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Anti-Harassment Policy

Table of contents

  1. All Unlawful Harassment Prohibited
  2. Sexual Harassment
  3. Sexual Harassment Complaint Procedure
  4. Investigation of Sexual Harassment
  5. Alternative Reporting and Remedies
  6. Other Types of Harassment
  7. Harassment Complaint Procedure
  8. No Retaliation
  9. Responsibilities of Supervisors and Managers
  10. Violations of This Policy
  11. Administration of This Policy
  12. Conduct Not Prohibited by this Policy
  13. Complaint Form Instructions

All Unlawful Harassment Prohibited

Parallel is committed to maintaining a workplace free of unlawful harassment. Parallel strictly prohibits and does not tolerate unlawful harassment against employees, interns, whether paid or unpaid, independent contractors, or any other covered persons because of race, color, religion, creed, national origin, ancestry, sex, gender, gender identity or expression (including status as a transgender individual), age, sexual orientation (including actual or perceived heterosexuality, homosexuality, bisexuality, and asexuality), physical or mental disability (including gender dysphoria and similar gender-related conditions), citizenship, genetic information or predisposing genetic characteristics, marital status, familial status, domestic violence victim status, military status, including past, current, or prospective service in the uniformed services, or any other characteristic protected under applicable federal, New York, or local law.

Sexual Harassment

All Parallel employees, other workers, and their employees and representatives (including vendors, customers, subscribers, clients and visitors) are prohibited from harassing employees, interns, independent contractors, and other covered persons based on that individual’s sex, gender, sexual identity or transgender status and regardless of the harasser’s sex or gender.

Sexual harassment means any harassment based on someone’s sex, gender, sexual orientation, sexual identity or transgender status. Sexual harassment can occur between any individuals, regardless of their sex or gender. Sexual harassment is considered a form of employee misconduct. Appropriate disciplinary action will be taken against individuals engaging in sexual harassment and against supervisory and managerial personnel who knowingly allow such behavior to continue.

Parallel prohibits retaliation against individuals who complain of sexual harassment or who testify or assist in any proceeding under the law. Any such retaliation is unlawful. No one will be subject to, and Parallel prohibits, any form of discipline, reprisal, intimidation, or retaliation for good faith reporting of incidents of sexual harassment of any kind, pursuing any sexual harassment claim, or assisting or cooperating in related investigations or other proceedings.

Sexual harassment is unlawful when it subjects an individual to inferior terms, conditions, or privileges of employment. Harassment need not be severe or pervasive to be unlawful. It can be any harassing conduct that consists of more than petty slights or trivial inconveniences. Sexual harassment includes harassment that is not sexual in nature (for example, offensive remarks about an individual’s sex or gender), as well as any unwelcome sexual advances or requests for sexual favors or any other conduct of a sexual nature, when any of the following is true:

  • Submission to or rejection of the advance, request, or conduct is
    • made either explicitly or implicitly a term or condition of employment; or
    • used as a basis for employment decisions.
  • The advances, requests, or conduct have the purpose or effect of substantially or unreasonably interfering with an employee’s work performance by creating an intimidating, hostile, or offensive work environment, even if the complaining individual is not the intended target of the harassment.

Parallel will not tolerate any form of sexual or other harassment, regardless of whether it is:

  • Verbal (for example, epithets, derogatory statements, slurs, sexually-related comments, gestures, noises, or jokes, unwelcome sexual advances, or requests for sexual favors).
  • Physical (for example, assault, groping, kissing, hugging, pinching, patting, or other inappropriate physical contact).
  • Visual (for example, displaying sexually suggestive posters, cartoons, or drawings, sending inappropriate adult-themed gifts, or leering or making sexual gestures).
  • Online (for example, derogatory statements or sexually suggestive postings in any social media platform including Facebook, Twitter, Instagram, Snapchat, etc.).

The above list is illustrative only, and not exhaustive. No form of sexual harassment will be tolerated.

Sexual harassment and all other forms of harassment are prohibited both at the workplace and at employer-sponsored events.

Sexual Harassment Complaint Procedure

Any employee, intern, independent contractor, or non-employee who has been subjected to behavior that may constitute sexual harassment, or witnesses behavior that may constitute sexual harassment, is encouraged to promptly speak to, write, email, or otherwise contact your direct supervisor or, if the conduct involves your direct supervisor, the next level above your direct supervisor or the People Ops Team, ideally within ten (10) days of the offending conduct.

