POLICY AGAINST HARASSMENT/NON-DISCRIMINATION

DNA encourages reporting of all actual or perceived incidents of discrimination, bullying, harassment or retaliation, regardless of the offender’s identity or position. Individuals who believe that they have been the victim of such conduct should discuss their concerns with their immediate supervisor or the Human Resource Dept. See the complaint procedure described below.

Examples of such behavior may include, but are not limited to, threatening remarks, workplace violence or offensive, intimidating, malicious, or insulting behavior.

DNA encourages individuals who believe they are being subjected to such conduct to promptly advise the offender that his or her behavior is unwelcome and to request that it be discontinued. DNA recognizes that an individual may prefer to pursue the matter through complaint procedures.

Regarding DNA’s complaint procedure, individuals who believe they have been the victims of conduct prohibited by this policy or believe they have witnessed such conduct should discuss their concerns with their immediate supervisor or a Human Resources Representative. DNA encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken before relationships become irreparably strained.

Any reported allegations of harassment, discrimination, bullying or retaliation will be investigated promptly. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge.

DNA will maintain confidentiality throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action.

Retaliation against an individual for reporting harassment, bullying or discrimination or for participating in an investigation of a claim of harassment, bullying or discrimination is a serious violation of this policy and, like harassment, bullying or discrimination itself, will be subject to disciplinary action. Acts of retaliation should be reported immediately and will be promptly investigated and addressed.

Misconduct constituting harassment, discrimination, bullying or retaliation will be dealt with appropriately. Responsive action may include, for example, training, referral to counseling or disciplinary action such as a warning, reprimand, withholding of a promotion or pay increase, reassignment, temporary suspension without pay, or termination, as DNA believes appropriate under the circumstances.

If a party to a complaint does not agree with its resolution, that party may appeal to DNA’s Executive Management Team.

False and malicious complaints of harassment, discrimination, bullying or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) may be the subject of appropriate disciplinary action.