Arcadia Privacy Policy

Anti-Harassment Policy
Purpose
The Organisation is committed to ensuring a work environment that respects the dignity and worth of each individual. Inappropriate workplace behavior and unlawful harassment create conditions that are wholly inconsistent with this commitment. The purpose of the policy set forth below is not to regulate the personal morality of employees, but rather to foster a work environment that is free from all forms of harassment, whether that harassment is because of age, color, disability, gender identity, genetic information national origin, race, religion, sex, veteran status, or any other factor outlined in the Company's Code of Conduct/Ethics and/or protected by federal, state or Swiss country law.​
 
Scope
This policy applies to all volunteers.
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Policy Guidelines
The Organisation will not tolerate discriminatory harassment, including sexual harassment. This policy applies to all harassment occurring in the work environment and applies regardless of the gender of the individuals involved. This policy covers all volunteers of the Organisation, including applicants for volunteer employment and third parties over whom the Organisation has control.
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Sexual Harassment Defined
For 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:

• submission to such conduct is either explicitly or implicitly made a term or condition of an individual's voluntary employment; or

• submission to or rejection of such conduct is used as the basis for voluntary employment decisions affecting the individual; or

• such conduct unreasonably interferes with an individual's work performance or creates an intimidating, hostile or offensive working environment.

 
Some examples of what may constitute sexual harassment are: threatening to take or taking voluntary employment actions, such as discharge, demotion or reassignment, if sexual favors are not granted; demands for sexual favors in exchange for favorable or preferential treatment; unwelcome and repeated flirtations, propositions or advances; unwelcome physical contact; whistling; leering; improper gestures; tricks; horseplay; use of stereotypes; offensive, insulting, derogatory or degrading remarks; unwelcome comments about appearance; sexual jokes or use of sexually explicit or offensive language; gender‑ or sex‑based pranks; and the display in the workplace of sexually suggestive objects or pictures. The above list of examples is not intended to be all‑inclusive. Sexual harassment can happen between same-sex individuals as well as between opposite sex individuals. Volunteers should take care in informal business situations.
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Other Harassment Defined
For purposes of this policy, other harassment is defined as verbal or physical conduct that denigrates or shows hostility or aversion toward an individual because of his/her race, color, gender, age, religion, national origin, sexual orientation, disability, veteran status or any other characteristic protected by law, and that:

• creates an intimidating, hostile or offensive work environment; or

• unreasonably interferes with an individual's work performance.

 
Some examples of such harassment are: using epithets or slurs; mocking, ridiculing or mimicking another's culture, accent, appearance or customs; threatening, intimidating or engaging in hostile or offensive acts that focus on any characteristic protected by law, including jokes or pranks; the displaying on walls, bulletin boards or elsewhere on Company premises, or circulating in the workplace, of written or graphic material that denigrates or shows hostility or aversion toward a person or group because of any characteristic protected by law. The above list of examples is not intended to be all‑inclusive.
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Consensual Relationships
Consensual romantic and/or sexual relationships between an employee with supervisory authority and any subordinate, including one not directly reporting to the supervisor, will compromise the Organisation's ability to enforce its policy against sexual harassment. Consequently, if such relationships arise, the Organisation will consider them carefully and take appropriate action. Such action may include a change in the responsibilities of the individuals involved in such relationships or transfer of location within the Organisation to diminish or eliminate the supervisory relationship and workplace contact that may exist. Any supervisory employee involved in such a relationship is required to report the relationship to his or her supervisor and to Human Resources.
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Reporting Discriminatory Harassment
The Organisation strongly encourages the prompt reporting of all incidents of discriminatory harassment. If you believe you are being harassed or have observed harassment, the Organisation encourages you to notify Human Resources promptly. If, at any time, a volunteer feels it would be unreasonable to use this procedure to report harassment because of unusual or unique circumstances, the Organisation encourages the volunteer to discuss the concern with your direct manager, a senior level leader within your functional or to members of the Legal Department.
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Investigation
When a volunteer reports harassment as specified above, the Organisation will investigate promptly. The steps of an appropriate investigation cannot be fixed in advance, but will vary depending upon the nature of the allegations as well as in alignment with Swiss law. The Organisation will seek to maintain confidentiality throughout the investigative process to the extent practicable and consistent with the Organisation's need to undertake a full investigation.
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Resolving the Matter
Upon completion of the investigation, the Organisation will take appropriate remedial action if it is necessary and supported by the facts. Remedial action may include verbal or written counseling, referral to formal counseling, disciplinary suspension or probation, or discharge from the Organisation.​
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Non-retaliation
An individual who reports incidents that the volunteer, in good faith, believes to be violations of this policy, or who is involved in the investigation of harassment, will not be subject to reprisal or retaliation. Retaliation is a serious violation of this policy and volunteers should report it immediately. The report and investigation of allegations of retaliation will follow the procedures set forth in this policy. Any person found to have retaliated against an individual for reporting discriminatory harassment or participating in an investigation of allegations of such conduct will be subject to appropriate disciplinary action.​
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Communication
This policy is part of the Organisation's overall commitment to open communication. The Organisation encourages any volunteer with workplace concerns of any nature (including, but not limited to, any alleged discrimination) to bring those concerns to the attention of Human Resources.
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Equal Employment Opportunity
Purpose
The Organisation has established the following policy regarding Equal Employment Opportunity for the volunteers of Arcadia.
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Scope
This policy applies to all volunteers.
 