If you have not received a satisfactory response within five (5) days after reporting any incident of what you perceive to be harassment, please immediately contact people@parallelmarkets.com. This group will ensure that a prompt investigation is conducted.

Complaints or reports of sexual harassment must be made in writing. To submit a written complaint of sexual harassment, employees must use the Complaint Form provided below. Employees who are reporting sexual harassment on behalf of other employees must use the Complaint Form and note that it is on another employee’s behalf. The complaint should be as detailed as possible, including the names of all individuals involved and any witnesses.

Parallel is committed to enforcing this policy against all forms of harassment, including sexual harassment. However, the effectiveness of our efforts depends largely on employees telling us about inappropriate workplace conduct. If employees feel that they or someone else may have been subjected to conduct that violates this policy, they must report it immediately. If employees do not report sexually harassing or other harassing conduct, Parallel may not become aware of a possible violation of this policy and may not be able to take appropriate corrective action. Thus, each employee is obligated to report any violation in a timely manner. Employees can raise concerns and make reports without fear of reprisal, harassment, intimidation, threats, or coercion.

Investigation of Sexual Harassment

Parallel takes all complaints of harassment seriously. Parallel will promptly and thoroughly investigate the facts and circumstances of all complaints of sexual and other harassment, whether the complaint was made verbally or in writing. Any employee may be required to cooperate as needed in an investigation of suspected sexual or other harassment.

While the investigation process may vary from case to case, Parallel generally conducts an investigation as follows, with the People Ops Team taking the lead on:

  • Upon receipt of complaint, conducting an immediate review of the allegations, and taking any interim actions (e.g., instructing the respondent to refrain from communications with the complainant), as appropriate.
    • If complaint is verbal, requiring the individual to complete the Complaint Form in writing.
    • If he or she refuses, preparing a Complaint Form based on the verbal reporting.
  • If documents, emails or phone records are relevant to the investigation, taking steps to obtain and preserve them.
  • Requesting and reviewing all relevant documents, including all electronic communications.
  • Interviewing all parties involved, including any relevant witnesses.
  • Creating a written documentation of the investigation (such as a letter, memo or email), which contains the following:
    • A list of all documents reviewed, along with a detailed summary of relevant documents;
    • A list of names of those interviewed, along with a detailed summary of their statements;
    • A timeline of events;
    • A summary of prior relevant incidents, reported or unreported; and
    • The basis for the decision and final resolution of the complaint, together with any corrective action(s).
  • Keeping the written documentation and associated documents in a secure and confidential location.
  • Promptly notifying the individual who reported and the individual(s) about whom the complaint was made of the final determination and implement any corrective actions identified in the written document.
  • Informing the individual who reported of the right to file a complaint or charge externally, as detailed below.

All persons involved, including complainants, witnesses, and alleged harassers, will be accorded due process to protect their rights to a fair and impartial investigation. The investigation will be kept confidential to the greatest extent possible, consistent with conducting a thorough and fair investigation.

Parallel will take prompt corrective action as appropriate to eliminate sexual and other harassment, including disciplinary measures up to and including termination of employment.

Alternative Reporting and Remedies

Parallel requires employees to report incidents of sexual harassment internally. However, employees who believe they have been subjected to sexual harassment in the workplace also may seek relief by:

  • Filing a complaint alleging violation of the NYSHRL either with the Division of Human Rights (NYSDHR) or in New York State Supreme Court. NYSDHR’s main office contact information is: NYS Division of Human Rights, One Fordham Plaza, Fourth Floor, Bronx, New York 10458. You may call (718) 741-8400 or visit: www.dhr.ny.gov. You can also contact NYSDHR at (888) 392-3644 or visit dhr.ny.gov/complaint for more information about filing a complaint.
  • Filing a “Charge of Discrimination” with the Equal Employment Opportunity Commission (EEOC) for violation of federal anti-discrimination laws, including Title VII of the Civil Rights Act of 1964 (Title VII). Employees can contact the EEOC by calling 1-800-669-4000 (TTY: 1-800-669-6820), visiting their website at www.eeoc.gov, or by email at info@eeoc.gov.

