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Harassment & Discrimination

Dow Aero Logistics prohibits harassment and discrimination based on, or because of any personal characteristic that is protected by law as outlined below. Oklahoma, as do many other state laws, specifically provide protection from harassment or discrimination in employment because of:

  • Race 
  • Color
  • Religion
  • Sex
  • National Origin
  • Age
  • Genetic Information
  • Disability

The Policy applies to all persons at the workplace and/or involved in our operations, and prohibits unlawful harassment, discrimination, and/or retaliation towards any employee, intern (paid or unpaid), volunteer, or applicant of our organization by any employee, coworker, supervisor, manager, and/or by any third party who is regularly involved in our operations and/or who is authorized to be in our workplace or on our work site such as a customer, client, vendor, contractor, volunteer, etc.  

Prohibited conduct under this policy includes, but is not limited to:

  1. Verbal conduct such as epithets, derogatory jokes or comments, slurs or unwanted sexual advances, invitations or comments;
  2. Physical conduct such as assault, unwanted touching, impeding or blocking normal movement or any physical interference with normal work or movement, when directed at an individual because of sex, gender, or any other legally protected characteristic; 
  3. Visual conduct such as derogatory and/or sexually oriented posters, photography, cartoons, drawings, email, or other electronic or digital communications; 
  4. Threats and demands to submit to sexual requests as a condition of continued employment, or to avoid some other loss, and offers of employment benefits in return for sexual favors; and
  5. Retaliation for having reported or threatened to report harassment or discrimination.

Please note that within the workplace, our right to free speech is necessarily subject to our legal duty to create and foster a workplace free of harassment or discrimination.

Finally, each one of us, regardless of whether we are an individual contributor/employee, or a manager/supervisor is legally responsible for our own behavior if and when our actions are determined to be harassing. What does that mean? It means that in addition to the disciplinary consequences for violating this policy, which may include termination, people who harass others in the workplace may also be sued personally depending on the state in which the victim works, and therefore responsible for defending themselves in a lawsuit.

Responding to Harassing or Discriminatory Conduct

Employees

Any employee who believes that he or she has been subject to harassment, discrimination, or any other unwelcome attention, he or she may address the situation directly and immediately to the harasser, if possible. If the inappropriate conduct does not cease, or if the employee is unable to or uncomfortable with addressing the alleged harasser directly, he or she should report the incident to his or her own direct/indirect manager or to Human Resources as soon as possible.

It is important to report any and all concerns of sexual harassment or inappropriate sexual conduct to Human Resources as soon as possible. Management shall be made aware of the situation so that it can conduct an immediate and impartial investigation and take appropriate action to remediate or prevent the prohibited conduct from continuing.

Further details on reporting an incident can be found in the proceeding Complaints and Claims section.

Managers and Supervisors

Managers and supervisors must deal expeditiously and fairly with allegations of harassment or discrimination within their departments whether or not there has been a written or formal complaint. They must:

  • Take all complaints or concerns of alleged or possible harassment or discrimination seriously no matter how minor or who is involved.
  • Ensure that harassment, discrimination, or inappropriate sexually oriented conduct is immediately reported to Human Resources.
  • Take any appropriate action to prevent retaliation or prohibited conduct from recurring during and after any investigations or complaints.

Any direct/indirect managers and/or supervisors who knowingly allow or tolerate harassment, discrimination, or retaliation, including the failure to immediately report such misconduct to Human Resources, are in violation of Company policy and are subject to disciplinary action, up to and including termination of employment.

Human Resources

Human Resources is responsible for:

  1. Ensuring that both the individual filing the complaint  ("Complainant") and the accused individual ("Respondent") are aware of the seriousness of a harassment or discrimination complaint.
  2. Explaining this policy, along with the investigation procedures to the Complainant and Respondent.
  3. Exploring informal means of resolving harassment or discrimination complaints.
  4. Notifying law enforcement if criminal activities are alleged.
  5. Arranging for an investigation of the alleged harassment or discrimination.
  6. Notifying the Complainant and the Respondent of the corrective actions to be taken, if any, and administering those actions.

