WDLT Employee Handbook

DISCRIMINATION AND HARASSMENT

Any manager who learns of or observes harassing or discriminatory behavior, even if

it is in another department, or any manager who receives a complaint about

harassment or discrimination must immediately report the matter to their immediate

manager or to Human Resources, or the Chief Operating Officer if the matter involves

the Chairman/President, or the Chairman/President if the matter involves the Chief

Operating Officer.

Harassment or Discrimination Investigation

WDLT will investigate all complaints of discrimination and/or harassment and will

do so promptly, discreetly and with sensitivity. During the investigation, it may be

necessary for the Company to disclose facts and the name of the complainant to

alleged witnesses and to the alleged harasser, all of whom will be instructed to

maintain confidentiality.

Further, as noted above, all parties involved in a complaint are entitled to respect,

and any retaliation against a person who is an alleged target of harassment,

discrimination, or retaliation, has made a complaint, or has provided information

about a complaint, will not be tolerated.

Corrective Action

Violations of this policy may expose the organization to civil liability for damages,

penalties, and other non-economic harm. In addition, persons who violate this policy

may be subject to personal civil and criminal liability, depending on the

circumstances.

If it is determined that inappropriate conduct has occurred, WDLT will take such

action as is appropriate under the circumstances. Such action may range from

counseling to termination from employment and may include such other forms of

disciplinary action as the organization deems appropriate under the circumstances.

WDLT also recognizes that the question of whether a course of conduct constitutes

harassment or discrimination often requires a factual determination and that false

accusations can have a serious effect on innocent persons. Therefore, if an

investigation results in a finding that a person falsely accused another of harassment

or discrimination maliciously or recklessly, or the complaining employee knowingly

made false accusations, that employee will be subject to appropriate disciplinary

action.

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