Local jurisdictions may have additional protections against sexual harassment and discrimination. Employees can contact the county, city or town in which they live to find out if such a law exists.

For example, employees who work in New York City may file complaints of sexual harassment with the New York City Commission on Human Rights. Contact their main office at Law Enforcement Bureau of the NYC Commission on Human Rights, 40 Rector Street, 10th Floor, New York, New York; call 311 or (212) 306-7450; or visit www.nyc.gov/html/cchr/html/home/home.shtml.

If the harassment involves criminal activity, employees should contact the local police department.

Other Types of Harassment

Parallel’s anti-harassment policy applies equally to harassment based on an employee’s race, color, religion, creed, national origin, ancestry, age, physical or mental disability, citizenship, genetic information or predisposing genetic characteristics, marital status, familial status, domestic violence victim status, actual or perceived sexual orientation, military status, including past, present, or prospective service in the uniformed services or any other characteristic protected under applicable federal, state, or local law.

Such harassment often takes a similar form to sexual harassment and includes harassment that is:

  • Verbal (for example, epithets, derogatory statements, slurs, derogatory comments, or jokes).
  • Physical (for example, assault or other inappropriate physical contact).
  • Visual (for example, displaying derogatory posters, cartoons, or drawings, or making derogatory gestures).
  • Online (for example, derogatory statements or suggestive postings in any social media platform including Facebook, Twitter, Instagram, Snapchat, etc.).

This list is illustrative only, and not exhaustive. No form of harassment will be tolerated.

Harassment is prohibited both at the workplace and at employer-sponsored events.

Harassment Complaint Procedure

If you are subjected to any conduct that you believe violates this policy or witness any such conduct, you must promptly speak to, write, email, or otherwise contact your direct supervisor or, if the conduct involves your direct supervisor, the next level above your direct supervisor or the Human Resources Department, ideally within ten (10) days of the offending conduct. If you have not received a satisfactory response within five (5) days after reporting any incident of what you perceive to be harassment, please immediately contact the People Ops Team (people@parallelmarkets.com). This team will ensure that a prompt investigation is conducted.

Complaints or reports of any form of harassment must be made in writing. To submit a written complaint of harassment, employees must use the Complaint Form provided below. Employees who are reporting harassment on behalf of other employees must use the Complaint Form and note that it is on another employee’s behalf.

The complaint should be as detailed as possible, including the names of all individuals involved and any witnesses. Parallel will directly and thoroughly investigate the facts and circumstances of all claims of perceived harassment and will take prompt corrective action, if appropriate.

Additionally, any manager or supervisor who observes harassing conduct must report the conduct to the People Ops Team (people@parallelmarkets.com) so that an investigation can be made and corrective action taken, if appropriate. If employees feel that they or someone else may have been subjected to conduct that violates this policy, they must report it immediately. If employees do not report harassing conduct, Parallel may not become aware of a possible violation of this policy and may not be able to take appropriate corrective action. Thus, each employee is obligated to report any violation in a timely manner. Employees can raise concerns and make reports without fear of reprisal, harassment, intimidation, threats, or coercion.

No Retaliation

Retaliation against employees, interns, independent contractors, or any other covered individual who in good faith file complaints, or truthfully participate in or assist with an investigation or proceeding involving sexual or other harassment, is unlawful. Parallel prohibits retaliation against individuals who complain of sexual or other harassment or who testify or assist in any proceeding under the law. Any such retaliation is unlawful. No one will be subject to, and Parallel prohibits, any form of discipline, reprisal, intimidation, or retaliation for good faith reporting of incidents of sexual harassment or harassment of any kind, pursuing any sexual or other harassment claim, or assisting another individual to report sexual harassment or other harassment, or cooperating in related investigations or other proceedings.

Responsibilities of Supervisors and Managers

All supervisors and managers who receive a complaint or information about suspected sexual harassment or other harassment, observe what may be sexually harassing behavior or other harassing behavior, or for any reason suspect that sexual harassment or other harassment is occurring, are required to report such suspected sexual harassment or other harassment to the People Ops Team.

