In addition, reasonable accommodations are made for applicants’ and employees’ religious practices and beliefs, mental and physical disabilities, and for pregnancy, childbirth and related medical conditions, including lactation, in accordance with applicable local law.
Prohibited Harassment
Harassment is any unwelcome conduct (verbal, nonverbal or physical) that has the purpose or effect of creating a hostile or offensive environment, or can reasonably be expected to cause an individual to feel unsafe, uncomfortable, intimidated, threatened, bullied, humiliated, offended or distressed.
Also prohibited are unwelcome sexual advances, requests for sexual favors and other verbal or nonverbal behavior or physical contact of a sexual nature (regardless of how the overture is communicated), whether it occurs one time or as a repeated act or pattern of behavior and whether it occurs in person, virtually, or via electronic device, social media or other means.
It is important to understand that:
- Inappropriate conduct, harassment, sexual harassment may involve individuals of the same or different sex or gender and is prohibited regardless of sex, gender identity or whether the individual submits to the overture or rejects it.
- Harassment, sexual harassment and/or inappropriate conduct are often defined by the impact to the recipient rather than by the intent of the person causing the offense.
- Repeated inappropriate incidents and behavior can constitute harassment and/or sexual harassment even if one single incident may not be considered the same.
- Real or perceived power that often comes from different levels of seniority, responsibility or job level/position and the ability to use position to coerce will be considered when assessing claims of harassment.
Inappropriate behavior will not, therefore, be excused or justified by claiming that it was unintentional or humorous or because it occurred under the influence of alcohol or other substances.
Reporting
Employees who are aware of possible violations of this policy must immediately contact their Manager, Human Resources or report the incident via JPMorganChase’s Code Reporting Hotline. The Hotline is operated by an external company, staffed 24/7 and callers have the ability to identify themselves or report anonymously (where permissible by law). It can be reached by phone or via internet, mail or fax, and translation services are available on request. Managers who become aware of potential violations of this policy must immediately report the information to the Code Reporting Hotline.
Reporting obligations to the company do not prevent employees from reporting to the government or regulators conduct that they believe to be in violation of the law.
JPMorganChase is committed to promptly and effectively reviewing all potential violations and taking action to address as appropriate.
Confidentiality will be maintained to the extent possible consistent with JPMorganChase conducting a thorough inquiry or investigation and responding where appropriate.
Non-Retaliation
JPMorganChase prohibits intimidation of or retaliation against an individual because he/she objected to behavior prohibited under this policy, reported a concern in good faith, or assisted with any inquiry or investigation under this policy.
Oversight
The Firm’s “How We Do Business” Principles serve as a guide for how employees are expected to conduct themselves, and the Firm’s Code of Conduct sets forth the Firm’s expectations for each employee.
Senior Leadership is responsible for setting the “tone at the top” consistent with our Business Principles. The Board of Directors provides oversight of the business and affairs of the Firm, including its culture and conduct. Each of the Board committees oversees reputational risks and conduct risks within its scope of responsibility. The Compensation and Management Development Committee (“CMDC”) oversees the Firm’s Business Principles, culture and significant employee conduct issues and any related actions. The Audit Committee receives regular reports from management on the Code of Conduct program. Each member of the board annually affirms his or her compliance with the Code of Conduct.
Workplace Training
Frequent training and awareness programs for employees are designed to promote a workplace free of discrimination and harassment. All employees must complete the firm’s required training when assigned.