Harassment- and Bullying-Free Workplace Policy
Harassment- and Bullying-Free Workplace Policy

Our Company has worked hard to build a reputation for responsible behavior and fairness—a reputation that fosters trust with our customers, employees, community leaders and shareholders. We can continue to build trust only if we are steadfast in our focus on improving all aspects of Our Credo responsibilities, including the quality of our work environment. This philosophy is embodied in Our Credo and in our Policy on providing a workplace free of harassment and bullying.

All of us have a right to work in an environment free from the demoralizing effects of harassment, unwelcome offensive, and improper conduct. The Company will not tolerate harassment, bullying or conduct that could lead or contribute to harassment of employees by managers, supervisors, or co-workers. The Company also will actively seek to protect employees from harassment or bullying by non-employees in the workplace. Similarly, the Company will not tolerate harassment or bullying by its employees of non-employees with whom the Company employees have a business, service, or professional relationship.

Harassment includes sexual harassment and harassment based on an individual’s race, color, religion, sex (including pregnancy, childbirth, or related medical conditions), gender, sexual orientation, gender identity or expression, transgender status, national origin, age, disability (physical or mental), medical condition, genetic information, veteran’s status, military service, marital status, or any other classification protected by federal, state, or local law. Our Policy also prohibits any act of bullying that targets an individual or group of people and threatens, humiliates or intimidates them, or interferes with their work. Prohibited conduct includes: verbal conduct (such as jokes, threats, slurs, epithets, stereotyping, unwelcome comments about a person’s protected characteristics, or offensive or derogatory voicemails); physical conduct (such as physically interfering with work, or impeding or blocking movements based on a person’s protected characteristics); and visual conduct (such as racially offensive, derogatory or obscene videos, emails, texts, photographs, calendars, posters, cards, cartoons, drawings, gestures, unwelcome notes or letters, or any other written or graphic material).

Sexual harassment is inappropriate conduct that warrants separate attention and discussion. Sexual harassment may include a range of subtle and not so subtle behaviors and may involve individuals of the same or different genders. It includes harassment that is gender-based (for example, offensive remarks about an individual's dress, body or appearance, or their sex or gender), as well as conduct that is sexual in nature. Examples of prohibited sexual harassment include, but are not limited to, unwelcome sexual advances; requests for sexual favors; leering; blocking normal movement; sending sexually explicit e-mails, texts or voicemails; other verbal or physical conduct of a sexual or offensive nature, such as uninvited touching of a sexual nature; sexually related jokes and comments or innuendoes; any verbal or physical conduct of a sexual or otherwise offensive nature that is made either explicitly or implicitly a term or condition of employment, or if the submission to, or rejection of, such conduct by an individual is used as a basis for employment decisions affecting such individual; negative stereotyping and unwelcome comments about an individual’s body, color, physical characteristics, or appearance; questions or comments about a person’s sexual practices; making sexist remarks or derogatory comments, or taking hostile actions against an individual because of that individual’s gender, sexual orientation, gender identity/expression and/or the status of being transgender; and sexual assault, sexual battery, molestation, or rape.

There is a procedure for investigating and resolving issues of harassment or bullying at each operating company. Employees should promptly report violations of this Policy to their immediate supervisor, a higher level of management, or a Human Resources Leader. The employee may also contact Global Services – Human Resources (, use the Credo Hotline (, or call a toll-free number provided by country on these websites. The Credo Hotline is available 24 hours a day, 7 days a week and in 23 languages. If there is an immediate danger or threat in the workplace, employees can contact the Global Security Operations Center 24/7 (

Across the globe, we provide various training courses that address our Policies prohibiting harassment and bullying in the workplace, including within our Code of Business Conduct training. Allegations of harassment and bullying are taken very seriously by the Company and are appropriately investigated, generally by our Global Employee Relations group and as directed by our Law Department. All reported incidents will be investigated with an effort to keep the source of the report confidential, with the disclosure of information only as appropriate to facilitate the investigation or resolution of the matter. Where inappropriate conduct has occurred, specific disciplinary actions—up to and including discharge where appropriate—will be implemented. Any employee who, in good faith, reports a possible violation of this Policy will be protected from any form of retaliation.

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Last Updated: May 2019

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