Anti-Harassment Policy

This Anti-Harassment Policy is applicable to the ISMIE Mutual Insurance Company and all of its subsidiaries' (ISMIE) Board of Directors, policyholders, committee members, and participants at sponsored activities.

It is the policy of ISMIE that any type of harassment involving ISMIE staff, members of the Board of Directors, policyholders, or others by ISMIE policyholders or other attendees at or in connection with ISMIE meetings, including but not limited to seminars, dinners, receptions and social gatherings held in conjunction with ISMIE meetings, is prohibited conduct and is not tolerated.

ISMIE has zero tolerance for harassing conduct at any time where ISMIE policyholders and staff are conducting ISMIE business. This zero tolerance policy applies to annual meetings, meetings of ISMIE committees, and other leadership entities, as well as all ISMIE-sponsored events.

Definition

Harassment consists of any unwelcome conduct whether it be verbal, physical or visual that is offensive, denigrates or shows hostility or aversion toward an individual because of his/her race, color, religion, sex, sexual orientation, gender identity, national origin, age, disability, marital status, citizenship or other protected group status, and that: (1) has the purpose or effect of creating an intimidating, hostile or offensive environment; (2) has the purpose or effect of unreasonably interfering with an individual’s participation in meetings or events of ISMIE or any ISMIE entity; or (3) otherwise adversely affects an individual's participation in such meetings or events or, in the case of ISMIE staff, such individual’s employment opportunities or tangible job benefits.

Harassing conduct includes, but is not limited to: epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes; and written, electronic, or graphic material that denigrates or shows hostility or aversion toward an individual or group and is displayed on ISMIE’s premises, at the site of any ISMIE meeting or event, or circulated in connection with any ISMIE materials.

Sexual Harassment

Sexual harassment also constitutes discrimination, which is unlawful and is absolutely prohibited. For the purposes of this policy, sexual harassment is any form of aggressive, offensive or intimidating conduct based on someone's sex or gender and includes, but is not limited to: (1) unwelcome sexual advances, requests for sexual favors or other verbal or physical conduct of a sexual nature; (2) written or pictorial content of a sexual nature; and (3) conduct directed to an individual due to the individual’s sex or gender that creates an intimidating, hostile or offensive environment or otherwise unreasonably interferes with an individual's participation in meetings or events of any ISMIE entity or, in the case of ISMIE staff, such individual's work performance, by instances of such conduct.

Sexual harassment may include such conduct as explicit sexual propositions, sexual innuendo, suggestive comments or gestures, descriptive comments about an individual's physical appearance, electronic stalking or lewd messages, displays of foul or obscene printed or visual material, any unwelcome physical contact or impeding or blocking space or movement.

No Retaliation Policy

There will be no retaliation or discrimination against any individual, who reports harassment, submits a complaint, reports an incident witnessed, or participates in any way in the investigation of a harassment complaint. Each complaint of harassment or retaliation will be promptly and thoroughly investigated. Anyone found to have retaliated against an individual because of participation in the complaint or investigative process shall be subject to discipline.

Reporting and Investigation Process

1. Reporting a Complaint

Any persons who believe they have experienced or witnessed conduct in violation of this Anti-Harassment Policy during any ISMIE meeting, event or associated function should promptly notify the Chairman of the Board or the ISMIE Chief Compliance Officer.

Any persons who believe they have experienced or witnessed conduct in other activities associated with ISMIE (such as meetings of ISMIE councils, committee sections, or task forces) in violation of this Anti-Harassment Policy should promptly notify the Chairman of the Board or the ISMIE Chief Compliance Officer.

The ISMIE Chief Compliance Officer can be contacted in person, by telephone, or in writing at:

Robert John Kane
Chief Compliance Officer
312-580-2477
robertkane@ismie.com     
20 North Michigan Avenue, Suite 700
Chicago, IL 60602

2. Investigations

Investigations of harassment complaints will be conducted by the Chief Compliance Officer or designee. Each complaint of harassment or retaliation shall be promptly and thoroughly investigated. The Chief Compliance Officer will document all of the pertinent information regarding the complaint and involve any necessary designees from the Compliance Division, the Chairman of the Board, and the Legal Services Division. All persons involved in the investigation shall preserve all potential evidence, which includes making copies of all relevant documents and data, including but not limited to logs, emails, other communication, witness statements, witness lists, and other tangible evidence.

The Chief Compliance Officer will (a) use reasonable efforts to minimize contact between the complainant and the respondent during the pendency of an investigation and (b) provide the alleged respondent an opportunity to respond to allegations.

Upon receiving a complaint of harassment consideration will be given as to whether qualified investigators need to be engaged based upon the facts and the jurisdiction involved. Outside counsel may be consulted to determine a course of action prior to the referral of the complaint to appropriate disciplinary authority or law enforcement authorities, if appropriate. Upon the completion of the investigation, a report shall be prepared. Based on its investigation and the findings in the report, the Chief Compliance Officer will make a determination as to whether a violation of this Anti-Harassment Policy has occurred. The report shall be reviewed, evaluated and any preventative steps to assist in preventing future harassing activity shall be updated and implemented.

3. Disciplinary Action

If the ISMIE Chief Compliance Officer determines that a violation of this Anti-Harassment Policy has occurred, the Chief Compliance Officer shall notify the Chairman of the Board that such violation occurred and determine the appropriate disciplinary and/or corrective action. If a member of the ISMIE Board, committee, or a policyholder is determined to have violated this Anti-Harassment Policy, then the ISMIE Chairman of the Board shall determine the disciplinary and/or corrective action in consultation with the Chief Compliance Officer. If a non-policyholder or non-ISMIE party is the respondent, the Chief Compliance Officer shall refer the matter to the appropriate legal authorities, if appropriate.

Disciplinary and/or corrective action may include, but is not limited to, expulsion from the relevant ISMIE associated meeting or activity, participation in required training or education, censure, or revocation of membership.

4. Confidentiality

To the fullest extent possible, ISMIE will keep complaints, investigations and resolutions confidential, consistent with usual business practice. All individuals who make a report are assured that confidentiality will be maintained at all times insofar as is legal, practical, and consistent with a reasonable investigation. In accordance with the Non-Retaliation Policy, ISMIE will not retaliate or take adverse action against individuals who submit good faith complaints, regardless of whether the report is ultimately substantiated.

(5/29/19)