NBCUniversal Equal Employment, Anti-Harassment and Retaliation Policy (TV Production)

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1 NBCUniversal Equal Employment, Anti-Harassment and Retaliation Policy (TV Production) 1. EQUAL EMPLOYMENT NBCUniversal s policy is to provide equal employment opportunities to all applicants and employees without regard to race, color, religion, creed, sex, gender, gender identity/expression, age, national origin or ancestry, citizenship, physical disability, mental disability, protected medical condition, sexual orientation, marital status, pregnancy, veteran status, membership in the uniformed services, genetic information, or any other basis protected by applicable law ( protected characteristics ). To the extent required by applicable law, NBCUniversal also provides equal employment opportunities to individuals regardless of any perception that an individual has a protected characteristic or associates with a person who has or is perceived as having a protected characteristic. Accordingly, NBCUniversal prohibits discrimination against any of its employees by other employees (including supervisors and managers), and by third parties doing business with the Company, on the basis of any actual or perceived protected characteristic. Consistent with this policy, NBCUniversal is committed to making employment decisions based on merit, qualifications, and other job-related criteria without regard to an individual s protected characteristic(s). This policy covers all aspects of the employment relationship, including the application and hiring process, corrective action, promotion and transfer, compensation, and termination. Subject to applicable law, NBCUniversal also offers reasonable accommodations to qualified individuals with known disabilities to enable them to perform the essential functions of their positions. What constitutes a reasonable accommodation may depend on many factors including, but not limited to, the nature of the individual s disability and the essential functions of the position. NBCUniversal is not obligated to provide an accommodation that would impose an undue hardship on the Company. 2. ANTI-HARASSMENT NBCUniversal is strongly committed to providing a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in an environment free of unlawful harassment including, but not limited to, sexual harassment. Accordingly, NBCUniversal prohibits the harassment of its employees by other employees (including supervisors and managers), vendors, contractors, customers, and other third parties doing business with the Company based on any protected characteristics. Similarly, the harassment of any vendor, contractor, customer, or other third party doing business with the Company by any NBCUniversal employee or contractor based on any protected characteristic is also prohibited. HIR-01A: Attachment A

2 NBCUniversal also prohibits harassment based on the perception that an individual has a protected characteristic or is associated with a person who has or is perceived as having a protected characteristic. Any employee who violates this policy or engages in harassing or other inappropriate behavior is subject to disciplinary action, up to and including termination. Harassment may exist when an individual is subjected to unwelcome conduct, whether verbal, physical or visual, based on an actual or perceived protected characteristic, and the conduct has the effect of unreasonably interfering with the individual s job performance or creating an intimidating, hostile or offensive work environment, is made either explicitly or implicitly a term or condition of employment, or where submission to such conduct is used as the basis for an employment decision. Some specific examples of inappropriate conduct are: making inappropriate verbal statements, such as suggestive jokes, derogatory or degrading comments, epithets and slurs; inappropriate written materials, such as suggestive jokes, cartoons or offcolor or obscene letters, notes or invitations transmitted by or otherwise; inappropriate physical conduct, such as unwanted touching, impeding or blocking another person s movements, leering or sexual gestures; displaying objectionable items, pictures, magazines, cartoons, posters or Internet/World Wide Web material; asking for dates, or making sexual advances, where it is clear, or becomes clear, that the overture is unwelcome; threatening or engaging in reprisals or retaliation after such an overture is rejected; conduct of a sexual or otherwise objectionable nature at company-sponsored parties, events or meals, or in company facilities. 3. CONSENSUAL RELATIONSHIPS NBCUniversal recognizes that consensual sexual or romantic relationships may develop between employees. These relationships potentially can result in complications for the two individuals involved or for the Company. Therefore, if a consensual relationship develops between employees, the employees are strongly encouraged to report the relationship to Human Resources. In the case of a supervisor and a subordinate, or employees of unequal levels of seniority in the same department, the more senior employee is required to report the relationship to Human Resources. Upon learning of the relationship, NBCUniversal may take all steps that it deems appropriate to avoid any HIR-01A: Attachment A

