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Sexual harassment is a form of harassment that is based on a person's sex, and includes requests <br />for sexual favors, sexual advances, or other sexual conduct where: <br />• The conduct is made as a term or condition of employment; <br />• The acceptance or refusal of the conduct is used as a factor in employment decisions; or <br />• The conduct creates an intimidating, hostile, or offensive environment. <br />Because Stifel strives to ensure a professional, respectful work environment, Stifel reserves the <br />right to respond to unprofessional or disrespectful behavior, even if not illegal, or no one has <br />complained about the behavior. <br />Effective leadership requires that managers talk with their Associates about their job performance. <br />Managers should be clear about how each Associate is performing and how the Associate's overall <br />behavior contributes to the workgroup's ability to deliver results. While these discussions may be <br />difficult, they should always be conducted with professionalism and respect. <br />The Firm also prohibits Associates from engaging in bullying behavior. Bullying is defined as <br />aggressive or inappropriate behavior, either direct or indirect, whether verbal, physical, or <br />otherwise, conducted by one or more persons against another, and which is repeated or is highly <br />likely to be repeated in the course of employment. The Firm will not tolerate bullying behavior. <br />The Firm provides periodic, mandatory anti -harassment and anti -discrimination training for all <br />Associates. Any Associate who fails to complete such training when provided will be subject to <br />disciplinary action. <br />If the Firm receives allegations of misconduct, it will conduct a fair, timely, and thorough <br />investigation that provides all parties an appropriate opportunity to participate, and reaches <br />reasonable conclusions based on the evidence collected. <br />The Firm prohibits retaliation, including but not limited to threats, whether verbal, written, or by <br />electronic means, against any individual who reports and/or provides any information concerning <br />unlawful discrimination, harassment, and/or other violations of Firm policies, rules, and standards <br />of conduct. Any Associate found engaging in retaliation will be subject to disciplinary action, up <br />to and including termination. <br />Non -Retaliation <br />It is unlawful and expressly against Firm policy for any Associate to retaliate against any other <br />Associate for making a complaint of discrimination or harassment, or for cooperating in an <br />investigation of any allegations of discrimination or harassment. Accordingly, individuals who <br />report incidents of discrimination or harassment in good faith, or who cooperate in an investigation <br />regarding any such allegations, will not be subject to any form of retaliation. <br />Any Associate who believes that he or she has been retaliated against, or who believes that he or <br />she has witnessed any form of unlawful retaliation, is required to report it immediately to his or <br />Effective 2019 <br />