This Equal Employment Opportunity (EEO) Statement on behalf of ACG- Achilles  Consulting Group (EAVA), EAV -A reaffirms the company’s policy and commitment to  providing equal employment opportunities for all team members, job applicants and in all employment decisions.

The company recruits, hires, trains, and ensures that all personnel decisions and  actions, including but not limited to compensation, benefits, transfers, promotions,  layoffs, returns from layoff, discipline, terminations, company-sponsored training,  education, tuition assistance and social and recreational programs are administered  without regard to:
• Race
• Color
• Religion
• Sex
• Sexual orientation
• Gender identity
• National origin
• Age
• Veteran Status
• Physical or Mental disability (except where the disability prevents the individual  from being able to perform the essential functions of the job and cannot be  reasonably accommodated in full compliance with the law)


All team members are expected to comply with this EEO Statement. Managers and  supervisors who are responsible for meeting business objectives are expected to  cooperate fully in meeting Kokosing’s equal employment opportunity objectives and  their overall performance will be evaluated accordingly.

If you believe or suspect that you are being treated in violation of this EEO policy, you  must immediately contact your HR Representative, your supervisor, or any other  member of management so that an investigation can immediately occur. The company  will neither condone nor tolerate any act of discrimination and/or any violation of this  EEO policy. Similarly, the company will not tolerate any act of retaliation against an  individual who makes a complaint under this policy or aides in any investigation of such a complaint. Any team member found to have violated this policy in any manner will be  subject to disciplinary action, including discharge.

POLICIES & PROCEDURES FOR PREVENTING SEXUAL & NON-SEXUAL HARASSMENT

The company prohibits:
• sexual harassment of any team member either in the workplace or in any work related setting.
• harassment based on race, color, religion, sex, sexual orientation, gender identity,  national origin, age, veteran status, or disability.


The company will not tolerate any team member conduct or activity, or display of  graphic material, that has the purpose or effect of violating this policy. In addition,  within the limits of the company’s power and control, the company will attempt to prevent any non-team member (including, but not limited to, anyone working for another  contractor, an inspector, or a supplier) from repeating any reported conduct or activity,  or display of graphic material, that has the purpose or effect of causing harassment  either in the workplace or in any work-related setting.

DEFINITION OF HARASSMENT

It is sexual harassment for any manager or supervisor (or any other team member with the power to affect another team member’s terms or conditions of employment to:
• promise a raise, a promotion, or any other job benefit to another team member.
• threaten another team member with some kind of adverse action, to obtain sexual favors from that team member.


It is also sexual harassment for any team member to engage in any conduct or activity,  or to display any graphic material, that fits the following descriptions:
• it is sexual in nature.
• it is unwelcome.
• it reasonably interferes with a team member’s work performance or creates a  hostile or offensive work environment.


Non-sexual harassment is based on a team member’s race, color, religion, sex, sexual  orientation, gender identity, national origin, age, veteran status or disability and shows hostility toward a team member and unreasonably interferes with a team member’s work performance or creates a hostile or offensive work environment.

The conduct, activity and graphic materials that frequently cause harassment include, but are not limited to, the following:
• Abusive and vulgar comments
• Insults
• Obscene name-calling
• Slurs and off-color jokes
• Sexual advances, invitations, and inquiries
• Obscene gestures
• Physically threatening acts, such as blocking an individual’s movement.
• Unwelcome physical contact
• Sexual pin-ups, posters, photographs, calendars, cartoons, drawings, or graffiti
• Persistent prying into someone’s personal life.
• Following an individual


All such conduct, activity and graphic material can cause harassment. They violate this  policy if they have the purpose or effect of unreasonably interfering with another Team member’s work performance, or they create an intimidating, hostile or offensive work  environment.

PROCEDURE FOR REPORTING HARASSMENT

The company not only insists on a work environment free of all harassment, but also  urges all team members actively to support the company’s effort to create and maintain  a positive work environment. The company encourages any team member who believes that he or she is being  harassed to promptly tell the harasser to stop. The company also encourages any team  member who believes that he or she is being harassed to report the objectionable  conduct, activity and/or graphic material to his or her immediate superior or to one of  the following individuals by calling 1 (985).630.7307

The company encourages all team members to report harassment promptly, so that the  company can respond in a timely fashion. The person to whom the team member  reports harassment should write a brief description of the problem. The team member  should make his or her own written notes at the time of the problem, or shortly  thereafter, to help the person prepare and support the report.

