Policies

Objective

Justice Education Society (JES) is committed to the highest ethical standards and to open and fair business conduct in all of its projects worldwide. General work conduct standards are outlined in our Code of Conduct. In addition, employees, consultants, volunteers, directors, and officers shall not, directly or indirectly, give, offer, promise, authorize or agree to give or offer a loan, payment, reward, advantage, gift, favour or benefit of any kind, however characterized, to a foreign public official, political party, party official or candidate, or to any person or organization, for the benefit of a foreign public official, political party, party official or candidate, or any person or organization, in contravention of the Canadian Corruption of Foreign Public Officials Act, SC 1998, c. 34, as amended.

Through compliance with this Anti-Corruption and Anti-Bribery Policy, we uphold our high moral and ethical principles and demonstrate a commitment to best practices with respect to anti-corruption behaviour in all areas of our work.

Any link to bribery and corruption would be damaging to our reputation and would undermine the trust built with beneficiaries, partners, donors and the public. We must provide a clear message to our staff, stakeholders and partners that bribery and corruption is not tolerated and that the organization has effective measures in place to guide, prevent and deal with any corruption and bribery issues.

Application

This Policy applies to all employees, consultants, volunteers, directors, and officers of the Justice Education Society (JES). JES expects all employees, consultants, volunteers, directors and officers to know and follow this Anti-Corruption and Anti-Bribery Policy.

Failure to comply with this Policy may be grounds for disciplinary action, up to and including termination of employment for just cause or other business relationships.

Definitions

Corruption is the misuse of public power for private profit, or the misuse of entrusted power for private gain

Bribery is giving or receiving money, free trips, meals, or other gifts or an inducement of any kind in exchange for information, new business, to facilitate or damage implementation of ongoing business, or to influence official policy or actions. An inducement is something which helps to bring about an action or desired result.

Bribery and corruption can take the form of:

• Cash payments
• Phony jobs or “consulting” relationships
• Kickbacks
• Political contributions
• Charitable contributions
• Social benefits
• Gifts, hospitality, and reimbursement of expenses

Facilitating Payment is a small, unofficial payment made to expedite routine governmental action that does not involve obtaining, retaining or directing business, such as processing work orders or other administrative requests.

Government Official is any official of a governmental entity, a public international organization, a regional development bank or other multilateral organization, or indigenous representative. For purposes of this Policy, government-owned companies and their instrumentalities are considered to be governmental entities, and their employees, officers, directors, agents, consultants and contractors are considered to be government officials.

Kickback is a payment of any part of a contract amount made to an employee or agent of a contracting party by another contracting party, directly or by use of other techniques such as subcontracts, purchase orders or consulting agreements, to channel payments to a government official, politician, contracting party or its employees or agents, or their relatives or business associates.

Policy

JES has a zero-tolerance approach to bribery and corruption. You are strictly prohibited from offering, paying, promising, authorizing or receiving any bribe, facilitating payment, kickback or other thing of value to or from any government official or government employee, directly, or indirectly through a third party, to secure any contract, concession or other improper advantage for JES.

You must understand and comply with this Policy, and, when in doubt, seek interpretation and guidance from your supervisor or the CEO.

Following are definitions of specific behaviour that we expressly prohibit:

1. Misuse of Authority: You may not use JES resources, property, personnel, facilities, equipment, time, or funds for personal financial gain or to gain favorable political or legal treatment. 
2. Bribery: You will not provide to or accept from any government official or another person or organization, any gift, gratuity, money, or other form of compensation or benefit when it is intended to influence official acts or receive special consideration or benefit.
3. Financial Records: Our financial books and records must correctly record both quantitative and qualitative aspects of a transaction. Quantitative aspects refer to the amount of the transaction. Qualitative aspects include the written description of the transaction and the accounts that are credited or debited for the transaction. You must ensure that there is a reasonable relationship between the substance of a transaction and how it is described in JES’s books and records.
4. Gifts: It is prohibited to give or receive inducements, including gifts and entertainment, to or from government officials on a scale that might be perceived as creating an obligation on that official. Gifts may not be given or accepted with the intention or expectation of influencing a party to obtain or retain business or a business advantage, or as a reward for the provision or retention of business or a business advantage, or in exchange for favors or benefits. Detailed information about gift giving and receiving may be found in JES’ Conflict of Interest Policy.

