Kuku FM is committed to providing equal employment and career opportunities, without discrimination or harassment on the basis of race, colour, sex, age, disability, religion, national origin, marital or veteran status, sexual orientation, ancestry, political belief, or activity, cancer-related medical condition, genetic characteristics or any other category protected by law. All Company decisions, including but not limited to compensation, benefits, transfers, promotions, dismissals, Company-sponsored training and educational programs, and any other terms and conditions of employment will be made without regard to those factors. Further, Kuku FM will not tolerate discrimination or harassment based on these or any other legally protected categories.

Definitions of Harassment

• Sexual harassment constitutes discrimination and is illegal under the law. For the purposes of this policy, sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when, for example: (i) submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment; (ii) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or (iii) such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile or offensive working environment.
• Sexual harassment may include a range of behaviors and may involve individuals of the same or different gender. Depending on the circumstances, these behaviors may include, but are not limited to:  unwanted sexual advances or requests for sexual favors; sexual jokes and innuendo; verbal abuse of a sexual nature; commentary about an individual's body, sexual prowess or sexual deficiencies; leering, catcalls or touching; insulting or obscene comments or gestures; display or circulation in the workplace of sexually suggestive objects or pictures (including through e-mail); and other physical, verbal or visual conduct of a sexual nature.
• Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal or physical conduct that denigrates or shows hostility or aversion toward an individual because of any characteristic protected by law and that: (i) has the purpose or effect of creating an intimidating, hostile, or offensive work environment; (ii) has the purpose or effect of unreasonably interfering with an individual's work performance; or (iii) otherwise adversely affects an individual's employment opportunities.
• Harassing conduct includes, but is not limited to: epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes and display or circulation in the workplace of written or graphic material that denigrates or shows hostility or aversion toward an individual or group (including through e-mail).

Individuals and Conduct Covered

These policies apply to all Kuku FM employees, and prohibit harassment, discrimination, and retaliation whether engaged in by fellow associates, by a supervisor or manager, or by someone not directly connected to Kuku FM (e.g., an outside vendor, consultant, or customer).

Conduct prohibited by these policies is unacceptable in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings, and business-related social events.

Retaliation is Prohibited

Kuku FM prohibits retaliation against any individual who reports discrimination or harassment or participates in an investigation of such reports.  Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of a claim of harassment or discrimination is a serious violation of this policy and, like harassment or discrimination itself, will be subject to disciplinary action up to and including termination.

Complaint Procedure

Reporting an Incident of Harassment, Discrimination or Retaliation

Kuku FM strongly urges the reporting of all incidents of discrimination, harassment, or retaliation, regardless of the offender's identity or position. Individuals who believe they have experienced conduct that they believe is contrary to Kuku FM policy or who have concerns about such matters should file their complaint, preferably in writing, with Human Resources.

IMPORTANT NOTICE: Associates who have experienced conduct they believe is contrary to this policy have an obligation to take advantage of this complaint procedure. An Associate’s failure to fulfill this obligation could affect his or her rights in pursuing legal action.

Early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment. Therefore, while no fixed reporting period has been established, Kuku FM strongly urges the prompt reporting of complaints or concerns so that rapid and constructive action can be taken.

The availability of this complaint procedure does not preclude individuals who believe they are being subjected to harassing conduct from promptly advising the offender that his or her behaviour is unwelcome and requesting that it be discontinued.

The Investigation

Any reported allegations of harassment, discrimination or retaliation will be investigated promptly.  The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge.