Workplace Violence Prevention

The workplace violence prevention program has been developed by Dow Aero ("Company") to identify and respond to acts, or threats, of violence in the workplace. This program applies to Company employees, contractors, and visitors.

Acts of violence includes any physical hostilities, whether intentional or unintended recklessness, which harms or threatens the safety and wellbeing of another individual. Threats of violence involves any behavior that, by its very nature, could be interpreted by a reasonable person as an intent to cause physical harm to another individual; includes verbal assaults and intimidating gestures.

The Company strives to provide employees a safe environment in which to work. Therefore, the Company will not tolerate violence, or threats of violence, in the workplace. Any employee determined to have violated this program, or whom brings forth claims that are not of good-faith, can be subject to disciplinary action, up to immediate termination of their employment. Non-employee violations of this program can result in immediate and permanent removal from all Company premises, with notice of their actions being reported to the individual’s employer. The Company may notify law enforcement of serious violations to this program when the safety and wellbeing of other individuals is at risk.

Responsibilities

Any person subject to, or whom observes, imminent acts of violence shall call 911 immediately. Any employee, contractor, or visitor who believes a crime has been committed, whether against themselves or others, has the right to file a report with an appropriate law enforcement agency.

Environmental Health and Safety (EHS) and Human Resources (HR)

The highest ranking officials for the Company’s Environmental Health and Safety (EHS) and Human Resources (HR) departments are responsible for:

  • Conducting a collaborative internal investigation of the incident(s) upon any act, or threat, of violence.

    • May partner with senior management, legal counsel, and law enforcement agencies to determine an appropriate response to any incident.

The highest ranking official for the Company’s Human Resources (HR) department is responsible for:

  • Assigning disciplinary action upon an employee violating this program.

The Company’s Environmental Health and Safety (EHS) and Human Resources (HR) departments are responsible for:

  • Gathering and maintaining any information regarding workplace acts, or threats, of violence.

    • Collaborative efforts shall be made to ensure the safety and wellbeing of all employees, contractors, and visitors, while remaining in compliance with statutory and regulatory requirements.

  • When previously trained, can immediately remove the violation’s offender from Company premises when warranted by their hostile actions or threats.

The Company’s Human Resources (HR) department is responsible for:

  • Providing a referral to an appropriate counseling service for an employee desiring assistance:

    • For anger or stress management; or

    • Who are victims, observers, or otherwise adversely affected by an act, or threat, of violence.

Managers and Supervisors

Manager and supervisor responsibilities are:

  • To promptly respond or receive council relating to incidents of any act, or threat, of violence in the workplace.

    1. Council can be requested from either the Company’s Environmental Health and Safety (EHS) or Human Resources (HR) departments.

    2. In serious cases where an act of violence has occurred or is perceived to be imminent, notify law enforcement immediately by calling 911.

Employees

Every employee:

  • Shall report any act, or threat, of violence to the nearest manager or supervisor, Environmental Health and Safety (EHS) or Human Resources (HR) department personnel, or senior management.

    • In serious cases where an act of violence has occurred or is perceived to be imminent, notify law enforcement immediately by calling 911.

Response to Types of Violence

Threats of Violence

  1. Any individual who experiences or observes a threat of violence shall immediately report the incident to the nearest manager or supervisor.

    • If perceived appropriate, law enforcement should be notified.

  2. The notified manager or supervisor shall promptly assess the situation and either directly intervene or immediately consult with the Company’s Environmental Health and Safety (EHS) or Human Resources (HR) department.

    • If perceived appropriate, law enforcement should be notified ahead of contacting EHS and HR.

  3. If not immediately notified, the Company’s Environmental Health and Safety (EHS) or Human Resources (HR) department shall be promptly notified so that an investigation can be conducted regarding the alleged threat.

  4. Based on any findings from the investigation, appropriate actions shall be taken.

Acts of Violence Not Involving Injuries or Weapons

  1. Any individual who experiences or observes an act of violence shall immediately report the incident to the nearest manager or supervisor.

    • If appropriate, law enforcement should be notified.

  2. The notified manager or supervisor shall promptly assess the situation and either directly intervene or immediately consult with the Company’s Environmental Health and Safety (EHS) or Human Resources (HR) department.

  3. Appropriate actions shall be taken to ensure

  4. If not immediately notified, the Company’s Environmental Health and Safety (EHS) or Human Resources (HR) department shall be promptly notified so that an investigation can be conducted regarding the alleged threat.

    • Separate from any criminal investigation conducted by law enforcement, the Company’s Environmental Health and Safety (EHS) or Human Resources (HR) department, and its designees, shall lead in conducting an independent Company investigation of the incident.

      • Appropriate action shall be taken, disciplinary or otherwise.

    • The Company’s Human Resources department can coordinate a counseling service referral upon requested.

Acts of Violence Involving Injuries or Weapons

  1. Any person observing an incident shall:

    1. Find an appropriate place to shelter themself, and potentially others, from harm.

    2. Call 911.

    3. Notify Environmental Health and Safety (EHS) or Human Resources (HR) department personnel when possible.

      • Employees and management should not intervene unless, in their best judgment:

        • They believe the situation is too critical to wait for law enforcement; and/or

        • They believe their direct intervention would be successful in protect the safety and wellbeing of themselves and other employees.

  2. The affected and surrounding work areas on the particular Company premise shall be evacuated

  3. The Company’s Environmental Health and Safety (EHS) or Human Resources (HR) department shall be promptly notified so that an investigation can be conducted regarding the incident.

    • Separate from any criminal investigation conducted by law enforcement, the Company’s Environmental Health and Safety (EHS) or Human Resources (HR) department, and its designees, shall lead in conducting an independent Company investigation of the incident. In conjunction with the supervisor or management.

      • Appropriate action shall be taken, disciplinary or otherwise.

    • The Company’s Human Resources department can coordinate a counseling service referral upon requested.

Weapons-Free Facilities and Job Sites

In providing an additional measure to ensure the safety of all individuals at Company premises, and that maintains its complex contractual agreements, the unauthorized possession and use of weapons is strictly prohibited. Weapons can include, but are not limited to:

  • Firearms and ammunition;

  • Non-work use knives or other blades;

  • Mace and teargas;

  • Explosives; and

  • Any object that may resemble a weapon or be used to inflict physical harm.

Only the Company's President/CEO, Ronda Hudson-Dowding, may authorize any employee to possess any weapon at the workplace

Persons Covered

All employees are subject to this policy, including contract, temporary, or internship employees, as well as independent contractors and other visitors. Any government-issued license, along with state and local law permitting the possession of any weapon, does not supersede this Company policy. Any employee in violation of this policy shall be subject to disciplinary action, up to and including termination of employment, while contractors or visitors may be immediately removed from the facility or job site, whether temporarily or permanently. Law enforcement can be notified in the event an individual is perceived to potentially use the unauthorized weapon as an act of violence.

Searches of Personal Property

The Company reserves the right at any time and at its discretion to search all Company-owned or leased vehicles, along with packages, containers, briefcases, purses, lockers, desks, enclosures, and persons entering the Company workplaces, for the purpose of determining whether any weapon is, or has been, brought into the Company workplace in violation of this policy. Employees who fail or refuse to promptly permit a search under this policy shall be subject to disciplinary action, up to and including termination of employment, while anyone else shall be immediately removed from the facility, whether temporarily or permanently.

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