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her supervisor. In the event that this is not possible for any reason, or the Associate is <br />uncomfortable reporting the conduct to his or her supervisor, the Associate must report the conduct <br />to Human Resources. The reporting and investigation of allegations of retaliation will follow the <br />procedures set forth in the reporting and investigation of discrimination or harassment. Any person <br />found to have retaliated against an individual for reporting discrimination or harassment, or for <br />participating in an investigation of allegations of any such conduct, will be subject to disciplinary <br />action, up to and including termination of employment. <br />Reporting and Investigation <br />It is the responsibility of every Associate to further the implementation of the Firm's policies <br />forbidding discrimination, harassment, and retaliation. <br />If any Associate believes that he or she has been subjected to discrimination, harassment, or <br />retaliation, or believes that he or she has witnessed any form of discriminatory, harassing, or <br />retaliatory conduct in the workplace, he or she is required to report the incident(s) to his or her <br />supervisor. In the event that this is not possible for any reason, or the Associate is uncomfortable <br />reporting the conduct to his or her supervisor, the Associate must report the incident(s) to Human <br />Resources or to Stifel's Legal Department. An Associate may also report an allegation to the <br />Firms EthicsPoint Hotline by calling 1466-514-5292. An appropriate person will conduct a <br />prompt and thorough investigation of the allegations. Because discrimination, harassment, and <br />retaliation issues can be sensitive, Stifel will take reasonable efforts to protect the privacy of all <br />parties involved. However, confidentiality cannot be assured because it may be necessary to <br />discuss allegations with the accused individual or others in order for the Firm to conduct a thorough <br />investigation. As with any other investigation conducted by the Firm, Associates involved in an <br />investigation must: <br />• Cooperate fully; <br />• Be completely honest and forthcoming; and <br />• Agree to limit the flow of information only to those who need to know as determined by <br />the Firm. <br />If, as a result of the investigation, it is determined that unlawful discrimination, harassment, and/or <br />retaliation has occurred, the Firm will take such prompt remedial action as it deems reasonably <br />necessary under the circumstances to both stop the inappropriate conduct and prevent it from <br />recurring in the future. Depending on the circumstances, appropriate remedial action may take the <br />form of disciplinary action, up to and including termination of employment. <br />If an investigation results in a finding that an Associate knowingly made a false complaint, or a <br />witness knowingly made a false statement, disciplinary action may be taken, up to and including <br />termination of employment. <br />Effective 2019 <br />