Anti-Discrimination/Anti-Harassment Policy

Statement of Policy

Vernon Township (the Township) is committed to maintaining a work environment which is free
from all forms of harassment or discrimination. In keeping with this commitment, the Township will
not tolerate any form of harassment, including sexual harassment, or discrimination of any kind based
upon race, color, religion, sex, ancestry, national origin, age, disability, pregnancy, sexual orientation,
marital status, citizenship status, or other legally protected group status, by its employees or against
its employees by anyone, including supervisors, co-workers, contractors, vendors, constituents or
visitors. This Policy is intended to assure that the Township is taking all steps to prevent harassment
and discrimination in the workplace and to immediately address any harassing or discriminatory
conduct that does occur.

Each Township employee bears the responsibility to refrain from discrimination or harassment in the
workplace. Township employees who engage in discriminatory or harassing conduct may be subject
to disciplinary action, up to and including termination of employment. Furthermore, it is the
responsibility of all supervisors to make sure that the work environment is free from harassment or
discrimination of any kind.

The Township also prohibits retaliation of any kind against anyone who has reported discrimination
or harassment, whether that concern relates to discrimination against or harassment of the individual
raising the concern or against another individual.

Definitions and Examples of Prohibited Conduct

A. Sexual Harassment

Sexual harassment, according to the Equal Employment Opportunity Commission and the Illinois
Department of Human Rights, and for the purposes of this Policy, consists of unwelcome sexual
advances, requests for sexual favors or other verbal, non-verbal, or physical acts of a sexual or sex-
based nature, where:

(a) submission to such conduct is made, either explicitly or implicitly, a term or condition
of an individual's employment;

(b) submission to or rejection of such conduct by an individual is used as the basis for
employment decisions affecting such individual; or

(c) such conduct has the purpose or effect of substantially interfering with an individual's
work performance or creating an intimidating, hostile, or offensive working environment.

1
Sexual harassment can occur between men and women, or members of the same gender. This
behavior is unacceptable in the work place itself and in other work-related settings.

Sexual harassment affects the victim and other employees as well. Sexually-oriented acts or sex-based
conduct have no legitimate governmental purpose. Where such conduct is directed by a supervisor
(or someone in a management position) toward a subordinate, the former will be held to a higher
standard of accountability because of the degree of control and influence he or she has or is perceived
to have over the employment conditions and benefits of the subordinate.

Prohibited acts of sexual harassment may include a range of subtle and not so subtle behaviors and
may involve individuals of the same or different gender. Such behavior may include, but is not limited
to: unwanted sexual advances; requests for sexual favors; sexual jokes and innuendo; verbal abuse of
a sexual nature; commentary about an individuals body, sexual prowess or sexual deficiencies;
leering; catcalls; touching; insulting or obscene comments or gestures; display or circulation in the
workplace of sexually suggestive objects or pictures (including through e-mail, instant messaging,
texts, Internet or computer usage); and other physical, verbal or visual conduct of a sexual nature.
Harassment that does not include sexual activity or language may also constitute discrimination if it
is severe or pervasive and directed at employees because of their gender. The above prohibited
conduct that occurs outside of the workplace or outside of work hours may also constitute sexual
harassment.

B. Protected Class Harassment and Discrimination

Protected class harassment or discrimination consists of unwelcome conduct of any kind, whether
verbal or physical, or disparate treatment affecting an individuals terms and conditions of
employment based upon a persons protected status such as race, color, religion, sex (gender),
ancestry, national origin, age, physical or mental disability, pregnancy, sexual orientation, marital
status, citizenship status, or other legally protected group status.

Harassing conduct (based on other protected categories) includes, but is not limited to: epithets, slurs
or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes and display or
circulation of written or graphic material that denigrates or shows hostility or aversion toward an
individual or group (including through e-mail, instant messaging, texts, Internet or computer usage)
because of his or her protected status.

The Township will not tolerate harassing or discriminatory conduct that affects tangible job benefits,
that interferes with an individuals work performance, or that creates an intimidating, hostile or
offensive work environment.

C. Bullying

The Township prohibits acts of harassment or bullying, and has determined that a safe and civil
environment is necessary for employees to be successful and productive. Bullying, like other

2
disruptive or violent behaviors, is conduct that disrupts both an employees ability to positively
contribute to the Township and serve constituents. Bullying does not have to but may include conduct
toward another based upon his or her protected characteristic as set forth above. Demonstration of
appropriate behavior, treating others with civility and respect, and refusing to tolerate harassment or
bullying is expected of all supervisors, co-workers, vendors, and contractors.

Bullying is conduct that meets all of the following criteria:

is directed at one or more employees;

substantially interferes with work/prevents work from being accomplished; and
adversely affects the ability of an employee to contribute in a positive manner in the workplace
by placing the employee in reasonable fear of physical harm and/or by causing emotional
distress.

