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EQUAL EMPLOYMENT OPPORTUNITY AND POLICY PROHIBITING HARASSMENT, DISCRIMINATION, AND RETALIATION

We at PatientPop have a responsibility to our employees to foster and promote a workplace both inside and outside of the office where all individuals can interact cooperatively and collaboratively in a healthy, safe, and fun work environment. We want to continue to make PatientPop a great place to work, and we expect individuals working at or with PatientPop to uphold our values and exercise respect, compassion, and civility in all work and work-related interactions. We want all individuals to feel safe and encouraged to bring their authentic selves to work, and in order make this possiblet, PatientPop wants to make clear that as a Company we have a legal responsibility to maintain a work environment that is free from unlawful harassment, discrimination, and retaliation and we do not tolerate any known discrimination, harassment or retaliation of any kind.

At PatientPop, we are committed to providing a safe and positive work environment where everyone can be successful. To foster and promote this environment, all employees should expect, and have a responsibility to uphold, a culture and work environment that is free from harassment, discrimination, misconduct, and retaliation (see specific definitions of these terms beginning below). This policy applies to conduct by and towards different types of individuals, including but not limited to, all employees (employees, co-workers, managers, executives, interns), non-permanent workers (temporary, 1099 consultants, vendors), customers/practice employees and other third parties. For information on PatientPop’s anti-discrimination stance on customers/practices, please review PatientPop’s Policy on Interacting with Discriminatory Customers. This EEO policy applies to conduct that takes place at work, work-related events like offsites and work trips, work-related social gatherings like holiday parties, and other company events.

Employees who are discovered to have violated this policy are subject to disciplinary action, which may include: coaching, training, verbal or written warning, affected performance review ratings, or termination of employment.

Non-permanent workers, visitors, candidates and all other third parties are also expected to abide by this policy and behave appropriately when at work and company events and interacting with employees or other non-permanent workers. If non-permanent employees are found to have violated this policy, it may result in actions such as a removal from the premises or event, or termination of a business contract. If you observe behavior by a third party towards our employees or our non-permanent employees onsite at the office, during work, or during a work related event, please use your voice and report the incident via the appropriate avenue (see reporting a concern below).

PatientPop may also, at its own discretion, take into account and review allegations of behavior that occur outside the course of employment, to the extent permitted by law, where PatientPop determines such conduct may significantly affect or have a negative impact on the workplace and its members.

This policy outlines issues of conduct in relation to harassment, sexual harassment, discrmination, and other problematic conduct. This policy also outlined where these conduct issues can be reported, how concerns are addressed and handled, and describes PatientPop’s policy against retaliation of any kind.

Harassment

Harassment is unwelcome, unlawful conduct (physical, verbal or non-verbal) based on an individual’s protected status that creates an environment that is hostile, toxic, intimidating, abusive, or where experiencing such conduct is a condition of employment. PatientPop does not tolerate unlawful harassment by any individuals. Harassment can vary in severity, and can be one severe incident or a series or less severe incidents. Harassment can range from extreme forms such as violence, threats or physical touching to less obvious actions like ridiculing, teasing, jokes, or repeated microaggressions based on a co-worker’s protected status. Harassment can also be sexual in nature, which is addressed separately below. Examples of harassment may include:

  • Verbal harassment
    • Insensitive or derogatory joke;
    • epithets, slurs, negative stereotyping;
    • unwelcome remarks about an individual’s body, color, physical characteristics, appearance, or protected status;
    • demeaning or ridiculing comments;
    • threatening, intimidating, humiliating, or hostile acts that relate to a protected characteristic;
    • repeated microaggressions;
  • Physical harassment
    • physical interference with normal work;
    • impeding or blocking movement;
    • staring or leering at a person’s body
    • unwelcome physical contact;
    • assault or violence;
  • Psychological Harassment
    • Bullying or ostracizing behavior
  • Visual harassment
    • displaying or sharing offensive or obscene photographs, calendars, posters, cards, cartoons, memes, .gif files, Slack emoticons, e-mails, drawings, animations, gestures, unwelcome notes/letters, and any other written or graphic material that denigrates or shows hostility or aversion towards an individual because of protected characteristic that is placed on walls, bulletin boards, or elsewhere on the employer’s premises, on virtual work spaces (Slack, e-mail, Chatter, instant messenger, blogging, web posting, etc.), or circulated in the workplace;
    • viewing on Company computers or networks materials that are harassing or discriminatory in nature

This list is illustrative only, and not exhaustive. No form of harassment will be tolerated at PatientPop. All employees have an obligation to comply with this policy, and if you observe or become aware of conduct that may be in violation of this policy, you should immediately report it. PatientPop may consider conduct to be in violation of this policy even if it does not legally qualify as unlawful harassment under the law.

