Anti-Harassment, Discrimination and Retaliation Policy

All employees, regardless of their positions, are covered by and are expected to comply with this policy and to take all appropriate measures to ensure that prohibited conduct does not occur. Appropriate disciplinary action will be taken against any employee who violates this Anti-Harassment, Discrimination and Retaliation Policy, up to and including termination.

J. Kent, in compliance with all applicable federal, state and local anti-discrimination and harassment laws and regulations, enforces this policy as follows and prohibits the following conduct as harassment, discrimination and retaliation:

Harassment

J. Kent prohibits harassment, including sexual harassment, of any kind, and will take immediate action in response to any complaints or knowledge of violation. For the purpose of this policy, harassment is any verbal or physical conduct designed to threaten, intimidate or coerce any person working for J. Kent when the harassment is because of the person’s race, color, national origin, age, religion, disability status, gender, sexual orientation, gender identity, genetic information, marital status or any other reason protected by federal, state, or local law. J. Kent expressly prohibits any employee, Client (including any agent or employee of a Client), vendor or any other person from conduct that is harassing, including making sexual advances, requests for sexual favors or any other verbal or physical conduct of a sexual nature that is unwelcome and that has the purpose or effect of (i) unreasonably interfering with your work performance or creating an intimidating, hostile or offensive work environment; or (ii) when submission to such conduct is made, either explicitly or implicitly, a condition of J. Kent Employment or an Assignment or is used for the basis of any employment decision including but not limited to any Assignment or any term or condition of any Assignment.

Discrimination

It is a violation of J. Kent’s policy to discriminate in regards to employment opportunities, benefits or privileges, to create a discriminatory work environment, or to use discriminatory evaluation standards in employment if the basis of that discriminatory treatment is because of the person’s race, color, national origin, age, religion, disability status, gender, sexual orientation, gender identity, genetic information, marital status or any other reason protected by federal, state or local law. This policy is intended to comply with the prohibitions stated in federal and state anti-discrimination laws.

Retaliation

No action will be taken that negatively impacts a person’s employment with J. Kent in response to filing a bona fide complaint of discrimination or harassment, appearing as a witness in an investigation of a complaint, or serving as an investigator of a complaint.

Complaint Process

You have an important responsibility in the effective implementation of this policy, including in preventing discrimination and harassment. J. Kent expects and requires that an employee will immediately report any harassment or discriminatory action in writing, to the President of J. Kent and not discuss it with any other J. Kent employees. You must not assume that J. Kent knows about any discrimination or harassment until it is reported, in writing, to the President of J. Kent, regardless of what you may have been told by any other person and regardless of any information that employees otherwise may have received from any person. If discrimination or harassment occurs, the only thing you may assume and rely upon is that no employee, staff member, Client (including any agent or employee of a Client), vendor or any other person has the authority or approval of J. Kent to engage in discrimination or harassment.

Upon receipt of written information about discrimination or harassment, an investigation will be conducted and appropriate action will be taken based upon the information received about the discrimination or harassment, up to and including termination.

If any J. Kent employee believes that the response of J. Kent to a report of discrimination or harassment proves insufficient to remedy the situation, either at the time that the action is first taken or at any future time, or is insufficient to prevent other discrimination or harassment from occurring in the future, he/she must report this immediately, in writing, to the President of J. Kent. Filing groundless or malicious complaints is an abuse of this policy and will be treated as a violation.

Confidentiality

J. Kent cannot guarantee confidentiality for an individual who reports that they are a victim of, or witness harassment or discrimination. J. Kent will not, in any way, retaliate against any individual who makes a bona fide complaint of discrimination or harassment, or who is involved in an investigation of harassment or discrimination in any capacity.