Workplace Violence Prevention and Response Policy

The following highlights prohibited conduct, workplace violence responses, and the responsibilities of employees, managers and the HR department. It was written for a bank.

The Bank strives to maintain a productive work environment free of violence and the threat of violence. We are committed to the safety of our employees, vendors, customers and visitors. To ensure a safe workplace, and to reduce the risk of violence, all employees should review and understand all provisions of this Workplace Violence Prevention and Response Policy.

Our Violence Prevention Policy

The Bank does not tolerate any type of workplace violence committed by or against employees. Any threats or acts of violence against an employee, vendor customer, visitor or property will not be tolerated. Any employee determined to have committed such acts will be subject to disciplinary action, up to and including termination from the Bank. Where appropriate, the Bank will report violent incidents to local law enforcement authorities.

A violent act/threat of violence is defined as any direct or indirect action or behavior that could be interpreted, in light of known facts, circumstances and information, by a reasonable person, as indicating the potential to harm, endanger or inflict pain or injury on any person or property.

This list of behaviors, while not inclusive, provides examples of prohibited conduct:

• physical assault, threat to assault or stalking an employee or customer;
• possessing or threatening with a weapon;
• intentionally damaging property of the Bank or personal property of another;
• aggressive or hostile behavior that creates a reasonable fear of injury to another person;
• harassing or intimidating statements, phone calls, voice mails, or e-mail messages, or those which are unwanted or deemed offensive by the receiver;
• racial or cultural epithets or other derogatory remarks associated with hate crime threats.

Any questions about what constitutes violent behavior should be directed to your Employee Relations Specialist.

Our Weapons Policy

The possession, transfer, sale or use of weapons or dangerous instruments as defined below (even if licensed to carry a weapon) or any paraphernalia associated with such a weapon, is prohibited on Bank-owned or leased premises. This includes, but is not limited to, parking lots, personal cars, Bank-sponsored events, and Bank-owned cars.

Possession of weapons is prohibited at any time while conducting Bank business, except as may be required as a condition of employment. Violation of this policy may result in disciplinary action up to and including termination. Where appropriate, the Bank will report the transfer, sale, or use of weapons or dangerous instruments to the local law enforcement authorities.

A weapon is defined as any:

• firearm (including a BB gun, whether loaded or unloaded);
• knife, (including a switchblade or other knife having an automatic spring release device);
• stiletto (excluding a small pen or pocket knife);
• police baton or nightstick;
• any other martial arts weapons; or
• electronic defense weapons.

A dangerous instrument is defined as any instrument, article or substance that, under the immediate circumstances, is capable of causing death or physical injury.

Any employee that has a question as to whether an instrument, article or substance is considered a weapon or dangerous instrument in violation of this policy should ask for clarification from their supervisor, manager or Employee Relations Specialist prior to bringing the instrument, article or substance on Bank-owned or leased premises.

Exceptions to the weapons policy must be approved beforehand by senior management. Any weapon or dangerous instrument on Bank-owned or leased premises may be confiscated. There is no reasonable exception of privacy with respect to such items in the workplace. Employees� desks, workstations, offices and files may be subject to security searches.

Workplace Violence Response Procedure

Emergencies -- A situation is considered an emergency if:

• An injury has occurred; or
• There is an immediate threat of physical harm or injury.

In an emergency, consider your personal safety first. If possible, follow the steps below:

Step 1 -- Call 911, if appropriate.

Step 2 -- Call the Workplace Violence Hotline at __________.

Step 3 -- Notify your supervisor or manager.

Non-emergencies -- A situation is considered a non-emergency if:

• No injury has occurred;
• There is no immediate danger; but
• The words or gestures of one person have induced fear of physical harm in another person.

Procedure -- In the event of a non-emergency:

• Notify the Workplace Violence Hotline, or
• Place a confidential (and, if you wish, anonymous) call to the Workplace Violence at _______________.

Your Responsibilities

• Refrain from threats or acts of violence against employees, customers, vendors or property.
• Call 911 and request assistance if the situation is perceived as dangerous.
• If an emergency, immediately call the Workplace Violence Response Hotline at ______________ to report the incident and notify your manager or supervisor.
• In the event of a non-emergency:

Notify the Workplace Violence Hotline at _______________, or

Place a confidential call to the Workplace Violence Prevention Voicemail Box at _____________ to report any knowledge of a real or potential violation of this policy as well as any suspicious or unusual behaviors of employees, vendors or customers.

Manager's Responsibilities

• Enforce this policy fairly and uniformly.
• Call 911 and request assistance if the situation is perceived as dangerous.
• Attempt to identify and diffuse all conflicts as soon as possible without endangering your safety or the safety of others.
• In the event of an emergency, immediately call the Workplace Violence Response Hotline at _________________ to report the incident and notify your manager.
• In the event of a non-emergency:

Notify the Workplace Violence Hotline at _________________, or

Place a confidential call to the Workplace Violence Prevention Voicemail Box at _________________ to report any knowledge of a real or potential violation of this policy as well as any suspicious or unusual behaviors of employees, vendors or customers.

• Cooperate with Employee Relations and Security in any investigation conducted.
• Do not attempt to challenge or disarm an armed and dangerous person.

HR Responsibilities

• Follow the Bank�s crisis management process. This includes coordinating with the appropriate personnel/departments such as Security, Real Estate Services and Corporate Communications.
• Take steps to ensure there is no reprisal towards employees who report violent acts.
• Maintain confidentiality where appropriate.
• Investigate all direct or indirect threats to determine all information relative to the incident.

SOURCE: Reprinted with permission from "Exhibit Books of Personnel Policies-Set II; Volume 1: Employment and Standards of Conduct," Watson Wyatt Data Services.