Sexual Harassment

Sexual harassment is unwelcome, unlawful conduct (physical, verbal or non-verbal) that is sexual in nature. There are two distinct categories of sexual harassment, and examples of sexual harassment include:

  • Quid Pro Quo - When an individual’s submission to or rejection of unwelcome sexual conduct is used as a basis for employment decisions affecting that individual
    • Making unwanted sexual advances and requests for sexual favors;
    • Using the acceptance or rejection of sexual advances as a basis for employment decisions;
  • Hostile Environment - When unwelcome sexual conduct unreasonably interferes with an individual’s job performance or creates an intimidating, hostile, or offensive working environment, even if it does not lead to tangible or economic job consequences.
    • displaying or sharing offensive or obscene photographs, calendars, posters, cards, cartoons, memes, .gif files, Slack emoticons, e-mails, drawings, animations, gestures, unwelcome notes/letters, and any other written or graphic material that denigrates or shows hostility or aversion towards an individual because of protected characteristic that is placed on walls, bulletin boards, or elsewhere on the employer’s premises, on virtual work spaces (Slack, e-mail, Chatter, instant messenger, blogging, web posting, etc.), or circulated in the workplace;
    • viewing content that is sexual in nature on Company computers or networks;
    • questions about a person’s sexual practices, or gossiping about sexual experiences;
    • Unwanted comments about physical appearance;
    • Jokes, pranks, signs, and discriminatory comments that are sexual in nature;
    • staring or leering at a person’s body
    • Unwanted physical or verbal contact or advances or any kind

Sexual harassment can occur between same-sex individuals or opposite sex individuals. Sexual harassment is unlawful whether it involves co-worker harassment, harassment by a supervisor or manager, or by persons doing business with or for the Company. Sexually harassing conduct doesn’t need to be motivated by sexual desire to be considered unlawful.

When considering whether a behavior qualifies as harassment or sexual harassment, PatientPop considers whether a reasonable person would conclude that the behavior created a hostile or offensive environment. “I didn’t mean it that way”, “it was a joke” and “I/we were drinking” are not excuses for inappropriate conduct. We hold PatientPop employees to the same standard regardless of their impairment due to alcohol.

Discrimination

Discrimination is behavior towards an individual on the basis of a protected status that causes an individual’s employment to be adversely affected. Discrimination can include taking actions against someone based on a protected class such as: intentionally reducing someone’s performance review score, reducing a bonus or salary, not nominating someone who is eligible for a promotion, putting someone on a performance improvement plan, or moving someone off of certain projects or customers. These examples are illustrative and not exhaustive.

Protected Status

PatientPop Inc. is an equal opportunity employer and makes employment decisions on the basis of merit and business needs. The Company does not unlawfully discriminate or tolerate harassment by any person, on the basis of a protected status. Protected status may include characteristic (actual or perceived) like:

  • race, color, ethnic or national origin (including, but not necessarily limited to, language use and possession of a drivers’ license issued to undocumented persons unable to obtain a drivers’ license under federal law);
  • religion (including, but not necessarily limited to, religious creed, dress, and grooming practices);
  • citizenship, immigration status, nationality, or ancestry;
  • political activity or affiliation;
  • marital status;
  • age;
  • sexual orientation, sex, gender identity, gender expression, transgender status, gender, pregnancy, or taking or requesting statutorily protected leave;
  • Victim of Domestic violence or sexual assault/stalking
  • military and veteran status;
  • mental or physical disability*, medical condition, genetic information of the employee or a family member;
  • or any other characteristics protected under applicable federal, state, or local laws

*To comply with applicable laws ensuring equal employment opportunities to qualified individuals with a disability, PatientPop will make reasonable accommodations for the known physical and/or mental disability of an otherwise qualified individual unless undue hardship would result.

Retaliation

PatientPop prohibits retaliation against an individual for raising a concern or violation of this policy or law, or for participating in any workplace investigation. Retaliation can occur towards any person, including but not limited to co-workers, managers, and third parties, for reporting any incidents of harassment or discrimination (perceived or otherwise), or for participating in any investigation of incidents of harassment or discrimination. Retaliation of any kind is strictly prohibited.

Any report of retaliation by the one accused of harassment or discrimination, or by co-workers, supervisors, or managers, will also be promptly and thoroughly investigated in accordance with the Company’s investigation procedures outlined below (Workplace Invesitgations). If a complaint of retaliation is substantiated, appropriate disciplinary action, up to and including discharge termination of employment, may be taken. If you report a concern and feel that you are experiencing retaliation, you should report this concern and it will be looked into.

Reporting a Concern & Investigations

If you observe an individual violating this policy and would like to voice a concern, this section outlines the reporting procedure and investigation information.