Complaints and Claims

Human Resources shall investigate complaints, allegations, and claims made by employees of, those associated with, and individuals whom do business with the Company. Human Resources shall investigate situations following incidents when deemed appropriate.

To initiate a formal investigation into an alleged violation, you may be asked to provide a written statement about the alleged misconduct and any complaint should include (if possible): 

  1. The name, department, and position of the person or persons allegedly causing harassment or discrimination.
  2. A description of the incident(s), including the date(s), location(s), and the presence of any witnesses.
  3. The effect of the incident(s) on the Complainant's ability to perform his or her job, or on other terms or conditions of his/her employment.
  4. The names of other individuals who might have been subject to the same or similar harassment/discrimination.
  5. What, if any, steps the Complainant has taken to try to stop the harassment or discrimination.
  6. Any other information the Complainant believes to be relevant to the harassment or discrimination complaint.

Direct/indirect managers or supervisors who observe or have knowledge of conduct they believe could potentially be harassing or discriminatory have a mandatory duty to report the conduct or situation to Human Resources.

In an effort to make it easy for employees to submit a complaint regarding prohibited conduct please review the following methods to submit your complaint:

  1. Submit a written or verbal complaint to Human Resources (Email hr@dowaero.com | Phone 1.405.670.6800; 804); and/or
  2. Submit a written or verbal complaint to your direct manager or supervisor.
    • If you are not comfortable making a complaint to your direct manager, you may submit a complaint to any other manager in your direct manager’s chain of command; and/or
  3. Submit a written complaint (allows anonymous submissions) through our Contact Human Resources website here or at: https://dowaero.com/contacthr

Investigations

Upon receipt of a complaint, allegation, or claim or following an incident, the Company shall undertake a thorough, objective, and good-faith investigation. The investigator may be either an internal Company staff member or an external consultant based on the nature and specific details of the situation.

Any investigation authorized by the Company shall be an objective, good faith investigation based on witness interviews and workplace evidence while providing due process for all relevant parties. 

The Company shall initiate an investigation in a timely fashion after receipt of a complaint, allegation, claim, or incident. The Company may document and track its receipt of a complaint, allegation, or claim of a violation of Company Policy or following an incident; its initiation of a responsive investigation; and its findings upon conclusion of the investigation for purposes of documenting the entire process to ensure a timely and responsive complaint, allegation, claim, or incident procedure, including a timely closure to the investigation, as well as to provide visibility and insight to the Company of trending problems within the workforce and/or problems with specific employees or third-parties.

Given the sensitive nature of any and all investigation and/or investigation tracking records, the Company shall maintain any and all such records as privileged and confidential. Without waiving the Company privilege and its right to keep the investigation records confidential, the Company shall provide initiator a timely response regarding the findings of the investigation.

In the event the Company determines a violation of Company Policy, that additional Policy is required, or current Policy necessitates refinement then effective remedial action shall be taken appropriate to and/or proportionate with the nature and severity of the conduct. Depending on the nature of conduct as well as the workplace situation, the Company may solicit initiator’s preference regarding the options for remedial actions and outcomes.

Anti-Retaliation

No one will be retaliated against for filing a complaint and/or assisting in a complaint or investigation process. Further, we will not tolerate or permit retaliation by managers or fellow coworkers against any complainant or anyone assisting in an investigation.

We encourage all employees to report any incidents, especially those that regard harassment and discrimination, immediately so the complaints can be quickly and fairly resolved. 

    Confidentiality

    All inquiries, complaints, and investigations are treated confidentially. Information is revealed strictly on a need-to-know basis. Information contained in a formal complaint is kept as confidential as possible. However, the identity of the complainant is usually revealed to the respondent and witnesses. Human Resources takes adequate steps to ensure that the complainant is protected from retaliation during the period of the investigation. All information pertaining to a harassment or discrimination complaint/investigation is securely maintained by Human Resources. Human Resources may answer any questions relating to the procedures for handling information related to harassment or discrimination complaints/investigations to the Complainants and Respondents.


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