CANADIAN CORPORATE BUSINESS POLICY

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1 CANADIAN CORPORATE BUSINESS POLICY Title: Non-Discrimination & Harassment Original Date: January 2012 Prepared by: Director, Human Resources Revision Date: Reviewed by: Gary Mistak Glenn Gammage Grant Gamble RVP Canada ECS VP Ops Canada VP & GM Canada W & C Non-Discrimination & Harassment Anixter prides itself as being an equal opportunity employer which abides by local human rights laws and is committed to maintaining a positive and productive work environment, exempt from any type of workplace harassment. This is accomplished by: Adopting a zero tolerance approach towards psychological, physical and sexual harassment in the workplace; Ensuring safety and sensitivity to the needs of employees working alone; Being pro-active in challenging inappropriate comments and jokes, removing offensive visual materials, supporting employees who encounter verbal harassment; Encouraging employees who are being harassed to make formal complaints. Approaching employees sensitively if there is reason to suspect harassment is occurring; Educating employees about harassment and their rights and responsibilities. Ensuring that new employee orientation includes information about the harassment policy and procedures; Ensuring that where harassment is confirmed as a result of an investigation, appropriate disciplinary action is taken; Make it the responsibility of all employees to model appropriate behaviour reflecting Anixter s Core Values in all business situations during work and non work hours; Letting all employees know that tolerating or ignoring harassing behaviour is unacceptable and a breach of this policy and the law. A harassment free work environment depends upon the mutual respect, understanding and cooperation of all employees which further supports Anixter s Core Values. As part of this commitment, Anixter has adopted this policy covering all forms of harassment in the workplace. Anixter s Commitment Anixter is committed to the prevention of harassment in the workplace in accordance with local laws. We shall take all reasonable precautionary steps to ensure our employees have a safe and healthy workplace, free from all forms of harassment. There shall be no workplace harassment, directed against any employee, anyone Anixter conducts business with or any member of the public. Accordingly, this policy applies to all employees, contractors and staff at Anixter and to all persons who attend at the Workplace, including but not limited to all customers, clients & suppliers with whom employees deal and employees family members who enter Anixter property or interact with Anixter staff while at work.

2 Harassment Harassment may occur once or over a series of incidents and is described as any hostile or unwanted conduct, comment, gesture or contact. Harassment includes unwanted conduct based on prohibited grounds of discrimination and harassment in local human rights statutes, for example, on grounds such as race, colour, religion or religious beliefs, sex, place of origin, ancestry, record of offences or criminal record, source of income, age, physical/mental disability, political belief, marital/family status, sexual orientation or personal prejudice that: a) is likely to embarrass, offend or humiliate the targeted person or group of people; b) indicates, implicitly or explicitly, that submission to a specific behaviour is an employment condition; c) serves as a basis for determining the employee s entitlement to promotion, salary increase, job security or company benefits; d) affects an employee s performance via intimidation; or e) creates an intimidating, hostile or offensive work environment. Psychological Harassment Characterised by a single or series of incident(s) that may occur over a period of time. Such behaviour(s) have an impact on the dignity or, the psychological or physical integrity of an employee, resulting in a negative or unhealthy work environment. A broad range of behaviours can be considered as psychological harassment, including but not limited to: a) insulting, degrading, offending or intimidating a person with vulgar or coarse remarks; b) displaying pin-ups, offensive cartoons and graffiti; c) leering, ogling, making obscene gestures; d) disregarding an employee: to start rumours, ridicule, humiliate, insult the employee or to comment on their beliefs or their private life; e) discrediting a person: to force an employee to execute tasks considered degrading or to belittle a person s skills set. f) isolating an employee: to ignore or deny a person s presence or to isolate an employee from others; g) destabilizing an employee: to make fun of an employee s gender, body, race, convictions, values, tastes, political views or any similar behaviour. Sexual Harassment Characterized by a single or a series of incident(s) regarded as non-desired sexual advances, requests for sexual favours, or any type of verbal or physical behaviour that is sexual in nature. A broad range of behaviours can be considered as sexual harassment, including but not limited to: a) Sexist jokes or use of sexual vocabulary that makes an employee(s) feel uncomfortable or the speaker keeps repeating to the listener(s) although the listener clearly indicates the jokes make him or her feel uncomfortable; b) Degrading comments regarding people of the same or opposite sex; c) Intimidating leering that makes another feel uneasy/threatened; d) Inappropriate comments on one s physical appearance or anatomy; e) Sexually suggestive / obscene / opportunist comments or gestures; f) Comments or questions regarding one s sexual life; g) Demands for sexual favours in return for employment or promotion;

