended to create an intimidating, hostile, or offensive working environment, (ii) interferes or is intended to interfere with the individual’s work environment or performance, or (iii) otherwise adversely affects the individual’s employment.

Examples of such harassment include, but are not limited to:

Using or making reference to epithets, slurs, negative stereotyping, or threatening, intimidating or hostile acts, which relate to race, color, religion, gender, national origin, age, disability, veteran status, or any other characteristic protected by law; and

Publication or circulation of any written or graphic material that defames or shows hostility or aversion toward an individual or group because of their race, color, religion, gender, national origin, age, disability, veteran status, or any other characteristic protected by law.

This policy’s prohibition against harassment specifically includes, but is not limited to, sex-based and sexual harassment. Sexual harassment occurs when unwelcome conduct of a sexual nature becomes a condition of an employee’s continued employment or creates an intimidating, hostile, or offensive working environment.

Examples of sexual and sex-based harassment include, but are not limited to, the following:

Requests for sexual favors (whether explicitly or implicitly);

Unwanted physical contact of any nature, including touching, rubbing, pinching, or brushing the body;

Verbal harassment, such as sexual innuendoes, suggestive comments, jokes of a sexual nature, sexual propositions, and threats;

Non-verbal conduct, such as display of sexually suggestive objects or pictures, leering, whistling, or obscene gestures; and

Acts of physical aggression, intimidation, hostility, threats, or unequal treatment based on sex (even if not sexual in nature).

Any employee who believes he or she has been harassed in any way in violation of this policy should report the conduct immediately to the employee’s supervisor. If the supervisor is unavailable or you believe it would be inappropriate to contact that person, you should immediately contact the Administrator or any other member of management.

Any employee who experiences harassment by a non-employee, or who observes harassment of an employee by a non-employee, should report such harassment to his or her supervisor, the Administrator, or any other member of management.

All reports will be treated seriously and confidentially to the extent reasonably possible. PMG will not take or allow anyone else to take any adverse action against an employee because he or she has reported, or participated in the investigation of, legitimate concerns of possible discrimination or harassment. PMG will immediately conduct a thorough and impartial investigation of all complaints received and such investigations will be conducted in a timely and confidential manner. Upon the conclusion of its investigation, PMG will advise the complaining employee of its findings as well as any steps taken to prevent future violations.

Supervisors are responsible for the administration of this policy. Should any supervisor learn of a violation of this policy, they are expected to take whatever steps are necessary to prevent further harm to the affected employee and immediately report the conduct to the Administrator or any member of management for a full and prompt investigation. Failure to report such conduct will be considered a violation of this policy and will subject the supervisor to disciplinary action, up to and including discharge.

Any employee suspected of engaging in harassing or retaliatory conduct of any nature in violation of this policy after reasonable investigation will be subject to disciplinary action, up to and including immediate termination. If PMG finds that an employee has violated the policy against harassment, appropriate disciplinary action will be taken, up to and including termination.

Policy No.  104  Issued  2/10/2006  Applicable  5/22/2009