Anti-harassment and Anti-discrimination policy

Modis promotes a workplace that is free of harassment and discrimination based on

sex, race, color, religion, gender, national origin, sexual orientation, pregnancy, gender

identity, marital status, age, disability, veteran status, active military status, genetic tests

and information or an individual’s status as a domestic violence victim, or any other

applicable legally protected status.

Any such harassment and discrimination are prohibited and a violation of Modis policy.
They will not be tolerated in the workplace by anyone, including supervisors,
co-workers or non-employees. Any retaliation against someone reporting harassment
or discrimination or individuals cooperating with an

investigation is also prohibited and will not be tolerated.

For purposes of this policy,

“workplace” includes, but is not limited to, Modis work sites, client sites, Modis/client

sponsored social events, employee gatherings, and work-related travel.

Harassment definition

In general, harassment means persistent and unwelcome conduct or actions based on

a legally protected characteristic or activity. Sexual harassment is one type of

harassment and includes unwelcome sexual advances, unwelcome physical contact of

a sexual nature or unwelcome verbal or physical conduct of a sexual nature. It does not

refer to compliments of a socially acceptable nature.

Unwelcome verbal or physical conduct of a sexual nature includes, but is not

limited to:

• Unwelcomed touching

• The display of offensive sexually graphic materials

• “Quid Pro Quo” offers of employment perks or threats of adverse employment

decisions conditioned upon sexual favors

Harassment on any basis (race, sex, age, disability, etc.) exists whenever:

• There is a repeated making of unsolicited, inappropriate gestures or comments.

• The conduct unreasonably interferes with an employee’s work or creates an

intimidating, hostile, or offensive work environment

• Verbal conduct such as epithets, derogatory jokes, comments or slurs based on

Modis Employee Handbook

(a protected characteristic, whether made verbally, in writing, electronically, or

communicated in any other manner.)

Obligation to report

In order to take appropriate corrective action, Modis must be sufficiently aware of the

harassment, discrimination, or retaliation.

Modis will respond promptly to all complaints of harassment, retaliation, and/or

discrimination. The investigation will be conducted confidentially to the extent

reasonably possible.