Examples of bullying behavior may include but are not limited to:
spreading malicious rumors, gossip, or innuendo
excluding or isolating someone socially
mocking, humiliating, or belittling a person
intimidating a person
undermining or deliberately impeding a person's work
physically abusing or threatening abuse
removing areas of responsibilities without cause
constantly changing work guidelines
establishing impossible deadlines that will set up the individual to fail
withholding necessary information or purposefully giving the wrong information
making jokes that are 'obviously offensive' by spoken word or e-mail
intruding on a person's privacy by pestering, spying or stalking
assigning unreasonable duties or workload which are unfavorable to one person (in a way that
creates unnecessary pressure)
underwork - creating a feeling of uselessness
yelling or using profanity
criticizing a person persistently or constantly
belittling a person's opinions
unwarranted (or undeserved) punishment
blocking applications for training, leave or promotion
tampering with a person's personal belongings or work equipment.

The Township expects all employees to conduct themselves in a manner that displays proper regard
for the rights and welfare of other employees, contractors, vendors, constituents and visitors. All
employees have a responsibility to stop bullying in the workplace. Bystander support of bullying can
encourage further bullying; therefore, the Township prohibits both active and passive support for acts
of bullying.

3
Individuals Covered Under The Policy

This policy covers all employees of the Township. The Township will not tolerate, condone or allow
harassment or discrimination, whether engaged in by fellow employees, supervisors, officers or by
other non-employees who conduct business with the Township, including constituents, vendors,
contractors, and other visitors. The Township supports and encourages reporting of all incidents of
harassment, discrimination and bullying, regardless of who the offender may be. An employee who
believes that he or she has experienced or witnessed bullying is encouraged to report the incident as
soon as possible to their direct supervisor, their supervising elected official, or to the Township
Supervisor. A prompt, thorough, and complete investigation of each alleged incident will be
conducted. Where the alleged offender is not an employee or of the Township, the Township
Supervisor, in consultation with the complainant, will review the complaint and make every effort to
identify a reasonable remedy if harassment, discrimination or bullying has been confirmed.

Responsibility of Supervisory Employees and Elected Officials

Each supervisory employee and elected official is responsible for maintaining the workplace free from
harassment, discrimination and bullying. This is accomplished by promoting a professional
environment and by addressing harassment, discrimination and bullying in accordance with this
Policy. In addition, all supervisory employees and elected officials are required to report complaints
of harassment, discrimination or bullying to the Township Supervisor. A supervisory employee or
elected official must address an observed incident of harassment, discrimination or bullying or a
complaint with seriousness, take prompt action to investigate it, report it, and end it, and implement
appropriate disciplinary action. This also applies to cases where an employee tells the supervisory
employee or elected officials about behavior that constitutes sexual harassment, or other harassment,
discrimination or bullying, but does not want to make a formal complaint. In addition, supervisory
employees and elected officials must ensure that no retaliation will result against an employee making
a complaint of harassment, discrimination or bullying.

Responsibility of Individual Employees

Each individual employee has the responsibility to refrain from harassment, discrimination and
bullying in the workplace and to report incidents of harassment, discrimination or bullying. An
individual employee who harasses, discriminates against or bullies a fellow employee is liable for his
or her individual conduct and will be subject to disciplinary action, up to and including termination of
employment.

Complaint Process

If an employee believes that he/she is a victim of harassment, bullying or discrimination in violation

of this Policy, the employee should immediately tell the offending person that the behavior is not
welcome and must be stopped. The Township recognizes that such a confrontation may be ineffective
or impossible. In the event that such informal, direct communication between individuals is either

4
ineffective or impossible, or even when such communication has occurred, the following steps should
be taken to report a complaint of harassment, bullying or discrimination.

A. Reporting of Incident: All employees are required to report any suspected

harassment, bullying or discrimination by another employee to his or her immediate
supervisor, except where the immediate supervisor is the individual accused of harassment,
bullying or discrimination. In that case, the complaint should be reported to the appropriate
supervising elected official or the Township Supervisor. In the case of an instance of sexual
harassment, if the victim prefers to report the suspected harassment to someone of the same
gender as that of the victim, the complaint can be reported to any appropriate supervisory
employee or elected official. The report may be made initially either orally or in writing, but
reports made orally must ultimately be reduced to writing.

B. Investigation of Complaint: When a complaint of harassment, bullying or

discrimination has been reported, the Township Supervisor or his or her designee will begin
a fact-finding investigation. The Township Supervisor or his or her designee will initiate an
investigation of the suspected harassment, bullying or discrimination within five (5) working
days of notification. The fact-finding investigation will include an interview with the
employee(s) who made the initial report, the person(s) toward whom the suspected conduct
was directed and the individual(s) accused of the harassment, bullying or discrimination. Any
other person who may have information regarding the alleged harassment, bullying or
discrimination may also be interviewed.