Any manager or supervisor who receives a report of harassment, or who suspects  harassment for other reasons, shall have an affirmative duty to contact one of the  company officials responsible for investigating whether harassment is occurring.

Any team member who observes harassment or suspects harassment is occurring is  urged to report the activity to his or her supervisor or one of the company’s officials  responsible for investigating harassment complaints.

COVERED INDIVIDUALS

This policy applies to all the company’s team members. Although it has limited power  and control over individuals working for other employers, and an equally limited ability  to discipline such persons, the company also intends this policy to apply to anyone else  who may be able to harass one or more of the company’s team members in the  workplace or work-related setting.

The company encourages any team member who believes that he or she is being  harassed by a non-team member to report that fact to his or her immediate superior, or  to one of the designated individuals.

The company will also apply this policy to any outside complaints from other employers  or their Team members about the conduct or activity of any one or more of the  company’s team members in the workplace or any work-related setting.

INVESTIGATIONS

The company will promptly investigate and attempt to resolve all reports of  harassment. The scope and other details of each investigation will depend on the  nature of the report and the related circumstances. In each instance, the company will  handle the matter with as much discretion as the circumstances permit, in an effort to protect the privacy of the persons involved.

All managers and supervisors, including but not limited to the company’s investigators,  shall keep all reports of harassment confidential, except as necessary to investigate and resolve such matters, and/or to respond to any related legal or administrative  proceedings. Because of the sensitive nature of these matters, the company also encourages all team members to help keep all reports, investigations, and related  matters confidential. Two individuals will be designated to conduct the investigation.

While a team member’s wishes will be taken into consideration, the investigators have  an independent duty to conduct a thorough investigation as they see fit. In any event,  the investigator will keep the reporting team member and the alleged harasser informed  of the progress of their investigation, and the investigator will notify both parties of any  final decisions.

Among the first steps investigators will normally take are the following:
• Inform the reporting team member of his or her rights under this policy.
• Inform the reporting team member of the company’s procedures for investigating  and resolving reports of harassment and/or retaliation.
• Confirm the reporting team member’s name and position.
• Confirm the alleged harasser’s name and position.
• Check the company’s records to determine whether the reporting team member or the alleged harasser has complained of harassment or been charged with  harassment in the past.
• Upon interviewing the alleged harasser, remind him or her of the company’s  policy on any retaliation against a team member for reporting harassment.


Among the facts that the investigator will normally try to gather are these:
• The frequency and type of the alleged harassment and, if possible, the exact  dates, times, and locations
• Whether there were witnesses to the alleged harassment, and, if so, what they  observed
• How the reporting team member responded to the alleged harassment


Whether the reporting team member has talked to any other team member about the  alleged harassment – and, whether the team member has talked to any other manager  or supervisor, a This Equal Employment Opportunity (EEO) Statement reaffirms the company’s policy and commitment to providing equal employment opportunities for all  team members, job applicants and in all employment decisions.

The company recruits, hires, trains, and ensures that all personnel decisions and  actions, including but not limited to compensation, benefits, transfers, promotions,  layoffs, returns from layoff, discipline, terminations, company-sponsored training, education, tuition assistance and social and recreational programs are administered  without regard to:
• race
• color
• religion
• sex
• sexual orientation
• gender identity
• national origin
• age
• veteran status
• physical or mental disability (except where the disability prevents the individual  from being able to perform the essential functions of the job and cannot be  reasonably accommodated in full compliance with the law)

All team members are expected to comply with this EEO Statement. Managers and  supervisors who are responsible for meeting business objectives are expected to cooperate fully in meeting Kokosing’s equal employment opportunity objectives and their overall performance will be evaluated accordingly.

If you believe or suspect that you are being treated in violation of this EEO policy, you  must immediately contact your HR Representative, your supervisor or any other  member of management so that an investigation can immediately occur. The company  will neither condone nor tolerate any act of discrimination and/or any violation of this  EEO policy. Similarly, the company will not tolerate any act of retaliation against an  individual who makes a complaint under this policy or aides in any investigation of such  a complaint. Any team member found to have violated this policy in any manner will be  subject to disciplinary action, including discharge.

