Executive Blueprints Inc: Executive Blueprints Inc Harassment,
Discrimination & Your Responsibilities February 2006
Training Guidelines: Training Guidelines Ground Rules for an interactive workshop:
Respect Mutual Confidentiality
Commitment to understand Concepts and Distinctions
Think Loud Thoughts
Every Individual is an Essential Component
Examples are provided for discussion and exchange of ideas for perspective only. This training is not a substitute for legal advice. If you are aware of harassment or discrimination in your environment, refer to your policy and procedure for escalation, reporting and response. Contact your manager or Human Resource regarding personal questions or situations.
Agenda: Agenda California AB1825 Title VII Civil Rights Act of 1964 Title I Americans with Disabilities California SB1809 Sue your Boss Examples for Discussion What to do, Your Responsibilities
California AB1825: California AB1825 Organizations with 50 or more employees must provide all supervisory personnel with the following:
Two hours of sexual harassment training within one year of January 1, 2005
Sexual harassment training and education once every two years
“More than 50 employees” includes organizations that regularly employ 50 or more persons, including independent contractors and temporary personnel.
A “Supervisor” is any individual having the authority to hire, transfer, suspend, lay off, recall, promote, discharge, assign, reward, or discipline other employees, or the responsibility to direct them, or to adjust their grievances, or effectively to recommend that action . . . If the exercise of that authority is not of a merely routine or clerical nature, but requires the use of independent judgment.” This language does not refer to title of manager or supervisor. It refers to individuals who exercise a position of authority or decisions over others, including contracted or temporary personnel. (You do not need a title to be in this role.)
California AB1825: California AB1825 Training must be of high quality and conducted via a classroom or other interactive training, and include the following topics:
Information and practical guidance regarding federal and state statutory laws about sexual harassment
Information about correction of sexual harassment and the remedies available to victims of sexual harassment
Practical examples aimed at instructing supervisors in the prevention of harassment, discrimination, and retaliation Training does not automatically protect an employer from liability in the event of a sexual harassment claim. However, failure to maintain legal compliance places the employer at much Higher Risk.
Sexual Harassment Defined: Sexual Harassment Defined Sexual harassment as defined by the United Stated Equal Employment Opportunity Commission (EEOC):
“Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature constitutes sexual harassment when submission to or rejection of this conduct explicitly or implicitly affects an individual's employment, unreasonably interferes with an individual's work performance or creates an intimidating, hostile or offensive work environment.”
The victim as well as the harasser may be a woman or a man. The victim does not have to be of the opposite sex.
The harasser can be the victim's supervisor, an agent of the employer, a supervisor in another area, a co-worker, or a non-employee.
The victim does not have to be the person harassed but could be anyone affected by the offensive conduct.
Unlawful sexual harassment may occur without economic injury to or discharge of the victim.
The harasser's conduct must be unwelcome.
Types of Sexual Harassment: Types of Sexual Harassment There are two legally recognized types of sexual harassment: “Quid Pro Quo” sexual harassment (2) “Hostile Environment” sexual harassment
Quid Pro Quo: Quid Pro Quo Quid Pro Quo:
Quid pro quo sexual harassment occurs when an individual's submission to or rejection of sexual advances or conduct of a sexual nature is used as the basis for employment decisions affecting the individual or the individual's submission to such conduct is made a term or condition of employment. It is sufficient to show a threat of economic loss to prove quid pro quo sexual harassment.
A single sexual advance may constitute harassment if it is linked to the granting or denial of employment benefits.
Courts have held employers strictly liable for quid pro quo sexual harassment initiated by supervisory employees.
A subordinate who submits and then changes her or his mind and refuses can still bring quid pro quo sexual harassment charges.
Hostile Environment: Hostile Environment Hostile Environment:
Hostile environment sexual harassment occurs when unwelcome sexual conduct unreasonably interferes with an individual's job performance or creates a hostile, intimidating or offensive work environment even though the harassment may not result in tangible or economic job consequences, that is, the person may not lose pay or a promotion. There are two conditions that determine liability for employers in cases of hostile environment sexual harassment:
The employer knew or should have known about the harassment, and
The employer failed to take appropriate corrective action
Hostile Environment: Hostile Environment Hostile Environment:
An employer can be held liable for the creation of a hostile environment by a supervisor, by non-supervisory personnel, or by the acts of the employer's customers or independent contractors if the employer has knowledge of such harassment and fails to correct it. An employer may be expected to know about the hostile environment
if there was a complaint to management
if management failed to establish a policy against sexual harassment
if the harassment is openly practiced or well-known among employees.
