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CCI Anti-harassment and Discrimination Statement

 

Camaquiri Conservation Initiative S.A (CCI) is committed to providing a respectful and inclusive environment for all who visit and work with us, in which people are treated with dignity, decency, and respect. We believe in the need for a safe and harassment-free environment for our visitors, staff, and vendors.

Camaquiri Conservation Initiative S.A will not tolerate unlawful discrimination or any sexual harassment, coercion, or assault at any of our facilities or in any of our programs. Through enforcement of this policy and by education of employees and visitors, CCI will seek to prevent, correct, and discipline behavior that violates this policy.

All employees and visitors are covered by and are expected to comply with this policy and to take appropriate measures to ensure that prohibited conduct does not occur.

 

Camaquiri Conservation Initiative S.A, in compliance with all applicable federal, state and local anti-discrimination and harassment laws and regulations, enforces this policy in accordance with the following definitions and guidelines:

 

Discrimination

It is a violation of CCI’s policy to discriminate in the provision of employment opportunities, benefits or privileges; to create discriminatory work conditions; or to use discriminatory evaluative standards in employment if the basis of that discriminatory treatment is, in whole or in part, the person's race, color, national origin, age, religion, disability status, sex, sexual orientation, gender identity or expression, genetic information or marital status.

Discrimination of this kind may also be strictly prohibited by a variety of federal, state and local laws, including Title VII of the Civil Rights Act of 1964, the Age Discrimination Act of 1967 and the Americans with Disabilities Act of 1990 as well as “LEY SOBRE LA PROHIBICIÓN DE DISCRIMINACIÓN DEL TRABAJO 1960” of Costa Rica. This policy is intended to comply with the prohibitions stated in these anti-discrimination laws.

 

Harassment

Camaquiri Conservation Initiative S.A prohibits harassment of any kind, including sexual harassment, and will take appropriate and immediate action in response to complaints or knowledge of violations of this policy. For purposes of this policy, harassment is any verbal or physical conduct designed to threaten, intimidate or coerce an employee, co-worker, visitor or any person working for or on behalf of CCI.

The following examples of harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

• Verbal harassment includes comments that are offensive or unwelcome regarding a person's national origin, race, color, religion, age, sex, sexual orientation, pregnancy, appearance, disability, gender identity or expression, marital status or other protected status, including epithets, slurs and negative stereotyping.

• Nonverbal harassment includes distribution, display or discussion of any written or graphic material that ridicules, denigrates, insults, belittles or shows hostility, aversion or disrespect toward an individual or group because of national origin, race, color, religion, age, gender, sexual orientation, pregnancy, appearance, disability, sexual identity, marital status or other protected status.

 

Sexual harassment

Sexual harassment is a form of unlawful discrimination under Title VII of the Civil Rights Act of 1964 as well as under Ley contra Hostigamiento o Acoso Sexual en el Empleo y la Docencia N° 7476 of Costa Rica and is prohibited under CCI's anti-harassment policy. According to the Equal Employment Opportunity Commission (EEOC), 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 or rejection of such conduct is used as the basis for employment decisions ... or such conduct has the purpose or effect of ... creating an intimidating, hostile or offensive working environment."

 

Sexual harassment occurs when unsolicited and unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature:

• Is made explicitly or implicitly a term or condition of employment.

• Is used as a basis for an employment decision.

• Unreasonably interferes with an employee's work performance or creates an intimidating, hostile or otherwise offensive environment.

 

Sexual harassment may take different forms. The following examples of sexual harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

• Verbal sexual harassment includes innuendoes, suggestive comments, jokes of a sexual nature, sexual propositions, lewd remarks and threats; requests for any type of sexual favor (this includes repeated, unwelcome requests for dates); and verbal abuse or "kidding" that is oriented toward a prohibitive form of harassment, including that which is sexual in nature and unwelcome.

• Nonverbal sexual harassment includes the distribution, display or discussion of any written or graphic material, including calendars, posters and cartoons that are sexually suggestive or show hostility toward an individual or group because of sex; suggestive or insulting sounds; leering; staring; whistling; obscene gestures; content in letters, notes, facsimiles, e-mails, photos, text messages, tweets and Internet postings; or other forms of communication that are sexual in nature and offensive.

• Physical sexual harassment includes unwelcome, unwanted physical contact, including touching, tickling, pinching, patting, brushing up against, hugging, cornering, kissing, fondling, and forced sexual intercourse or assault.

 

Courteous, mutually respectful, pleasant, no coercive interactions between employees that are appropriate in the workplace and acceptable to and welcomed by both parties are not considered to be harassment, including sexual harassment.

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Confidentiality

All complaints and investigations are treated confidentially to the extent possible, and information is disclosed strictly on a need-to-know basis. The identity of the complainant is usually revealed to the parties involved during the investigation. All information pertaining to a complaint or investigation under this policy will be maintained in secure files by CCI Board of Investors.

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Complaint procedure

CCI has established the following procedure for lodging a complaint of harassment, discrimination or retaliation. CCI will treat all aspects of the procedure confidentially to the extent reasonably possible.

1. Complaints should be submitted as soon as possible after an incident has occurred to Israel Mesen Rubi or a member of CCI Board of Investors. Complaints can be sent via e-mail to isrmesen@gmail.com or contact Mr. Mesen via phone call at 011 506 87146371. You may also notify your professor or travel guide for help reporting the incident.

2. Upon receiving a complaint or being advised by a professor or travel guide that violation of this policy may be occurring, Mr. Mesen will notify and review the complaint with both the CCI Board of Investors and with CCI’s legal counsel Martin Coto Valverde.

3. Mr. Mesen or a member of the CCI Board of Investors, will initiate an investigation.

4. During the investigation, Mr. Mesen or a member of the CCI Board of Investors, together with legal counsel or other management employees, will interview the complainant, the respondent and any witnesses.

5. Upon conclusion of an investigation, Mr. Mesen or other person conducting the investigation will submit a written report of their findings to the CCI Board of Investors.

6. CCI Board of Investors and legal counsel will review the investigative report and any statements submitted by the complainant or respondent and discuss the results of the investigation with Mr. Mesen and other management staff, as appropriate. If it is determined that a violation of this policy has occurred, the CCI Board of Investors will recommend appropriate disciplinary action.

7. Once a final decision is made by the CCI Board of Investors, Mr. Mesen or a member of CCI Board of Investors will meet with the complainant and the respondent separately and notify them of the findings of the investigation. If disciplinary action is to be taken, the respondent and complainant will be informed of the nature of the discipline and how it will be executed.

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Alternative legal remedies

Nothing in this policy may prevent the complainant or the respondent from pursuing formal legal remedies or resolution through local, state, or federal agencies or the courts