Reporting Procedure

JES is dedicated to the identification and rectification of malpractice. Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

No retaliation will be taken against whistleblowers for any disclosure made in good faith.

Employees must report any suspected malpractice, including by any employees, consultants, volunteers and officers of JES, to the CEO. The President of the Board needs to be contacted in the case of a suspected malpractice by the CEO and/or a Board Director.

When making a report, you are encouraged to provide as much specific information as possible including names, dates, places and events that took place, your perception of why the incident(s) may be a violation, and what action you recommend be taken.

Reports should include as much detailed information as possible to allow proper investigation of your concerns. Reports will be handled in a confidential manner. The action taken after a report is received will depend on the nature of the concern. Reports may or may not be investigated at the sole discretion of JES. If JES determines that an investigation is warranted, it will take appropriate measures to implement a prompt and thorough investigation. Every effort will be made to protect the reporter’s identity (if provided) to the extent possible and subject to applicable law. Please note that it is possible that as a result of the information provided in a report, the reporter’s identity may become known to JES during the course of the investigation.

All employees have a duty to co-operate in an investigation. If such a person fails to co-operate in an investigation, or if they provide false information in an investigation, JES will take corrective action commensurate with the severity of the offence (up to and including termination of employment or other business relationships).

JES may discipline any employee who makes a report under this Policy without a reasonable, good faith belief in the truth and accuracy of the information they provide and such discipline may result in the termination of the individual’s employment.

Compliance

All employees, consultants, volunteers, directors, and officers must comply with this Policy and cooperate with any investigation initiated pursuant to this Policy. Adhering to this Policy is a condition of employment or other business relationships.

This policy should not be construed as preventing, limiting, or delaying JES from taking disciplinary action against any individual, up to and including termination of employment for cause, or other business relationships, in any circumstances where JES deems disciplinary action appropriate.

Questions about this Policy

If you have any questions, contact the CEO.

Objective

Our mission is to empower people to access and deliver justice in Canada and globally. This is accomplished through a variety of methods and programs that all reflect our vision: Justice for All.

In executing our programs, we work with and provide services to a wide demographic of people, from educators and school administrators to justice system professionals, recent immigrants, Indigenous communities and foreign governments and judicial authorities. We also provide services to over a million general public online users.

Our Code of Conduct Policy (Policy) guides our behaviour with all these stakeholders and amongst ourselves. It is driven by our desire to maintain the highest level of respect toward our clients and stakeholders, and to preserve our stellar reputation within the justice sector for ethical and responsible delivery of services of the highest caliber.

Application

This Policy applies to all employees, consultants, volunteers, directors, and officers of the Justice Education Society (JES). JES expects all employees, consultants, volunteers, directors, and officers to know and follow this Code of Conduct.

Failure to comply with this Code of Conduct may be grounds for disciplinary action, up to and including termination of employment for just cause or other business relationships.

