EEO and Workplace Behaviour Policy – USA

Policy Owner and Effective Date

People and Culture
Effective Date: 31 July 2024
Version 1

Purpose

To confirm expectations of all workers in relation to equal employment opportunity, discrimination, harassment (including sexual harassment and sex-based harassment), bullying and other forms of unlawful, inappropriate behaviour (e.g. victimisation).

Scope

This policy applies to all Workers, directors, contractors and labour hire workers, apprentices, trainees and volunteers collectively called Workers.
This policy applies to all behaviour of Workers in connection with work or working relationships, including behaviour:

  • in the workplace (whether during or outside of normal working hours);
  • when at work, including when working online (such as over emails and MS Teams), and while working offsite or from home;
  • at work-related events (eg client functions, work-related social functions and conferences);
  • when interacting with other Workers, including when not at work (including on social media, whether during or outside of normal working hours); and
  • when interacting with third parties (such as clients) where that interaction occurs in connection with work.

Equal Opportunity Statement

TEG Live US Inc is committed to the principles of equal employment.

We are committed to complying with all federal, state, and local laws providing equal employment opportunities, and all other employment laws and regulations. It is our intent to maintain a work environment that is free of unlawful harassment, discrimination, or retaliation based on an individual’s:

  • Race
  • Religion
  • National origin
  • Ancestry
  • Citizenship
  • Physical or mental disability
  • Medical condition
  • Genetic information
  • Marital status
  • Reproductive health decision-making
  • Gender
  • Age
  • Sexual orientation
  • Veteran and/or military status
  • Protected medical leaves
  • Domestic violence victim status
  • Political affiliation
  • Any other status protected by federal, state, or local laws.

The Company is dedicated to the fulfillment of this policy in regard to all aspects of employment, including, but not limited to, recruiting, hiring, placement, transfer, training, promotion, rates of pay, and other compensation, termination, and all other terms, conditions, and privileges of employment. The Company will conduct a confidential, prompt, and thorough investigation of all allegations of discrimination, harassment, retaliation, or any violation of the Equal Employment Opportunity Policy. The Company will take appropriate corrective and remedial action, if and where warranted. The Company prohibits retaliation against any Workers who provide information about, complain about, or assist in the investigation of any complaint of discrimination or violation of the Equal Employment Opportunity Policy. We are all responsible for upholding this policy. You may discuss questions regarding equal employment opportunity with your Manager or the People and Culture team or any other designated member of management.

Workplace Harassment

TEG Live US Inc has a strict policy against all types of workplace harassment, including sexual harassment and other forms of workplace harassment based upon an individual’s:

  • Race
  • Religion
  • National origin
  • Ancestry
  • Citizenship
  • Physical or mental disability
  • Medical condition
  • Genetic information
  • Marital status
  • Reproductive health decision-making
  • Gender
  • Age
  • Sexual orientation
  • Veteran and/or military status
  • Protected medical leaves
  • Domestic violence victim status
  • Political affiliation
  • Any other status protected by federal, state, or local laws.

This policy protects all Workers from unlawful harassment and discrimination. This includes harassment by Workers, managers, supervisors, contractors, interns, volunteers, vendors, suppliers, and customers. In addition, this policy extends to conduct connected with an individual’s work, even when the conduct takes place away from the workplace, such as a business trip or business-related social function.

Harassment

Harassment means verbal or physical conduct that insults or shows hostility or aversion toward an individual because of the individual’s:

  • Race
  • Religion
  • National origin
  • Ancestry
  • Citizenship
  • Physical or mental disability
  • Medical condition
  • Marital status
  • Gender
  • Age
  • Sexual orientation
  • Veteran and/or military status
  • Protected medical leaves
  • Domestic violence victim status
  • Political affiliation
  • Any other status protected by federal, state, or local laws

While it is not possible to list all the circumstances that may constitute other forms of workplace harassment, some examples of conduct that may constitute workplace harassment include:

  • The use of disparaging or abusive words or phrases, slurs, negative stereotyping, or threatening, intimidating, or hostile acts that relate to the above-protected categories;
  • Written or graphic material that insults, stereotypes, or shows aversion or hostility toward an individual or group because of one of the above-protected categories and that is placed on walls, bulletin boards, or elsewhere on our premises, in emails or voicemails, or otherwise circulated in the workplace; and
  • A display of symbols, slogans, or items that are associated with hate or intolerance toward any select group.

Sexual Harassment

Sexual harassment is defined as any unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature.

Sexual harassment can happen to anyone, regardless of the gender of either the harasser or the person harassed. Employees, interns, temporary workers, and visitors to places of public accommodations are all protected by sexual harassment laws. Anyone in a workplace could be a sexual harasser, from supervisors and co-workers to vendors and visitors. Sexual harassment does not have to occur in the workplace for it to be illegal. For example, it can be at an off-site office holiday party or at a happy hour. It also does not have to take place face-to-face but can occur on social media or through text messages.

Examples of quid pro quo sexual harassment, which occurs when someone in a position of power offers a benefit in exchange for sexual attention or threatens your job if you refuse sexual attention, include:

  • You are offered a job or promotion in return for sexual favors.
  • Your supervisor threatens to cut your hours if you won’t date them.
  • Your boss threatens you with a poor performance review if you don’t go out to dinner with them.

