Colas strongly believes that all people should be treated with respect, trust, honesty, fairness, and dignity. Diversity is a cornerstone of our culture here at Colas. We value our differences and believe that such diversity of people, skills, and abilities is a strength that needs to be nurtured. Our policy of equal opportunity applies to all employment practices, including but not limited to, recruitment, employment, job assignments, training, compensation, benefits programs, promotions, transfers, layoffs, termination, and social/recreational programs. All employment-related decisions must be based solely on jobrelated requirements and on the individual’s qualifications. There are no exceptions.

• Employees will comply with all federal, state, and local equal employment opportunity laws.
• The Company will employ persons and make employment related decisions without regard to an individual’s race, color, religion, sex, age, creed, national origin, citizenship, ancestry, marital status, sexual orientation, gender identity, employable physical or mental disability, medical condition, genetic information, military or veteran status, or any other characteristic protected by law.
• The Company is committed to compliance with the American with Disabilities Act (“ADA”) and will make reasonable accommodations for qualified individuals with known disabilities. This policy governs all aspects of employment, including selection, job assignment, compensation, discipline, termination, and access to benefits and training.
• All managers are responsible for annually reviewing equal employment opportunity laws and the Company’s applicable policies with their employees.
• As stated in the Company’s Equal Employment Opportunity Policy, it is the Company’s policy to provide all employees with a workplace free of discrimination, sexual harassment, harassment, intimidation, coercion, and retaliation.
• All employees, officers, and directors are also responsible for conducting themselves so that their actions are not considered sexually harassing, bullying, demeaning, or intimidating in any way. This can include any conduct that involves the use of email, social media, the internet, or other forms of electronic communication.
• We have zero tolerance for workplace violence. Employees who engage in violence or make threats of violence in the workplace will be subject to disciplinary action, including termination of employment, and, when appropriate, criminal prosecution.
• The Company also intends to comply with the United Nations Universal Declaration of Human Rights and with the fundamental principles of the International Labor Organization, in particular concerning forced and child labor.
• Under the law, sexual harassment is generally defined as either:
  • Unwelcome sex-based conduct that is so severe and pervasive that it creates an intimidating, hostile, or offensive work environment; or
  • Sex-based conduct by someone’s supervisor or manager that tangibly affects the employee’s job – for example, the imposition of discipline, rejection for promotion, or loss of pay or benefits.
• Sexual harassment can occur in a variety of forms. It may include:
  • Unwelcome sexual advances;
  • Requests for sexual favors; and/or
  • Verbal remarks or physical contact or conduct of an intimate or sexual nature, such as uninvited touching or sexually suggestive comments, that interfere with another person’s work performance or that create an intimidating, hostile, or offensive work environment.
• The Company has zero tolerance for discrimination or harassment of any kind, and employees will be subject to disciplinary action, including termination, for violations.
• The Company will not tolerate retaliation against anyone who in good faith raises a concern or reports a violation.
• The Company is also committed to full compliance with all immigration, labor standards, and wage and hours laws. For specific information regarding your rights and responsibilities under EEO laws and our Company’s policies, refer to the Company’s EEO policy.
• The safety and security of all of our employees is of paramount importance. Threats, threatening behavior or acts of violence against any employee, customer or anyone else while representing the Company will not be tolerated. Violations of this policy will lead not only to disciplinary action being taken (including possibly dismissal), but also to arrest and/or prosecution by the applicable authorities.
• Questions that arise should be referred to your Human Resources Department, local Ethics Manager or, if you feel uncomfortable raising a particular issue, then you should contact the Colas Ethics Hotline.

ETHICS LEADERSHIP MOMENT: A co-worker keeps asking you to go on a date. You have politely refused his invitations but he continues to ask. How should you handle?