POLICY NUMBER: FP-HR-002
CONFIDENTIAL INTERNAL COMMUNICATION LAST UPDATED: 05/01/2017
HARASSMENT AND
VIOLENCE-FREE
WORKPLACE
POLICY NUMBER: FP-HR-002
HARASSMENT AND VIOLENCE-FREE WORKPLACE
CONFIDENTIAL INTERNAL COMMUNICATION — Department Sponsor: Human Resources
2
PURPOSE
The purpose of this Global Policy is to ensure all Hilton Team
Members:
• Are aware of the Company’s commitment to maintain a
work environment that is free of harassment and workplace
violence;
• Are aware of and understand that acts of harassment or
violence are not tolerated by Hilton and are considered a
serious oense;
• Who are subjected to acts of harassment or violence are
encouraged to seek any assistance they may require in order
to pursue a resolution; and
• Are advised of available recourse if they are subjected to,
or become aware of, situations involving harassment or
violence.
POLICY SUMMARY
Hilton is committed to developing and maintaining a workplace
environment that reflects awareness and sensitivity to
individual abilities and appreciation of cultural dierences. In
doing so, the Company seeks to avoid any behavior against
a Team Member that could be interpreted as unlawful
harassment or violence. This policy applies to all activities
that occur while on Company premises, or while engaging in
Company business, activities or social events, and outlines
Hilton standards, prohibited conduct, and the process to follow
if this policy has been violated.
BACKGROUND / SCOPE
This Harassment and Violence-Free Workplace Policy (the
“Policy”) is in place to ensure all global locations of Hilton (the
“Company”) are following the same standards for a harassment
and violence-free workplace. It replaces all prior versions,
including HR-19 Harassment-Free Workplace Policy and HR-24
Workplace Violence Policy.
APPLICABILITY
This policy applies to:
• Team Members of all Corporate/Regional locations and
hotels/properties owned, operated or managed by Hilton,
whether or not the Team Members are employed by Hilton.
EXCLUSIONS / EXCEPTIONS
This policy does not apply to the following:
• Franchised Property Team Members
POLICY NUMBER: FP-HR-002
HARASSMENT AND VIOLENCE-FREE WORKPLACE
CONFIDENTIAL INTERNAL COMMUNICATION — Department Sponsor: Human Resources
3
POLICY DETAILS
A. Hilton Standards
In exercising its right as an employer, Hilton will endeavor at all times to
provide a safe and healthy work environment that supports both the
productivity and the dignity of every Team Member. Hilton will not tolerate
harassment or workplace violence, which is likely to interfere with the Team
Members’ ability to perform their work and may harm or compromise their
health and safety.
The Company is committed to:
• Investigating reported incidents of harassment and violence in an
objective and timely manner;
• Taking necessary action to respond to those incidents;and
• Providing support for Complaints.
POLICY NUMBER: FP-HR-002
HARASSMENT AND VIOLENCE-FREE WORKPLACE
CONFIDENTIAL INTERNAL COMMUNICATION — Department Sponsor: Human Resources
4
B. Prohibited
Conduct-
Harassment
Harassment is a particular kind of discrimination and targets an individual or
group based on a personal characteristic. It refers to behavior that demeans,
humiliates or embarrasses a person and that a reasonable person ought to
have known would be unwelcome. Harassment is a course of conduct that
usually involves more than one incident over a period of time; however, a
single severe incident may be considered harassment.
The behavior prohibited by this policy includes, but is not limited to:
• Any unwanted conduct which has the purpose or eect of violating
dignity or creating an intimidating, hostile, degrading, humiliating or
oensive environment, as defined by the applicable laws.
• Verbal, non-verbal or physical abuse on the part of any Team Member
who discriminates, interrupts or interferes with the work of another
Team Member, or who creates an intimidating, oensive or hostile
work environment.
Examples of harassment include, but are not limited to:
• Written or verbal abuse or threats;
• Unwelcome remarks, jokes, slurs or taunting of a discriminatory
nature;
• Practical jokes that embarrass or insult someone;
• Ignoring, isolating or segregating a person because of a personal
characteristic;
• Materials that are of a discriminatory nature that are displayed
publicly, circulated in the workplace, etc.;
• The dissemination, sharing or display of emails, websites or images
from the Internet that include content of an inappropriate, explicit
harassing or discriminatory nature;or
• Unwelcome sexual advances, request for sexual favors or physical
conduct of a sexual nature which may include, but is not limited
to,when:
— Submission to such conduct is made either explicitly or implicitly
as a term or condition of an individual’s employment.
— Submission to or rejection of such conduct by an individual
is used as the basis for employment decisions aecting such
individuals.
— Such conduct has the purpose or eect of substantially
interfering with an individual’s work performance or creating an
intimidating, hostile, or oensive working environment.