Policy

• Respect for the law: You must act with honesty and integrity and in accordance with all professional standards and/or governing rules, laws and/or legislation that have application to the responsibilities you perform for or on behalf of JES. You are expected to educate yourself on the standards, laws, rules and regulations that govern your work for JES, and seek clarification or direction from your supervisor or other appropriate individual at JES where you are unsure.
• Expected Behaviour: JES is committed to providing a workplace free from discrimination, bullying and harassment and expects that all relationships among persons in the workplace will be professional and free of discrimination, bullying and harassment. For further information, see the JES Bullying and Harassment Policy.
• Business Opportunities: JES employees, consultants, volunteers, directors, and officers are prohibited from using their position with JES to solicit or conduct business for personal benefit or gain. Employees, consultants, volunteers, directors, and officers are also prohibited from taking for themselves personally or for the benefit of others, opportunities that are discovered through the use of JES property or information.
• Fair Dealing: JES volunteers, consultants, directors and officers should endeavour to deal fairly with JES’ clients, stakeholders, suppliers, and competitors. No individual should take unfair advantage of anyone through manipulation, concealment, abuse of privileged information, misrepresentation, or any other unfair or unlawful dealing practice.
• Confidentiality: Confidential information, in any form, that you receive through your employment must not be disclosed, released, or transmitted to anyone other than persons who are authorized to receive the information. If you are in doubt as to whether certain information is confidential, you must ask your supervisor before disclosing, releasing, or transmitting it. Information from foreign entities that is gathered as part of process and procedural training and education will be held as confidential until such time as express consent is received by the original owner of the information to disclose, release or otherwise transmit it.
• Integrity of Records and Internal Controls: The accuracy, reliability and integrity of JES’ records is critical to its on-going success. Appropriate accounting and financial policies, procedures, controls and audit processes must be maintained. All business records, expense accounts, invoices, bills, payroll and employee records and other reports must be prepared with care and honesty. All assets, liabilities and transactions must be accurately and completely reported in JES’ books and records and supported by necessary documentation. No asset, liability or transaction is to be concealed from management or JES’ auditors.
• Public Comment: JES volunteers, consultants, directors and officers should not speak publicly, including to the media, where it could be perceived as an official act or representation of the position of JES, unless authorized to do so by the Chief Executive Officer (CEO). Requests to speak publicly and/or comment on behalf of JES should be sent to the CEO.
• Conflict of Interest: You should avoid all situations that present a conflict of interest or that reasonably present the appearance of a conflict of interest. Please refer to the JES Conflict of Interest Policy that describes in greater detail the definition of conflict used by JES, and what steps you should take in the event that you find yourself in a conflict of interest relationship or situation. Procedures for disclosure of such relationships are provided in the Guidelines for Disclosure section of the Conflict of Interest Policy. All employees are required to read and sign JES’ Conflict of Interest Policy in addition to signing this Code of Conduct Policy.
• Fraud, Theft, and Intentional Damage: Fraud and theft are not tolerated at JES. This includes, for example, the misappropriation or theft of assets, the intentional misrepresentation of expense claims, benefits claims, hours worked and/or the purchase of goods and/or services, and the misrepresentation of financial information. 
• Intentional Damage: You are strictly prohibited from stealing or intentionally damaging JES project or property. The theft or intentional damaging of JES project or property results in disciplinary action up to and including termination from employment or termination of other business relationship. Furthermore, you are held responsible for reimbursing JES for the costs of theft or intentional damage.
• Criminal Conduct: You are strictly prohibited from knowingly engaging in any activity or action that would violate the criminal laws of Canada and/or the criminal laws of the host country, where applicable. Commission of a criminal offense may lead to disciplinary action, up to and including termination from employment or termination of other business relationship. If you are charged with a criminal offense, you are required to immediately report this fact in writing to the CEO of JES.JES reserves the right to suspend any employee while a criminal investigation is on-going or until the charges are resolved, or terminate the employee, or other business relationship, as warranted.
• Political Activity If you choose to participate in partisan political activity, you must do so during off-hours and you cannot use your position at JES, JES equipment, or facilities in connection with such political activity.

Reporting

All JES employees, consultants, volunteers, directors and officers who know of, or suspect, a violation of this Policy or of any applicable law, rule or regulation have an obligation to immediately report this information to their supervisor or any member of the Senior Leadership Team. Actual or suspected violations should also be reported to the person’s supervisor or any member of the Senior Leadership Team. However, where an employee, volunteer, consultant, director, or officer is not comfortable going to their supervisor or a member of the Senior Leadership Team, they should consult, in confidence, with human resources (HR) or the CEO. All reported violations will be promptly investigated and treated confidentially to the extent possible. Employees, volunteers, consultants, directors and officers are expected to cooperate fully in internal investigations of misconduct.

In addition, you must report to HR a safety hazard or unsafe condition or act in accordance with the provisions of the B.C. Occupational Health and Safety Regulation, BC Reg. 296/97, (http://www.bclaws.ca/civix/document/id/complete/statreg/296_97_00), as amended from time to time.

Code of Conduct Violations

Violation of the principles and explicit rules outlined in the Code of Conduct is a serious matter and may be subject to disciplinary action, up to and including termination of employment with JES for just cause or termination of other business relationship.

Retaliation

No one will be subject to retaliation because of a good faith report of suspected violation of this Policy, or for assisting in an investigation into a breach of this Policy. At the same time, any person found to have made a false or malicious report or knowingly providing false or misleading information during an investigation will be subject to disciplinary measures up to and including termination of employment for just cause or termination of other business relationship.

Introduction

Justice Education Society’s (JES) vision is to seek Justice for All. We strive for a world free of prejudice, bias, discrimination, violence and harmful practices in which everyone’s rights are respected, everyone is treated fairly and everyone has equal access to justice. We believe that the empowerment of persons of all genders, who face intersecting forms of marginalization and exclusion, is fundamental to achieving gender equality and social justice, and for contributing to the progress and development of a stronger, more peaceful, and sustainable world.

