OTHER SAMPLE WORK

Sexual Harassment Policy

Written for a Local Police Department by Crystal Morgan

As captain in charge of operations within this police department, including supervision of the human resources department, it is within the parameters of the color of this office to fully investigate the recent allegations by a female officer of sexual harassment by her supervisor. At the start of this investigation, it has been discovered that the current sexual harassment policy is not in compliance with current mandates handed down by Supreme Court rulings. Therefore, the Chief has directed that a new sexual harassment policy is drafted immediately. He also wishes to have a plan drafted for the implementation of the training program, challenges that will exist in implementation and training, as well as information on data related to sexual harassment against women in law enforcement so this department may overcome the issues most prominent. In accomplishing this, the nearest police department’s sexual harassment policy will be compared to the same policy at the state level for reference and guidance in this endeavor. At this point, the time has arrived for this department to begin training on this updated sexual harassment policy guidelines which will be implemented immediately.

Sexual Harassment Policy

There have been many changes in compliance requirements regarding sexual harassment in the workplace which the Supreme Court has ruled upon over the last decade or so which reflect the changes in societal norms, needs, and expectations. This policy is intended to establish standards and definitions while implementing procedures to be followed for reporting, investigating, and following through with disciplinary action, when necessary in regards to offensive behavior of a sexual nature. The sexual harassment policy reads as follows:

Definitions

Sexual harassment. The definition of sexual harassment for purposes of this police department is all-inclusive of any unwelcome conduct toward another based on any sexual aspect related to the victim. This includes unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when this conduct explicitly or implicitly affects an individual’s employment, unreasonably interferes with an individual’s work performance, or creates an intimidating, hostile, or offensive work environment. “The harasser can be the victim's supervisor, a supervisor in another area, a co-worker, or someone who is not an employee of the employer, such as a client or customer (EEOC, 2015). The victim and harasser may be of the same sex and of either gender. The victim does not have to be the person harassed but could be anyone affected by the offensive conduct and said conduct must be unwelcome.

Harassment. Harassment occurs when an individual engages in unwelcome conduct toward another based on a person’s age, gender, marital status, sexual orientation, race, national origin, disability, or in retaliation against anyone who reports suspected harassment or who is involved in a harassment investigation. This conduct is prohibited and subject to the procedures outlined in this policy. “Offensive conduct may include, but is not limited to, offensive jokes, slurs, epithets, or name-calling, physical assaults or threats, intimidation, ridicule or mockery, insults or put-downs, offensive objects or pictures, and interference with work performance” (Moe, 2015). Harassment is officially illegal when the victim must put up with the offensive behavior to maintain their employment or when the conduct is severe enough that it creates a work environment a reasonable person would consider intimidating, hostile, or abusive.

Third party harassment. Third party harassment is defined as any unwelcome behavior that is not directed at an individual but is a part of that individual’s work environment, is offensive to that individual; and is based on a person’s age, gender, marital status, sexual orientation, race, national origin, or in retaliation against anyone who reports suspected harassment or who is involved in a harassment investigation. According to Supreme Court ruling in Metropolitan Government of Nashville, Human Resources in 2008, “the anti-retaliation provision of Title VII extends to people who speak out, not just on their own initiative…The Court reasoned that the plain meaning of the statute includes people who "oppose" sexually obnoxious behavior by merely disclosing the violation and need not initiate the disclosure” (Oyez, 2008). Therefore, the anti-retaliation provision of Title VII of the Civil Rights Act does apply to individuals that are not considered the victim or the harasser if they report conduct directed toward another which makes them uncomfortable or if they are involved in an internal investigation about a sexual harassment claim.

Retaliation. This policy protects the accuser or third parties involved in the investigation, such as witnesses or outsiders reporters. Retaliation laws make it illegal to “fire, demote, harass, or otherwise "retaliate" against people… [who plan on or have] filed a charge of discrimination, because they complained to their employer or other covered entity about discrimination on the job, or because they participated in an employment discrimination proceeding“(EEOC, 2015). Police departments are publicly-held entities and therefore, whistleblowers are also protected against retaliation under the Sarbanes-Oxley Act.

Reporting and Investigating

All officers, regardless of rank, hold a duty to report any suspected violation of this policy by any co-worker, supervisor, or others associated with or doing business with this department. It is the responsibility of every single employee to report such behavior as well as obvious violations through the proper channels and to cooperate with the investigation completely, without prejudice.

