Prohibition of Harassment, Discrimination, and Retaliation

One of the fundamental principles upon which our business is based is our commitment to provide employees with a working environment free from all forms of harassment, discrimination, and retaliation. Actions, words, jokes or comments by any employee, supervisor or customer based on an individual’s race, color, religion, national origin, age, disability, genetic information, sexual orientation, gender, gender identity, pregnancy status, status as a veteran, uniformed service or other protected characteristic simply will not be tolerated.

Sexual harassment is defined as any unwelcome sexual advance, whether verbal, graphic or physical when:

1. Submission to such conduct is made, either explicitly or implicitly, a term or condition of an individual’s employment; or
2. Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting the individual; or
3. Such conduct has the purpose or effect of substantially interfering with a person’s work performance or creating an intimidating, hostile or offensive work environment.

There are other types of behavior, depending on the circumstances, that could be considered a violation of this policy and that could result in discipline up to and including termination. The Company reserves the right to exercise its judgment in determining other types of prohibited behavior. This policy strictly prohibits any retaliation against an employee or other person who reports a concern about harassment or other inappropriate behavior.

To achieve our goal of providing a workplace free from harassment, discrimination, and retaliation we have developed a procedure by which inappropriate conduct can be reported and dealt with if encountered by employees. Any employee who feels that he or she has experienced or witnessed harassment, discrimination, or retaliation should promptly contact The Shelly Company’s EEO officer at 844-623-6087 or submit a written account of the harassment, discrimination, or retaliation to the Vice President of Human Resources.

Complaints will be investigated in a confidential manner, to the extent practical and permitted by law. Corrective action will be taken as appropriate based on the investigation. Every employee should feel free to raise concerns about harassment or discrimination without fear of reprisal.

The Company strictly prohibits and does not tolerate unlawful retaliation against any employee, by any employee. All forms of unlawful retaliation are prohibited, including any form of discipline, reprisal, intimidation or other form of retaliation for participating in any activity protected by law.

Examples of protected activities include:

• Making a good faith internal complaint with human resources or management specifically opposing unlawful discrimination or harassment or complaining about violations of wage and hour law (for example, if an employee believes they have been sexually harassed or not paid overtime they are owed).
• Filing a good faith complaint of unlawful discrimination or harassment with the US Equal Employment Opportunity Commission (EEOC) or in court.
• Participating in the Company’s internal investigation into allegations of harassment or discrimination.
• Supporting another employee’s internal or administrative complaint of unlawful discrimination (by, for example, testifying or providing an affidavit in support of a co-worker who has filed a discrimination complaint with the EEOC).
• Requesting an accommodation under the Americans with Disabilities Act
• Requesting or taking leave under the Family and Medical Leave Act or state leave statutes.
• Filing a worker’s compensation claim.

The examples above are illustrative only, and not exhaustive. No form of retaliation for any protected activity will be tolerated.

Any employee, regardless of position or title, who has engaged in retaliation in violation of this policy, will be subject to discipline, up to and including termination of employment.
If you have any questions about this anti-harassment, discrimination, and retaliation policy, please contact an EEO officer directly.

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