Versatile Venture Capital (“VVC”) is committed to providing a work environment free of sexual or any other form of unlawful harassment or discrimination. VVC has a no-tolerance policy, and is committed to maintaining a respectful, courteous work environment in all work- related settings that respects the dignity and worth of each employee. Inappropriate workplace behavior and unlawful harassment are wholly inconsistent with this commitment. No employee, contract worker, customer, vendor or other person who does business with this organization is exempt from the prohibitions within this policy.
Harassment or discrimination based on race, color, ethnicity, sex (including pregnancy, childbirth, breastfeeding, or related medical conditions), gender (including gender identity and gender expression), religion (including religious dress and grooming practices), religious creed, marital status, age, national origin, ancestry, citizenship, physical or mental disability, military and veteran status, genetic information, medical condition (including cancer and genetic characteristics), sexual orientation, or any other protected class, characteristic, or consideration made unlawful under applicable federal, state, or local laws, is illegal and prohibited by VVC’s policy. Such conduct by or toward any employee, contract worker, customer, vendor or anyone else who does business with VVC will not be tolerated.
Sexual or other unlawful harassment or discrimination includes any verbal, physical, or visual conduct based on sex, race, age, national origin, disability or any other legally protected basis if:
- submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment or engagement;
- submission to or rejection of such conduct by an individual is used as a basis for decisions concerning that individual’s employment or engagement; or
- it creates a hostile or offensive work environment.
Sexual harassment includes unwelcome sexual advances, requests for sexual favors, and lewd, vulgar, or obscene remarks, jokes, posters, or cartoons, and any unwelcome touching, pinching, or other physical contact. Other forms of unlawful harassment or discrimination may include racial epithets, slurs, and derogatory remarks, stereotypes, jokes, posters, or cartoons based on race, national origin, age, disability, marital status, or other legally protected categories. Prohibited harassment also includes the transmission of materials such as cartoons, jokes, or links to offensive materials online using VVC’s electronic communications system, or through other online conduct.
Treating any employee or individual differently or unfairly because of the characteristics listed above is also prohibited. Unlawful discrimination includes conduct that is based on the perception that anyone has any of those characteristics, or is associated with a person who has or is perceived as having any of those characteristics. All VVC employees, other workers, and representatives are prohibited from engaging in unlawful discrimination. This policy applies to all terms and conditions of employment, including, but not limited to, recruiting, hiring, training, promotion, discipline, compensation, benefits, and termination of employment.
VVC is designating an Ombud to receive any complaints related to individuals working for or with VVC; investigate; and determine an appropriate response if any. Temporarily, VVC has designated David Teten as Ombud; the Firm will shortly designate an unrelated third party to serve that role.
Employees or contract workers who feel that they have been harassed or discriminated against, or who witness any harassment or discrimination by an employee, contract worker, customer, vendor, or anyone else who does business with VVC, should immediately do any of the following you deem helpful:
- If you feel comfortable enough to do so, tell the person engaging in the harassing and/or discriminating behavior that his or her actions are not welcome and they must stop.
- Report the incident verbally or in writing to the Ombud.
- Report the incident verbally or in writing to your supervisor/manager, and/or another supervisor with whom you feel comfortable.
- If the incident is committed by your supervisor/manager, report the incident verbally or in writing to another supervisor with whom you feel comfortable, or Human Resources.
- Report any additional incidents or retaliation that occur to your supervisor/manager, and/or another supervisor with whom you feel comfortable, or Human Resources.
Any manager or supervisor who observes, or receives a report of, any form of unlawful harassment, discrimination, or retaliation for conduct protected by this policy, must promptly report the conduct to the Ombud so that an investigation can be conducted and, if appropriate, remedial action can be taken.
Any reported incident will be investigated by qualified personnel in a fair, impartial, timely, and thorough manner that provides all relevant parties with the opportunity to be heard and to present any information he or she thinks is relevant or important for consideration, and that allows VVC to reach reasonable conclusions based on the information collected. In responding to and taking action to address a complaint, VVC will be as discreet as reasonably possible under the circumstances, and will maintain confidentiality of the matter to the extent reasonably possible, subject to its obligation to conduct a full and fair investigation. Appropriate action will be taken by VVC to stop and remedy any and all such conduct, including interim measures during a period of investigation. The investigation will be completed in a timely manner, after which VVC will inform the complaining party of the conclusions reached concerning the complaint.
VVC will not allow retaliation against anyone who makes a complaint under this policy. Employees and contract workers are protected by law from retaliation for opposing or reporting unlawful harassment or discrimination, or for otherwise participating in processes connected with an investigation, proceeding, or hearing conducted by VVC or a government agency with respect to such complaints. VVC will take disciplinary action up to and including immediate termination of any employee who retaliates against another employee or contract worker for engaging in any of these protected activities. Contract workers will be subject to termination of their engagement with VVC for engaging in retaliation.
Violations of Policy
Any employee or contract worker who violates this policy will be subject to disciplinary action, up to and including termination of his or her employment or engagement. To the extent a customer, vendor, or other person with whom VVC does business engages in unlawful harassment or discrimination, VVC will take appropriate corrective action to address that situation.
Any employee who has questions about this policy or requires further information on the subject of sexual or other harassment or discrimination should contact the Ombud.