3 actual or perceived conflict of interest including, but not limited to, changing reporting relationships, transferring one or both of the employees to another position, or if no suitable position can be found, terminating one or both employees. ` 4. INTERNAL COMPLAINT PROCEDURE If you believe that you have been discriminated against, harassed, or retaliated against, have observed or learned of unlawful discrimination, harassment or retaliation, or that any other violation of this policy has occurred, or if you have any questions concerning this policy, you must immediately contact: Your line management; or Your local Human Resources representative; or Jennifer Abbondanza, Vice President, Corporate Diversity ( ); or Lisa Hughes, Vice President & Deputy Chief Compliance Officer ( ) or Susanna Zwerling, Vice President Compliance ( ). You also may reach the Ombuds office directly via at or by calling the Integrity Helpline (anonymously, if you wish) at ; or Lupe Nunez, U.S. Spanish-language contact (818) You are not required to report possible discrimination, harassment or retaliation to your immediate supervisor. Any supervisory employees with knowledge of any possible discrimination, harassment or retaliation must bring such information immediately to the attention of Human Resources. This obligation exists even if the conduct was not reported to them, or if the individual who raised the complaint or concern requests that the situation not be reported or investigated. In response to a report of possible discrimination, harassment or retaliation, NBCUniversal will conduct a fair, impartial, timely and thorough investigation by a qualified individual who provides all parties appropriate due process and reaches reasonable conclusions based on the evidence. The investigation will be documented and tracked for reasonable progress. Any appropriate remedial action and resolutions will be taken. NBCUniversal will keep reports made under this policy and any resulting investigation confidential to the extent possible. However, in some circumstances, dissemination of information to others may be necessary. 5. RETALIATION PROHIBITED NBCUniversal strictly prohibits retaliation against an individual who in good faith raises a complaint or concern regarding discrimination or harassment, otherwise opposes discrimination or harassment, reports a violation of this policy, participates in an investigation under this policy, files a charge or complaint of discrimination or harassment with an appropriate government agency or court, participates in an investigation or proceeding related to discrimination or harassment conducted by an appropriate government agency or court, or otherwise engages in protected activity HIR-01A: Attachment A

4 under the law. It is also a violation of this policy for any employee to knowingly raise or participate in a false concern or complaint that this policy has been violated, or provide false or misleading information in the course of an investigation under this policy or in an investigation or proceeding conducted by a governmental agency or court. HIR-01A: Attachment A

5 HUMAN RESOURCES REPRESENTATIVES TV PRODUCTION UCP, UT & FIRST RUN SYNDICATION NAME Darren Chiappetta Giuliana Eminente Kate O Brien TELEPHONE NUMBER (Oversight for All Locations) (First Run Syndication) (East Coast US and Canada) HIR-01A: Attachment A

6 California law requires us to advise California employees of the following: In addition to using NBCUniversal s internal complaint procedure, employees or applicants in California also may file complaints of discrimination or harassment with the California Department of Fair Employment and Housing. The California Department of Fair Employment and Housing Communication Center telephone number is The Southern California Office is located at 320 West 4 th Street, 10 th Floor, Los Angeles, CA The Northern California Office is located at Civic Center Drive, Suite 250, Fremont, CA The Department conducts investigations of complaints. If the Department finds evidence of a violation of law, the Department may file a formal accusation. The accusation will lead either to a public hearing before the Fair Employment and Housing Commission or a lawsuit filed on the complainant s behalf by the Department. If the Commission finds that discrimination or harassment occurred, it can order monetary remedies, such as back pay, fines or damages, and other remedies such as reinstatement, promotion, or changes in policies and practices. Whether or not the Department finds probable merit in a complaint, the charging party may file a lawsuit in court upon receipt of a right-to-sue letter from the Department. HIR-01A: Attachment A

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