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CCC Harassment Policy


CCC absolutely opposes harassment, discrimination and retaliation on the basis of sex (which includes pregnancy, childbirth, breast feeding and medical conditions related to pregnancy, childbirth or breastfeeding), pregnancy, race, color, sexual orientation, gender (including sex stereotyping), gender  identity and gender expression, transgender, marital status, age (40 and over), religious creed (including religious dress and grooming practices), national origin (including language use restrictions), ancestry, citizenship status, military and veteran  status, medical condition (cancer and genetic characteristics), denial of Family and Medical Care Leave, genetic information and/or physical or mental disability (including HIV and AIDS) and any other basis prohibited by applicable law in all forms not only because they are illegal forms of discrimination, but also because of CCC’s continued interest in providing an environment free from hostile, intimidating or offensive conditions.

It is a violation of this policy for any employee (including coworkers, interns, managers and supervisors), freelancer, independent contractor or other persons performing services to CCC pursuant to a contract to harass or discriminate against an employee, freelancer, independent contractor or other persons performing services to CCC pursuant to a contract or applicant on the basis of the employee’s, independent contractor’s or applicant’s protected status as stated herein.

This policy applies to all terms and conditions of employment, including, but not limited to, hiring, placement, promotion, disciplinary action, layoff, recall, transfer, leaves of absence, compensation and training.

Harassment may include, but is not limited to, the following acts of behavior that are taken because of a person’s protected classification as stated herein.  The following are examples of behavior unacceptable to CCC and would violate this policy.  Please note that this is not an exhaustive list and other types of conduct could fall within this policy:

Speech:  Epithets, derogatory comments or slurs, and propositions on the basis of a person’s protected classification as stated herein.  This may include, but is not limited to, inappropriate comments on someone’s appearance, including dress or physical features, or dress consistent with gender identification or racial oriented stories and jokes.

Physical Acts:  Assaults, impeding or blocking movement, offensive touching or any physical interference with someone’s normal work or movement.  This may include, but is not limited to, pinching, grabbing, patting, propositioning, leering or making explicit or implied job threats or promises in return for submission to physical acts.

Visual:  Derogatory posters, cartoons, or drawings related to a protected classification as stated herein.

Sexual Harassment includes:

(i) unwelcome sexual advances or unwelcome conduct of a sexual nature;

(ii) requests for sexual favors or conduct of a sexual nature when:

  1. submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment;, or
  2. submission to or rejection of such conduct by an individual is used as the basis for any employment decision affecting the individual;, or
  3. 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; or

(iii) sexual misconduct, which means any behavior of a sexual nature which also involves coercion, abuse of authority, or misuse of an individual’s employment position.

Sexual Harassment includes behavior that the employee finds offensive, and which interferes with the work effectiveness of the employee and his or her co-workers. Such behavior includes, but is not limited to:

  1. Sex-oriented verbal joking or abuse
  2. Subtle pressure for sexual activity
  3. Unwelcome physical contact
  4. Demands for sexual favors, which may be accompanied by implied or overt promises of preferential treatment or threats concerning an individual’s employment status.

Training:  All employees must participate in a minimum of one (1) hour of sexual harassment prevention training annually. Anyone who supervises or manages employees must participate in a minimum of two (2) hours of sexual harassment prevention training annually.

It is important to note that harassment, discrimination and retaliation is not limited to conduct that CCC’s employees engage in.  Harassment, discrimination and retaliation can also include conduct taken by outside vendors, customers, or third parties that provide services to CCC or even members of the public. Information regarding legal services, including governmental, that are available to employees who may be victims of sexual harassment, can be obtained in the Human Resources Department.

Any adverse action taken because an employee, applicant, or any third person has reported harassment, discrimination or retaliation or has participated in the complaint and investigation process described herein is prohibited. “Adverse conduct” includes: taking sides because an individual has reported harassment, discrimination or retaliation, spreading rumors about a complainant, shunning and avoiding an individual who reports harassment, discrimination or retaliation or real or implied threats of intimidation to prevent an individual from reporting harassment, discrimination or retaliation. Individuals who make good faith reports of harassment, discrimination or retaliation, and those who associate with an individual who is involved in reporting harassment, discrimination or retaliation or who participates in the complaint or investigation process are protected from retaliation.

Anyone that believes that he or she has been harassed, discriminated against or retaliated against according to this policy may notify any of the following. There is no need to follow the chain of command:

  1. Immediate supervisor;
  2. Any supervisor or manager within or outside of the department.
  3. Department Heads; or
  4. Human Resources representative

Any supervisor, manager, or department head who receives a harassment, discrimination and/or retaliation complaint must immediately notify a Human Resources Manager who is not involved in the allegations of the complaint.

Upon receiving notification of a harassment, discrimination and/or retaliation complaint, a designated member of the Human Resources Department will conduct a fair, prompt and thorough investigation of the complaint. The designated member of the Human Resources Department will (a) document and track the progress and (b) provide a timely response to and timely closure of such investigation. Reasonable and appropriate corrective action pursuant to applicable laws based on the information collected during the investigation will be taken, where necessary, including appropriate discipline, if any against the party engaging in the conduct. Such discipline, dependent upon the circumstances, may range from a written warning that may include a change in the terms and conditions of employment, up to and including termination.

Every possible effort will be made to assure the confidentiality of complaints made under this policy. Complete confidentiality cannot occur, however, due to the need to fully investigate and the duty to take effective remedial action.  As a result, confidentiality will be maintained to the extent possible.

Employees who work in Chicago or support employees who work in Chicago are subject to the additional provisions set forth in the addendum attached to this policy.

Chicago Addendum

In addition to the foregoing policy, all employees who work in Chicago or support employees who work in Chicago, shall be subject to the following additional provisions:

  1. Sexual harassment and retaliation are illegal in Chicago; and
  2. Participation in one (1) hour of bystander training is required annually; and
  3. Employees have the right to file charges of sexual harassment with the following government agencies:

    1. Commission on Human Relations, 740 N. Sedgwick, 4th Floor Chicago, Illinois 60654, 312-744-4111,
    2. U.S. Equal Employment Opportunity Commission (EEOC) Chicago District Office, 230 South Dearborn Street., Suite 1866, Chicago, Illinois 60604, 321-872-9744, 866-740-3953 (TTY),
    3. Illinois Department of Human Rights, 555 W. Monroe Street, Suite 700, Chicago, Illinois 60601, 312-814-6200, 866-740-3953 (TTY)