Personal Impact: Personal Impact One study found that fully 50% of women who filed a complaint in California were fired; another 25% resigned due to the stresses of the complaint process or the harassment itself. A study of federal employees reported that those who have been harassed lose $4.4 million in wages and 973,000 hours in unpaid leave each year. 90% to 95% of sexually harassed women suffer from some debilitating stress reaction, including anxiety, depression, headaches, sleep disorders, weight loss or gain, nausea, lowered self-esteem and sexual dysfunction.
Business Impact: Business Impact The costs are borne not only by the victims of harassment; they create financial havoc for employers as well.
Sexual harassment costs a typical Fortune 500 company $6.7 million per year in absenteeism, low productivity and employee turnover. That does not include additional costs for litigation expenses, executive time and tarnished public image should a case wind up in court.
Types of Harassment: Types of Harassment California Law defines the following types of harassment Verbal Harassment – Epithets, derogatory comments or slurs Physical Harassment – Assault, impeding or blocking movement, or any physical interference with normal work or movement, when directed at an individual Visual Harassment – Derogatory posters, calendars, cartoons or drawings Sexual Favors – Unwanted sexual advances which condition an employment benefit upon an exchange of sexual favors Gender Harassment – Due to pregnancy, childbirth or related medical conditions
Personal Liability: Personal Liability Harassers Are Personally Liable
If you, as an employee, are found to have engaged in sexual harassment, or if you as a manager know about the conduct and condone or ratify it, you may be personally liable for monetary damages.
Your company does not have to pay for damages assessed against you personally.
In addition, the company may take appropriate disciplinary measures, including termination, against any employee who engages in sexual harassment.
* Silence + Knowledge = Consent
Federal Law: Federal Law Federal Law, “It’s not just a California Thing” Title VII of the Civil Rights Act prohibits harassment of an employee based on race, color, sex, religion, or national origin. The Age Discrimination in Employment Act (ADEA) prohibits harassment of employees who are 40 or older on the basis of age The Americans with Disabilities Act (ADA) prohibits harassment based on disability. All EEOC Statutes prohibit retaliation for complaining of discrimination or participating in complaint proceedings
Federal Law: Federal Law When does Harassment violate Federal Law? Harassment violates federal law if it involves discriminatory treatment based on race, color, sex (with or without sexual conduct), religion, national origin, age, disability, or because the employee opposed job discrimination or participated in an investigation or complaint proceeding under the EEOC statutes.
Federal law does not prohibit simple teasing, offhand comments or isolated incidents that are not extremely serious. The conduct must be sufficiently frequent or severe to create a hostile work environment or result in a “tangible employment action,” such as hiring, firing, promotion, or demotion.
Discrimination: Discrimination What is Discrimination?
Discrimination covers actions taken against people because of their membership, perceived membership, or associated membership in certain protected classes.
Discrimination means treating people differently, and disadvantageously, compared with other people not in the same class. Remember that everyone is part of a protected class. Everyone has a race and marital status, is perceived as one gender or another, and associates with people in protected classes. Disparate (unequal) treatment Employee or Applicant is treated differently, specifically because of his or her protected class status Disparate (unequal) impact Employment practice that appears neutral on its face but is discriminatory against protected classes in practice (unequal requirements)
Discrimination: Discrimination Examples of discrimination
Base employment decisions (hiring, firing, promotions, benefits, etc) on protected class status
Rely on stereotypes to judge competence, qualification, or intelligence
Any employment action that has adverse impact on hiring, training or promotion or retention of employees in a protected class
Engage or permit employees to engage in harassment of a protected class
Act on perception of disability without evaluating fitness for a particular job
Retaliate against an employee, applicant or contractor for opposing harassment or discrimination, filing a complaint, assisting in an investigation, etc
Refuse to honor an otherwise eligible employees request for pregnancy disability leave under CFRA or FMLA
Refuse to accommodate religious requirements
Inquire on a job application if the applicant has ever been arrested
SB1809 Sue Your Boss Law: SB1809 Sue Your Boss Law The original law, effective 1/1/04, under Senate Bill 796, allowed individual employees and attorneys to sue for alleged violations and bypass state agency enforcement. SB 796 created penalties for every Labor Code violation and enabled the employee to share in any penalty awarded by the court. The court could also award attorneys' fees. Not surprisingly, this law resulted in a flurry of anti-employer lawsuits.
