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Confidential — for Internal Use Only

Associate Handbook August 2016 |

26

STEP 2

All complaints will be investigated in an impartial, fair, appropriate and timely manner.

STEP 3

Both the complainant and the alleged harasser will be informed of the results of the investigation.

STEP 4

If the complaint has been determined to be valid, the HR manager will follow up with the person making the

complaint to ensure that the harassment or discrimination has stopped or the situation has been addressed.

Confidentiality

All complaints of discrimination, harassment, or retaliation will be handled as confidentially as possible.

Information relating to an investigation will only be disclosed on a need-to-know basis. All parties involved in

the complaint and the investigation will be instructed to maintain confidentiality regarding the complaint and

their participation in the investigation so far as consistent with applicable law.

Penalties for Discrimination, Harassment or Retaliation

Appropriate discipline, up to and including termination, will be imposed for any violation of this policy.

Questions about the Harassment-Free Work Environment Policy or ICMA‑RC’s enforcement of it should be

referred to your HR manager.

INTERACTIONS WITH OTHERS

Maintaining the Confidences of Other Parties

Associates must not divulge to ICMA‑RC or another ICMA‑RC associate any confidential or proprietary

information that may expose ICMA‑RC to potential liability. You should also maintain confidential

information to which you may have access during the course of business.

Recording/Eavesdropping on Conversations

To facilitate open communication and eliminate the unsettling effect to the expression of views that may

exist when one person is concerned that his or her conversation with another is being secretly recorded, and

that recording may inhibit spontaneous and honest dialogue especially when sensitive or confidential matters

are being discussed, and to protect client financial and personal information, no associate may secretly or

otherwise tape, record, videotape or transmit with camera phones or any electronic or other equipment any

conversation, communication, activity or event involving ICMA‑RC or its associates, customers or clients, or

other individuals with whom the corporation does business unless expressly authorized by the President/CEO,

General Counsel or head of Human Resources.

However, ICMA‑RC reserves the right to monitor and record business-related telephone calls to and from our

Call Centers for performance and to ensure quality service. Also note that some training sessions or webinars

may be recorded for future use.