INFORMATION SHARING

Unless otherwise stated in this Privacy Policy, ACG / EAVA may disclose your personal data to another entity (i) for purposes of outsourcing one or more of its services or the functions described above; (ii) to confirm or update information provided by you; (iii) to inform you of Events, information about its services, and other important information, (iv) for other purposes disclosed at or before the time the information is collected, or (v) for purposes you have explicitly consented to. In cases where information is shared, we will seek assurances where practicable that the receiving party has implemented appropriate technical and organizational measures to ensure the security of your personal data. The legal basis for the transfer of your personal data under data protection legislation will be that it is necessary for the fulfillment of our engagement, that it is necessary for the purpose of our legitimate interest to provide you with our services and run our Events in the most efficient way, or, when you have consented to the sharing of data, your consent.​

We may provide your personal data to our affiliates, including without limitation to the extent permitted by applicable law. For this purpose, we may transfer the information you provide outside your country to another country that does not have similar data protection legislation and may provide a lower level of protection for your information. We may share your Personal Information with vendors we have hired to provide services for us where it is necessary for the service. We are permitted to share your personal data with our affiliates or vendors where they process data on our behalf and with whom we have concluded a contract on commissioned data processing. We may also release Personal Information about you if you explicitly consent to the sharing of your data, or if we are required or authorized by law, or if we reasonably believe that the disclosure is necessary in order to (a) fulfill a government request; (b) conform with the requirements of law or to comply with legal process served on us; or (c) protect or defend our legal rights or property or third party licensors of any material on the Website.

RESULTS

Once the investigator finishes looking into the matter, he or she will communicate the  results of the investigation and any related decision to the reporting team member and  to the alleged harasser. If a violation of this policy is found, the investigator will:
• communicate that finding to the reporting team member (and, if someone else,  to the victim of the harassment)
• inform the victim of the remedial steps and the disciplinary action that the  company intends to take.
• inform the harasser of the results of the investigation. Unless it terminates the harasser, the company will, in addition to any other disciplinary action, direct a  letter to the harasser informing that individual that the company is likely to terminate their employment if they are later found to have engaged in any further  harassment.


If no violation of the policy is found, the investigator will:
• communicate that fact to the reporting team member and to the alleged  harasser.
• remind both parties that this policy remains in full force.
• inform the parties that the company will retain a record of this investigation, and  that the record may be used in any future investigations involving the same  individuals.

Investigators will weigh the credibility of different team members. Investigators will not  automatically decline to find a violation of this policy because there were no witnesses  to the alleged conduct or activity and/or the alleged harasser denies any wrongdoing.

REMEDIES

The company will provide a prompt and effective remedy for any harassment that it can verify. Remedies may include:
• Transfer the harasser to a new position where he or she will have little or no  further contact with the victim.
• If the victim agrees, transfer the victim to an equivalent position where he or she may limit or avoid contact with the harasser.
• Require the harasser to apologize to the victim.
• Remind all witnesses not to discuss the details of the investigation or identify  anyone who may have been involved.
• Refer victim to Team Member Assistance Program
• Refer harasser to Team Member Assistance Program

DISCIPLINARY ACTION

The company will also take disciplinary action against any team member found to have violated this policy. At a minimum, the company will reprimand such a team member.  Additional discipline may include, but need not be limited to:
• Written reprimand.
• Temporary suspension without pay.
• Transfer (to an equivalent or less desirable position)
• Discharge


The company may discharge a first offender, depending on the nature and severity of  the harassment. The penalty for a second offense will be more severe than the penalty  for a first offense, and discharge is a likely result.

RETALIATION

No manager, supervisor or other team member may in any way retaliate against any  other team member for making a report of sexual harassment, or a report of any other  harassment based on race, color, religion, gender, national origin, age or disability. The company will treat retaliation by the alleged harasser or any other team member as a  separate and independent violation of this policy. If the company finds that a team  member retaliated, the company will take disciplinary action against that team member. The procedure for reporting retaliation is the same as the procedure for reporting  harassment. The company strongly encourages team members to report any retaliation  immediately.

FALSE ACCUSATIONS

The company recognizes that false accusations of harassment can have serious  effects on innocent persons. If an investigation leads the company to conclude that a  team member has knowingly made false accusations of harassment, the company may  also take disciplinary action against that team member.