We recognize that to achieve our mission to empower people to access and deliver justice in Canada and globally, and to contribute to the Sustainable Development Goals, considerations of gender, diversity, and inclusion must be front and center in all that we do. Gender equality, diversity and inclusion are an intrinsic part of who we are, driving how we lead our organization, how we work, how we deliver our services and programs, and how we contribute to our communities at the regional, national and international levels.

Application

This Policy applies to JES, its Board and its committees, employees, contractors, consultants and volunteers.

Statement

Our goal is to create an institutional foundation that embraces inclusive and equitable principles, exemplified by a diverse and representative workforce, allowing us to celebrate and foster a culture that provides a flexible, engaging and empowering work environment. We believe this is achieved through:

• building and leveraging diverse, complementary capabilities within and between teams;
• engaging, mobilizing and retaining the best available talent, with a focus on attracting applicants with diverse socio-cultural identities, and providing them with ongoing learning opportunities;
• encouraging and utilizing diverse ways of thinking to create the best solutions to build individual, community and stakeholder capacities; and
• by delivering our services in a collaborative manner, building linkages and partnerships across socio-economic and cultural barriers and differences.

These actions will give JES a competitive advantage through productivity, innovation, agility and accountability for sustainable performance and equitable growth. These actions will also allow JES to deliver on our vision, mission and commitment, and to best support the diverse individuals, communities and stakeholders that we serve.

Our Commitment

To achieve our goal, JES will:

• Conduct regular gender, diversity and inclusion audits with a focus on data, policies, processes and culture in order to identify areas of strength, improvement, opportunities and challenges.
• Develop and implement a strategy and action plan to address systemic or cultural barriers that hinder the attraction, recruitment, retention and progression of diverse talent.
• Analyze and monitor the gender and diversity composition of human resources at all levels (Board, management, staff, volunteers, contractors and consultants) and take steps to address any gaps and make improvements.
• Build engagement around gender, diversity, and inclusion issues amongst JES management team and create a culture of openness and accountability.
• Strengthen capacity in gender mainstreaming with a particular focus on intersectional gender analysis and gender budgeting skills training.
• Provide regular gender, diversity, and inclusion training to all staff, volunteers, contractors and consultants to maintain a culture of inclusion and diversity.
• Integrate measures and provide training to prevent sexual and gender-based violence and to protect against sexual exploitation and abuse for all staff, volunteers, contractors, consultants, and clients.
• Ensure that all human resources policies, processes and procedures are reviewed and developed to include considerations supporting gender and diversity.
• Prioritize human, technical and financial resources to meet our gender and diversity commitments.
• Consider gender and diversity in financial resource allocation decisions (gender and diversity budgeting) at institutional and project levels.
• Integrate transformative and inclusive gender and diversity approaches into project design, delivery, monitoring and evaluation.
• Ensure the production and inclusion of data disaggregated by sex, gender, age, and other relevant socio-cultural identities to inform priorities, actions and decisions across our domestic and international programs.
• Ensure that all communications, training, marketing and fundraising materials incorporate gender and socio-culturally inclusive language and positive images.

Responsibilities

The JES Board and leadership team are responsible for the implementation of this policy and all Board and its committees, staff, volunteers, contractors and consultants must comply with this policy. JES’ CEO will regularly report on the implementation of this policy to the JES Board.

Definitions

Diversity – recognizing and valuing differences in people’s identities, characteristics, and experiences.

Gender budgeting – analyzing and preparing budgets from a gender perspective, to understand how persons of different genders may be affected.

Gender equality – the equal valuing of women, men and non-binary persons, and the varying roles that they play; and ensuring equal rights and opportunities for persons of all genders.

Gender mainstreaming – “a strategy to assess the implications for both men and women, of any planned actions, policies or programmes in all areas and at all levels. This approach recognizes the need to take social and economic differences between men and women into account to ensure that proposed policies and programmes have intended and fair results for women and men, boys and girls.”

Harmful practices – socio-cultural practices that lead to violations of the human rights of persons of all genders and ages.

Inclusion – valuing, welcoming, and ensuring equal opportunities for persons of all genders, ages, and socio-cultural identities.

