HILL INTERNATIONAL, INC. MEMORANDUM DATE: January 7, 2011 TO: All Hill Employees , a FROM: | Irvin E. Richter ye v RE: ANTI-HARASSMENT AND PROFESSIONAL BEHAVIOR POLICY ANNUAL NOTICE 2011 This is to reiterate that it is Hill’s established policy on Anti-Harassment and Professional Behavior which provisions are as follows Hill is committed to a work environment in which all individuals are treated with respect and dignity Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits discriminatory practices, including harassment. Each employee will be dealt with fairly and honestly. Therefore, Hill expects that all relationships among persons will be business-like and free of bias, prejudice and harassment. This applies not only to the workplace, but to any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events It is the policy of Hill to prohibit harassment in the workplace based on gender, race, color, religion, national origin, ancestry, age, physical disability, mental disability, medical condition, veteran status, family responsibilities, marital status, sexual orientation, family care, medical leave status, citizenship status, creed, or any other characteristic protected by law. Sexual harassment is a specific form of harassment that is illegal under federal, state, and local laws. Sexual harassment prohibits harassment based on gender (including same gender harassment), pregnancy and childbirth, and related medical conditions. Sexual harassment and harassment based on protected class membership is illegal and is a form of misconduct that undermines the integrity of the employment relationship and negatively impacts upon the morale and productivity of our employees. Sexual harassment or harassment of any employee on the basis of his or her membership in a protected class is strictly prohibited. Harassment is defined as verbal, physical, or visual conduct that creates an intimidating, offensive, or hostile working environment. It is conduct that interferes with work performance, or otherwise adversely affects an individual’s employment opportunities. Harassing conduct includes, but is not limited to: epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion toward an individual or group and that is circulated or displayed in the workplace. For the purposes of our policy, sexual harassment is defined as unweleome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature.Anti-Harassment & Professional Behavior Memo January 7, 2011 Page 2 of 4 Sexual Advances or Favors. It is a violation of this policy for any employee to threaten or insinuate, expressly or implicitly, that a subordinate is required to submit to sexual advances or to provide sexual favors as a condition of employment, continued employment, or any term, condition or benefit of employment, or that a subordinate’s refusal to submit to sexual advances or to provide sexual favors will affect adversely the subordinate’s employment, continued employment, or any term, condition or benefit of employment. Sometimes social relationships may develop at work. However, no employee ever should feel compelled to date, become romantically involved with, or continue such a relationship with another employee. Any employee who feels any unwelcome pressure from another employee in this way is urged to use the complaint procedure below. It makes no difference if the victim of sexual harassment is of the same or opposite sex as the harasser Hostile Environment Sexual Harassment. It is a violation of this policy for any employee to engage in unwelcome sexual conduct which has the purpose or effect of interfering unreasonably with another employee's work performance or of creating an intimidating, hostile or offensive working environment. Examples of prohibited conduct may include but are not limited to: physical assaults or other physical conduct of a sexual nature, including unwanted touching; unwanted sexual advances, propositions, or other sexual comments; sexual displays or publications anywhere in the workplace; taking retaliatory action against an employee for discussing or making a sexual harassing complaint, Examples of unwelcome behavior can be something said, something in writing (print or e-mail), something acted out; the presence of something sexually demeaning; touching; sexual remarks, innuendoes, and jokes; graphic cartoons or graffiti of a sexual nature; persistence in asking employees for dates; lewd or suggestive comments regarding personal life or appearance; comering or blocking a person’s pathway; suggestive gestures and language; obscene language; and originating, forwarding or accessing electronic communications or data of a sexual nature via e-mail or the Internet, All Employees. This policy applies to All Hill employees, including temporary employees, and full and part time employees and prohibits unlawful harassment by any employee towards another. Non-Company Employees. These prohibitions against harassment also apply to non-employees. Non- employees include third parties, such as vendors, clients, subconsultants, contractors, and the general public who have contact with Hill