Duty to report. To support this police department in providing a safe and comfortable work environment for all and to protect both the department as well as the city from possibly large monetary lawsuits, each employee has an obligation to report suspected violations of this policy. In the 1997 Supreme Court case, Faragher v. City of Boca Raton, “the Court held that an employer is vicariously liable under Title VII of the Civil Rights Act of 1964 for actionable discrimination caused by a supervisor” (Oyez, 1998). The police department, for these purposes, is a subsidiary of the city in which it resides. Therefore, those with knowledge of another being harassed that do not report the violation will be brought into the investigation and it may be found that disciplinary action against the potential witness is required. Additionally, as more time passes, the investigation becomes more difficult to complete accurately causing excessive expense to the department which could have been avoided

Reporting. The method utilized to issue a report may vary dependent upon the situation and individuals involved. Often the problem may stem from a lack of communication that is easily cleared up with or misunderstanding. If the victim feels comfortable confronting the alleged offender, they may let the person know through an informal discussion that the behavior is not appropriate and needs to stop immediately. If it is a case of employees being unaware of the fact that their behavior is perceived by others to be insulting, humiliating, harassing, or discriminatory then the behavior should cease instantly. There is no requirement that the harasser receives warning or that contact is made with the alleged offender prior to filing formal complaints. If the behavior does not cease after confrontation or the victim does not feel comfortable approaching the alleged harasser, a formal report must be filed with their immediate supervisor unless this person is somehow involved in the harassment. In which case, the report would be submitted to the office just above the office of the highest ranked officer or employee involved. This report should contain date(s) the incident(s) happened, specific facts of the incident(s), location(s) the incident(s) occurred at, names of any witnesses, and any other information which may be helpful in the investigation.

Investigation. The supervisor receiving the report is mandated to investigate unless they feel their involvement will create a conflict of interest ((i.e.: employee reporting supervisor behavior or the supervisor is friends with the person of interest), at which time they are to remand the report to the next level up on the corporate chain or another appropriate office. The investigation will take place for any and all reports no matter the recipient’s opinion on the matter. For all reports, the accused will be placed on 48 hour paid leave during which time an emergency investigation will take place. All investigations will consist of interviews with the reporter, the accused, hospital records (if applicable), and any witnesses which have been named by either party as well as any other parties which may be pertinent to the investigation. Additionally, there will be productivity audits, if applicable, to look for discrepancies’ in work style or other changes which may align with dates on the report.

Supervisor’s Role. All supervisors and higher ranked officers are held to a higher standard. Acting in such a role demands the officer ensure those under their supervision feel comfortable in the work environment. Supervisor’s will also face harsher penalties if found guilty of engaging in sexual harassment because this department believes in the statement stating ‘the more power you hold, the more accountable your actions are’. Failure to respond and thoroughly investigate an allegation regarding this policy within an eight hour work shift may be grounds for disciplinary action up to and including termination. Employees who initiate or investigate alleged violations of this policy will respect the confidentiality and privacy of individuals reporting discrimination or other forms of harassment as protected by law. According to the decision by the U.S. Supreme Court in the 2003 case Pennsylvania State Police v Suders, if the alleged victim can prove they took measures to eliminate the harassment with no success and the work environment has become one in “which a "reasonable person ... would have felt compelled to resign" [they] could bring suit even if she had not filed a report with the employer before resigning” (Oyez, 2003). This case makes it clear that this department is expected to take notice of lower ranked officer’s feelings of discomfort as well as the relationships between officers and/or employees in their care. Upon receipt of a complaint, supervisors are to take any action they are empowered to take then pass their finalized reports up the chain of command for completion. Such documents are to be hand delivered to the superior officer; mailings, faxing, emailing, etc. are not acceptable methods of delivery.

Training Program

Purpose

Simply creating and maintaining an updated policy for the department means nothing if the officers and employees are not aware of the policy or know how to access it for reference in the future. To overcome this hurdle, training will be necessary for current officers and employees as well as any new hires that come on later. There are many purposes this training is meant to accomplish. Amongst the many topics, the primary focus of this training will

“identify and describe forms of sexual harassment [with]…examples, outline the agency’s grievance procedure, explain how to use it,…discuss the importance of doing so, discuss the penalty for violating the policy, emphasize the need for a workplace free of harassment, offensive conduct, intimidation, or other forms of discrimination” (Rubin, 1995).

To ensure the policy remains current and that all employees or officers are aware of it as well as any changes which may be implemented, retraining will be required every 4 years for officers and every 2 years for supervisors and other highly ranked officers.

Implementation

Training on the new sexual harassment policy will take place over the next two weeks. The initial meeting is mandatory and will be called for all employees, officers, management, supervisors, and executives to attend through physical appearance or telecommunication (Skype) at which time you will be informed the reasons behind creating this policy, the essential basics of what it contains, and how training will be carried out. After this is completed, Human Resources will be required to rearrange work schedules to allow time for every employee and officer to attend a training session without losing productivity. The new schedules will be distributed to all supervisors who will then inform the employees of the reason for this one-time change as well as which session they are to attend based on that department’s needs. At the training sessions, employees will be given the time they need to clarify any questions or concerns then asked to sign a document that will be kept on file declaring their acceptance of a hard copy, their understating of the policy, and acknowledgement of the various locations this policy can be accessed at. Upon signing, of course, each employee will be provided with a hard copy of the new sexual harassment policy and informed of the open door policy for reporting or asking questions. Finally, the policy will be made available on the department’s website as well as its social networking page for review.

Given the number of training sessions provided and the fact that human resources added time for each employee to have the opportunity to attend at least one session, the first line of compliance assessment will be made by the supervisors. Each supervisor will be informed of every employee or officer under them who has completed training as it happens. It is the supervisor’s responsibility to make sure everyone attends a session then submits for disciplinary action if training is skipped. No employee will be permitted to work without completing training once their assigned time has passed. Anyone who refuses to attend will be suspended without pay until they do and written up for insubordination unless good cause can be proven. However, if more than one or two officers from a single department miss training, the supervisor and manager will also be investigated. If it is found that either of these has somehow interfered with training time, they will be demoted and retrained while the officers will be provided a new training session time slot.

Challenges to Policy-Making Process and Training

It goes without mentioning that there will be existing challenges to this policy-making process and training implementation. Each of these will be addressed individually due to the importance of ensuring smooth implementation of this policy. Among these concerns, there is the worry that supervisors will not exhibit behavior which portrays the importance of this policy in the work environment. If the policy is not implemented and demonstrated from the top-down, it holds no weight. To address this, there is a clause in the policy holding those higher ranked officers and supervisors to stronger penalties if found violating the policy. Additionally, these same positions are subject to disciplinary action for not ensuring those they supervise are able to actually attend their training sessions or for downplaying the policy’s importance in any way. Due to human nature, we tend to take new policy seriously but then slowly let things slide until the policy no longer matters in personal opinion. To counteract this, we have supervisors and higher offices are expected to attend retraining twice as often as their officers and will be suspended without pay if their training lapse until it is complete.

A police department often contains a wide variety of inter-departments. This can prove difficult in writing policy. For this reason, there will be more than one policy and each will be directed at a specific inter-department while making sure to utilize clear and concise language, applicable to each position. Many complain that it is difficult to allot room in the budget for officers and employees to engage in training hours. However, this is easily countered by exhibiting that the typical settlement of a sexual harassment case against a government entity ranges somewhere in the upper millions. Comparatively, training is a drop in the bucket

Compare and Contrast Local versus State

To fully understand what a sexual harassment policy for police departments looks like at both the state as well as the small town level, a comparison between the sexual harassment policy for the Town of Buckley and the Washington State Patrol was completed. The commonalities are vast. Both policies provide definitions of the most important terms and the definitions are almost identical. Another major similarity exists in looking at the spirit of the law. While the letter of the law consists of the literal translation of each rule, indicating clear and obvious guidelines, but the spirit of the law is “broader, and reflects the intention behind the law. While usually obvious, this may not be explicitly stated” (Deolitte Development, LLC, 2013). The spirit of the law will wholly reflect the principles of responsibility, integrity, respect, and quality. One example of the letter of the law for these purposes can be found in rules regarding overtime and what types of action will result in disciplinary measures. To reduce the number of positions that will be eliminated now that the companies have merged, overtime will require approval of a manager and will only be issued when absolutely necessary. Now, following the example of overtime, the Spirit of the Law indicates that when an employee has reached the threshold of scheduled hours and is asked to stay later by management, denial of such a request is not grounds for disciplinary measures and acceptance is completely voluntary. However, under the spirit of the law, employees that regularly work toward the good of the company will be acknowledged and rewarded accordingly but not punished for denying such request. The spirit of the law for the sexual harassment policies compared here are extremely similar, in nature. The entirety of each policy’s idea is not to make those you work with uncomfortable or else.

The major differences found are in the letter of the law. Knowledge of availability and easy access is not a requirement for the Town of Buckley while the State Patrols office had it readily on hand to be emailed within 10 minutes because that is the rule at this department. Another difference is found in reporting. When a sexual harassment complaint is filed by an officer with the Town of Buckley, it is submitted to the city administrator or city attorney even when it is handed to a supervisor. However, the State Patrol has an entire process outlined to intake complaints explaining who should file them, what they should include, and how they are to be handled in-house. The final and most important difference between them is that the State Patrol’s policy is easy to read, outlined for simple reference, and detailed while the Town of Buckley’s policy looks as if someone copied city legal codes and pasted them on the document without much relation from one statement to the next.

Women in Law Enforcement

Sexual harassment is a common experience for woman in law enforcement due to the patriarchal culture which has existed in this profession for so long. In fact, “the rate of sexual harassment in policing is much higher than in other occupations. Female officers consistently rate the prejudiced attitude of their male coworkers to be the biggest stress of their jobs” (Womens Justice Center, 2010). While this statement does not clarify whether the problem is improving or not, it does make it clear that prejudice among males regarding a woman’s ability to adequately fill the role of a law enforcement officer is negative and the highest stressors they are facing. This says a lot. This is a collective statement from women who work in a profession where being shot at, losing a friend or co-worker, and working with the most difficult individuals in our population is to be expected at in their career yet they find male attitudes to be more stressful than all of that. Yet another journal study concluded that

“The percentage of policewomen is still relatively small and the rate of increase of policewomen has grown at a snail's pace since 1971. Unfortunately…court-ordered plans still remain necessary to get some police agencies to implement policies to recruit, promote, and retain women. Two major barriers still exist in many police departments: sexual harassment and poor maternity leave policies” (Horne, 2006).

The many scholarly articles reviewed seem to have one concessive. The only true agreement located is that there is no accurate statistical data on sexual harassment against female law enforcement officers because retaliation for such claims is abundant despite the laws put in place to prevent such actions. Women who complain of sexual harassment are viewed as too soft for the job and the type of retaliation varies from the blunt and obvious to passive aggressive. Those who have placed complaints all too often explain that after this fact comes to light within the department, they deal with shunning, isolating, ostracizing, other officers may even fail to provide backup in critical situations and refuse to communicate or cooperate with the victim on assignments. Some of this backlash is tolerable and chalked up to ‘the blue code of silence’ but other types of backlash are deadly to the officer and the citizens she is attempting to protect.

As captain of this department, sexual harassment will not be tolerated at any level, between any individuals. The new sexual harassment policy is all inclusive of recent Supreme Court decisions and the current complaint will be investigated according to its procedures. Since training and implementation is immediate with a strong emphasis on top-down exemplary behavior, we expect this department to set the stage through example for others to follow to ensure all officers and employees feel safe and comfortable working in this environment. The utilization of both sexual harassment policies reviewed provided us with many reference points as well as showed us weaknesses that we hope to have improved upon. These documents, combined with the data we located related to sexual harassment against women in law enforcement, provided some solutions to the challenges we expect to face in implementation and training on the new sexual harassment policy. We believe the officers and employees in this department are ready for the new era of seamlessly working together as people, with no regard to gender or other sexual factors.

References

Cole et al., (2013). The Criminal Justice System; Politics and Policies. Belmont, CA: Wadsworth

Deloitte Development, LLC. (2013). Personal Integrity, Public Trust Code of Ethics & Professional Conduct. Deloitte Development, LLC. Code of Ethics & Professional Conduct Personal Integrity, Public Trust. Retrieved from: https://www2.deloitte.com/content/dam/Deloitte/us/Documents/about- deloitte/us_about_ei_coe2013_06042013.pdf

EEOC, (2015). Sexual Harassment. U.S. Equal Employment Opportunity Commission; Types of Discrimination. Retrieved from: http://www.eeoc.gov/laws/types/sexual_harassment.cfm

EEOC, (2014). Charges Alleging Sexual Harassment FY 2010 - FY 2014. Equal Opportunity Employment Commission; Statistics > Enforcement & Litigation Statistics. Retrieved from: http://www.eeoc.gov/eeoc/statistics/enforcement/sexual_harassment_new.cfm

Horne, (2006). Policewomen: Their First Century and the New Era. The Police Chief, vol. 73, no. 9, September 2006. Retrieved from: http://www.policechiefmagazine.org/magazine/index.cfm? fuseaction=display_arch&article_id=1000&issue_id=92006

Moe, S., (2015). Discrimination and Other Forms of Harassment. Olympia, WA: 2015 Washington State Patrol Regulation Manual.

Oyez, (1998). Faragher v. City of Boca Raton. Oyez Supreme Court Media. Retrieved from: http://www.oyez.org/cases/1990-1999/1997/1997_97_282

Oyez, (2008). Metropolitan Government of Nashville, Human Resources. Oyez Supreme Court Media. Retrieved from: http://www.oyez.org/cases/2000-2009/2008/2008_06_1595

Rubin, (1995). Civil Rights and Criminal Justice: Primer on Sexual Harassment. National Institute of Justice; October 1995. Retrieved from: https://www.ncjrs.gov/pdffiles/harass.pdf

Womens Justice Center, (2010). Why is Policing an Important Career for Women? Women in Policing. Retrieved from: http://justicewomen.com/police_women.html

Code of Conduct

Written for a newly merged company from one being publicly held and the other privately held by Crystal Morgan

The newly merged UWEAR/PALEDENIM corporation continuously pursues business endeavors which will be conducted in a “lawful, ethical, and moral manner in all countries in which we have the privilege to work” (Bradbury, 2015). While we acknowledge the fact that there are varying expectations across the world with which we conduct business regarding legal and cultural requirements, this code sets forth basic guidelines all employees and representatives are required to follow.

A committee, termed the Ethical Code of Conduct Committee, has been established to build upon, investigate, and pursue any pertinent consequences of violating this code. The Office of Ethics and Compliance maintains an open door policy to provide advice to any employee regarding the company code, to provide support prior to or during an investigation, and to receive then investigate reported violations. Reports or concerns may be submitted anonymously by turning in a written report or calling 1-800-555-1215 to complete a verbal report. However, it should be noted that investigations following an anonymous report are limited due to the nature of such a complaint. This office is made up of all employees holding a seat on the Ethical Code of Conduct Committee and is chaired by the company’s Vice President.

Professional Conduct

Employees of the new company will be expected to abide by both the letter of the law as dictated here as well as the spirit of the law indicated here.

The letter of the law is the literal translation of each rule, indicating clear and obvious guidelines.

One example of this can be found in rules regarding overtime and what types of action will result in disciplinary measures. To reduce the number of positions that will be eliminated now that the companies have merged, overtime will require approval of a manager and will only be issued when absolutely necessary.
Additionally, the new teams will be expected to work together and fill in where necessary, regardless of what they believe there responsibilities to be. Given such requirements, management will not assign an employee to undertake a role as a fill-in without prior training and the employee will be paid according the position’s pay-grade for the entire time period during which the employee is fulfilling said duties.

2. The spirit of the law is “broader, and reflects the intention behind the law. While usually obvious, this may not be explicitly stated” (Deolitte Development, LLC, 2013). The spirit of the law will wholly reflect the principles of corporate responsibility, integrity, respect, and quality.

Following the example of overtime, the Spirit of the Law indicates that when an employee has reached the threshold of scheduled hours and is asked to stay later by management, denial of such a request is not grounds for disciplinary measures and acceptance is completely voluntary. However, under the spirit of the law, employees that regularly work toward the good of the company will be acknowledged and rewarded accordingly but not punished for denying such request.
The spirit of the Law dictates that employees will step in to fill a need prior to being asked if time permits. Again, taking such action will be acknowledged and rewarded accordingly while not acting accordingly does not provide grounds for immediate disciplinary action.

3. Under the regulations of the U.S. Equal Employment Opportunity Commission, no potential or current employee will face discrimination of any kind on the basis of gender, race, religion, age, disability, genetic information or any other class of individual protected by the law. This law encompasses hiring, disciplinary action, firing, treatment between employees, promotion, as well as other interactions between individuals within the workplace.

Gifts and Entertainment

The company strives to gain and maintain clientele on the basis of quality, value, and integrity provided by services pertinent to the nature of the uniform supply business. Considering the international aspect of doing business there will be circumstances during which the question of whether to give or accept gifts and offers or entertainment is acceptable or not based on the client’s cultural expectations and company policy.

It is strictly against company policy as well as legal boundaries to socialize with stake holders during contract negotiations. This is non-negotiable and violation of this rule is grounds for immediate termination.
As a representative of this company, it is not permitted to accept or offer any entertainment that can be considered extravagant or inappropriate in nature. Invitations which are extended or accepted for entertainment purposes are only permissible if attendance serves a defendable business-related purpose and is reasonable in cost.
Nominal gifts are only acceptable if they are usual and customary to this business (i.e.: office supplies, calendars, coffee mugs, etc.).

“Gifts or entertainment should not be accepted or extended by you if they could be reasonably considered to:
Improperly influence any Deloitte U.S. Entity’s business relationship with, or create an obligation to, a client, supplier, contractor, or alliance.
Violate laws, professional standards and regulations, or this Code of Ethics and Professional Conduct.
Constitute an unfair business inducement.
Cause embarrassment to or negative impact upon our firm or any Deloitte U.S. Entity” (Deolitte Development, 2013)
If there is any question regarding entertainment and gift acceptance or offers, the situation should be presented to the Ethical Code of Conduct Committee representative who presides over the representatives department.

4. If a situation arises where the representative could be placed in the position of plausible accusations but denying the invitation will likely result in lost clientele, the representative is required to invite a third party along from this corporation to protect all parties involved and offer guidance when needed.

Ideally, this party would be fulfilled by said representative’s supervisor or manager but it is within the manger’s realm of responsibility to assign a proxy in their absence.

5. In addition to the policy being set forth regarding all gifts and entertainment, the representative of this business has the obligation to know and oblige by the client’s own policies related to this subject matter.

Relationships in the Workplace

A personal relationship between employees is a topic requiring strict obedience to the Letter of the Law. It is a well-established fact that an average American “spends 90,000 hours at work over their lifetime” (Business Insider, 2015). The true issue lies in how these relationships are expressed, the nature of the relationship, and the relationship between said individual’s positions within the company.

Personal relationships between employee’s holding equal positions in the workplace are not restricted. However, any expression of affection or discussion of what occurs in private is not to be displayed during company hours.
Personal relationships which may develop between any employee holding a position of superiority within the company over the other party engaged in said relationship are strictly forbidden with the following exceptions:

Legally Married Couples
Signed ‘Love Contracts’ which release the company from liability and explicitly delineate violations which could affect said employee’s standing with the company if this relationship interferes in any way with daily work. These may only be submitted after private interviews for both parties with their Human Resource Representative have been conducted to ensure this is a mutual decision barring any coercion.

3. If a relationship between the company’s representative and the client is seen as becoming more than professional, the representative will be interviewed regarding the nature of the relationship. In such a case, the representative will need to account for any questionable behavior and may need to provide proof. If the result of the inquiry is not conclusive, the client will be assigned to a different employee than the one in question. . Personal Relationships which develop between a company representative and a company client are also forbidden with the following exceptions:

If the representative wishes to engage in personal relations with any client of this company, they have the right to do so on their own time as an individual that is not representing the company. For this to occur without violation, the representative will need to file a request and receive an interview by their manager at which time they will be told that the client will be transferred to a different employee, a non-disclosure agreement will be required, and the nature of the relationship will be filed with the signature or both the employee and the client. The representative will be held strictly accountable for any violations of this agreement. If it is disclosed that discussion of this company has taken place between the employee and their former client once this has occurred, it will result in immediate termination.

Compliance Reporting

All employees hold a duty to report any suspected violation, fraudulent, illegal, or unethical issues by any colleague, client, supplier, contractor, alliance, or others associated with or doing business with this company (Deloitte Development, LLC., 2013). It is the responsibility of every single employee to report suspicious behavior as well as obvious violations through the proper channels and to cooperate with the investigation completely, without prejudice. Failure to do so will result in an immediate disciplinary measure.

To report suspicion of violations, it is ideal that the employee first report to their supervisor. If the employee feels this will compromise the investigation in any way (i.e.: employee reporting supervisor behavior or the supervisor is friends with the person of interest) then the employee is to report to the next level up on the corporate ladder.

The supervisor receiving the report is mandated to investigate unless they feel their involvement will create a conflict of interest, at which time they are to remand the report to the next level up on the corporate chain or another appropriate office.

2. An investigation will take place for any and all reports.

For all reports with any sort of legal barring, such as sexual harassment or theft, the accused will be placed on 48 hour paid leave during which time an emergency investigation will take place. This will include a member of upper management and a committee chair for the applicable office.

3. All investigations will consist of interviews with the reporter, the accused, and any witnesses which have been named by either party as well as any other parties which may be pertinent to the investigation.

