It is Eastern Frontier Educational Foundation, Inc.'s (the "Foundation") policy that all employees, visiting scholars-in-residence ("scholar") and other guests have the right to work and reside in an environment free of discrimination on the basis of any protected characteristic including race, color, sex, sexual orientation, physical or mental disability, religion, ancestry or national origin or age. The Foundation will not tolerate any form of harassment by supervisors, co-workers, residents, vendors or Board members. This policy is intended to prohibit offensive conduct, either physical or verbal, that threatens human dignity and employee morale and which interferes with a positive and productive work environment.

Harassment, including but not limited to racial and sexual harassment, is illegal.

Definition of Sexual Harassment

As outlined in the Equal Employment Opportunity Commission Sexual Discrimination Guidelines and relevant Maine anti-discrimination laws, sexual harassment includes:  

Unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when (1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment, (2) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individuals, or (3) such conduct has the purpose or effect of substantially interfering with an individual's work performance or creating an intimidating, hostile, or offensive working environment.

The following examples are common of the types of conduct that may constitute sexual harassment:
- Slurs, jokes or degrading comments of a sexual nature.
- Unwelcome sexual advances.
- Suggestive or lewd remarks.
- Discussions about or inquiries into one's sexual experiences.
- Unwelcome hugging, touching, or kissing.
- Requests for sexual favors.
- Repeated offensive sexual flirtation or propositions.
- The display of sexually suggestive pictures or objects.
- Repeated unwelcome physical contact or touching such as patting, pinching, constant brushing against another's body.

This policy prohibits any overt or subtle pressure for sexual favors including implying or threatening that an applicant's or your cooperation of a sexual nature (or lack thereof) will have any effect on your employment, job assignment, wages, promotion, or any other condition of employment, or future job opportunities. This policy also prohibits any conduct that would tend to create an intimidating, hostile, or offensive work environment.

Retaliation against an employee, scholar or guest who has complained about sexual or other harassment and retaliation against any such party for cooperating with an investigation of a harassment complaint is unlawful.

Consistent with the laws and with the above guidelines, it is the Foundation's policy that no action will be taken affecting you (either favorably or unfavorably) on the basis of such conduct as submitting to sexual advances, refusing to submit to sexual advances, protesting sexual overtures, or raising a complaint concerning the alleged violation of this policy. You will not be retaliated against in any way for refusing to submit to or making a complaint about harassment nor will you be retaliated against for participating in an investigation of a complaint about harassment.

Complaints and Investigations

Supervisors and managers are responsible for monitoring behavior, which can be construed to be harassment, and for initiating necessary action to eliminate such behavior. Any employee, scholar or guest who feels that he or she is a victim of harassment should immediately report the matter to a supervisor. If you do not feel comfortable talking to your or another supervisor, or if you have made a complaint and do not feel it was acted upon appropriately, you may make a report to Stephen Dunn.

Complaints can also be made directly to Stephen Dunn in person or by telephone at (914) 450-4874 or at P. O. Box 472, Jonesport, ME  04640 or at steved@dunndata.com. Employees not comfortable speaking with Mr. Dunn regarding any complaints of harassment should make complaints directly to Tom De Haven or John Beckman in person or at tomdehaven@hotmail.com or beckman@usna.edu.

The Foundation will immediately investigate any complaints of harassment and, where warranted, will take disciplinary action against any employee, scholar or guest engaging in harassment. Depending on the circumstances, such disciplinary action may include suspension, demotion, or termination of employment.

The Foundation will protect the confidentiality of harassment allegations to the extent possible. While the Foundation cannot guarantee complete confidentiality, information about the allegation of harassment will be shared only with those who need to know about it. Records relating to harassment complaints will be kept confidential on the same basis.

Any questions regarding this policy should be addressed to Stephen Dunn or Tom De Haven or John Beckman. Any employee, scholar or guest who believes that he or she has been the victim of harassment, or who has knowledge of that kind of behavior, is urged to report such conduct immediately. No party will be retaliated against for complaining about harassment.

In addition, you should be aware there are State agencies charged with the responsibility of enforcing anti-discrimination laws. These agencies investigate complaints of unlawful discrimination in employment, including claims involving sexual harassment.

The Maine Human Rights Commission will attempt to resolve complaints of discrimination to the mutual satisfaction of those involved. However, the Maine Human Rights Act authorizes the Commission to pursue remedies to unlawful discrimination in court when conciliation fails. The Maine Human Rights Commission can be contacted at the following address and number:

Maine Human Rights Commission
State House, Station 51
Augusta, Maine 04333
(207) 624-6050

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