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Statement on Sexual Harassment

It is Springhill Medical Services, Inc's policy to prohibit intentional and unintentional harassment of or against job applicants, contractors, interns, volunteers or employees by another employee, supervisor, vendor, customer or any third party on the basis of actual or perceived race, color, creed, religion, national origin, ancestry, citizenship status, age, sex or gender (including pregnancy, childbirth and pregnancy-related conditions), gender identity or expression (including transgender status), sexual orientation, marital status, military service and veteran status, physical or mental disability, genetic information or any other characteristic protected by applicable federal, state or local laws (referred to as "protected characteristics"). Such conduct will not be tolerated by Springhill Medical Services, Inc.


The purpose of this policy is not to regulate our employees' personal morality, but to ensure that no one harasses another individual in the workplace, including while on Company premises, while on Company business (whether or not on Company premises) or while representing the Company. In addition to being a violation of this policy, harassment or retaliation based on any protected characteristic as defined by applicable federal, state, or local laws also is unlawful. For example, sexual harassment and retaliation against an individual because the individual filed a complaint of sexual harassment or because an individual aided, assisted or testified in an investigation or proceeding involving a complaint of sexual harassment as defined by applicable federal, state, or local laws are unlawful.


Harassment Defined

Harassment generally is defined in this policy as unwelcome verbal, visual or physical conduct that denigrates or shows hostility or aversion towards an individual because of any actual or perceived protected characteristic or has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile or offensive environment. Harassment can be verbal (including slurs, jokes, insults, epithets, gestures or teasing), visual (including offensive posters, symbols, cartoons, drawings, computer displays, text messages, social media posts or emails) or physical conduct (including physically threatening another, blocking someone's way, etc.). Such conduct violates this policy, even if it does not rise to the level of a violation of applicable federal, state or local laws. Because it is difficult to define unlawful harassment, employees are expected to behave at all times in a manner consistent with the intended purpose of this policy.


Sexual Harassment Defined

Sexual harassment can include all of the above actions, as well as other unwelcome conduct, such as unwelcome or unsolicited sexual advances, requests for sexual favors, conversations regarding sexual activities and other verbal, visual or physical conduct of a sexual nature when: submission to that conduct or those advances or requests is made either explicitly or implicitly a term or condition of an individual's employment; or submission to or rejection of the conduct or advances or requests by an individual is used as the basis for employment decisions affecting the individual; or the conduct or advances or requests have the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile or offensive working environment. Examples of conduct that violate this policy include: Springhill Medical Services, Inc Copyright 2020, 2021, 2022, 2023

1. unwelcome flirtations, leering, whistling, touching, pinching, assault, blocking normal movement;

2. requests for sexual favors or demands for sexual favors in exchange for favorable treatment;

3. obscene or vulgar gestures, posters or comments;

4. sexual jokes or comments about a person's body, sexual prowess or sexual deficiencies;

5. propositions or suggestive or insulting comments of a sexual nature;

6. derogatory cartoons, posters and drawings;

7. sexually-explicit e-mails, text messages or voicemails;

8. uninvited touching of a sexual nature;

9. unwelcome sexually-related comments;

10. conversation about one's own or someone else's sex life;

11. conduct or comments consistently targeted at only one gender, even if the content is not sexual; and

12. teasing or other conduct directed toward a person because of the person's gender.


Reporting Procedures

If the employee, patient or visitor has been subjected to or witnessed conduct which violates this policy, the employee, patient or visitor  should immediately report the matter to the Head of Human Resources. If the they are unable for any reason to contact this person, or if the employee, patient or visitor has not received an initial response within five (5) business days after reporting any incident of what the employee, visitor or patient perceives to be harassment, the employee, patient or visitor should contact Compliance Officer.


Investigation Procedures

Every report of perceived harassment will be fully investigated, and corrective action will be taken where appropriate. All complaints will be kept confidential to the extent possible, but confidentiality cannot be guaranteed. All employees must cooperate with all investigations conducted pursuant to this policy.


Retaliation Prohibited

In addition, the Company will not allow any form of retaliation against individuals who report unwelcome conduct to management or who cooperate in the investigations of such reports in accordance with this policy. If the employee has been subjected to any such retaliation, the employee should report it in the same manner in which the employee would report a claim of perceived harassment under this policy. Violation of this policy including any improper retaliatory conduct will result in disciplinary action, up to and including termination.

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