QUERY: Can you provide us with a sample workplace violence policy?

RESPONSE: The following material is found in Ceridian's HR Compliance Reference System:

WORKPLACE VIOLENCE

The safety and security of Company employees is of the utmost importance to Company. Company has adopted a Zero Tolerance Policy for workplace violence.

Acts or threats of physical violence including intimidation, coercion, and/or harassment, which involve or affect Company employees, visitors, guests or other individuals will not be tolerated. (Harassment of a sexual nature is dealt with under the Company sexual harassment policy.) Violations of this policy will be investigated by Company Security. Violations of this policy may lead to disciplinary action including dismissal, arrest, and prosecution.

Company Security will continually strive to prevent and minimize the potential of violence in the workplace by:

• Continually reviewing and evaluating physical security at all Company facilities
• Providing training and education to employees
• Evaluating and assisting in responding to workplace violence issues.
• Maintaining accurate and up to date reports and evaluations of all violence related issues and incidents.

Company’s prohibition against threats and acts of violence applies to all persons involved in the Company’s operation, including but not limited to Company personnel, contract and temporary workers, and anyone else on Company property worldwide. Violations of this policy by any individual on Company property, by any individual acting as a representative of Company while not on Company property or by any individual worldwide when his/her actions affect Company’s business interests will be met by appropriate action.

General examples of prohibited workplace violence include, but are not limited to, the following:

• All threats or acts of violence occurring on Company property, regardless of the relationship between the Company and the parties involved in the incident.
• All threats or acts of violence not occurring on Company property but involving someone who is acting in the capacity of a representative of Company.
• All threats or acts of violence not occurring on Company property involving an employee of Company if the threats or acts of violence affect the interests of the Corporation.

Specific examples of conduct that will be considered "threats or acts of violence" prohibited under this policy include, but are not limited to, the following:

• Hitting or shoving an individual.
• Threatening to harm an individual or his/her family, friends, associates, or their property.
• The intentional destruction or threat of destruction of property owned, operated or controlled by the Company.
• Making harassing or threatening telephone calls, letters or other forms of written and electronic communication.
• Intimidating or attempting to coerce an employee to do wrongful acts.
• Harassing surveillance, also known as “stalking”, the willful, malicious and repeated following of another person.
• Making a remark suggesting or implying that an act to injure persons or property is "appropriate", regardless of the location where such a remark is made.
• Possession or use of any firearm, weapon, or any other dangerous device on Company owned or controlled property, with the exception of law enforcement officers in the course of their normal duties and security personnel specifically authorized by Company Security. Additionally, the carrying of firearms is prohibited at Company sponsored functions or while conducting Company business even if that business is outside of Company’s premises. This prohibition includes all facilities, including those in locations where individuals are permitted and licensed to possess or carry firearms by law. In addition, in states that require it by statute, all Company owned or controlled properties will post signage advising all Company personnel, contract and temporary workers and anyone else entering the property that firearms are not permitted.

Firearms, weapons and dangerous devices are defined by the applicable state or national statute in the jurisdiction of each Company owned or controlled property.

Company owned or controlled property is defined as the space in any building, including the parking and campus areas of that building, where Company is an owner or tenant and maintains a business presence.

Company sponsored event is defined as one which is promoted and communicated by the Company through both formal and informal means.

Conducting Company business includes but is not limited to visits to customer and vendor sites, attendance at conferences and trade shows, and other business activity that may be conducted at hotels, restaurants or other meeting places.

After receiving notification of a workplace violence issue, Company Security will initiate an investigation and will respond utilizing internal and external resources as needed.

Any person who makes threats, exhibits threatening behavior, or engages in violent acts on Company property shall be removed from the premises as quickly as safety permits, and shall remain off company premises pending the outcome of an investigation. Company Security will initiate an appropriate response. This response may include, but is not limited to, suspension and/or termination of any business relationship, reassignment of job duties, suspension or dismissal and/or criminal prosecution of the person or persons involved.

All Company personnel are responsible for notifying Company Security of any threats that they have witnessed, received or have been told that another employee has witnessed or received, whether on or off the premises. Even without an actual threat, personnel should also report any behavior they have witnessed which they regard as threatening or violent, when that behavior might be carried out on a Company-controlled site, or at a company sponsored event, or when that behavior might occur between Company employees off the premises. Employees are responsible for making this report regardless of the relationship between the individual who initiated the threat or threatening behavior and the person or persons who were threatened or were the focus of the threatening behavior.

All individuals who apply for or obtain a protective or restraining order which lists company locations as being protected areas must provide to Company Security a copy of the petition and declarations used to seek the order, a copy of any temporary protective or restraining order which is granted, and a copy of any protective or restraining order which is made permanent.

Company will provide opportunities for employees to be trained in the risk factors associated with workplace violence and proper handling of emergency situations in order to minimize the risks of violent incidents occurring in the workplace.