Anti-Discrimination, Anti-Harassment Policy

Anti-Discrimination, Anti-Harassment Policy and Compliant Procedure

STATEMENT OF POLICY
Saint-Gobain strives to provide a productive work environment in which all of our employees can contribute
at their highest levels. Part of that responsibility is ensuring a work environment free from all forms of
discrimination and any discriminatory or sexual harassment.
Saint-Gobain companies based in the U. S. have a policy of maintaining a working environment free from
discrimination and harassment, based on age, race, color, religion, national origin, ancestry, disability status,
genetic information, sex, gender, gender identity, sexual orientation, marital status, or military/veteran
status. All employees, regardless of their positions, are covered by and are expected to comply with this
policy, and to take appropriate measures to ensure that prohibited conduct does not occur. Appropriate
disciplinary action, up to possible termination, will be taken against any employee who violates this policy.
Suppliers and customers are also expected to abide by this policy. If the harasser is a supplier or customer,
appropriate action will be taken to end the harassment and prevent future occurrences.
Each of us has the right to work in an environment of dignity and respect. Working together, we can make
sure this environment is a reality in all of the companies within Saint-Gobain Corporation.
PROHIBITED CONDUCT UNDER THE POLICY
DISCRIMINATION
It is a violation of this policy and the Companys Code of Ethics to discriminate in the provision of
employment opportunities, benefits or privileges; to create discriminatory work conditions; or to use
discriminatory evaluative standards in employment if the basis of that discriminatory treatment is, in whole
or in part, the age, race, color, religion, national origin, ancestry, disability status, genetic information, sex,
gender, gender identity, sexual orientation, marital status, or military/veteran status. Discrimination also
may be strictly prohibited by a variety of federal, state and local laws, including Title VII of the Civil Rights
Act 1964, the Age Discrimination Act of 1975, and the Americans With Disabilities Act of 1990. This policy is
intended to comply with the prohibitions stated in these antidiscrimination laws. Discrimination in violation of
this policy will be subject to severe discipline up to and including termination.
DISCRIMINATORY HARASSMENT
Harassment is unwelcome, offensive conduct motivated by an individuals age, race, color, religion, national
origin, ancestry, disability status, genetic information, sex, gender, gender identity, sexual orientation,
marital status, or military/veteran status. The harassment is unlawful when the offensive conduct becomes a
condition of continued employment or the conduct is severe or pervasive enough to create a work
environment that a reasonable person would consider intimidating, hostile or abusive. Harassment can occur
in many circumstances, including between supervisor and employee, a supervisor in another area and
employee, between two or more supervisors, between two or more co-workers, or by a non-employee of the
Company (supplier or customer). The harassment could be unwelcomed and offensive to one individual,
even if the offensive conduct was directed at a different individual.
Examples of conduct which may constitute discriminatory harassment, include, but is not limited to:
1.

Verbal: Offensive jokes, slurs, epithets or name calling, negative stereotypes, physical threats,
intimidation, ridicule or mockery, insults or put-downs, or any comments that are unwelcome
regarding an individuals age, race, color, religion, national origin, ancestry, disability status, genetic
information, sex, gender, gender identity, sexual orientation, marital status, or military/veteran
status. Verbal abuse or "kidding" that is oriented toward a prohibitive form of harassment, and
considered unwelcome.

2.

Nonverbal:The distribution, display or discussion of any written or graphic material, including

postings, cartoons, or online media or other material that ridicules, denigrates, insults, belittles, or
shows hostility or aversion toward an individual or group because of age, race, color, religion,
national origin, ancestry, disability status, genetic information, sex, gender, gender identity, sexual
orientation, marital status, or military/veteran status; insulting sounds; leering; staring; obscene
gestures; content in letters and notes, facsimiles, email, photos, text messages, Internet postings,
etc., that is hostile in nature or ridicules because of ones age, race, color, religion, national origin,
ancestry, disability status, genetic information, sex, gender, gender identity, sexual orientation,
marital status, or military/veteran status.

3.

Physical:Unwelcome, unwanted physical contact, including but not limited to poking, brushing up
against, pushing, shoving, hitting or any kind of assault.

SEXUAL HARASSMENT
Sexual harassment refers to harassment which is sexual in nature. Sexual harassment in this form may
include unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a
sexual nature when (1) submission to such conduct is made either explicitly or implicitly a term or condition
of an individuals employment, (2) submission to or rejection of such conduct by an individual is used as the
basis for employment decisions affecting such individual, or (3) such conduct has the purpose or effect of
unreasonably interfering with an individuals work performance or creating an intimidating, hostile, or
offensive working environment.
Examples of conduct which may constitute sexual harassment, include, but is not limited to:
1.