C. Report: The Township Supervisor or his or her designee will objectively gather and
consider the relevant facts and shall prepare a written report within ten (10) working days
after his or her completion of the investigation of the harassment, bullying or discrimination
unless extenuating circumstances prevent him or her from doing so. The report shall include
a finding that harassment, bullying or discrimination occurred, harassment, bullying or
discrimination did not occur, or there is inconclusive evidence as to whether harassment,
bullying or discrimination occurred. A copy of the report will be given to the employee(s)
who made the initial report, the employee(s) to whom the suspected harassment, bullying or
discrimination was directed, and the individual(s) accused of the harassment, bullying or
discrimination.

D. Records; Confidentiality: Employees who report incidents of harassment, bullying

or discrimination are encouraged to keep written notes in order to accurately record the
offensive conduct. Every effort shall be made to keep all matters related to the investigation
and various reports confidential. In the event of a lawsuit, however, the Township advises
that records it maintains and the complainant maintains may not be considered privileged
from disclosure. All parties involved in the investigation of a complaint of harassment,
bullying or discrimination shall maintain all information received in confidence. Any breach
of this confidentiality requirement will subject the breaching party to discipline, up to and
including termination. The Township Supervisor will maintain all documentation of the

5
 investigation. Notwithstanding the foregoing, any and all records made or compiled during
the course of an investigation are public records that are subject to the provisions of the
Freedom of Information Act.

E. Timeframe for Reporting Complaint: The Township encourages the prompt

reporting of complaints so that rapid response and appropriate action may be taken. Delayed
reporting of complaints will not, in and of itself, preclude the Township from taking remedial
or disciplinary action.

F. Protection Against Retaliation: The Township will not in any way retaliate or
permit any employee to retaliate against an individual who makes a report of harassment,
bullying or discrimination or provides information related to such report. Any witness to an
incident of harassment, bullying or discrimination is also protected from retaliation.
Retaliation is a serious violation of this policy and should be reported immediately. Any
person found to have retaliated against another individual for reporting harassment, bullying
or discrimination will be subject to the same disciplinary action provided for
harassment/bullying/discrimination offenders, meaning disciplinary action up to and
including termination of employment. No one making a complaint of harassment, bullying or
discrimination or providing information related thereto will be retaliated against, even if a
complaint made in good faith is not substantiated.

Discipline/Sanctions

Disciplinary action will be taken against any employee found to have engaged in harassment,
discrimination or bullying of any other employee. When appropriate, disciplinary action for
subsequent offenses by an individual employee will be progressively taken in the following order:

1. Verbal reprimand.
2. Written reprimand.
3. Suspension.
4. Termination.

Notwithstanding the above, the Township reserves the right to repeat steps and skip steps in the
progressive disciplinary policy as appropriate, and the extent of sanctions may depend in part upon:
the length and conditions of employment of the particular employee; the nature of the offense; to
what degree the conduct involved relates to or impacts upon the terms and conditions of any persons
employment with the Township; whether the conduct in question involves an isolated incident or
repetitive behavior; and the overall work record of the employee responsible for the conduct. The
Township has the right to apply any sanction or combination of sanctions, up to and including
termination, to deal with unreasonable conduct, harassment, discrimination or bullying.

Where a hostile work environment has been found to exist, the Township will take all reasonable
steps to eliminate the conduct creating such an environment.

6
False and Frivolous Charges

If an investigation results in a finding that the complainant falsely accused another of harassment,
discrimination or bullying knowingly or in a malicious manner, the complainant will be subject to
appropriate sanctions, including the possibility of termination. False and frivolous charges do not
refer to charges made in good faith which cannot be proven. Given the seriousness of the
consequences for an individual accused of harassment, discrimination or bullying, a false and
frivolous charge is a severe offense that can itself result in disciplinary action, including termination.

Education / Training

Education and training for employees at each level of the work force are critical to the success of the
Townships policy against harassment and discrimination. The Anti-Harassment/Anti-Discrimination
Policy will be distributed to all employees and all new hires. In addition, employees will receive periodic
training, on Township time, regarding the Townships Anti-Harassment/Anti-Discrimination Policy.

All supervisory employees and elected officials will participate, on Township time, in annual training
sessions so that Township supervisors and managers understand their responsibilities under the
Townships Anti-Harassment/Anti-Discrimination Policy and complaint procedure. Such training will
explain: the types of conduct that violate the Townships policy; the seriousness of the policy; the
responsibilities of supervisory employees and elected officials when they learn of alleged harassment,
discrimination or bullying; and the prohibition against retaliation.

External Procedures for Filing a Complaint of Harassment or Discrimination

The Township strives to resolve any incident of harassment, discrimination or bullying through the
internal process outlined above. All employees, however, have the right to file formal charges with the
Illinois Department of Human Rights (IDHR) and/or the United States Equal Employment Opportunity
Commission (EEOC). A charge with IDHR must be filed within one hundred eighty (180) days of the
incident of harassment or discrimination. A charge with EEOC must be filed within three hundred (300)
days of the incident.

The Illinois Department of Human Rights may be contacted as follows:

CHICAGO (312) 814-6200

SPRINGFIELD (217) 785-5100
TTY (866) 740-3953

The United States Equal Employment Opportunity Commission can be contacted as follows:

CHICAGO (312) 869-8001

TTY (800) 669-4000

7
An employee who is suddenly transferred to a lower paying job or passed over for promotion after filing
a complaint with IDHR or EEOC may file a retaliation charge with either of these agencies. The charges
must be filed within 180 (IDHR) or 300 (EEOC) days of the retaliation.

An employee who has been physically harassed or threatened while on the job may also have grounds
for criminal charges of assault and battery.

Retaliation Prohibited

Retaliation against an individual for reporting harassment, discrimination, bullying or illegal or

dishonest activity or for participating in an investigation of any such claim is a serious violation of this
policy and, similar to harassment, discrimination, or bullying itself or illegal or dishonest activity, will
subject the employee to disciplinary action, up to and including termination. Acts of retaliation should
be reported immediately and will be promptly investigated and addressed.

Any employee who has any questions or concerns about these policies should talk with their immediate
supervisor or the Township Supervisor.

Workplace Violence Policy

It is the objective of the Township to ensure the safety and well-being of its employees, constituents and
visitors. Therefore, the Township has established a zero tolerance policy for any violent acts or threats
directed by any Township employee, contractor, vendor, constituent or visitor.

A. Definition

Violence in the workplace includes, but is not limited to:

Any physical behavior involving aggressive physical contact with any other person, including
pushing, hitting, fighting, throwing objects or otherwise intentionally injuring another person
or attempting to injure another person;

Any physical behavior which places a reasonable person in fear of receiving imminent
physical injury or other aggressive physical contact of the sort described above;

Verbal or written threats of physical harm, either directly or implicitly, against any person;
and

Any act of vandalism or other intentional damage or destruction of Township property or

personal belongings on Township property.

8
 Workplace violence also includes instances where these sorts of acts or threats are made against
an employee by a non-employee.

B. Reporting Workplace Violence

Employees who become aware of any threat of violence in the workplace, whether by an
employee or non-employee, are obligated to immediately report in writing such action to the
employees immediate supervisor. In the immediate supervisors absence, or in cases involving
the immediate supervisor, the employee may bypass the immediate supervisor and make a
complaint directly to the appropriate elected official or the Township Supervisor. Employees
should not confront the person against whom their complaint is lodged. Failure to immediately
report an act or threat of workplace violence may result in disciplinary action, up to and including
termination of employment.

If the immediate supervisor receives a complaint, it shall be his/her responsibility to notify the
appropriate elected official or the Township Supervisor as soon as is reasonably possible. Any
elected official who receives or is notified of a complaint shall notify the Township Supervisor as
soon as reasonably possible.

The Township Supervisor shall review all complaints and investigations. All complaints will be
given a high priority and investigated as quickly as possible by the Township Supervisor or his
or her designee. When appropriate, the Township will refer acts or threats of workplace violence
to the police or other authorities for possible criminal prosecution.

C. Discipline for Violations

Violations may result in discipline up to and including termination of employment. Employees

should also understand that such behavior may be criminal and could result in criminal
prosecution.

D. Retaliation

Where an employee reasonably and in good faith opposes or reports any workplace violence or
testifies, assists or participates in an investigation of or hearing concerning allegations or threats
of violence, no person or group of persons may retaliate against the employee. Retaliation
includes any act of harassment, verbal abuse, verbal threats, or any other or additional act of
workplace violence. Retaliation will also be considered a violation of this policy and may result
in discipline up to and including termination of employment.

9
 Employee Receipt Acknowledgement Form

I hereby acknowledge receipt of the Vernon Township Anti-Harassment/Anti-

Discrimination Policy and Workplace Violence Policy.

I further acknowledge and understand that it is my responsibility to read and comply with
the aforementioned Policies and any revisions made to such Policies in the future.

Disregarding or failing to comply with these Policies could lead to disciplinary action, up to
and including termination of employment.

EMPLOYEE'S NAME (printed): __________________________________________________

EMPLOYEE'S SIGNATURE: ______________________________________________________

DATE RECEIVED: ________________________________________________________________

10