3 h) Unwelcome sexual propositions or flirts; i) Repeated and unwelcome invitations to socialize; j) Stalking an employee; k) Unwelcome physical contact such as pinching, grabbing, kissing, rubbing, massaging, caressing; l) Verbal violence or threats; or m) Sexual aggression. Physical and sexual assault or threats of violence directed towards an employee, their family and their possessions are also criminal matters. Harassment by an employee in the workplace constitutes a serious violation of this policy and of Anixter s ethic and values. All incidents of workplace harassment will be investigated with the utmost urgency. Any one found to have engaged in any form of harassment shall be subject to disciplinary action up to and including termination of their employment. All complaints of violation of this policy shall be investigated by Human Resources and appropriate action will be recommended to senior management. Complaints will be dealt with in confidence, to the extent possible, with fair consideration given to all parties involved. Employee Responsibilities Employees also have a responsibility to support Anixter s efforts to create a harassment-free workplace by adhering to this policy and working in compliance with any supporting policies, programs and procedures. All employees are encouraged to report incidents of harassment promptly, as set out below. Managers/Supervisors Responsibilities All managers and supervisors must adhere to this policy and any supporting programs, policies or procedures. Managers and Supervisors must ensure that this policy and all supporting policies and procedures are followed by employees and that employees have the information and instruction they need to understand Anixter's policies and procedures. Anixter s Responsibilities Anixter shall ensure that all necessary policies and procedures are implemented and maintained and that all employees have the information and instruction needed to protect them from workplace harassment. Reporting Procedure An employee who believes that he/she has been subjected to harassment can: (a) (b) confront the harasser directly, make their disapproval or unease known, and ask for the behaviour to stop; or report the incident to their immediate manager/supervisor, anyone in human resources or any member of management with whom they feel comfortable. If an employee attempts to deal with a situation of harassment by dealing with the person directly, the employee should immediately report the matter if the harassment continues or if their request is ignored.

4 Employees who witness or become aware of another employee or worker who may be subject to workplace harassment, must also immediately report such matters to their immediate manager/supervisor, any member of the Human Resources team, or any member of management with whom they are comfortable. Upon being made aware of an incident of Workplace Violence, any supervisor/manager or member of management, shall be responsible for immediately informing Human Resources. A written record of the circumstances shall be developed and maintained by Human Resources. Written records shall include the nature of the behaviour, dates, times, witnesses (if any) and any action taken by the employee to stop the violent behaviour. Human Resources will also work with the applicable supervisor/manager or member of management, to ensure that an investigation is completed promptly. Managers/Supervisors and Human Resources staff shall otherwise take every reasonable precaution to ensure the safety of any employee subject to workplace harassment while at work. In appropriate circumstances, this may involve removing the employee from the workplace, altering their hours of work and duties or anything else deemed necessary to protect the employee. Such changes will not be implemented without discussion with the employee. The accused employee, if any, shall also be protected. The employee accused of workplace harassment shall have an opportunity to explain and defend themselves. All information related to a report or incident of workplace harassment shall be kept strictly confidential by Human Resources, to the extent possible. Complete confidentiality and anonymity cannot be guaranteed. Investigation Procedure Human Resources shall be responsible for investigating incidents of workplace harassment that are reported. Investigations may be completed internally or through the use of an external consultant, at Anixter s sole discretion. The form an investigation takes will depend on the nature of the incident and the people involved. Typically, an investigation will require interviewing the complainant, the alleged offender and any witnesses. At the conclusion of the investigation, a decision or recommendation will be made in consultation with senior management, and both parties will be advised of the outcome. Not all investigations will result in a written report and, generally speaking, any such reports will be the property of Anixter and treated as confidential. Parties are not typically entitled to a copy of any report or underlying documentation such as witness statements. If a complainant is not satisfied with the result or recommendation following an investigation, they will have the opportunity to meet with Human Resources to discuss the matter further and always have the right to commence a formal complaint with the local health and safety or human rights commission or tribunal. In Quebec the Act respecting Labour Standards provides recourse in the event of psychological harassment in the workplace, which is available to every employee, whether unionized or nonunionized, or at the senior managerial level. The Act set a 90-day period to file such a compliant. Confidentiality All parties involved in a harassment complaint must recognize the seriousness of the matter and respect, in every possible way, the confidentiality of the issue in order to preserve the dignity, integrity and the self esteem of all concerned. The parties involved must keep all information regarding the complaint confidential throughout each step of the process. Not respecting confidentiality may result in disciplinary action up to and

5 including termination of employment. The privacy and reputation of all employees/individuals involved must be respected and protected. All parties involved must not, except to the extent necessary to report on or investigate the situation, reveal the name of the complainant, the name of the alleged harasser nor the events in the matter. Documentation regarding the matter will not be placed in the complainant s file and must remain confidential and retained by Human Resources. Disciplinary Action If harassment contrary to this policy is found, the harasser shall be subject to immediate disciplinary action up to and including termination of employment, without notice, for just cause. Intentionally accusing someone of harassment, which is known to be false, is also a serious offence and shall be subject to disciplinary action up to and including termination of employment, without notice for just cause. Management has a responsibility to promptly report all complaints of harassment in the workplace. Managers who fail to take appropriate corrective action when made aware of harassment will themselves be subject to disciplinary action up to and including termination of employment, without notice for just cause.

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