Policy Prohibiting Discrimination, Harassment, and Retaliation

(This policy applies to U.S. employees only. Please note California, Massachusetts, New York, Oregon, and Vermont have state-specific laws regarding harassment. Additional information pertinent to California, New York, and Oregon is below.)

DeedyCo and its affiliated companies (the Company) is committed to providing a work environment free of unlawful discrimination, harassment, or retaliation. Consistent with the MBM® Guiding Principles, it is sound philosophy to recognize and treat employees fairly, impartiality, awareness, and sensitivity. We will grant equal opportunity in all aspects of employment to all persons without unlawful discrimination.

Company policy strictly prohibits discrimination or harassment based on color, race, religion, religious creed, sex, gender or gender identity, gender expression, sexual orientation, national origin, citizenship, ethnicity, ancestry, age, physical disability, mental disability, medical condition, pregnancy (including medical needs which may arise from pregnancy, childbirth, or related medical conditions), military and veteran status, genetic information, marital or familial status, political affiliation, union membership, or any other basis prohibited by law. Harassment includes any verbal or other conduct that is offensive, bullying, intimidating, or disparaging to any individual or group and is based on that individual’s inclusion in a legally protected group. The Company also prohibits unlawful discrimination or harassment based on the perception that an individual is a member of such a group or is associated with an individual who is perceived to be a member of a protected group. All such discrimination or harassment is unlawful.

Sexual harassment is a specific form of unlawful harassment that includes unwelcome conduct that is either sexual or which is directed at an individual because of that individual’s sex when:

  • Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive work environment.
  • Such conduct is made either explicitly or implicitly a term or condition of employment; or
  • Submission to or rejection of such conduct is used as the basis for employment decisions affecting an individual’s employment.

Conduct that is prohibited includes, but is not limited to, the following behaviors:

  • Verbal conduct such as epithets; slurs; derogatory and/or sexually-oriented jokes or comments; discussion or inquiries about one’s own or someone else’s sexual activities; or unwelcome sexual advances, propositions, flirtations, invitations, or comments.
  • Visual displays such as derogatory and/or sexually-oriented posters, photographs, pornographic exhibitions, cartoons, drawings, or symbols.
  • Dissemination of derogatory and/or sexually-oriented voicemail, e-mail, graphics, downloaded material or websites;
  • Unwelcome touching of a sexual nature, gestures, intentional blocking of normal movement or interfering with work, or other conduct directed toward a person because of their gender, race, or any other protected basis; and
  • Threats and demands for submitting to sexual requests as a condition of continued employment or to avoid some other loss and offers of employment benefits in return for sexual favors.

The use of any media, including phones, e-mail, instant messaging, or the Internet, for unlawful discrimination, harassment or retaliation will not be tolerated.

The Company’s Policy Prohibiting Discrimination, Harassment, and Retaliation applies to all persons involved in the operation of the Company and prohibits unlawful discrimination, harassment, or retaliation, whether directed toward employees, applicants for employment, or other people the Company does business with, such as outside vendors, contractors, customers, or visitors.

Any individual found to have engaged in inappropriate or unlawful conduct will be subject to remedial or disciplinary action, up to and including termination. All managers and supervisors who know discriminatory or harassing behavior must immediately report their concerns whether the conduct is reported or observed. Managers and supervisors who knowingly allow discrimination or harassment to continue will be subject to disciplinary action, up to and including termination.

All reported concerns will be promptly assessed and determined by the appropriate level of investigation and response. All allegations and investigations will be handled with confidentiality consistent with our legal and ethical responsibilities to a reasonable extent. The Company will take all appropriate measures to ensure a neutral, fair, and timely investigation to all persons involved, including complainants, witnesses, and alleged perpetrators. This includes ensuring that investigations are conducted by a resource suited to investigate the concern, appropriately considering the need for independence and impartiality. Any employee may be required to cooperate as needed in an investigation of alleged discrimination or harassment.

If an employee believes that they have been subjected to discrimination, harassment or retaliation, has observed such conduct, or has knowledge or someone confides in an employee that a co-worker or other individual in the workplace believes that they have been subject to such behavior, the employee must contact any of the following: their immediate supervisor, any member of management, any local, divisional, or corporate human resources leader, any Compliance and Ethics resource, any lawyer in the Legal department.