Examples of a hostile work environment, which is when a coworker, supervisor, or third party makes repeated inappropriate and unwanted sexual advances, comments, or requests, include:

  • People at work talk about sex all day.
  • People comment about other employees’ bodies.
  • Someone at work touches you without your consent.

Retaliation

Retaliation means any adverse employment action taken against an Worker because the Worker engaged in activity protected under this policy. Protected activities may include, but are not limited to, reporting or assisting in reporting suspected violations of this policy and/or cooperating in investigations or proceedings arising out of a violation of this policy.

Adverse employment action is conduct or an action that materially affects the terms and conditions of the Worker’s employment status or is reasonably likely to deter the Worker from engaging in protected activity. Even actions that do not result in a direct loss of compensation may be regarded as an adverse employment action when considered in the totality of the circumstances. Examples of retaliation under this policy include, but are not limited to: demotion, suspension, reduction in pay, denial of a merit salary increase, failure to hire or consider for hire, refusing to promote or consider for promotion because of reporting a violation of this policy, harassing another Worker for filing a complaint, denying employment opportunities because of making a complaint or cooperating in an investigation, changing someone’s work assignments for identifying harassment or other forms of discrimination in the workplace, treating people differently such as denying an accommodation, not talking to an Worker when otherwise required by job duties, or otherwise excluding the Worker from job-related activities because of engagement in activities protected under this policy.

Reporting Discrimination, Harassment, and/or Retaliation

If you feel that you have witnessed or have been subjected to any form of discrimination, harassment, or retaliation, immediately notify Lauren Cavana, GM People and Culture or the People and Culture team at peopleandculture@teg.com.au or any member of management.

The Company prohibits retaliation against Workers who, based on a reasonable belief, provide information about, complain, or assist in the investigation of any complaint of harassment or discrimination.

We will promptly and thoroughly investigate any claim and take appropriate corrective and/or remedial action where we find a claim has merit. If the Company begins an investigation, we will endeavour to conduct the investigation in a timely manner and will keep the investigation confidential to the extent possible. In the same way, anyone involved in an investigation of harassment has an obligation to keep all information about the investigation confidential. That is why the Company will only share information about a complaint of harassment with those who need to know about it. Failure to keep information about an investigation confidential may result in disciplinary action. Investigations will be documented and tracked for timely resolution.

If our policy against harassment is found to have been violated, appropriate corrective action which may include termination of employment, will be taken against the harasser so that further harassment will be prevented. Both the rights of the alleged harasser and the complainant will be considered in any investigation and subsequent action.

The Company will follow up as necessary to ensure that no individual is retaliated against for making a complaint or cooperating with an investigation.

State and Federal Remedies

California

In addition to our internal complaint procedure, Workers may also contact either the Equal Employment Opportunity Commission (EEOC) or the California Civil Rights Department (CRD) to report unlawful harassment. You must file a complaint with the CRD within three years of the alleged unlawful action. The EEOC and the CRD serve as neutral factfinder and will attempt to assist the parties to voluntarily resolve their disputes. For more information, contact the Office of Human Resources or the nearest EEOC or CRD office.

Connecticut

In addition to the Company reporting process, if you believe you have been subjected to discrimination or harassment, you may file a formal complaint with either or both of the government agencies listed here. Using the Company complaint process does not prohibit you from filing a complaint with these agencies. Note that claims must be filed with the Equal Employment Opportunity Commission (EEOC) and the Connecticut Commission on Human Rights and Opportunities (CCHRO) within 300 days of the alleged act of discrimination or harassment.

Filing of Complaints Outside Company

You may file formal complaints of discrimination, harassment, or retaliation with the agencies listed below. Contact these agencies directly for more information about filing processes.

California Civil Rights Department

2218 Kausen Drive, Suite 100 Elk Grove, CA 95758
Voice: 800-884-1684
TTY: 800-700-2320
California Relay Service: 711
Email: contact.center@dfeh.ca.gov
Website: www.calcivilrights.ca.gov
Online sexual harassment training courses: https://calcivilrights.ca.gov/shpt/

U.S. Equal Employment Opportunity Commission

450 Golden Gate Avenue 5 West P.O. Box 36025 San Francisco, CA 94102-3661
Phone: 800-669-4000
Fax: 415-522-3415
TTY: 800-669-6820
ASL Video Phone: 844-234-5122
Website: https://www.eeoc.gov/field-office/sanfrancisco/location

EEOC Boston Office

Address: John F. Kennedy Federal Building, 475 Government Center, Boston, MA 02203
Phone: 800-669-4000 Fax: 617-565-3196
TTY: 800-669-6820
ASL Video Phone: 844-234-5122
Website: https://publicportal.eeoc.gov/portal/

CCHRO

Address: 450 Columbus Blvd., Suite 2, Hartford CT 06103
Phone: 860-541-3400
TTY: 860-541-3459
Toll Free: 800-477-5737
Email: See website for regional office email addresses
Website: https://portal.ct.gov/chro

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