POLICY NUMBER: FP-HR-002
HARASSMENT AND VIOLENCE-FREE WORKPLACE
CONFIDENTIAL INTERNAL COMMUNICATION — Department Sponsor: Human Resources
5
C. Prohibited
Conduct-
Violence
No Team Member shall subject any other person to workplace violence or
allow or create conditions that support workplace violence.
Acts of violence can take the form of inappropriate physical contact or a
verbal threat, and may occur as a single event or may involve a continuing
series of incidents. These acts can:
• Destroy an individual’s dignity;
• Lower morale;
• Cause physical harm;
• Provoke fear; and
• Break down team cohesiveness.
Examples of workplace violence include, but are not limited to:
• Threatening behavior such as shaking fists, destroying property or
throwing objects;
• Verbal or written threats that express an intent to inflict harm;
• Conduct intended to intimidate others through violence;
• Physical attacks; or
• Any other acts that would arouse fear in a reasonable person under
the circumstances.
POLICY NUMBER: FP-HR-002
HARASSMENT AND VIOLENCE-FREE WORKPLACE
CONFIDENTIAL INTERNAL COMMUNICATION — Department Sponsor: Human Resources
6
D. Complaints
Process
Hilton’s commitment is to ensure that all concerns and complaints are
investigated in a fair, timely and confidential manner and consistent with an
appropriate investigation and subject to any local law requirements, and all
parties to a complaint have the right to have their side heard.
Any Team Member who feels he/she has been subjected to harassment or
workplace violence should:
• Let their objections to the behavior be known to the alleged
oender, directly or with the assistance of a third party (if the Team
Member is comfortable doing this).
• If this eort proves unsuccessful, or if the Team Member feels
uncomfortable conducting the first step, the Team Member should
notify their immediate Manager, who may work with Human
Resources as needed. If the alleged harassment or violence is from
the Team Member’s Manager, the Team Member should follow the
next step and contact Human Resources.
• The Complainant may also ask for support directly from his/her
Human Resources representative. If the source of the alleged
harassment or violence is from a Human Resources Department
Team Member, the Complainant should report it to the General
Manager of the Hotel, a Regional Human Resources representative,
or the President or other Executive in the Corporate Oce.
Team Members who witness such conduct should immediately notify their
Manager or Human Resources.
The Hotel or Corporate Oce shall immediately initiate a just and impartial
investigation of all complaints presented and shall take the corresponding
action for a solution of the problem. Based on the results of the Company’s
investigation, disciplinary action may be taken in accordance with local
legislation and practice, as appropriate under the circumstances.
Team Members who choose to, or are asked to, file a written complaint
should carefully record details of the incident(s), including the date and time
of the incident(s), the nature of the harassment or violence, and names of
parties who may have witnessed the incident. This document will be the
Complainant’s personal record and property.
POLICY NUMBER: FP-HR-002
HARASSMENT AND VIOLENCE-FREE WORKPLACE
CONFIDENTIAL INTERNAL COMMUNICATION — Department Sponsor: Human Resources
7
E. Not Meeting
Hilton Standards
Any Team Member who subjects another Team Member, Guest, client or
business associate of Hilton to harassment or workplace violence may
be subject to formal disciplinary action. Should any form of harassment
or violence occur, the Company has procedures in place to deal with the
incident and prevent any future occurrences. The Company reserves the
right to determine what type of disciplinary action may result from proven
instances of harassment, violence or false complaints, subject to the terms
of any local law, applicable collective bargaining agreement or binding
agreement. A Manager failing to report a complaint to Human Resources
may also be subject to disciplinary action.
The following conditions will be considered when determining corrective
action:
• The impact of the incident on the Complainant;
• The impact of the incident on the team (how the work environment is
aected);
• The nature of the incident;
• The degree of aggressiveness and physical contact;
• The period of time and frequency of the incidents; and/or
• If a violation to this policy has occurred before by the Team Member.
The following disciplinary actions may be considered depending on the
particular incident and applicable local law (including any applicable collective
bargaining agreement):
• Apology;
• Training;
• Referral to an assistance program;
• Reassignment or relocation;
• Written warning up to and including suspension;
• Termination;
• Notification to police; and/or
• Legal action.
POLICY NUMBER: FP-HR-002
HARASSMENT AND VIOLENCE-FREE WORKPLACE
CONFIDENTIAL INTERNAL COMMUNICATION — Department Sponsor: Human Resources
8
F. Confidentiality
To the extent possible consistent with a proper investigation, the Company
will treat its investigations as confidential, and requires that all Team
Members interviewed in connection with an investigation maintain the
confidentiality of the investigation. The Company will provide appropriate
support to all parties involved. Any individual who becomes aware of an
incident of harassment or violence should not disclose the details of the
incident to any third party without prior consultation with Human Resources.