Policy Guidelines
Arcadia is an equal opportunity employer for voluntary work and conducts all hiring and employment practices strictly in accordance with applicable fair employment practices and regulations. Discrimination in employment on the basis of any classification protected under federal, state or local law is a violation of our policy and is illegal. To the extent protected by applicable law, the Company does not discriminate in hiring or employment on the basis of: Age, Ancestry, Color, Creed, Ethnicity, Gender identity, Genetic information, Marital status, Mentor or physical disability (including HIR and AIDS), National origin, Pregnancy, Race, Religion, Sex, Sexual orientation, Veteran status, Or other categories defined by federal, state or local law.
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This policy applies to all terms and conditions of voluntary employment, including, but not limited to, recruitment and hiring, upgrading, classification, placement, promotion, termination, leaves of absence.
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To comply with applicable laws ensuring equal employment opportunities, the Organisation will attempt to make reasonable accommodations as required by law. Issues subject to reasonable accommodation may include religious belief or practice, gender identity, pregnancy or disability as required by law.
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Please direct any questions regarding this policy to Human Resources. The Organisation strongly encourages volunteers to report all incidents of discrimination promptly. If, at any time, a volunteer feels it would be unreasonable to use this procedure to report discrimination because of unusual or unique circumstances, the Company encourages the volunteer to discuss his/her concerns with a member of the management team. The Company will:

1. Investigate volunteer complaints;

2. Take appropriate corrective action to stop discrimination;

3. Protect volunteers from retaliation for reporting or participating in an investigation; and,

4. Act with discretion to protect volunteers privacy to the extent that this is possible and consistent with the Organisation's commitment to a workplace free of illegal discrimination.

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Volunteer Records
Purpose
To safeguard volunteer records and maintain the highest level of confidentiality for volunteers of Arcadia.
 
Scope
This policy applies to all Organisation volunteers to the extent permitted by state/local law.
 
Policy Guidelines
Volunteer records are the property of the Organisation. You may inspect documents in your file in the presence of a Human Resources representative at a mutually convenient time. No copies of documents in your file may be made, except for documents that you have previously signed. You may add your version of any disputed item to the file. Volunteers may request to review their employee records by contacting the Human Resources department.
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The Organisation regards volunteer records as confidential. Disclosure of volunteer records to anyone outside the Organisation will be limited to business needs and in accordance with data privacy laws, provided that, the Organisation will cooperate with requests from authorized law enforcement or local, state or federal agencies conducting official investigations and as otherwise legally required.
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Conflicts of Interest
Purpose
Volunteers have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest, including minimizing conflicts of interest that may arise from close personal relationships among volunteers of Arcadia.
 
Scope
This policy applies to all Organisation volunteers to the extent permitted by state/local law.
 
Policy Guidelines
A conflict of interest exists when personal, financial, business or commercial interests compete with your obligation to serve the interests of the Organisation. Volunteers have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. Even the perception of a conflict of interest can cause harm to the Organisation and to the volunteer involved.
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Generally, an actual or potential conflict of interest occurs when a Volunteer is in a position to influence a decision that may result in a personal gain for the volunteer (or for a relative or close personal relationship) as a result of your Organisation business dealings. Personal gain may result when a volunteer or relative has a significant ownership in a firm with which the Organisation does business, but also when a volunteer or relative receives any kickbacks, bribes, substantial gifts, or special considerations as a result of any transaction or business dealings involving the Organisation.
For the purposes of this policy, the term “relatives” includes those related by blood, marriage, or similar relationships.
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"Close personal relationships" include dating, romantic involvement, best friends, or living in the same household. Close personal relationships between volunteers can lead to conflicts of interest, or perceptions of such conflicts, and can adversely affect employee morale. Volunteer relationships with vendors, suppliers, customers and providers must remain professional at all times in order to avoid a conflict of interest, or a perception of such a conflict. In addition, volunteer relationships with colleagues, especially manager-subordinate relationships, and those in business support relationships (HR, Finance, etc.) must also remain professional.
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In the event that a close personal relationship develops that may present as a conflict of interest, the volunteer involved should inform their manager so that any appearance of favoritism or impropriety can be avoided. The Organisation reserves the right to take appropriate action to resolve the conflict of interest, or appearance of a conflict.
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The Organisation considers applicants who are relatives of current volunteers on the same basis as all other applicants and uses the same screening, pre-employment interviewing, selecting and hiring practices as are used for non-relative applicants. In order to avoid a conflict of interest, or a perception of a conflict of interest, the Organisation reserves the right to make decisions concerning the placement or supervision of a relative (i.e., relatives supervising each other, relatives working in the same department) on a case-by-case basis in order to avoid problems of reporting relationships, safety, security, morale and conflicts of interest.
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Solicitation and Distribution of Literature
Purpose
In order to maintain a professional business environment, the Organisation has established the following policy for the volunteers of Arcadia regarding the solicitation and distribution of non-Arcadia related literature.
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Scope
This policy applies to all Organisation volunteers to the extent permitted by country specific state law.
 
