Workplace Harassment, Discrimination & Violence Policy

OVERVIEW

Miovision Technologies Incorporated (“Miovision”) is committed to providing a work environment to all employees that is free from harassment, discrimination and improper interpersonal conduct and violence. Miovision recognizes its moral and legal responsibility to protect its employees from harassment, discrimination and improper interpersonal conduct and violence and to act if it does occur. Miovision will not tolerate, condone or ignore workplace discrimination or harassment and both are prohibited whether intentional or unintentional.

WHAT IS HARASSMENT?

Harassment is any comment or conduct that is hurtful, malicious, or intimidating to you. It is unacceptable conduct that may create a hostile or uncomfortable working environment. It can occur at work or outside of work. Harassment is not restricted to any one group of people – it can happen to anyone. Harassment can take several forms including but not limited to, those defined below.

SEXUAL HARASSMENT

Sexual harassment includes unwelcome sexual conduct and communications that unreasonably interfere with an employee’s work performance or create an intimidating, hostile, or offensive environment.

While not exhaustive, the following is a list of prohibited conduct:

  • Unwelcome verbal and physical sexual advances or propositions;

  • Unwelcome remarks or jokes about a person’s body, attire or sex;

  • Practical jokes of a sexual nature;

  • Offering employment benefits in exchange for sexual favors;

  • Making or threatening reprisals after negative response to sexual harassment;

  • Visual conduct such as leering, making sexual gestures, displaying or distributing sexually suggestive objects or pictures, cartoons or posters;

  • Verbal conduct such as making or using sexually derogatory comments, slurs, or jokes; Suggestive or obscene letters, notes, or invitations; and

  • Physical conduct such as assault, impeding or blocking movements unless used in self-defense, or unwanted touching (including causing fear of unwanted touching).

DISCRIMINATION

Discriminatory harassment includes, but is not limited to, harassment based on race, ancestry, place of origin, color, ethnic origin, citizenship, creed, sex, sexual orientation, age, marital status, same-sex partnership status, family status or disability. It includes any verbal, written or physical act that makes the employee feel uncomfortable at work or interferes with an employee’s ability to perform their job. More subtle behavior such as innuendos or taunting, which may reasonably be perceived to create a negative psychological or emotional work environment, is also unacceptable. This kind of behavior will not be tolerated. Unacceptable behavior includes, but is not limited to, one or more of the following:

  • Unwanted jokes, practical jokes, malicious stories, boisterous behavior, horseplay or teasing;

  • Physical violence in any form;

  • Social exclusion, isolation or non-cooperation at work; Posting or distributing pictures, cartoons or drawings; and

  • Use of slurs or other offensive language.

Workplace Harassment Does Not Include:

  • Appropriate evaluation, direction, or discipline by a manager;

  • The investigation of a complaint of harassment or violence in the workplace by People Operations and/or a people leader;

  • Verbal expression or written material that is relevant or appropriately related to an employee’s duties;

  • Expressing differences in personal taste, opinion or preference, unless it becomes baiting, badgering or disruptive to work performance;

  • Conduct which both parties find mutually acceptable, such as bantering, good-natured joking, occasional compliments of a multi-culturally socially acceptable nature, or innocuous social invitations; and;

  • Consenting relationships do not constitute harassment. However, such relationships may become harassment when one person abuses a position of power over the other. In addition, when a relationship ends, continued unwanted attention may constitute harassment.

RESPONSIBILITIES

Company Responsibilities

  1. All employees have the right to work in an environment free from discrimination, violence or harassment as defined above. In addition, all employees have a right to equal treatment with respect to employment without discrimination. Miovision is responsible for creating and maintaining this discrimination-free, violence-free and harassment-free workplace.

  2. Miovision is committed to treating any complaint of discrimination, violence or harassment as a serious matter and acting in the strictest confidence.

  3. Any discrimination or harassment of employees or violence against employees that is determined to be in violation of Miovision, values, guidelines or legislation pertaining to workplace violence, discrimination and harassment, will be met with appropriate disciplinary action.

  4. All reasonable efforts will be made by Miovision to protect the privacy of the individuals involved in a complaint. In many cases, however, the duty of Miovision to investigate and remedy discrimination or harassment makes absolute confidentiality impossible. Miovision will attempt to limit disclosure of confidential information to those employees with a “need to know”. In certain circumstances, we may be obligated to involve law enforcement to ensure that the situation is addressed appropriately.

Manager Responsibilities

  1. All managers are expected to lead by example and contribute to a violence-free, discrimination-free and harassment-free workplace.

  2. All managers are required to make any employment-related decisions free from violence, discrimination or harassment of any kind.

  3. Managers are prohibited from making sexual solicitations or advances to an employee for whom they can grant or deny a benefit (such as a promotion, salary increase, etc.) and from engaging in reprisals because an employee has resisted or refused their solicitations or advances. If potential for such a relationship occurs, and you are unsure how to proceed, please speak to your HR Business Partner or a member of the Executive Team.