So, What Changed? The amendment to SB 1809 does not repeal SB796 or the penalties it created, but it does empower courts to award lesser penalties to avoid unjust results. It also creates procedural steps that must be followed for three broad categories of alleged Labor Code violations before an employee lawsuit may be filed. (Labor Code sections 2699 and 2699.5) The employee must now first notify the employer and the appropriate state agency of the alleged violation. The notice must include the specific code provisions alleged to have been violated, and the facts and arguments supporting the violation. All time limits run from the postmark date of this notice.
Miller v Department of Corrections: Miller v Department of Corrections On July 18, 2005 the California Supreme Court (Miller v Department of Corrections) issued a ruling involving two former employees at the valley State Prison for Women. The employees claimed that the warden of the prison at which they were employed accorded unwarranted favorable treatment to numerous female employees with whom the warden was having sexual affairs, and that such conduct constituted sexual harassment in violation of California law.
The sexual favoritism was sufficiently widespread as to constitute an actionable hostile work environment. The consistent behavior conveyed a perceived requirement to engage in sexual conduct with a superior to get promoted.
Burlington v Ellerth: Burlington v Ellerth In the June 1998 Supreme Court Case of Burlington v Ellerth, the court ruled that the employer would be strictly liable if the employee suffered tangible employment action. The employer is liable even if the employee never complains.
Tangible employment action includes refusal to hire, failure to promote, reassignment with significantly different or unfavorable responsibilities, or termination. If the employee does not suffer tangible employment action, the employer may not be liable if BOTH
The employer exercised reasonable care to prevent and promptly correct the harassing behavior and
The employee unreasonably failed to take advantage of any preventative or corrective opportunities provided by the employer
What do you think?: What do you think? An employee sues her employer alleging that her boss continuously harassed her for being late to work. He sent repeated emails, voice mail and reminded her daily of her attendance, threatening to fire her if she did not comply with the attendance policy of the company. Does she have a case? The law prohibits harassment based on race, religious creed, color, national origin, ancestry, disability, marital status, sex, age or sexual orientation.
It is not a case of harassment if the boss is applying company attendance policy equally to all employees. What if there is also a male coworker who is late, but only the woman receives reprimands with repeated emails, voice mails and threats? This could be a reasonable case for the employee. Apply company policy, reprimand and benefits consistently and equally to all employees.
What do you think?: What do you think? Is it sexual harassment for a supervisor to give a favorable employment benefit (bonus, raise or promotion) to an employee with whom the boss has romantic interests? If the employee has earned the favorable employment benefit by documented exceptional performance related to job responsibilities, an isolated instance of benefit is not harassment. However, the perception of favoritism can have a negative impact on overall morale and may lead to other claims of discrimination. If there is continued favoritism, and not an isolated instance, it increases risk of perceived harassment to the other employees. Be careful . .
What do you think?: It does not matter if the supervisor is male or female, or if the employee is male or female. What do you think? What happens if the employee is not romantically interested in the supervisor but voluntarily submits to sexual advances in the hopes of getting a promotion or a raise? The EEOC guidelines provide that where an employment opportunity of benefit is granted because of an individual’s submission to the employer’s sexual advances or requests for sexual favors, the employer may be liable for unlawful sex discrimination against others who were qualified for, but denied, the position.
What do you think?: What do you think? Two married employees are having an affair. During lunch another employee sees them holding hands and kissing at a local restaurant. Is this harassment? A Consensual Affair is not unlawful harassment.
Legal definitions of harassment are not intended to be a reflection of personal morality, so it is important to separate the circumstances of the action from the people or personal beliefs. Many companies maintain an Ethics Policy, Corporate Governance and Standards of Conduct that may be more defined than the legal definitions of harassment. In this case, the company should thoroughly train on the Standards of Conduct and apply these guidelines consistently to all employees.
What if the couple was seen holding hands on the company parking lot?
What do you think?: What do you think? Can an employee be found personally liable for sexual harassment damages? Yes.
“An employee of an entity subject to this subdivision is personally liable for any harassment prohibited by this section that is perpetrated by the employee, regardless of whether the employer or covered entity knows or should have known of the conduct and fails to take immediate and appropriate corrective action.”
- Government Code 12940(j)(3) An employee could be found liable even if the employer is not.