Policy Guidelines
Volunteers may not solicit or promote, either verbally, via posters/flyers and/or via email, for any non-Arcadia cause or organization during working time. Non-Arcadia causes and organizations include, but are not limited to, fundraising sales (i.e., Girl Scouts, school events, sports teams) and personal businesses (i.e., Avon, Pampered Chef). Working time includes the working time of both the volunteer doing the solicitation and the employee being solicited.
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In addition, no volunteer shall distribute or circulate any non-Arcadia written or printed material or literature (including by electronic communications) via an Arcadia specific email address at any time, during his or her working time or during the working time of the volunteer or volunteers to whom such activity is directed. Distribution of such material/literature only may occur during non-work periods.
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Under no circumstances will non-volunteers be permitted to solicit or to distribute any written material or literature via Arcadia channels. Please immediately report any outside solicitors to the building management and/or the most senior employee at the time.

Disciplinary Procedure
Purpose and Scope
The purpose of the Disciplinary Procedure is to ensure that volunteers of the Organisation are treated fairly in investigating and dealing with allegations of unacceptable conduct, competence, attendance or capability issues. This Disciplinary Procedure will apply to all volunteers. This Disciplinary Procedure is intended as a statement of current policy in relation to all of its volunteers, taking into account the Code of Conduct and any Swiss labour laws. However the Organisation reserves the right to make any changes and amendments to this Disciplinary Procedure that it considers necessary, at any time, at its sole discretion.
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The Organisation reserves the right to depart from the precise requirements of this Disciplinary Procedure where it is expedient to do so and where the resulting treatment of the volunteer is no less fair. The Organisation also reserves the right to skip stages of this Disciplinary Procedure where in the Organisation’s opinion, it is appropriate to do so, either due to the seriousness of the allegation or complaint, or otherwise.
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All cases of disciplinary action under this Disciplinary Procedure will be documented and placed in the volunteer’s personnel file. A copy of the Organisation’s disciplinary records concerning you will be supplied to you at your request.
 
NOTE: The Organisation reserves the right to continue with a disciplinary process notwithstanding the fact that an individual may have raised a grievance or complaint in relation to the same or different matter.
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A. INVESTIGATION AND DISCIPLINARY HEARING
The Organisation will undertaking an investigation if it considers it necessary. This investigation will be carried out by a senior volunteer who has not been involved in the incident/matter complained of. During an investigation, the Organisation reserves the right to suspend you. In such circumstances you will receive written notice of your suspension. Before any disciplinary action is taken, you will be called to a Disciplinary Hearing. You will be given prior notice of the Disciplinary Hearing and you will be provided with a list of the complaint(s) made against you and copies of any evidence to be used in support of the complaint(s). At the Disciplinary Hearing you will be given an opportunity to state your case. You will be entitled to be represented by a consenting fellow volunteer of your choice.
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B. SANCTIONS AND GROSS MISCONDUCT
Where the Organisation determines that disciplinary action is required, the following sanctions may be applied:

• Verbal Warning: Kept on file for 6 months.

• First Written Warning: Kept on file for 9 months.

• Final Written Warning: Valid for 6 months; further misconduct will lead to termination.

• Dismissal: Decisions to dismiss require reference to a C-Suite member.

 
The Organisation reserves the right to dismiss a volunteer summarily without notice for acts of Gross Misconduct including: Theft or fraud; Falsification of records; Physical violence; Serious harassment; Unsuitable for employment; Unauthorised use or disclosure of confidential information; Breach of Health and Safety rules which endanger the health and safety of others; and/or; Acts of dishonesty.
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C. APPEALS
You have a right to appeal against any disciplinary decision. You should inform the3 CHRO in writing of your wish to appeal within five working days of the date of the decision setting out the grounds of your appeal. Disciplinary sanctions will take effect automatically pending the outcome of any Appeal Hearing. For the avoidance of doubt where a decision to terminate is appealed and the dismissal is upheld, the date of termination of voluntary employment is the date of the original decision and not the date of the appeal.
 
The Appeal Hearing will be conducted as soon as possible thereafter at which you will be given an opportunity to state your case and will be entitled to be represented by a consenting fellow volunteer of your choice (other than an volunteer the subject of current disciplinary action in respect of the same complaint). As above, the Organisation reserves the right to refuse your chosen representative attendance at the Appeal Hearing where, for example, in the reasonable opinion of the Organisation, his/her attendance would hinder the effective running of the Appeal Hearing. You will be given the opportunity to change your chosen representative.
 
The outcome of the Appeal Hearing will be final.
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