4. Additionally, there will be financial and productivity audits, if applicable.

5. Upon conclusion of the supervisor’s investigation:

If the accused is found innocent of the claim, auditory records and written reports will be submitted to the Ethics Committee for record keeping purposes.
If suspicion still lingers by the investigator after the required steps have been taken, all auditory and written records will be submitted to the Ethics Committee for further investigation.
Any accused under paid leave due to a legal report will remain on leave until the investigation is completed by the Committee but pay will be removed. If the suspicion falls upon an executive level employee, the employee is expected to submit their report directly to the Ethics Committee.

6. All said reports will be submitted to the Stand Alone High Level Ethics Committee which is headed by the Vice President of this newly formed company and will be audited by the Corporate Social Responsibility Officer.

The committee is made up of current supervisors who fill a chair from each of the various departments within the company. Fulfilling such a role is the primary purpose for the employee assigned, making the supervisory position secondary to this post.

7. To ensure honesty at all levels of the committee, all members will hold an equal vote and only supervisors with seniority, employee recommendations, and no disciplinary history will be considered.

8. Given the extensive scope of investigations into ethical violations, a verdict will be handed down from the committee to the employee’s supervisor.

It is the supervisor’s responsibility to ensure the accused has been cleared of all suspicion among their co-workers as well as to the actual employee.
If the employee has been suspended pending investigation, they will receive both a phone call and a letter via registered mail informing them of the investigation (without witness names), the process, the decision and the reason the decision was made. The employee will either be informed of their return date to work or the official termination of employment date as well as any further legal action which may be pursued.
Any founded accusations of non-legal issues will be submitted to the employee’s official record.

Compliance with Laws and Regulatory Orders

The newly merged business is a publicly held, international company with a base in the United States, placing it under direct scrutiny from the public, US Securities and Exchange Commission, Federal Trade Commission, and many other governing bodies. These facts make it clear that there are laws and regulations which much be abided by for the sake of the company and its’ reputation.

Conducting business with other companies outside of our base state requires employees to understand and follow the guidelines set by the Uniform Commercial Code (UCC) when filing financial statements and securing loans through proper lien processes or face immediate disciplinary action.
Accusation of corruption or acceptances of bribes are historically difficult to defend against under the US Foreign Corrupt Practices Act which encompasses anti-bribery provisions for all United States corporations. “Corporate liability in the US is based on the principle of respondeat superior.

This principle renders a company liable for the wrongful acts of its employees committed during the course of their employment” (Norton Rose Fulbright US LLP, 2015). This is only one example of the many laws in place to prevent corruption and bribery in America’s corporation.
The majority of these laws hold the company responsible for actions of its employees and the plausible legal implications include “legal penalties… [which] can be severe, including legal fees and fines or sanctions by governmental agencies. The resulting negative publicity can cause long-range damage to the company’s reputation that is even more costly than the legal fees or fines” (Hill, 2015). There is no minimum monetary amount for gifts or threshold of value which must be met for accusation and consequential prosecution of illegal activity. Therefore, it has been concluded that guidelines expressed under ‘Gifts and Entertainment’ are to be strictly followed by all representatives of the company, regardless of the cultural basis of the client or business associate.

3. The newly implemented regulations under the Sarbanes-Oxley Act, Section 806 (SOX) which “prohibit publicly- traded companies from retaliating against employees who report various acts of wrongdoing to their employers” (Foti, 2013) will be enforced by the office of the Corporate Social Responsibility Officer, Sharon Reese.

This Act extends to protection of all employees who file a report intended to identify any fraud or violation of an SEC regulation, even if it does not impact shareholders.
Employees should be aware that even the most common or frivolous of claims will be investigated to the full extent of this offices ability and without prejudice.

4. To protect the company from any claims pertaining to the Equal Pay Act (EPA), employees will receive monetary compensation based on the category of pay-grade they fall into which is dictated by the responsibilities of the office they hold and no other factors.

Discipline and Termination

No disciplinary action will be taken without an official report being filed and investigation completed.
Even discipline taken against those who have failed their duty to report will first be submitted to an investigation with all extenuating circumstances taken into consideration.
The first founded investigation will result in a warning, the second founded investigation will result in suspension without pay, and a third founded accusation will result in termination of employment with the company.

