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SEXUAL DISCRIMINATION & HARASSMENT COMPANY POLICY

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Summary
Prevention is the best tool to eliminate sexual discrimination and harassment in the workplace. Employers are encouraged to take steps necessary to prevent sexual discrimination and harassment from occurring. They should clearly communicate to employees that sexual discrimination and harassment is against the law and will not be tolerated. They can do so by establishing an effective complaint or grievance process and taking immediate and appropriate action when an employee complains.

Policy Statement

The Company is committed to implementing and maintaining an effective Sexual Discrimination and Harassment Policy along with any additional specific written rules, regulations and procedures as may be amended at the sole discretion of the Company from time to time. The Company expects and demands that all of its personnel, employees and individuals involved with the Company as independent contractors, consultants, advisors abide by these policies. Disciplinary action may include dismissal, and may extend, as appropriate, to individuals responsible for the failure to prevent, detect or report an offense.

Prohibited Behavior

Sexual harassment in any form (physical, verbal. or environmental) is unacceptable and will not be tolerated. Consequences of any such incident will be commensurate with the action. Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature constitutes sexual harassment when submission to or rejection of this conduct explicitly or implicitly affects an individual's employment, unreasonably interferes with an individual's work performance or creates an intimidating, hostile or offensive work environment.

Sexual harassment can occur in a variety of circumstances, including but not limited to the following:


--The victim as well as the harasser may be a woman or a man. The victim does not have to be of the opposite sex.
--The harasser can be the victim's supervisor, an agent of the employer, a supervisor in another area, a co-worker, or a non-employee.
--The victim does not have to be the person harassed but could be anyone affected by the offensive conduct.
--Unlawful sexual harassment may occur without economic injury to or discharge of the victim.
--The harasser's conduct must be unwelcome.


Response to Violations
The Company may, if it learns of a violation of any applicable laws, regulations or standards of conduct, take all reasonable steps to respond appropriately to the violation and to prevent further similar violations.

Expected Behavior
Management and supervisory personnel are required to be familiar with, and stay current on all Equal Employment Opportunity laws, rules and regulations as they apply to the Company and make sure that all personnel in their respective departments are informed of, and adhere to the same.

Non-Compliance

Failure to comply with the provisions stated in this Policy or in any additional rules, regulations or guidelines promulgated by the Company in general will result in administrative action that could include dismissal. All officers, directors, Employees and Agents will read and abide by this Policy.

Signatures

Signatures acknowledge understanding and agreement to abide by this Policy and are required as a condition of employment.

Sexual harassment is a form of sex discrimination that violates Title VII of the Civil Rights Act of 1964

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Our Office

Miami

1840 Coral Way
4th Floor
Miami, FL 33145
Toll Free: (800) 603 - 3900
(305) 854-6000
Fax: (305) 857-3700
Natalia Utrera, Esq.,
Managing Attorney

New York City

1 Maiden Lane
5th Floor
New York, NY 10038
Toll Free: (800) 576-1100
(212) 962-1000
Fax: (212) 964-5600
Nicolas Spigner, Esq.
Managing Attorney

Clifton, NJ

642 Broad St., Suite 1B
Clifton, NJ 07013
Toll Free: (888) 336-8400
(973) 473-2000
Fax: (973) 778-2900
Sandy A. Adelstein
Managing Attorney

Los Angeles

8939 S Sepulveda Blvd.
Suite 400
Los Angeles, CA 90045
Toll Free: (888) 520-7800
(310) 258-9700
Fax: (310) 258-9400
Nicolas Spigner, Esq.
Managing Attorney

Delaware

9 East Loockerman Street
Suite 202
Dover, DE 19901
Toll Free: (888) 641-3800
(302) 744-9800
Fax: (302) 674-2100
Courtney Riordan, Esq.
Managing Attorney

Las Vegas

2545 Chandler Avenue
Suite 4
Las Vegas, NV 89120
Toll Free: (888) 530 4500
(702) 364 2200
Fax: (702) 458 2100
Joel S. Beck, Esq.
Managing Attorney

Chicago

Continental Office Plaza, Suite L12
2340 Des Plaines River Road
Des Plaines, IL 60018
Toll Free: (888) 514-9800
(312) 443-1500
Fax: (312) 443-8900
Michael C. Welchko, Esq.
Managing Attorney

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Toll Free: 1 (800) 734 - 9900
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Natalia Utrera, Esq.,
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