Intersecting forms of marginalization and exclusion – gender inequalities may intersect with additional forms of marginalization and exclusion that are based on other social identities and factors, such as age, race/ethnicity, religion, ability, sexual orientation etc.

Intersectional gender analysis – understanding and recognizing multiple and intersecting differences between people, such as gender, sex, religion, age, ability, sexual orientation etc.

Persons of all genders – individuals may have different gender identities and/or sexual orientations. Gender and sexual differences are not only linked to the binary designation of women/men or male/female.

Socio-cultural identities – different social and cultural traits and characteristics to which people identify themselves and others.

Objective

Justice Education Society’s (JES) mission is to empower people to access and deliver justice in Canada and globally. This is accomplished through a variety of methods and programs that all reflect our vision: Justice for All.

In executing our programs, we work with and provide services to a wide demographic of people, from youth, educators, recent immigrants, Indigenous communities, justice system professionals, law enforcement, foreign governments and judicial authorities.

This Policy seeks to prevent sexual exploitation and abuse (SEA) by

1. promoting increased awareness;
2. promptly reporting, investigating and resolving any SEA incident that may occur; and
3. providing assistance and support to victims of SEA.

Application

This Policy applies to all employees, contractors, partner organizations, volunteers, board directors, and any individual engaged by JES.

Partner organizations will develop and implement and adhere to their own SEA policy, in accordance with the signed memorandum of agreement with JES, and their policy will be in compliance with the scope of this policy. In the absence of their own PSEA policy, this policy must be incorporated by reference into their contracts with JES and accepted by the signing party.

Definitions

“Sexual exploitation: any actual or attempted abuse of a position of vulnerability, differential power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another.

Sexual abuse: an actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions.” 

Policy

JES has a zero tolerance approach to SEA. JES does not allow any employee, contractor, partner organization, volunteer, board director or any individual engaged by JES to participate in any form of sexual abuse or exploitation. All are expected to uphold the highest standards of personal and professional conduct at all times, and to provide assistance and services in a manner that respects and fosters the rights of beneficiaries and other vulnerable members of the local communities.

JES strives to create and maintain a safe environment, free from SEA, by taking appropriate measures internally and in the communities where JES operates, through prevention and response in the work that we do.

Core Principles

JES abides by the six core principles of the Inter-Agency Standing Committee (IASC) on Sexual Exploitation and Abuse:

1. “Sexual exploitation and abuse by humanitarian workers constitute acts of gross misconduct and are therefore grounds for termination of employment.
2. Sexual activity with children (persons under the age of 18) is prohibited regardless of the age of majority or age of consent locally. Mistaken belief regarding the age of a child is not a defence. 
3. Exchange of money, employment, goods, or services for sex, including sexual favours or other forms of humiliating, degrading or exploitative behaviour is prohibited. This includes exchange of assistance that is due to beneficiaries.
4. Any sexual relationship between those providing humanitarian assistance and protection and a person benefitting from such humanitarian assistance and protection that involves improper use of rank or position is prohibited. Such relationships undermine the credibility and integrity of humanitarian aid work.
5. Where a humanitarian worker develops concerns or suspicions regarding sexual abuse or exploitation by a fellow worker, whether in the same agency or not, they must report such concerns via established agency reporting mechanisms.
6. Humanitarian workers are obliged to create and maintain an environment which prevents sexual exploitation and abuse and promotes the implementation of their code of conduct. Managers at all levels have particular responsibilities to support and develop systems which maintain this environment.”1
7. The Board will be informed by the CEO of all complaints and the results of the pursuant investigation.

Roles and Responsibilities

1. All employees and anyone who works with JES have the responsibility to promptly report incidences of SEA being perpetrated by anyone within JES. 
2. The management team is responsible for creating and maintaining an environment in which everyone knows what JES expects from them and feels able to report any suspicious or inappropriate behaviour. 
3. Employees must fully cooperate with investigations into incidents of SEA.
4. JES commits to maintaining a robust recruitment screening, referencing, background and police checks process for all employees, contractors, board directors and volunteers.
5. JES commits to SEA prevention by raising awareness and providing training to all employees, including empowering them to integrate the PSEA core principles into their daily work to ensure safe programming.
6. All employees, contractors, board directors and volunteers must sign the PSEA Declaration form confirming they have read, understood and agreed to abide by the PSEA Policy of JES. Adherence to the PSEA Policy is a condition of employment. Violation of the PSEA Policy may be grounds for termination of their employment for just cause without notice or pay in lieu of notice.
7. The management team must deal with situations of SEA immediately upon becoming aware of them, whether or not there has been a complaint. In addition, human resources (HR) and the CEO are responsible for conducting investigations as set out in this Policy, as well as implementing any follow-up steps that are determined to be appropriate following an investigation.