What do you think?: Yes.
There was a case involving a male employee who harassed his female supervisor. The female supervisor complained to her managers. The managers failed to take action. This created liability for the employer. What do you think? Can an employer be liable for Sexual Harassment committed by an employee against a Supervisor or Manager?
What do you think?: What do you think? A coworker invites an employee to join a group of other employees who regularly go out to dinner after work. Is this a hostile work environment? In determining whether harassment is sufficiently severe or pervasive to create a hostile work environment, the harassers conduct should be evaluated from the objective standpoint of a reasonable person. Title VII does not serve “as a vehicle for vindicating the petty slights suffered by the hypersensitive.” Thus, a single invitation to join a company group activity is not likely to be a violation. A coworker invites an employee on a date, and the employee declines the invitation. Is that harassment? The courts have determined that a co-worker single effort to go out on a date does not constitute an abusive working environment. The coworker repeatedly invites the employee on a date, even after the original offer has been declined. Is this harassment? If the employee is uncomfortable with the repeated efforts, it could create a hostile work environment.
What do you think?: What do you think? An employee puts pictures of nude models on the wall outside the office. Although nobody complains, should you do something? Yes. A “reasonable person” might be offended and therefore constitute a hostile work environment. Consider the potential victim’s perspective and not stereotypes of acceptable behavior. Ask to have them removed. What if the pictures are INSIDE the office? It is reasonable to assume that people go in the office. Ask to have them removed. What if they are in a desk drawer? The desk drawer is company property. Do not keep pictures there either. What if they are in a personal brief case or purse? Do not bring anything into the office environment that might be considered offensive by a “reasonable person”.
The ultimate test of reasonableness may be a jury of your peers.
What do you think?: What do you think? A male employee leaves a sexually explicit message for a female employee in the office with whom he has a romantic relationship.
Then he receives an equally sexually explicit message from a different female in the office.
Does he have a claim for harassment? Yes. Even though he left a sexually explicit message, it is presumed that the female employee with whom he has the romantic relationship is consensual.
The unwelcome explicit message from the other female was not consensual. If this were to occur, take preventative steps to be consistent and adopt a policy to eliminate all sexually explicit messages. This will reduce risk of a hostile work environment for all of the employees.
What do you think?: What do you think? An employee graphically describes sexual experiences of a non-employee related partner to other employees. Is this Sexual Harassment? Yes, if a person makes a reasonable complaint and is offended by the graphic details of her descriptions. Sexual Harassment can occur on business travel, conventions, group lunch, with vendors or contractors, or any location that employer / employee personnel exist in business related function, environment or activity.
Be considerate of the people around you. What if the conversation occurs off-site during lunch? Yes, if a person makes a reasonable complaint and is offended by the graphic details of her descriptions.
What do you think?: What do you think? An employee complains to a manager about Sexual Harassment, but asks not to investigate it.
“I just wanted you to know. I don’t want to get anyone in trouble. Don’t do anything unless it gets worse,” says the employee. Inaction = liability, there is no “off the record”.
Honor discretion and request for confidentiality during the documentation and thorough investigation. Reassure the employee that corrective action is intended to be preventative, not merely punitive.
It is not necessary to disclose the identity of the complaining employee to the accused employee, as long as you can investigate. Confidentiality reduces the risk of retaliation.
What do you think?: What do you think? What if it is only one person’s word against the other? The US Equal Employment Opportunity Commission Enforcement Guidance: Vicarious Employer Liability for Unlawful Harassment by Supervisors, dated 6/18/99:
If there are conflicting versions of relevant events, the employer will have to weigh each parties credibility. Factors to be considered are:
Inherent Plausibility: Is the testimony believable at face value?
Demeanor: Did the person seem to be telling the truth?
Motive to Falsify: Is there a reason to lie?
Corroboration: Is there a witness?
Past Record: Is there a history of similar behavior in the past?
If no determination can be made because evidence in inconclusive, the employer should still undertake preventative measures, like training and monitoring.
What do you think?: What do you think? Can a Company be liable for firing someone based on wrong determination resulting from a false claim of Sexual Harassment? Cotran v Rollins Hudig. Cal. Supreme Court, 1998
Cotran was Senior VP at Rollins Hudig. Two women accused him of sexual harassment. He allegedly exposed himself to them on multiple occasions.
Cotran denied the allegations, but was suspended pending investigations.