In addition to being subject to discipline if they engaged in sexually harassing conduct or other harassing conduct themselves, supervisors and managers will be subject to discipline for failing to report suspected sexual or other harassment, or otherwise knowingly allowing sexual or other harassment to continue.

Supervisors and managers will also be subject to discipline for engaging in any retaliation.

Violations of This Policy

Any employee, regardless of position or title, whom Parallel determines has subjected an individual to harassment or retaliation in violation of this policy, or has knowingly allowed such behavior to continue, will be subject to discipline, up to and including termination of employment.

Administration of This Policy

The People Ops Team is responsible for the administration of this policy. If you have any questions regarding this policy or questions about harassment that are not addressed in this policy, please contact the Human Resources Department.

Conduct Not Prohibited by this Policy

This policy is not intended to restrict communications or actions protected or required by state or federal law.

Complaint Form Instructions

Parallel is committed to providing a work environment free from discrimination, harassment, and retaliation. Parallel’s Anti-Harassment Policy outlines Parallel’s prohibitions against discrimination, harassment, and retaliation. This policy can be found in in the Parallel Employee Handbook.

This policy provides mandatory procedures with several options for employees to report prohibited conduct. One option for reporting discrimination, harassment, or retaliation is to complete this form and provide it to the People Ops Team. You are not required to use this particular form to file a complaint. However, you should read and be aware of Parallel’s mandatory reporting procedures, whether you choose to use this form or not.

Any employee can report discrimination, harassment, and retaliation, whether as a victim or a witness. Regardless of your experience with the discrimination, harassment, or retaliation, it is important to be as specific as possible in your complaint so that Parallel can fully investigate the conduct and take prompt corrective action, as necessary. Include all known information about the complaint, including the identity of any witnesses with knowledge of the allegations or offenses and any other known evidence related to the complaint. You are not limited to the space provided. Parallel encourages you to attach any additional materials that may assist us in investigating the claim. Although not encouraged because it limits our ability to verify the facts alleged in your complaint, you may submit this complaint anonymously.

To investigate the complaint, Parallel will need to interview you, those subject to the alleged discrimination, harassment, or retaliation (if not yourself), the alleged offender(s), and any known witnesses. However, Parallel will notify all individuals involved that the investigation is confidential to the extent permitted by law and make clear that unauthorized disclosures could result in disciplinary action.

To make a complaint, copy the following fields and your answers into an email to people@parallelmarkets.com:

Employee Name:

Employee Title:

Supervisor or Manager Name:

Supervisor or Manager Title:

Today’s Date:

Incident Date/Period of Ongoing Incidents:

Incident Time (if a single incident):

Incident Location (if a single incident):

Identify the individual(s) who participated in discrimination, harassment, or retaliation:

Identify the individual(s) subject to the alleged discrimination, harassment, or retaliation:

Identify (to the best of your knowledge) when the discrimination, harassment, or retaliation occurred. If it occurred over a period of time or continues to occur, identify that period of time:

Identify why you believe the discrimination, harassment, or retaliation occurred:

Describe in detail the facts that form the basis of this complaint (attach additional sheets of paper if necessary):

Has anyone else witnessed the alleged conduct? To the best of your knowledge, please identify those individuals and describe their scope of knowledge of the alleged conduct:

Are you aware of any other evidence of the alleged conduct (for example, documents, emails, videotapes, audiotapes, or other records or materials that substantiate your complaint)? To the best of your knowledge, please identify and describe any and all existing evidence and attach any and all existing evidence in your possession to this complaint:

Did you take any action to try to stop the alleged conduct? If so, please describe the action you took and what resulted:

Have you previously reported or complained about the alleged conduct or any other discrimination, harassment, or retaliation while employed at Parallel? If so, please identify the person you reported the conduct to, the date of the report, and the resolution:

How would you like to see the situation resolved?

I acknowledge that I have read and understand the above information. I certify that to the best of my knowledge, the information I have provided on this form is accurate. I understand and acknowledge that a copy of this complaint and any attachments may be provided to the alleged offender(s). I also understand that this complaint and any attachments may be viewed by appropriate administrators and other witnesses involved in the investigation of this complaint. I am willing to fully cooperate in this investigation.

Employee Signature: _____________

Date: ___________

Signature of Supervisor or Manager Reviewing Complaint: _____________

Date: ___________