employees. When non-employees are present at our workplace or interact with our employees (including through electronic communications), we expect them to apply the same standards of conduct that we expect of our employees. If any employee feels harassed, sexually or based on membership in a protected class, he or she should use the complaint procedure below. Conversely, we expect our employees to treat non-employees with the same courtesy and respect as co-workers. Harassment of non-employees by Company employees also is strictly prohibited. HRD Policies Annual Policy Netices\Ant Harassment & Professional Behavior PolicyAnti-Harassment & Professional Behavior Memo January 7, 2011 Page 3 of 4 Reporting and Investigation. We encourage the reporting of all perceived incidents of discrimination or harassment, regardless of the offender's identity or position, and prohibit retaliation against any individual who reports discrimination or harassment or participates in an investigation of such reports. Itis our policy to investigate any and all such reports. Individuals who believe they are being subjected to harassing conduct should promptly advise the offender that his or her behavior is unwelcome and request that it be discontinued. Often this action alone will resolve the problem. If the problem is not resolved the person may then want to pursue the matter through the internal complaint procedure, We recognize, however, that some individuals may not be comfortable dealing with a situation directly with the offender, and instead may wish to begin with the internal complaint procedure. An employee who feels he or she has been harassed in violation of this policy should immediately report that to their immediate manager, or to the Human Resources Department. Any employee not comfortable reporting to the Human Resources Department may directly contact the Legal Department. ‘The Human Resources Department and/or Legal Department will investigate all sexual harassment complaints, This may include, but is not limited to, interviewing the complaining party, supervisors and any other personnel, as required, to obtain sufficient, factual information upon which to make a determination. Confidentiality will be maintained throughout any investigation process to the extent consistent with adequate investigation and appropriate corrective action. At the conclusion of the investigation, the Human Resources Department will report its findings, along with recommendations to the appropriate management. The complaining party will be advised by the Human Resources Department in the presence of the employee's supervisor or department head (if complaint is against employee's supervisor) as to the final disposition of the complaint. Every effort will be made to resolve each complaint within 30 days after it is received. Ifa person who has made a complaint does not agree with its resolution, that person may appeal to Hill's President and C.0.0. False and malicious complaints of harassment, discrimination or retaliation as opposed to complaints which, even if erroneous, are made in good faith, may be the subject of appropriate disciplinary action. It is not Hill’s intention to regulate social relationships that are freely entered into by employees. However, it is our affirmative duty to develop and maintain a workplace free of sexual harassment and intimidation. We expect the full support and cooperation of every employee to achieve this goal Non-Retaliation. Coercion, retaliation, intimidation, or harassment directed against any employee who registers a complaint or serves as a witness on behalf of another employee is illegal. If any HRD Poticies Annual Policy Notices'Ant-Harassment & Professional Behavior PolicyAnti-Harassment & Professional Behavior Memo January 7, 2011 Page 4 of 4 employee feels that he or she has been retaliated against for making a complaint or participating in the investigation process that should be reported using the procedures above. Corrective Measures. Any employee found to have violated this policy will be subject to appropriate discipline, up to and including termination of employment, Other Forms of Discrimination. This policy also applies to forms of discrimination other than harassment. Any employee who believes that he or she has been discriminated against in any manner based upon his or her membership in a legally protected class (such as sex, race, national origin, religion, age, color, physical or mental disability, sexual orientation, marital status, creed, citizenship status, veteran status) should follow the complaint procedure described in the Reporting and Investigation provisions above. Questions. Questions about whether certain conduct is inappropriate should be addressed with the persons identified above under Reporting and Investigation. If you should have any questions about the Hill policy against sexual harassment and/or the procedure for filing complaints, please contact the Senior Vice President and Chief Administrative Officer at (856) 810-6248, [HRD Policies Annual Policy Notices'Ant-Harassment & Professional Behavior Policy