Complaint Reporting Process

If you feel that you are a SEA victim or you believe anyone engaged by JES is either a victim or perpetrator of SEA, you should take the following actions immediately:

Step 1 As long as you are comfortable doing so safely, a complaint or report should be submitted directly to your supervisor, HR or the CEO. The supervisor or HR has the responsibility to report to the CEO within 24 hours of receiving a SEA report.

Step 2 The report or written complaint should include as much detail as possible about the circumstances including dates, times, locations, persons involved, witnesses and the specific conduct that is the source of the complaint. Attach any supporting documents, such as e-mails, handwritten notes or photographs. If the complaint involves the individual to whom you normally report, then you should refer the complaint to that individual’s immediate manager, HR or to the CEO.

If the CEO is implicated in the complaint, the report or complaint should be submitted directly to the President of the Board, who will bring it to the Executive Committee’s attention within 24 hours.

If the President is implicated in the complaint, then the Vice-President or another member of the Executive Committee should receive the report and convene a sub-committee meeting within 24 hours. The sub-committee in consultation with the Executive Committee will investigate and decide on the best course of action.

The complainant is fully within their rights at any time to submit the report directly to an external authority, such as the local police service.

Investigation Procedure

Once JES receives a formal complaint it will conduct an investigation. In the event that a complainant does not proceed with a formal complaint, JES may still initiate an investigation if it is deemed to be a potential case of SEA.

The CEO or Board is responsible for ensuring that a fair and thorough investigation is conducted in a timely fashion, and that appropriate actions are taken.

The investigation process framework is described below:

1. Review the complaint and select the investigator. For the majority of complaints, JES will assign an appropriate person internally to conduct the investigation. In some circumstances, such as complex or sensitive situations, JES may appoint an external investigator to conduct an investigation.
2. Oversee the investigation, which includes:

• Interview complainant
• Interview respondent
• Interview witnesses, if any
• Review any relevant documents or evidence provided

1. Analyse the information and come to a decision.
2. Following the conclusion of the investigation, the investigator will provide a summary of the investigation findings to the complainant and the respondent. Both parties will have an opportunity to provide any additional information they believe may be relevant to the final outcome of the investigation.
3. When the investigation is concluded, the investigator will report their findings to the CEO or Board. The complainant and respondent will be advised of JES’ findings.
4. JES will then decide whether this Policy has been contravened and whether discipline and/or corrective action should be taken. If the investigation reveals that the complaint was without substance and filed in bad faith, appropriate action will be taken against the complainant.
5. If the Criminal Code may have been contravened, the case will be referred to authorities who have an independent legal mandate to investigate such cases.

The procedures in this Policy and any investigation carried out are intended to be flexible in order to respond to the specific circumstances at issue. JES reserves the right to engage in a different procedure as it deems appropriate in any given circumstance.

Victim Assistance

JES is committed to providing referrals to available support services for victims of SEA.

Confidentiality

Every reasonable effort will be made to ensure confidentiality throughout the process. Information will only be disclosed to the extent required for the purposes of carrying out a full and fair investigation, to address the findings from the investigation, or as required by law or to report a possible criminal offence. All parties involved in the resolution or investigation of a SEA complaint are expected to facilitate the process, co-operate and maintain confidentiality.

Retaliation

Employees will not be subject to retribution or reprisal for filing SEA complaints, participating in any investigation, or reporting any violation of law or the Policy. Retaliation of any type against any employees will not be tolerated and such conduct may result in disciplinary action, up to and including immediate termination for just cause.

Discipline

Any employee who is found to have engaged in conduct prohibited by this Policy will be subject to disciplinary action up to and including termination of employment for just cause. Any employee who makes false or reckless SEA allegations or makes such allegations for improper purposes will be subject to discipline, up to and including immediate termination of employment for just cause.

Review

JES will review this Policy annually. This Policy is not intended to address every situation and JES reserves the right to amend this Policy at its sole discretion, from time to time. All employees are expected to keep up-to-date with this Policy.