PART I SEXUAL HARASSMENT

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1 P.1 In This Section: PART I Sexual Harassment Policy Statement Sexual Harassment Definition Reporting Sexual Harassment Resolving a Complaint PART II Unlawful Harassment Policy Statement Unlawful Harassment Definition Reporting Unlawful Harassment Resolving a Complaint PART I SEXUAL POLICY STATEMENT Worldwide Flight Services is committed to providing a work environment free of sexual harassment for all employees. All employees are responsible for ensuring this policy is followed. Employees violating this policy and managers who condone violations of this policy may be terminated. The purpose of this Regulation is: 1. Define sexual harassment 2. Provide employees with guidelines for dealing with possible occurrences and the means to report such behavior 3. Provide supervisory personnel with guidelines for dealing with sexual harassment, should it occur in the work place. SEXUAL DEFINITION Federal law defines sexual harassment as: When: Requests for sexual favors Visual, verbal or physical conduct of a sexual nature 1. Submission to such conduct is made a term or condition of employment; or 2. Submission to or rejection of this type of conduct is used as a basis for employment decisions affecting the individual; or 3. This type of conduct has the purpose or effect of unreasonably interfering with an employee s work performance or creating an intimidating, hostile, or offensive working environment. This includes many forms of offensive behavior. The following is a partial list: Unwelcome sexual advances Offering employment benefits in exchange for sexual favors Making or threatening reprisals after a negative response to sexual advances Visual conduct: leering, making sexual gestures, displaying of sexually suggestive objects or pictures, cartoons or posters, pornography Verbal conduct: making or using derogatory comments, epithets, slurs, sexually explicit jokes, comments about an employee s body or dress Verbal sexual advances or propositions Verbal abuse of a sexual nature, graphic verbal commentary about an individual s body, sexually degrading words to describe an individual, suggestive or obscene letters, notes or invitations Physical conduct: touching, assault, impeding or blocking movements, sexual contact with a subordinate even if consensual Sexual harassment on the job is unlawful whether it involves co-worker harassment, harassment by a supervisor, or by persons doing business with or for the Company, including customers and vendors. Unwelcome sexual advances

2 P.2 REPORTING SEXUAL While employees have a responsibility to assist the Company in assuring a workplace free of sexual harassment, the following are specific employee and management responsibilities. 1. Employee Responsibility If you believe you are a victim of sexual harassment, you do not have to tolerate such conduct. The Company strongly encourages all employees to report any incidents of sexual harassment immediately and in sufficient detail, so the complaints can be quickly and fairly resolved. To report an incident, contact: Your supervisor; or Your Personnel Office; or Worldwide Flight Services Human Resources at HDQ You may make the complaint verbally or in writing. In either case, please include all details, specifying dates, witnesses, name(s) or individual(s) involved. A Sexual Harassment Complaint Form is available for the your use, if you desire. This policy does not prevent you from speaking with the offending party directly if you believe this would clear up any misunderstanding. If you choose to do so, state how you feel about his/her actions and request the person to cease the behavior immediately. 2. Management Responsibility Members of management are responsible for ensuring that no sexual harassment occurs within their area. Failure to take appropriate action concerning sexual harassment, tolerance of sexual harassment and/or participation in sexual harassment may result in disciplinary discharge. If you receive a complaint, or once you have reason to believe such conduct is occurring: a. Report it to your Personnel office b. Obtain either the employee s signed, written description, or the employee s signed concurrence in the investigator s written description of the employee s complaint, including the details contained in the Sexual Harassment Complaint Form, if possible. c. Assure the employee there will be an immediate investigation and the Company will not retaliate against the employee for resisting sexual harassment or making a complaint of sexual RESOLVING A COMPLAINT 1. Investigating the Complaint Human Resources will assign an investigator who will notify the complainant of the beginning of the investigation and who will provide follow-up information regarding the status of the investigation within 30 days. The investigator will immediately review all facts pertaining to the allegations and interview everyone involved. If the person accused of sexual harassment is a bargaining unit employee, union representatives may attend and represent a person accused of sexual harassment as provided for in applicable collective bargaining agreements. Subject to legal requirements, information concerning a complaint of sexual harassment shall be kept confidential (See Policy Against Sexual Harassment Statement of Confidentiality form). The purpose of this provision is to protect an employee who files a complaint, to encourage the reporting of any incidents of sexual harassment, and to protect the reputation of any employee wrongfully charged with sexual 2. Review of the Investigation Human Resources and management will review the findings of the investigation. If there is not enough evidence to support the accusation, the investigation will be terminated and no further action taken. If the findings support the accusation, management, in consultation with Human Resources, will determine the appropriate action to be taken. Any corrective action will be taken promptly and will be designed to stop the harassment immediately, and to prevent its recurrence. Such action may also include disciplinary action, up to and including the termination of the person charged.

