We are committed to providing all employees with a work environment free of discrimination or harassment of any kind. The purpose of this policy statement is to reaffirm our commitment to equal employment opportunity and to providing a harassment-free work environment for all employees. Each member of the Company is expected to be sensitive to and respectful of your coworkers and others with whom you communicate while working for us. We prohibit all forms of harassment or discrimination based on race, age, religion, color, creed, sex, sexual orientation, gender identity, national origin, physical, sensory or mental disability, marital or veteran status, genetic information, family status, ancestry or any other classification protected by law.

Harassment or discriminatory conduct of any kind, whether physical or verbal, committed by supervisors or non-supervisory personnel, is prohibited. Prevention of discriminatory activities must be practiced at all times, especially by supervisors. In those cases where discrimination can be established, disciplinary action up to and including dismissal may be taken.

Taking reprisal action against any employee because he or she has filed a discrimination or harassment complaint, furnished information or participated in any manner in an investigation, compliance review or hearing is prohibited. In those cases where reprisal action can be established, disciplinary action up to and including dismissal may be taken.

Harassment Defined
Different and unfair treatment of any employee or individual because of his or her race, color, sex, religion, national origin, age, disability or protected group status as defined by federal and state laws is prohibited. This includes harassment and intimidation. Harassment is behavior perceived by the receiver as unwelcome and includes, but is not limited to, the use of verbal or practical jokes, unwelcome touching, offensive remarks or put-downs, displays of objects and materials which create an offensive environment. It includes conduct that may not be unlawful but has been determined to be inappropriate in our workplace. If you feel you are the victim of discrimination or harassment in any form, you must immediately notify your supervisor or other management employees with whom you feel comfortable discussing the matter. You must also immediately notify your supervisor or management if you believe or become aware of such conduct being directed to another employee. If you are not comfortable reporting the conduct to your supervisor or other management you should report it directly to Ralph Schultz, John Park, or Cassandra Tetzlaff at 503-520-9991

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We strive for a respectful, pleasant and productive working environment, but we cannot ensure such an environment unless these issues are brought to our attention. The following steps have been established for filing and handling complaints of any employee based on alleged acts of discrimination:

1. Any employee may file a complaint by communicating directly with their supervisor or any member of management. The multiple options noted here for presenting a complaint are made available with the intent of giving the employee the opportunity to select a person with whom they feel comfortable. Any employee may file a complaint orally by meeting with management or by

submitting a complaint in writing. All complaints will be acknowledged within three days of receipt.

2. The Company will proceed with an investigation of the complaint. Confidentiality will be maintained as far as is practicable. If it is necessary to make the employee filing the complaint known to others, the employee shall be advised in advance and shall be told why it is necessary that they be identified.

3. On the basis of the facts developed, management will render a decision in writing as soon as possible after completion of the investigation. If corrective or remedial action is warranted appropriate disciplinary action will be taken.

4. Employees who file complaints or who testify, assist or participate in any manner in an investigation or hearing, will be safeguarded against intimidation, coercion, retaliation or discrimination of any kind. All such acts against complainants or other participants should be reported immediately to management.

5. All employees are required to fully cooperate in carrying out this policy and to avoid acts of discrimination or harassment or intimidation on the basis of race, color, gender, religion, national origin, disability, age, marital status or sexual orientation.

Sexual Harassment Defined
Sexual harassment is considered sex discrimination not only because of the sexual nature of the conduct to which the victim is subjected but also because the harasser treats a member or members of one sex differently from members of the opposite sex. Sexual harassment does not mean occasional compliments of a socially acceptable nature. Seeking, pursuing or being involved in a dating relationship with another employee or supervisor or subordinate could be perceived as sexual harassment. Should a non-work related personal relationship develop outside of the office and is unrelated to work activities between coworkers; managers and supervisors should be notified and the employees should modify their behavior to make sure there is no perception of or actual sexual harassment in connection with the relationship or as a result of a relationship ending.

 

Unwelcome sexual advances, requests for sexual favors or other verbal or physical conduct of a sexual nature constitutes sexual harassment 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 a basis for employment decisions affecting such individuals; or

3. Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an offensive work environment. Even conduct that is intended to be “innocent” may still constitute sexual harassment under this policy if the recipient of that conduct reasonably perceives it to be otherwise. If you are aware of any such conduct, it is your responsibility to take affirmative actions to stop it immediately either by telling the employee to stop the offensive conduct or reporting it immediately to management.

This complaint procedure is the sole vehicle for an employee to bring a harassment or discrimination complaint. Failure to use the complaint procedure may bar you from bringing a claim for harassment, discrimination or retaliation against the Company.