Two other women confessed to receiving obscene phone calls at home from the plaintiff, and Cotran was fired.
At trial, the plaintiff provided evidence of consensual affairs with the two women who had filed the original complaint.
The court found for the employer and determined that Rollins Hudig had acted in good faith and after investigation, had reasonable grounds for believing that the plaintiff had sexually harassed other employees.
What do you think?: What do you think? You can not retaliate against an employee or a witness for filing or assisting in the investigation of a Sexual Harassment complaint.
If you have a performance issue with the employee (like attendance), and then the employee files a complaint for Sexual Harassment, can the employer still take action, including termination? Yes, if the performance problems are adequately documented.
Any action must be consistent with company policy and other employees, and not related to the allegation of sexual harassment.
What do you think?: What do you think? Should a company announce the reason for termination of an employee as a result of Sexual Harassment? No. Treat all involved with confidentiality.
The employer faces the potential for a defamation action.
Results of investigation and course of action should be limited only to those who need to know.
What do you think?: What do you think? What if a vendor Sexually Harasses an employee? “An employer may also be responsible for the acts of non-employees, with respect to sexual harassment of employees, applicants, or persons providing service pursuant to a contract in the workplace, where the employer, or it’s agents or supervisors, knows or should have known of the conduct and fails to take immediate and appropriate corrective action. In reviewing cases involving the acts of non-employees, the extent of the employer’s control and any other legal responsibility which the employer may have with respect to the conduct of those non-employees shall be considered.”
What do you think?: What do you think? During a job interview for a receptionist position at a roofing company, a female applicant was told that the position would require being exposed to coarse language on the job and lots of stress. The applicant was asked if she could ‘handle it’. The applicant responded that she could and was hired for the position.
Thereafter, she was subjected to sexual comments, touching without permission, sexual jokes, nude calendars, rude gestures and innuendoes. She eventually left the job and filed a lawsuit claiming sexual harassment, retaliation, and constructive discharge. The roofing company claimed that the employee waived her right to file a complaint because she had been warned about the type of work environment she was entering.
What do you think? The court disagreed with the roofing company. An employee can not waive personal rights to work in an environment free from harassment.
What do you think?: What do you think? A receptionist at a Chicago securities firm was badgered by her boss for repeatedly wearing inappropriately provocative clothing. The plaintiffs boss criticized her for wearing suggestive short skirts, tight skirts and blouses, low-cut blouses, and other revealing clothes.
The boss allegedly told the plaintiff that her clothing left nothing to the imagination, and that he would not let his wife leave the house dressed like the receptionist did. She was reprimanded and ultimately terminated for unprofessional attire. She sued for sexual harassment.
What do you think? Dismissing the claim, the court characterized the situation as the “exact opposite” of most “hostile environment” claims. The judge observed that, although the plaintiff found her boss’s comments unwelcome, they were not sexual harassment, but rather reasonable requests for her to present herself more professionally.
What do you think?: What do you think? A bartender at Harrah’s Casino in Reno, Nevada brought a lawsuit alleging that her employer’s policy requiring female employees to wear makeup discriminates against her on the basis of sex, since male bartenders were not required to wear the same makeup.
Does this constitute sex discrimination?
What do you think? The court held that it was not. Grooming and appearance standards that apply differently to women and men do not constitute discrimination on the basis of sex. However, California Government Code 12947.5 states, “It shall be unlawful employment practice for an employer to refuse to permit an employee to wear pants on account of the sex of the employee.”
What do you think?: What do you think? Some female employees of a labor union alleged that a male supervisor, with little or no provocation, shouted at them, screamed at them, used foul language, invaded their personal space and used threatening physical gestures. The supervisor’s behavior was not, on it’s face, sex related or gender related. Eventually, the employees resigned and filed an action for constructive discharge claiming that they were subjected to harassment based on sex.
No one testified that the male supervisor made sexual overtures or lewd comments, that he referred to women employees in gender-specific terms, or that he imposed gender-specific requirements upon women employees.
What do you think? According to the court, there is no legal requirement that hostile acts be overtly sex or gender related in content. Harassing conduct need not be motivated by sexual desire to support an inference of discrimination on the basis of sex.
How to Stop Harassment: How to Stop Harassment When appropriate, confront the harasser and ask him or her to stop The harasser may not realize the advances or behavior are offensive. When it is appropriate and reasonable, you may tell the harasser that the behavior is unwelcome and must stop. Sometimes a simple communication is sufficient to resolve the situation. Step One – Ask the person to stop. Report Sexual Harassment Contact your supervisor, human resource department or officers of the company designated to investigate harassment. Sexual harassment or retaliation should be reported promptly. You do not need to be the recipient of harassment to report it. The Organization must Investigate and Take Action An investigation may damage a reputation or create retaliation. To avoid this, investigations must be discreet and considerate of the privacy of all parties involved. If evidence of improper conduct exists, take appropriate disciplinary action and document throroughly.
Prevention: Prevention “An Ounce of Prevention is worth a Pound of Cure”
Employers should develop, distribute, post and enforce a policy prohibiting all forms of harassment.
Employers should conduct yearly harassment training for ALL employees.
Employers should publish a procedure for reporting complaints.
The policy should be in writing. Employers should document, with employee signature, training attendance and receipt of policy.
Employers should promote an environment of mutual respect and acceptance. Prevention and education should be a positive reinforcement. Creating a threatening or confrontational atmosphere can have other adverse affects on employee morale. Treat prevention as a mature and disciplined response to a potentially highly emotionally charged subject, with dignity and respect.
Early Intervention Techniques: Early Intervention Techniques Person to Person – Communicate Concerns
Focus on the situation, issue, unwanted or inappropriate behavior. Do not make it personal or focus on the individual
Be specific about the behavior or environment (pictures, cartoons, etc) that is unwelcome or inappropriate
Tell the individual that it is unwelcome and ask them to stop the behavior or to remove the offensive material
Do it as soon as possible. Do not wait or dwell on your own emotional response
Encourage the other person’s commitment to correct the situation and to not repeat the circumstances
If you are uncomfortable with direct confrontation of the situation, consult with your supervisor, human resource or company designated officer
In Event of Complaint: In Event of Complaint COMPLAINTS MUST BE DOCUMENTED
Even if the complaint is verbal from the employee, employers must document the complaint and the response completely. There is no “Off the Record”
Review the complaints with all parties in complete confidentiality
Investigate with open ended questions, allow each person to express ‘their side of the story’ for fair and impartial understanding. Do not use leading questions, multiple choice questions, True / False or Yes / No questions
Focus on the circumstances, not the individuals
Corrective Action: Corrective Action Take Immediate Action to Stop Harassment and make sure it does not recur
Disciplinary action should be proportional to the seriousness of the circumstances
The employer should correct effects of the harassment
Possible Corrective Action
- No Action Necessary - Counseling - Verbal Warning - Written Warning - Improvement Plan - Final Written Warning - Suspension - Termination
Schedule Closure Meetings with both the Alleged Target and the Alleged Source
Closure with Alleged Source: Closure with Alleged Source Meet, Document and Include the Following
Date and type of complaint
The specific and detailed results of the investigation, do not generalize
The corrective action taken
An explanation of consequences for retaliation or continued behavior
An affirmation of complete confidentiality
A detailed explanation of follow-up to ensure no retaliation
The follow-up plan to assure that the behavior or circumstances have been corrected
Closure with Alleged Target: Closure with Alleged Target Meet, Document and Include the Following
Date and type of complaint
The specific and detailed results of the investigation, do not generalize
The corrective action taken
An explanation of consequences for retaliation or continued behavior
An affirmation of complete confidentiality
A detailed explanation of follow-up to ensure no retaliation
The follow-up plan to assure that the behavior or circumstances have been corrected
Schedule a follow-up review meeting
A Positive Environment: A Positive Environment Acts or omissions that promote the perception of unfairness may damage morale or even be viewed as discrimination.
Apply rules equally to everyone. Do not make individual exceptions and do not “make examples” of anyone
Act consistently with honest appraisals
Assume that everyone wants personal advancement
Avoid making decisions based on subjective ‘feelings’, use objective facts
Explain rationale for decisions to employees, give clear instructions
Make sure that channels for communication are open, “open door policy”
Listen to all sides of the story, complaint or request
Document and maintain complete records or employment decisions
Living with Ethics: Living with Ethics Be an Example to Others
Be Professional and Courteous
Use Common Sense
Be Honest
Act with Integrity
Learn the Company Ethics Policy
Avoid Conflicts of Interest, or the perception thereof
If it “feels wrong” check it out, trust your instincts
Make your Actions a Reflection of Your Words
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Make your Actions a Reflection of Your Words
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