3 P.3 The person making the complaint will be notified when the investigation is completed and whether it was closed without action or resulted in appropriate action being taken to stop future sexual 3. Follow-Up Management shall make follow-up inquiries after the completion of the corrective action to ensure the objectionable conduct has stopped, and shall prepare a report documenting those inquiries to Human Resources. PART II UNLAWFUL POLICY STATEMENT Worldwide Flight Services is committed to providing a work environment for all employees free of unlawful Worldwide Flight Services maintains a strict policy prohibiting harassment because of: race gender religious creed color national origin ancestry mental or physical disability medical condition union or non-union affiliation marital status age sexual orientation or any other basis protected by federal, state, or local law or ordinance. All such harassment is prohibited. All employees are responsible for ensuring this policy is followed. Employees violating this policy and managers who condone violations of this policy may be terminated. The purpose of this Regulation is: 1. Define unlawful harassment 2. Provide employees with guidelines for dealing with possible occurrences and the means to report such behavior 3. Provide supervisory personnel with guidelines for dealing with harassment, should it occur in their work group UNLAWFUL DEFINITION Worldwide Flight Services unlawful harassment policy applies to all persons involved in the operations of the Company and prohibits harassment by any employee of the Company including supervisors and co-workers, as well as by any person doing business with or for the Company. Harassment in any form, including verbal, physical and visual contact, threats, demands, and retaliation is prohibited. Harassment includes, but is not limited to: 1. Verbal conduct such as epithets, derogatory comments, jokes or slurs, or unwelcome sexual advances, invitations or comments; 2. Visual conduct such as derogatory or otherwise offensive posters, cards, calendars, photographs, cartoons, graffiti, drawings or gestures, pornography; 3. Physical conduct such as assault, unwelcome touching, blocking normal movement or interfering with work when this type of conduct is engaged in on the basis of gender, race, or any other protected basis; 4. Graffiti that is written, painted, sprayed or otherwise communicated on Worldwide Flight Services property; 5. Threats and demands to submit to sexual requests in order for an employee to keep their job or avoid some other loss, or offers of job benefits in return for sexual favors; 6. Retaliation for having resisted, reported, or threatened to report An employee may have a claim of harassment even if there is not job loss or some of their economic benefit.

4 P.4 The law prohibits any form of protected basis harassment that impairs an employee s working ability or creates an intimidating, hostile, or offensive work environment. REPORTING UNLAWFUL 1. Employee Responsibility If you believe you are a victim of unlawful harassment, you do not have to tolerate such conduct. The Company strongly encourages all employees to report any incidents of harassment forbidden by this policy immediately so that complaints can be quickly and fairly resolved. To report an incident, contact: Your supervisor; or Your Personnel Office; or Worldwide Flight Services Human Resources at HDQ You may make the complaint verbally or in writing. In either case, please include all details, specifying dates, witnesses, name(s) or individual(s) involved. A Unlawful Harassment Complaint Form is available for the your use, if you desire. This policy does not prevent you from speaking with the offending party directly if you believe this would clear up any misunderstanding. If you choose to do so, state how you feel about his/her actions and request the person to cease the behavior immediately. 2. Management Responsibility Members of management are responsible for ensuring that no harassment occurs within their area. Failure to take appropriate action concerning harassment, tolerance of harassment and/or participation in harassment may result in disciplinary discharge. All employees have a responsibility to assist the Company in assuring a workplace free of If you receive a complaint, or once you have reason to believe such conduct is occurring: a. Report it to your Personnel office d. Obtain either the employee s signed, written description, or the employee s signed concurrence in the investigator s written description of the employee s complaint, including the details contained in the Unlawful Harassment Complaint Form, if possible. c. Assure the employee there will be an immediate investigation and the Company will not retaliate against the employee for resisting harassment or making a complaint of RESOLVING A COMPLAINT 2. Investigating the Complaint Human Resources will assign an investigator who will notify the complainant of the beginning of the investigation and who will provide follow-up information regarding the status of the investigation within 30 days. The investigator will immediately review all facts pertaining to the allegations and interview everyone involved. If the person accused of harassment is a bargaining unit employee, union representatives may attend and represent a person accused of harassment as provided for in applicable collective bargaining agreements. Subject to legal requirements, information concerning a complaint of harassment shall be kept confidential (See Policy Against Unlawful Harassment Statement of Confidentiality form). The purpose of this provision is to protect an employee who files a complaint, to encourage the reporting of any incidents of sexual harassment, and to protect the reputation of any employee wrongfully charged with 3. Review of the Investigation Human Resources and management will review the findings of the investigation. If there is not enough evidence to support the accusation, the investigation will be terminated and no further action taken. If the findings support the accusation, management, in consultation with Human Resources, will determine the appropriate action to be taken. Any corrective action will be taken promptly and will be designed to stop the harassment immediately, and to prevent its recurrence. Such action may also include

5 P.5 disciplinary action, up to and including the termination of the person charged. The person making the complaint will be notified when the investigation is completed and whether it was closed without action or resulted in appropriate action being taken to stop future 4. Follow-Up Management shall make follow-up inquiries after the completion of the corrective action to ensure the objectionable conduct has stopped, and shall prepare a report documenting those inquiries to Human Resources.