Addressing/Reporting a Concern

All PatientPop employees have a responsibility to help promote a workplace that is free from harassment, discrimination, and retaliation. If you believe you have been subject to harassment, discrimination, or retaliation of any kind or any conduct that violates this policy, or you have observed this problematic conduct in others at PatientPop, you have an obligation to report the facts of the conduct via one of the following channels:

  • You can talk to your manager or a second or third-tier manager
  • You can talk to another manager not in your reporting line
  • You can talk to someone on the HR team
  • You can talk to an executive or any member of the leadership team

The important thing is that you bring the matter to the PatientPop’s attention promptly so that any concern of harassment or discrimination can be investigated and addressed appropriately.

Concerns may be relayed verbally or in writing. When addressing a conduct concern, please include as much information and specific detail as possible. The more information you provide, the better and more poignantly we can investigate the concern.

We want PatientPop to continue to be a great place to work, and we take your concerns seriously when they are voiced. If you observe or experience something that doesn’t feel right, please speak up and address it.

Obligations for Managers

Managers have a responsibility to foster and uphold a safe, respectful and inclusive work environment on their teams and across the company. If you are a manager, you must report any complaints of misconduct to Human Resources or the as soon as possible so the Company can attempt to resolve the concern. Managers may be subject to disciplinary action if they actively engage in or ignore behavior that is in violation of this policy. Reporting concerns or violations of this policy in a timely manner is important, and managers should try to relay or report any conduct concerns as soon as possible. Obstructing or delaying reported conduct can result in disciplinary action.

What happens after I report a concern?

After you bring a concern to the attention of a manager or HR, the concern will be promptly and thoroughly investigated. Each and every concern is different, but in general these are some of the measures that will be taken after you report a workplace concern. If you reported the issue to a manager, that manager will loop in HR. HR will likely need to speak with you to gather information, and it is their responsibility to remain impartial, respectful, and professional during this process. It is possible that from the initial conversation HR may need to speak with more individuals (witnesses, etc.), and employees/managers are legally required to comply with a workplace investigation and provide truthful statements. If there are documents, resources, or other data that needs to be reviewed to provide more context on the workplace concern, those resources will be evaluated during the investigation as well.

If there are things that may make you more comfortable during the investigation process, please express those to HR or your manager. Once the members looking into your workplace concern have completed their investigation, they will work with the appropriate business leaders to recommend disciplinary action, which can include but is not limited to, coaching, training, written warnings, impact on performance ratings or, demotion, suspension, or termination of employment. Once action has been taken, HR will follow up with you to let you know the result of the investigation and if any policies were violated and the overall outcome of investigation.

Workplace Investigations

All claims will be promptly and thoroughly investigated by qualified personnel in a fair and impartial manner. Investigations will be documented and tracked, and all information disclosed during the course of the investigation will remain confidential, except as necessary to conduct the investigation and take any remedial action, and in accordance with applicable law. Oftentimes when employees approach HR with a concern, they ask that things be kept confidential. We cannot guarantee absolute and complete confidentiality when dealing with addressing workplace concerns, but information will only be disclosed on a strictly need to know basis as is required to carry out the investigation properly. Managers will only be informed on a need to know basis.

All employees and supervisors have a duty to cooperate in the investigation of alleged harassment or discrimination. In addition, failing to cooperate or deliberately providing false information during an investigation shall be grounds for disciplinary action, including termination of employment. At the conclusion of its investigation, if the Company determines a violation of policy has occurred, it will take effective remedial action to commensurate with the severity of the offense. This action may include disciplinary action against the accused party, up to and including termination. Steps will be taken, as reasonable and necessary, to prevent any further violations of policy.

Additional Agency Information

In addition to the Company’s internal complaint procedure, employees should also be aware that the federal Equal Employment Opportunity Commission (EEOC) and applicable state agencies, including the California Department of Fair Employment and Housing (DFEH), the New York Division of Human Rights, and the Nevada Equal Rights Commission (NERC) investigate and prosecute complaints of harassment, discrimination, and retaliation in employment.

Information about the EEOC complaint procedure can be found on their website (www.eeoc.gov). You may also contact the EEOC at:
1-800-669-4000 (English)
1-800-669-6820 (TTY)

Information about the DFEH can be found on their website (www.dfeh.ca.gov). You may also contact the DFEH at the following numbers if you are calling within California:
1-800-884-1684 (English)
1-800-700-2320 (TTY)

Information about the NERC can be found on their website (http://detr.state.nv.us/nerc.htm). You may also contact the NERC at:
(702) 486-7161 (Las Vegas)
(775) 823-6690 (Northern Nevada)

Information about the New York Division of Human Rights can be found on its website (www.dhr.ny.gov/). You may also contact the New York Division of Human Rights at:
1-888-392-3644

Modification

The Company can modify this policy unilaterally at any time without notice. Modification may be necessary to maintain compliance with local, state, and federal laws and/or accommodate organizational changes within the Company.

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