Verbal: Sexual innuendoes, suggestive comments, jokes of a sexual nature, sexual propositions, lewd
remarks, threats. Requests for any type of sexual favor (this includes repeated, unwelcome requests
for dates). Verbal abuse or "kidding" that is oriented toward a prohibitive form of harassment,
including that which is sex oriented and considered unwelcome.

2.

Nonverbal: The distribution, display or discussion of any written or graphic material, including
calendars, posters and cartoons that are sexually suggestive or show hostility toward an individual
or group because of sex; suggestive or insulting sounds; leering; staring; whistling; obscene
gestures; content in letters and notes, facsimiles, email, photos, text messages, Internet postings,
etc., that is sexual in nature.

3.

Physical:Unwelcome, unwanted physical contact, including but not limited to touching, tickling,
poking, pinching, patting, brushing up against, hugging, cornering, kissing, fondling; forced sexual
intercourse or assault.

Courteous, mutually respectful, pleasant, non-coercive interactions between employees that are acceptable
to and welcomed by both parties are not considered to be harassment, including sexual harassment.
PROCEDURE
REPORTING COMPLAINTS
The Company has established a procedure for any employee to follow if he/she believes he/she has been
subjected to discrimination or harassment:
1.

The individual should feel empowered to address the source directly. Although confronting the
harasser or person discriminating may be difficult, we encourage you to ensure the source
understands your perception and expectations.

2.

If the employee is not comfortable confronting the source, or if the conduct does not stop even after
being asked, the individual should report the nature and circumstances of the discrimination or
harassment immediately to his/her supervisor.

3.

If the employee is not comfortable reporting the conduct to his/her supervisor for any reason or is
not satisfied with the remedial action taken by the supervisor, the employee should immediately
report the conduct to the locations Human Resources manager.

4.

If at any time an employee feels he/she needs to contact someone off-site, he/she should contact
the Human Resources Director for his/her business group. If this is not appropriate because of the
circumstances, or the employee is not comfortable reporting to the business groups Human
Resources, he/she should contact the Corporate Vice President - Human Resources.

5.

If the employee is not comfortable with any of the reporting methods above, he/she may also report
to the Saint-Gobain anonymous business conduct hotline, available 24 hours a day, 7 days a week,
at 1-800-548-2088 or 1-508-795-2736. Although individuals may make his/her complaint
anonymously, it should be understood that the employee will be asked to provide a sufficient level of
detail in order for a comprehensive investigation to be performed.

6.

Employees are also welcome to report any discrimination or harassment to the e-mail found in the
global address book at US-GROUP-COMPLIANCE-ALERT-US. The e-mail, however, is not anonymous.

While the Company strongly encourages the prompt reporting of good faith complaints, false and malicious
complaints of discrimination, harassment or retaliation (as opposed to complaints that, even if erroneous, are
made in good faith) may be the subject of appropriate disciplinary action.
INVESTIGATION AND CORRECTIVE ACTION
Because the Company takes seriously anyone who steps forward with a complaint, all complaints are
investigated promptly and fairly, maintaining the employees sense of dignity and respect. The investigation
is kept confidential to the greatest extent possible. If a supervisor receives a complaint of discrimination or
harassment, he or she will report it to the locations Human Resources manager, and as appropriate, the
supervisor and/or HR will conduct an investigation. A typical investigation may involve meetings with all
parties, including possible witnesses. Misconduct constituting discrimination, harassment, or retaliation will
be dealt with appropriately. Responsive action may include, for example, training, referral to coaching,
reassignment, withholding of a promotion or pay increase, and/or disciplinary action such as verbal or written
warnings, temporary suspension without pay, last chance agreements, or termination, as the Company
believes is appropriate under the circumstances. A report regarding the resolution of the complaint is made
to the person initiating the complaint at the conclusion of the investigation.
NO RETALIATION
There will be no retaliation against any employee who brings forth a complaint of sexual harassment or who
cooperates in the investigation of such a complaint. The Company will make all reasonable efforts to
maintain the confidentiality of the investigation and complaint resolution. Any employee who participates in
retaliatory actions toward an employee who files a discrimination or harassment complaint, or toward
anyone who cooperates in an investigation of such a complaint will be subject to stern disciplinary action up
to and including termination of employment.
APPEAL
The process for appealing the resolution of a complaint or an allegation of retaliatory action may be covered
under the locations normal procedures or union contract. However, if the complaining employee is not
satisfied with the results at the local level, he/she may appeal the complaint resolution, the determination of
retaliation, and all other decisions related to a discrimination or harassment complaint directly to the Human
Resources Department of the individuals specific business group or, ultimately, to the Corporate Vice
President - Human Resources Department. Again, the individual may also contact the Ethics Hotline at
1.800.548.2088 to ensure the appropriate management team members are notified so they are able to
address the situation.

By initialing the box below, I certify that I have read the above information, and I agree to the
conditions of hiring.
Your Initials:

___

Date: