EQUAL EMPLOYMENT OPPORTUNITY POLICY

The Premier Hockey Federation and its Member Clubs (the “Company”) is an equal opportunity employer and complies with all applicable federal, state, and local fair employment practices laws. The Company strictly prohibits and does not tolerate discrimination against employees, applicants, or any other covered persons because of race, color, gender, gender identity, sex, age, ancestry, national origin, religion, physical or mental disability or handicap, mental illness, sexual orientation, genetic information, pregnancy or pregnancy-related conditions, membership in the uniformed services and any other characteristic protected by applicable law (“Protected Categories”). All Company employees, other workers, and representatives are prohibited from engaging in unlawful discrimination. This policy applies to all terms and conditions of employment, including recruiting, hiring, training, and development, promotion, compensation, benefits administration, transfer, discipline, layoff, and termination of employment, in keeping with all applicable federal, state, and local statutes.

The Company complies with the Americans with Disabilities Act (ADA), as amended by the ADA Amendments Act and all similar applicable state or local law. Consistent with those requirements, the Company will reasonably accommodate qualified individuals with a disability if such accommodation would allow the individual to perform the essential functions of the job unless doing so would create an undue hardship. Any employee who needs assistance to perform the employee’s job duties because of physical or mental conditions should contact such Member Club’s President and/or General Manager, and in the case of the Premier Hockey Federation, the Senior Vice President of Hockey Operations.

Employees of the Company also have the right to be free from discrimination in relation to pregnancy or pregnancy-related conditions including, but not limited to, lactation or the need to express breast milk for a nursing child. In addition, they have the right to reasonable accommodations for pregnancy or pregnancy-related conditions.

Some examples of reasonable accommodations include, but are not limited to:

More frequent or longer unpaid breaks;
Time off to attend to a pregnancy complication or recover from childbirth;
Acquisition or modification of equipment or seating;
Temporary transfer to a less strenuous or hazardous position;
Job restructuring;
Light duty;
A private, non-bathroom space for expressing breast milk;
Assistance with manual labor; or
A modified work schedule.

If you believe you need an accommodation, or if you have questions regarding the Company’s process for requesting reasonable accommodations for qualified employees or candidates for employment, please refer any such request or questions to such Member Club’s President and/or General Manager, and in the case of the Premier Hockey Federation, the Senior Vice President of Hockey Operations or other appropriate operations officer. For certain accommodations, the Company may request documentation from an appropriate health care professional. The Company will also, where appropriate, provide reasonable accommodations for an employee's religious beliefs or practices.

No Retaliation

No one will be subject to, and the Company prohibits, any form of discipline, reprisal, intimidation, or retaliation for good faith reports or complaints of incidents of discrimination of any kind, pursuing any discrimination claim, or cooperating in related investigations.

The Company is committed to enforcing this policy against all forms of discrimination. However, the effectiveness of our efforts depends largely on employees telling us about inappropriate workplace conduct. If employees feel that they or someone else may have been subjected to conduct that violates this policy, they should report it immediately.

Violations of this Policy

Any employee regardless of position or title, whom the Company determines has subjected an individual to discrimination or retaliation in violation of this policy will be subject to discipline, up to and including termination of employment.

Discrimination and Harassment Policy

The Company strives to create and maintain a work environment in which people are treated with dignity, decency, and respect. The environment of the Company should be characterized by mutual trust and the absence of intimidation, oppression, and exploitation. The Company will not tolerate unlawful discrimination or harassment, including sexual harassment, of any kind. Through enforcement of this policy and by education of employees, the Company will seek to prevent, correct and discipline behavior that violates this policy.

The purpose of this policy is not to regulate our employees’ personal morality, but to ensure that no one harasses another individual in the workplace, including while at any facilities of any Member Club or the Premier Hockey Federation, while on Member Club business (whether or not on the premises of Member Club or the Premier Hockey Federation) or while representing a Member Club or the Premier Hockey Federation.

This policy refers to but is not limited to, harassment of any employee based on membership in a Protected Category. Harassment includes the display or circulation of written materials or pictures which are degrading or hostile on the basis of membership in a Protected Category and verbal abuse, slurs, or insults based on those factors and directed at or made in the presence of persons in a Protected Category.

Harassment also refers to behavior that is personally offensive, impairs morale, and interferes with the work effectiveness of employees. Any harassment of employees by other employees will not be permitted, regardless of their working relationship.

All employees, regardless of their positions, are covered by and are expected to comply with this policy and to take appropriate measures to ensure that prohibited conduct does not occur. Because the Company takes allegations of discrimination and harassment seriously, it will respond promptly to complaints of discrimination harassment, and where it is determined that such conduct occurred, it will act promptly to eliminate the conduct and impose such corrective action as may be necessary, including disciplinary action or dismissal where appropriate.

Please note that, while this policy sets forth our goal of promoting a workplace that is free from harassment, the policy is not designed or intended to limit our authority to discipline or take remedial action for workplace conduct that we deem unacceptable, regardless of whether that conduct satisfies the legal definition of harassment. Further, any retaliation against an individual who has complained about harassment or retaliation against individuals for cooperating with an investigation of a harassment complaint is similarly unlawful and will not be tolerated.

The sexual harassment complaint and investigation procedure (discussed below) also applies to other forms of illegal harassment/discrimination based on membership in a Protected Category.

Definition of Sexual Harassment

“Sexual harassment” means sexual advances, requests for sexual favors, and verbal or physical conduct of a sexual nature when:

submission to or rejection of such advances, requests, or conduct is made either explicitly or implicitly a term or condition of employment or is used as a basis for employment decisions; or
such advances, requests, or conduct have the purpose or effect of unreasonably interfering with an individual’s work performance by creating an intimidating, hostile, humiliating, or sexually offensive work environment.

Under these definitions, direct or implied requests by a manager for sexual favors in exchange for actual or promised job benefits (such as favorable reviews, salary increases, promotions, increased benefits, or continued employment) constitutes sexual harassment.

The legal definition of sexual harassment is broad and, in addition to the above examples, other sexually oriented conduct, whether it is intended or not, that is unwelcome and has the effect of creating a workplace environment that is hostile, offensive, intimidating, or humiliating to male or female workers may also constitute sexual harassment. While it is not possible to list all those additional circumstances that may constitute sexual harassment, the following are some examples of conduct which, if unwelcome, may constitute sexual harassment depending upon the totality of the circumstances including the severity of the conduct and its pervasiveness:

Unwelcome sexual advances - whether they involve physical touching or not;
Dissemination of sexually explicit voicemail, email, graphics, downloaded material or websites;
Sexual epithets, sexual jokes, written or oral references to sexual conduct, gossip regarding one’s sex life;
Comments about an individual’s body and/or comments about an individual’s sexual activity, deficiencies, or prowess;
Displaying sexually suggestive objects, pictures, or cartoons;
Unwelcome leering, whistling, brushing against the body, sexual gestures, suggestive or insulting comments;
Inquiries into one’s sexual experiences; and/or
Discussion of one’s sexual activities.

All employees should take special note that, as stated above, retaliation against an individual who has complained about harassment, and retaliation against individuals for cooperating with an investigation of a harassment complaint, is unlawful and will not be tolerated by this organization.

Moreover, employees should note that sexual harassment can occur between individuals of the same gender and regardless of sexual orientation. The same standards that apply to harassment between individuals of the opposite sex apply to harassment cases involving individuals of the same gender.

Complaints of Sexual Harassment

Individuals who believe they have been subjected to harassment from a co-worker, a manager, a customer, a vendor/supplier, a visitor or other individual, whether or not employed by the Company should immediately bring the matter to the attention of their supervisor and/or such Member Club’s President and/or General Manager, and in the case of the Premier Hockey Federation, the Senior Vice President of Hockey Operations or other appropriate operations officer. Additionally, any employee or manager who becomes aware of any possible unlawful harassment or other violation of this policy, whether he or she is personally affected or not, is directed to advise Human Resources of such Member Club, and in the case of the Premier Hockey Federation, the Senior Vice President of Hockey Operations or other appropriate operations officer.

If any of our employees believe that he or she has been subjected to harassment, the employee has the right to file a complaint with such Member Club or the Premier Hockey Federation. This may be done in writing or orally. If you would like to file a complaint you may do so by contacting such Member Club’s President and/or General Manager, and in the case of the Premier Hockey Federation, the Senior Vice President of Hockey Operations or other appropriate operations officer.

Anybody, regardless of position or title, whom the Member Club or Premier Hockey Federation determines has engaged in harassment of any kind in violation of this policy, will be subject to prompt appropriate corrective action, up to and including discharge.

Every report of perceived sexual harassment will be promptly, thoroughly, and impartially investigated as the Company considers appropriate and corrective action will be taken where appropriate as determined by the Company in its reasonable discretion. Employees are required to cooperate in all investigations conducted pursuant to this policy. The identity of individuals who report a perceived violation of this policy, as well as any information obtained during the Company’s investigation, will be kept confidential to the extent possible, consistent with a thorough and impartial investigation with relevant legal requirements, but confidentiality cannot be guaranteed. In addition, the Company will not allow any form of retaliation against individuals who report unwelcome conduct to management in good faith or who cooperate in the investigations of such reports in accordance with this policy.

Harassment Investigation

When we receive a complaint, we will promptly investigate the allegation in a fair and expeditious manner. The investigation will be conducted in such a way as to maintain confidentiality to the extent practicable under the circumstances. Generally, our investigation will include a private interview with the person filing the complaint, with witnesses, and with the person alleged to have committed the harassment. All employees will be expected to cooperate fully in our efforts to investigate and enforce this policy. When we have completed our investigation, we will, to the extent appropriate, inform the person filing the complaint and the person alleged to have committed the conduct of the results of that investigation.

If an employee believes that his or her report or complaint of a possible violation of this policy has not been promptly or properly addressed, the employee should immediately contact such Member Club’s President and/or General Manager, and in the case of the Premier Hockey Federation, the Senior Vice President of Hockey Operations or other appropriate operations officer.

Disciplinary Action

If it is determined that inappropriate conduct has been committed by one of our employees, we will take such action as is appropriate under the circumstances. Such action may range from counseling to termination from employment, and it may include such other forms of disciplinary action as we deem appropriate under the circumstances.

State and Federal Remedies

In addition to the above, if you believe you have been subjected to sexual harassment, you may file a formal complaint with the United States Equal Employment Opportunity Commission (“EEOC”) or a similar state agency. Using our complaint process does not prohibit you from filing a complaint with these agencies. Each of the agencies has a short time period for filing a claim (EEOC – 300 days).