  4. Any manager or member of People Operations who receives a complaint of violence, discrimination or harassment has the responsibility to treat the complaint as a serious matter and follow the complaint review process (below).

  5. Managers are required to keep violence, discrimination and harassment complaints and any subsequent investigations confidential.

  6. Managers should inform People Operations concerning any complaints of violence, discrimination or harassment they receive or any behavior they witness that is contrary to these guidelines.

Employee Responsibilities

  1. All employees are expected to contribute to maintaining a violence-free, discrimination-free and harassment-free workplace.

  2. Employees are prohibited from making sexual solicitations or advances to managers. If potential for such a relationship occurs, and you are unsure how to proceed, please contact your HR Business Partner.

  3. All employees are expected to bring to the attention of Miovision any conduct, whether directed towards them, or witnessed by them and directed towards others, that is contrary to these guidelines.

DISCRIMINATION, HARASSMENT & VIOLENCE PROCESS

Why Do We Need A Discrimination, Harassment & Violence Process?

Workplace harassment & violence is unpleasant and intimidating and can be difficult to talk about as you may be worried about reprisal or embarrassment. However, it is essential that Miovision have a process in place so that employees can report either immediately or as soon as possible so the behavior can be stopped.

Employees making a complaint may be required to do so in writing as requested by their manager or People Operations. To keep the best interests of everyone in mind, any employee who is involved in, or assists with a violence, discrimination or harassment complaint investigation, is required to keep confidential all information they learn or provide.

Detailed Steps in the Harassment & Violence Process:

Overview of Steps:

More detailed investigation steps and reporting procedures can be found in the “Workplace Violence, Harassment and Discrimination Reporting Procedures and Forms” document.

  1. Ask the person to stop the harassment/violence immediately and tell them that it is not welcome. The harasser may not realize that their behavior is offensive, and a chat may be all that is needed. At any time, you may seek advice or assistance from your HR Business Partner or any member of the People Operations team. Confidentiality will be maintained at all times.

  2. Take notes on the harassment/discrimination/violence witnessed for each incident. This should include dates, times, who was present, where it occurred, and the comments made. If you asked them to stop, this should also be recorded with their response. Any threats of reprisal should also be noted.

  3. Go to Human Resources with the issue and your notes to file a formal complaint should the behavior not stop or worsen.

  4. If the complaint is made to the manager, the manager must inform Human Resources immediately of the situation.

  5. HR and your manager will initiate an investigation to determine the facts. All aspects of the investigation will be documented and will be dealt with confidentiality.

  6. Once an investigation has been initiated, all parties are encouraged to cooperate with those conducting the investigation.

All complaints will be dealt with in strictest confidence to ensure that the privacy and rights of the individuals involved are fully protected. If a complaint is substantiated, appropriate disciplinary action will be taken which many range from a reprimand or immediate termination of employment. Such action will be documented in the offender’s personnel file. Any complaint that is found to be invalid due to malicious, misleading and/or false statements against another employee will be subject to disciplinary action.

In some situations, Miovision will retain outside legal and investigative support to ensure the impartiality of the investigation.

Miovision prohibits retaliation of any kind against anyone for reporting or participating in an investigation of harassment or discrimination. Any such retaliation by any Miovision employee may result in disciplinary action.

What to Do If You Are Accused of Harassment or Violence?

  1. If you are at fault, stop the behavior immediately and apologize. Be aware that ceasing the behaviour and apologizing may not preclude you from having a formal complaint filed and disciplinary action taken, up to and including termination of employment.

  2. If you believe the complaint is unfounded, discuss the matter with Human Resources. If a complaint is unsubstantiated or untrue, no note of the complaint is entered in personnel files.

In keeping with our company ethics, Miovision:

  • Will not tolerate violations of the Human Rights Code in reference to employee/employer and prospective employee relationships.

  • Will establish and maintain consistent procedures for prompt, fair and equitable handling of complaints.

  • Will promptly, carefully and sensitively investigate complaints regarding the violation of any individual’s rights.

ANONYMOUS REPORTING OF WORKPLACE VIOLENCE, HARASSMENT OR DISCRIMINATION

Miovision leverages an anonymous reporting platform, Report It, in order to ensure that employees can safely and confidentially report incidents.

Step 1: Get the app by downloading it to your Apple or Android device through your Apple App Store or Google Play Store. You can also watch this video to learn more about how to use the Report It app.

Step 2: From the home screen, select New Report.

Step 3: Enter the Report It code for Miovision: ‘Miovision’

Step 4: You can also call Report It to report an incident at 877-778-5463 to create an anonymous report.

Please note that all employees are required to comply with Miovision’s company and departmental policies, rules, practices and regulations as laid out by the company which are now in force or which may be amended, revised or introduced from time to time.

[Last updated October 20, 2021]