Harassment Policy

It is the policy of the Firm that all employees, customers, and clients be free of discrimination and harassment on the basis of an individual’s race, color, sex, pregnancy, sexual orientation, national origin, genetic information, religion, marital status, veteran status, physical or mental disability, age or any other protected category under federal or state law. The Firm will not tolerate sexual or other unlawful discrimination or harassment in the workplace or in other settings in which employees, customers, and clients may find themselves in connection with their employment or agent-related business. The Firm also will not tolerate any retaliation against anyone complaining of harassment or anyone who has cooperated in an investigation of harassment in accordance with this policy.

The Firm takes allegations of violations of this policy seriously and will respond promptly to complaints of harassment. Where we determine that inappropriate conduct has occurred, the Firm will act promptly to eliminate the conduct and take any necessary corrective action, including disciplinary action where appropriate. While this policy sets forth our goals of promoting a workplace that is free of unlawful harassment, the policy is not designed or intended to limit the principal or managing broker’s authority to discipline or take other remedial action for any workplace conduct that we deem unacceptable, regardless of whether the conduct satisfies the legal definition of harassment. Agents are prohibited from engaging in any conduct in violation of this policy and are subject to removal from their duties or activities with the Firm for violations of this policy. Definition of Sexual Harassment We believe that all of our employees, customers, and clients have the right to a work and business environment free from all forms of unlawful discrimination and harassment. The Firm will not tolerate the harassment of any employee, customer, client or other covered third parties on any legally protected basis, including sex.

Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and other verbal, physical, and nonphysical conduct of a sexual nature when: • Submission to such conduct is made explicitly or implicitly a term or condition of employment; • Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting that individual; or • Such conduct has the purpose or effect of unreasonably interfering with an individual’s performance at work, or creates an intimidating, hostile, or offensive work environment. Under this definition, direct or implied requests by someone in a supervisory position for sexual favors in exchange for actual or promised job benefits such as favorable performance reviews, salary increases, promotions, increased benefits, or continued employment constitutes sexual harassment.

The legal definition of sexual harassment is broad and, in addition to the above examples, other unwelcome sexually oriented conduct, whether it is intended or not, that has the effect of creating a workplace that is hostile, offensive, intimidating, or humiliating to male or female employees, customers and clients may also constitute sexual harassment. Sexual harassment also includes non-sexual comments and conduct that are directed at an individual because of his or her gender or otherwise motivated by gender discrimination.

Examples of Prohibited Conduct:
The Firm will not tolerate unlawful harassment of any employee or client or customer by anyone employed or affiliated by the Firm at any level. The Firm specifically prohibits harassment for any discriminatory reason. Derogatory racial, ethnic, religious, age, sexual orientation, sexual or other inappropriate remarks, slurs, or jokes will not be tolerated. Each employee and agent must exercise his or her own good judgment to avoid engaging in conduct that may be perceived by others as harassment. Forms of prohibited harassment include, but are not limited to: • Verbal: sexual innuendoes, epithets based on legally protected categories, derogatory slurs, off-color jokes, unwelcome sexual advances, threats, suggestive or insulting sounds, sexual jokes, written or oral references to sexual conduct, gossip or discussion about one’s sex life, comments about an individual’s body, comments about an individual’s activity; • Visual/Non-Verbal: derogatory or sexually suggestive posters, cartoons or drawings; suggestive objects or pictures; email messages with sexual references or other references to protected categories; viewing inappropriate internet sites; graphic commentaries; leering; or obscene gestures; • Physical: unwanted physical contact including touching, brushing up against someone; interference with an individual’s normal work movement; assault; and • Retaliation: making or threatening reprisals as a result of a negative response to harassment. Scope of Prohibitions Harassment includes a wide range of behaviors, from the actual coercion of sexual relations to unwelcome offensive comments, jokes, innuendoes and other inappropriate statements and unwelcome emphasizing of an individual’s legally protected characteristics. It is not possible to list all of the additional circumstances and behaviors that may constitute harassment. However, the descriptions provided in this policy serve as some examples of conduct that, if unwelcome, may constitute harassment depending on the circumstances, including the severity of the conduct and its pervasiveness.

This policy prohibits all of the activities discussed above, by all employees and agents of the Firm, regardless of the position within the Firm. Harassment by clients, customers, or other nonemployees, including agents from other firms, who are on company premises or who come in contact with Firm employees is also prohibited.

Consequences for Violating this Policy:
Harassment may be indirect or even unintentional. Violations of this policy, whether intended or not, will not be permitted. If it is determined that one of our employees or agents has engaged in inappropriate conduct, we will take such action as is appropriate under the circumstances. Such action may range from counseling to immediate termination of employment, affiliation or contract, and may include other forms of disciplinary action, as we deem appropriate under the circumstances.

Retaliation is Prohibited: All employees and agents should take special note that, as stated above, retaliation against an individual who has complained about harassment under this policy or participated in an investigation of harassment will not be tolerated, and will be treated as another form of harassment in accordance with this policy. All incidents of retaliation must be immediately reported in accordance with the reporting procedure described below.

Reporting Procedure for Discrimination and Harassment: If you observe unlawful discrimination or harassment, you must follow this reporting procedure to notify us of the problem so that we can promptly and thoroughly investigate this matter and take appropriate action. Do not allow an inappropriate situation to continue by not reporting it, regardless of who is creating the problem.

No employee or agent of the Firm is exempt from its policies prohibiting harassment or discrimination.

• Any concerns should be immediately reported to the CEO and COO of LAER Realty Partners.
• We will investigate reported incidents promptly and in a fair and discreet manner.
• All complaints will be considered confidential, and disclosure will be limited to those with a need to know in order to investigate the complaint and/or take corrective action.
• The investigation will include a private interview with the person filing the complaint and, where appropriate, the witnesses. We will also conduct a private interview with the person alleged to have committed harassment. In circumstances where it is appropriate to do so, we will inform the person who filed the complaint and the person alleged to have committed the conduct of the results of the investigation. If we determine that inappropriate conduct has occurred, we will act promptly to eliminate the offending conduct and, where appropriate, to impose disciplinary action, up to and including immediate termination of employment, affiliation or contract. The Firm will also take other corrective or remedial actions, when appropriate. We encourage reporting of complaints so that we may appropriately address and correct any problems. An employee or agent who participates in good faith in any investigation under this policy has the Firm’s assurance that it will not tolerate any retaliation against him or her as a result of bringing the complaint or otherwise participating in the process. All employees and agents are expected to be truthful, forthcoming, and cooperative in connection with a complaint investigation.

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