Harassment Policy

SPRECKELS SUGAR COMPANY
HUMAN RESOURCES POLICY MANUAL
HARASSMENT POLICY
Policy:
The purpose of the Harassment Policy is to provide employees
with a clear understanding that harassment, discrimination and
retaliation will not be tolerated, and to provide Employees with a
procedure for complaints
PURPOSE
The purpose of the Harassment Policy is to inform the Employees of Spreckels
Sugar Company, (hereinafter referred to as "Company"), that harassment,
discrimination, and retaliation are unlawful and are prohibited by the Company;
and to provide Employees with a procedure for submitting a complaint of
harassment, discrimination or retaliation
The Company prohibits harassment of any kind, including sexual

harassment, discrimination, and retaliation. Harassment, discrimination or
retaliation against Employees by managers, supervisors, co-workers or non-
employees in the workplace is unlawful and will not be tolerated. Retaliation
against any Employee who reports an incident of harassment, or who
cooperates in a harassment investigation, is unlawful and will not be tolerated.
All Employees must refrain from unwelcome, offensive or inappropriate behavior
at work, and are responsible for assuring that the workplace is free of
harassment, discrimination and retaliation at all times. The Company takes
allegations of harassment seriously, and will respond promptly to all complaints of
harassment, discrimination and retaliation, The Company will impose corrective
action as it deems appropriate, including but not limited to disciplinary
action or termination of employment.
SCOPE
The Harassment Policy applies to:
• This policy applies to all persons including Spreckels Sugar employees,

visitors, service providers, contractors or any other person within the
Company’s premises.
The interpretation and administration of this policy is the responsibility of the

Human Resources Manager.
GENERAL GUIDELINES
The following general guidelines have been established to provide Employees with a
clear understanding of the Harassment Policy.
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Equal Employment Opportunity (EEO)
The Company prohibits harassment, discrimination, or retaliation based upon race,

color, national origin, religion, creed, age, marital status, height, weight, Vietnam
era/disabled veteran status, or disability, and any other basis prohibited by law.
Any Employee who feels he or she has been subjected to unlawful harassment,
discrimination, or retaliation should follow the Complaint procedure provided for in
this policy and within the Company's separate EEO policy
Retaliation Prohibited
Retaliation against an Employee who brings forward a claim of

harassment, discrimination or retaliation, or who cooperates with an
investigation, is unlawful and will not be tolerated by the Company
Sexual Harassment
Sexual Harassment includes any incident, or repeated incidents of unwelcome

verbal, visual, or physical conduct or requests of a sexual nature. It can occur
when a supervisor or manager conditions employment or benefit on an individual's
consenting to some type of unwelcome sexual behavior. It can also be conduct that
has the purpose or effect of unreasonably interfering with an individual's workplace
or performance, or creates an intimidating hostile or offensive work environment.
While it is impossible to list all conduct or behaviors that may constitute

sexual harassment, the following are some examples of conduct which, if
unwelcome, may constitute sexual harassment depending on the circumstances:
 sexual advances
 requests for sexual favors
 off-color language, jokes of a sexual nature, and verbal or physical
conduct relating to a gender or sex
 displaying sexually explicit pictures, articles, books, magazines,
photos, or cartoons
 discussion or inquiry about sexual activities
 leering, whistling, or other sexual gestures or body language
Scope of Sexual Harassment
The scope of sexual harassment is broad and may extend to situations where:
 The victim as well as the harasser may be male or female
 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 victims are not limited to the individual being harassed directly, but
may include anyone affected by the conduct
Preventing Sexual Harassment
The Company requires that every Employee take steps necessary to prevent
sexual harassment, discrimination or retaliation from occurring
COMPLAINT PROCEDURE
Any Employee who feels he or she has been subjected to harassment,
discrimination, or retaliation should report the incident to his/her supervisor
immediately. If the Employee does not feel comfortable reporting the incident to
his/her immediate supervisor, the Employee should report the incident to another
supervisor or to the Human Resources Department immediately. This complaint
may be reported verbally or on the attached sample Complaint Form (also available
in the Human Resources Department),
Investigatory Procedure
The following actions will be followed upon receipt of an Employee complaint:

1. Any Employee, supervisor or manager who receives a harassment
complaint must refer the complaint to the Human Resources Department
immediately.
2. The Company will investigate every complaint of discrimination, harassment
or retaliation, and will make every effort to keep the matter as confidential
as possible.
3. Every Employee has a duty to cooperate with a harassment investigation
4. The Company will make every effort to bring the matter to a resolution as
soon as possible by investigating and taking appropriate action depending
upon the facts gathered.
Discipline
If the Company determines that there has been a violation of this policy, the
Company will take such action as the Company deems appropriate based on the
circumstances, including but not limited to disciplinary action ranging from counseling
to termination of employment.
MISCELLANEOUS
While this policy sets forth the Company's goals in promoting a workplace that is free
of harassment, discrimination or retaliation, this policy is not designed or
intended to limit the Company's authority to discipline or take remedial action for
any workplace conduct which the Company deems unacceptable. Nothing
contained in this policy is to be construed as the Company constituting or giving
rise to a contract of employment, or creating a vested right to any of the benefits of
employment.
Savings Clause
In the event that any section of this policy conflicts with any state, Federal or local
law, the applicable law shall supersede the conflicting section of this policy and the
remainder of the policy shall continue in full force and effect. This Company in its
sole discretion reserves the right to change, modify or otherwise revise this policy
at any time as it deems necessary to comply with the needs of the Company, its
Employees or customers or any applicable laws, statutes, ordinances or
regulations.
ROLES AND RESPONSIBILITIES
The following roles and responsibilities exist with regard to the Company's
Harassment Policy:
Company Management.. Every manager is responsible for prevention, intervention

and reporting when made aware of harassment, discrimination or retaliation.
Managers are responsible for:
1. Training to insure Employees are aware of and understand the policy,

prevention and obligations.
2. Demonstrating the seriousness of the Company's commitment through their
own actions.
3. Quickly and effectively enforcing the policy when offenses are
observed or reported.
4. Guarding against retaliation or any appearance that retaliation will follow
any complaint of sexual harassment or cooperation with an investigation.
Employees. Each Employee is required to assume a personal commitment to:
1. Monitor own words and actions in the workplace

2 . Inform an individual when his/her conduct is unwelcome
3 . Cooperate with any harassment investigation
4. Immediately report any harassment, discrimination or retaliation observed.
The interpretation and administration of this policy is the responsibility of

the
HR MANAGER
This policy or program may be revised/amended or discontinued at

any time at the Company's discretion.
ATTACHMENT 1 — COMPLAINT FORM
SPRECKELS SUGAR COMPANY COMPLAINT FORM
If you feel you have been subjected to unlawful harassment,

discrimination, or retaliation, submit your complaint on this form, or verbally,
immediately to a supervisor or the Human Resources Department.
Employee's Name:
Department/Position:
Supervisor:
Date of Incident:
Describe the alleged incident in detail including the day and date on which the incident
occurred; the name of the individual who committed the alleged act; the approximate
time when the incident occurred, the acts which you believe constituted unlawful
harassment, discrimination or retaliation, including any verbal statements; your response or
reaction; any person or persons who witnessed the incident, and any other details that you
can recall regarding the incident. You may submit additional information on separate
sheets.

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SPRECKELS SUGAR COMPANY

HUMAN RESOURCES POLICY MANUAL

The Company prohibits harassment of any kind, including sexual

• This policy applies to all persons including Spreckels Sugar employees,

The interpretation and administration of this policy is the responsibility of the

Equal Employment Opportunity (EEO)

The Company prohibits harassment, discrimination, or retaliation based upon race,

Retaliation against an Employee who brings forward a claim of

Sexual Harassment includes any incident, or repeated incidents of unwelcome

While it is impossible to list all conduct or behaviors that may constitute

Scope of Sexual Harassment

Preventing Sexual Harassment

The following actions will be followed upon receipt of an Employee complaint:

ROLES AND RESPONSIBILITIES

Company Management.. Every manager is responsible for prevention, intervention

1. Training to insure Employees are aware of and understand the policy,

Employees. Each Employee is required to assume a personal commitment to:

1. Monitor own words and actions in the workplace

The interpretation and administration of this policy is the responsibility of

This policy or program may be revised/amended or discontinued at

ATTACHMENT 1 — COMPLAINT FORM

SPRECKELS SUGAR COMPANY COMPLAINT FORM

If you feel you have been subjected to unlawful harassment,

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