The project assigned to ALTAP was to work with UWEAR and PALEDENIM throughout the merger by solving problems and resolving conflicts by proposing solutions which would benefit both companies while easing the transition between and within the companies until they become one. In order to complete this project, collected research exposed many obstacles that were not anticipated by either company. For example, it was discovered that some government regulations had been overlooked and neither company had a code of conduct in place, leaving both companies open to legal as well as reputable dilemma’s if these issues were not resolved immediately. Oddly, the fact that the same issues had presented themselves for both companies may have contributed to easing the transition for the merger. As a result of this, ALTAP was able to work with both UWEAR and PALEDENIM to institute new policy and procedures identical to each other prior to the actual merger. Due to the fear employees in each company harbored regarding the oncoming changes, the ability to deliver results prior to the polished merger likely helped to slowly integrate the changes and additions which needed to be made in an environment with which they were familiar. Post-merger, these would be policies that every employee would have become familiar with, making them commonalities that all the employees could relate to and possibly even rally around. Ultimately, the best possible deliverable for this client was established in stages. The initial stage included government regulations applicable to publicly held companies which had been overlooked in the past, including the Sabranes-Oxley Act, Section 806 for UWEAR. By establishing procedures to bring UWEAR into compliance with these regulations at the same time as PALEDENIM, ALTAP was able to slowly integrate the smaller company (PALEDENIM) into the world of a larger, publicly-held company prior to the actual time when the employees would be forced to work toward one goal as one team.

The shock of learning that neither company has an established code of conduct is offset by the benefits of establishing one based on the strengths exhibited in both cultures. In fact, the lack of an official code of conduct combined with two very different cultural environments probably worked in favor of the newly merged company. Initiating a code of conduct enforced by a new Ethical Code of Conduct Committee made up of supervisors from both companies and headed by the Vice President prior to the actual merger provides ALTAP the opportunity to take the best of what actually works from each company and integrate the policies together to make the most optimal work environment for all involved. Additionally, the research conducted proves that the Human Resources Manager from UWEAR, Sharon Reese, exhibits most of the preferred traits sought out in a successful Corporate Social Responsibility Officer. Neither of these companies currently employs such a position but the newly merged company could certainly utilize one.

The culture of Total Quality Management is one variable that has not been included at this point but would provide exceptional benefits to making this merger successful as well as establishing and maintaining a loyal workforce with minimal turn-over.

“Total Quality is a description of the culture, attitude and organization of a company that strives to provide customers with products and services that satisfy their needs...The key principles of TQM are as following: Management Commitment, Employee Empowerment, Fact Based Decision Making, Continuous Improvement, and Customer Focus” (Hashmi, 2015).

It is through the new code of conduct, company procedures, company culture, and policies that TQM can be achieved in the newly merged uniform company. The first step toward integrating such a culture is reassigning positions that would otherwise have been eliminated, as is witnessed in reassigning Sharon Reese from Human Resources to the role of Corporate Social Responsibility Officer. If employees realize their job is not on a cutting block and that management realizes the valuable part they play toward the corporation’s success then all parties involved have a better opportunity to achieve great heights.

Ultimately, the new code of conduct framework provides the standard policies which could be incorporated for UWEAR and PALEDENIM that can be utilized and is best delivered as both a document as well as initial training with required annual training as the code evolves over time. This final deliverable should provide the newly merged company with comprehensive coverage of regulations and policies which the company should build upon to mold into what the company needs for a truly successful finished product.

References

Bradbury, (2015). Cintas Corporation Code of Conduct for Vendors. Cintas Corporation; Director of Social Compliance. Retrieved from: http://www.cintas.com/company/CODE_OF_CONDUCT_2006%20.pdf

Business Insider, (2015). 15 Seriously Disturbing Facts About Your Job. Happiness at Work; Psychology Today. Retrieved from: http://www.businessinsider.com/disturbing-facts-about-your-job-2011-2?op=1#ixzz3ZspoNTSI

Foti, (2013). SOX And Whistleblowers - Any Fraud Will Do. Forbes. Retrieved from: http://www.forbes.com/sites/insider/2013/06/13/sox-and-whistleblowers-any-fraud-will-do/

Hill, B. (2015). The Advantages of Ethical Behavior in Business. Houston Chronicle; Business Ethics. Retrieved from: http://smallbusiness.chron.com/advantages-ethical-behavior-business-21067.html

Hoshmi, (2015). Introduction and Implementation of Total Quality Management (TQM). Six Sigma. Retrieved From: http://www.isixsigma.com/methodology/total-quality-management-tqm/introduction-and-implementation- total-quality-management-tqm/

Norton Rose Fulbright US LLP, (2015). Corporate Criminal Liability for Bribery Offences. Norton Rose Fullbright; Issue 05; February 2015. Retrieved from: http://www.nortonrosefulbright.com/knowledge/publications/125162/corporate-criminal-liability-for-bribery- offences

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