Anonymous reporting is not possible, although the Company will endeavor
to maintain the confidentiality of any reporting party to the extent possible,
subject to its obligation to fully and thoroughly investigate all such reports.
The Company will preserve confidentiality as to information obtained in
connection with any investigation and all related information shall remain
confidential to the extent possible under the circumstances. Any Team
Member subject to this confidentiality obligation who discloses confidential
information without the Company’s express approval may be subject to
disciplinary action.
Any Team Member who reports unlawful harassment or cooperates in the
investigation of a complaint will be protected from retaliatory action. Team
Members engaging in retaliatory conduct will be subject to disciplinary
action.
G. Record Keeping
The documents corresponding to the investigation will be kept on file in
accordance with the Company’s Record Retention Policy and applicable data
protection laws.
H. Questions from
Team Members
Team Members should address any questions regarding this policy with their
Manager, General Manager or Human Resources representative.
DEFINITIONS
Term / Acronym with Definition
Harassment
Physical or verbal behavior a person displays or a hostile attitude towards
an individual based on a personal characteristic, or due to the respective
person’s relatives, friends, associates, or members of the association to
which he/she belongs, The actions or comments are viewed as demeaning
and unacceptable or unwelcome to the recipient or to anyone witnessing the
actions or comments.
Workplace Violence
Threatened, attempted or actual conduct of a person that causes or is
likely to cause physical injury or leads a Team Member to feel intimidated or
believe that they are likely to be subjected to physical injury, whether work-
related and/or at a work site or work-related event.
Verbal Abuse
Use of words to cause harm to the person being spoken to. Verbal abuse
may be in the form of shouting, insulting, intimidating, threatening, shaming,
demeaning, or derogatory language, among other forms of communication.
Complainant
A Team Member who raises the incident regarding an alleged violation to
this policy.
Manager
A Team Member who manages/supervises other Team Members.
POLICY NUMBER: FP-HR-002
HARASSMENT AND VIOLENCE-FREE WORKPLACE
CONFIDENTIAL INTERNAL COMMUNICATION — Department Sponsor: Human Resources
9
ROLES AND RESPONSIBILITIES
Entity / Personnel Responsibilities
Managers
Managers are responsible for:
• Ensuring that all Team Members are treated fairly and equitably and
are not subject to harassment or violence.
• Monitoring any practices and attitudes that may lead to harassment
or violence.
• Identifying training needs for Team Members.
• Ensuring that Team Members understand who to contact regarding
concerns about the Policy or when reporting an incident.
• Taking all reasonable steps necessary to promptly and eectively
eliminate any unlawful harassment or violence they uncover in or
related to the workplace.
• Supporting the reporting of all incidents to Human Resources, no
matter how minor they are.
• Ensuring the physical safety of the Team Members they supervise
and their own immediate physical safety if an incident of workplace
violence occurs.
Any reports of harassment or violence should be treated seriously and
sympathetically. Any Team Member in a supervisory role who is informed of
alleged harassment or violence occurring within the Company must notify
Human Resources. With the Complainant’s agreement and in conjunction
with the Human Resources representative, immediate and appropriate
action should take place, beginning with a thorough, confidential (to the
extent possible) investigation of the circumstances. In certain locations, the
investigation will proceed regardless of the Complainant’s agreement.
Human Resources
Human Resources is responsible for:
• Promoting a harassment and violence-free workplace.
• Educating Team Members about Hilton’s expectations for a
harassment and violence-free Workplace and the steps to take to
report violations of this policy.
• Ensuring that reported incidents of harassment and violence are
investigated in an objective and timely manner.
• Taking necessary action to respond to those incidents and providing
support to the Team Member(s) involved.
POLICY NUMBER: FP-HR-002
HARASSMENT AND VIOLENCE-FREE WORKPLACE
CONFIDENTIAL INTERNAL COMMUNICATION — Department Sponsor: Human Resources
10
RELATED DOCUMENTS, TOOLS AND TEMPLATES .
HWI-LG-001: Code of Conduct
Diversity & Inclusion Statement
FP-HR-001: Equal Employment Opportunity
Team Member Handbook
Union Agreements, where applicable
Team Member Issue Resolution
Local EEO Guidelines
Investigation Procedures
Records Retention Policy
Team Members
All Team Members have a responsibility to behave in ways that support a
harassment and violence-free working environment for themselves and their
fellow Team Members. They should actively:
• Behave respectfully towards other individuals (e.g., Team Members
and Guests) while at work and participating in any work-related
activity.
• Be prepared to challenge inappropriate behavior.
• Report incidents of harassment or workplace violence to their
immediate Manager or Human Resources Department, as the
situation warrants; and cooperate with any eorts to investigate and
resolve matters arising under this policy.
• Ensure their own immediate physical safety in the event of workplace
violence.
