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It is Benchmark Mortgage’s policy that sexual harassment of its employees or its customers by company personnel will not be tolerated. All employees, whether supervisors or non-supervisors, are responsible for ensuring that the workplace is free of sexual harassment. All personnel must avoid any action or conduct that could be in any way viewed as sexual harassment. In addition, any person who has been sexually harassed at work by anyone – including supervisors, coworker, customers – must promptly bring the problem to the attention of his or her immediate supervisor or an official of the company. In the event that the complaint involves the person’s immediate supervisor or someone in the employee’s direct line of command, that employee should go to a higher supervisor or manager, or should contact the director of human resources.

In order that all company personnel may understand exactly what is meant by the term sexual harassment, we have listed below four points that should be helpful in recognizing and defining the subject.

  1. Unwelcome advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature that affects employment decisions, interferes with work performance or creates a hostile work environment.
  2. Deliberate or repeated unsolicited verbal comments, gestures or physical contacts of a sexual nature that are unwelcome or offensive to a reasonably sensitive person. Included in this category are innuendos, jokes, sexually oriented comments or any other tasteless action of a sexual nature.
  3. Any repeated or unwanted sexual comments, looks suggestions, or physical contacts that are objectionable or cause an employee discomfort on the job or the condoning of a working environment inwhich such actions occur.
  4.  Any of the above activities between a direct supervisor and subordinates whether you think the activities are welcome or not, or are wanted or not.

It must be also understood that when a company leader, supervisor, manager -any company official – receives a complaint of sexual harassment, it must be investigated promptly and documentation placed in applicable personnel files. When a manager or supervisor becomes aware of a sexual harassment problem, the following steps are to be taken immediately to resolve it.

  1. Interview the person complaining of harassment. Ask the details of the specific instances of harassment, the dates and locations of each incident and the names of any witnesses.
  2. Encourage the complaining person to put the complaint in writing.
  3. Make a thorough investigation. Talk to witnesses and other employees. Contact the human resources department for any assistance you may need.
  4. Once the details of the complaint have been determined (and within no more than 24 hours, if possible), the person against whom the complaint is being made must be confronted by the supervisor and questioned about the alleged incidents of harassment. The complaining party should also be present at this interview, unless that person specifically requests not to bepresent.
  5. When the entire investigation is complete, take immediate necessary corrective action and apply whatever disciplinary measures may benecessary and appropriate.

Special safeguards should be applied in handling sexual harassment complaints in order to protect the privacy of the complainant as well as the accused party. Discussing the matter with other employees or persons who do not have the need to know (especially coworkers of the complainant), could lead to legal problems relating to embarrassment or even slander of an individual’s reputation and the identity of the party or parties involved should be therefore kept strictly confidential. The charging party should also be reassured by management that there will be no retaliation of any
kind by any supervisor or manager for having brought the complaint to the attention of management or the human resources department.

Enclosed with the policy statement is a notice to all Benchmark Mortgage employees regarding the company’s policy and attitude on sexual harassment. This notice is to be posted on all company bulletin boards throughout the organization so that employees may read it at their place of work.

Stewart Hunter
COO/Owner
Benchmark Mortgage