Retaliation, retribution, or harassment against any employee who, in good faith, asks any question, raises any concern regarding this policy, or participates in an investigation is against Company policy and is prohibited. “Good faith” does not mean that a reported concern must be correct. Still, it does require that the reporting party believes they are providing complete and truthful information when reporting a concern or asking a question.

If you have additional questions, please contact your H.R. leader.


Please note California, Massachusetts, New York, Oregon, and Vermont have state-specific laws regarding harassment. Additional information pertinent to California, New York, and Oregon is below. To receive a copy of this policy in Massachusetts or Vermont language, please contact H.R.

Additional Information for California Employees

The Company will ensure that, where it is appropriate to support the investigation, documentation is retained. Additionally, H.R. will ensure that investigations are appropriately tracked to ensure progress. While employees are encouraged to report claims internally, employees can also report allegations of discrimination, harassment, or retaliation to the California Department of Fair Employment and Housing or the U.S. Equal Employment Opportunity Commission.

C.A. Dept. of Fair Employment and Housing

Phone: 1-800-884-1684

Website: dfeh.ca.gov/complaint-process

E-mail: contact.center@dfeh.ca.gov

U.S. Equal Employment Opportunity Commission (“EEOC”)

Phone: 1-800-669-4000

Website: EEOC.gov

E-mail: info@eeoc.gov

Additional Information for Oregon Employees

Under Oregon’s Workplace Fairness Act, the statute of limitations is five years for employment discrimination claims or harassment based on a protected factor.

Employers may not require or coerce an Oregon employee to enter into a non-disclosure or non-disparagement agreement that has the purpose or effect of preventing the employee from disclosing or discussing workplace discrimination or harassment. A non-disclosure agreement is an agreement by which parties to the agreement agree not to disclose certain confidential information. A non-disparagement agreement is an agreement which prohibits a party or multiple parties to the agreement from making negative comments about one another.

Employees with workplace discrimination or harassment claims may voluntarily request to enter a settlement, separation, or severance agreement. In those cases, employees will have at least seven days after signing the agreement to revoke their signature.

Employers and employees should document any incidents involving prohibited discrimination or harassment, including sexual assault.

Additional Information for New York Employees

The definition of sexual harassment under New York law is harassment based on sex, sexual orientation, gender identity, and the status of being transgender. This form of harassment is an unlawful practice in violation of Title VII of the Civil Rights Act of 1964, Parts of the Civil Rights Law of 1991, the New York State Human Rights Law, and (where applicable) local anti-discrimination laws.

Unless a different approach is warranted, investigations will be conducted in accordance with the following steps:

  1. Upon receipt of a complaint, an immediate review of the allegations will be conducted, and any appropriate interim actions will be taken.
  2. Documents, e-mails, or phone records relevant to allegations will be obtained, reviewed, and steps will be taken to preserve these records to the extent necessary.
  3. All parties involved, including any relevant witnesses, may be interviewed.
  4. Findings from the investigation will be evaluated with appropriate parties, and relevant documents will be retained.
  5. Human Resources will notify the complainant and/or appropriate parties of the investigation’s conclusion and implement any corrective actions identified.
It is unlawful to retaliate against an individual who testifies or assists in any investigation or proceeding involving allegations of sexual harassment.

For allegations regarding sexual harassment: While employees are encouraged to report claims internally if an employee believes that they have been subjected to sexual harassment, the employee can choose to pursue legal remedies with the government agencies listed below, federal, state, or local anti-discrimination laws. Additionally, employees may opt to use the standard complaint form attached to this policy.

U.S. Equal Employment Opportunity Commission (“EEOC”)

Phone: 1-800-669-4000

Website: EEOC.gov

E-mail: info@eeoc.gov


New York State Division of Human Rights

Phone: 1-888-392-3644

Website: dhr.ny.gov/Complaint


New York City Commission on Human Rights

Phone: 718-722-3131

Website: NYC.gov/HumanRights


Local Police Department

Please reference local resources for contact information.