Anti-Discrimination & Sexual Harassment

Statement of Philosophy


B.R.A is proud of its tradition of a collegial work environment in which all individuals are treated with respect and dignity.  Each individual has the right to work in a professional atmosphere, that promotes equal opportunities and prohibits discriminatory practices, including sexual or other illegal harassment.  At B.R.A discrimination, sexual harassment, and illegal harassment in the workplace will not be tolerated.

Anti-Discrimination Statement


Our policy is to select, place, train, and promote the most qualified individuals based upon relevant factors such as work quality, attitude, and experience, so as to provide equal employment opportunity for all our employees in compliance with the applicable local, state, and federal laws and without regard to non-work-related factors such as race, color, religion, national origin, ancestry, sex, age, marital status, personal appearance, sexual orientation, gender identity or expression, family responsibilities, genetic information, disability, matriculation, political affiliation or any other characteristic protected by law.  The equal opportunity policy applies to all Firm activities including, but not limited to, recruiting, hiring, training, transfers, promotions, and benefits.


Behavior and/or employment practices not in accordance with this policy are unacceptable in the workplace itself and in other work-related settings such as business trips, court appearances, and business-related social events.

Definition of Sexual Harassment


For purposes of this policy, sexual harassment is defined as unwelcome or unwanted conduct of a sexual nature (verbal or physical) when (1) submission to such conduct is made either explicitly or implicitly a term or condition of employment; or (2) submission to or rejection of such conduct is made the basis for employment decisions; or (3) such conduct interferes unduly with work performance or creates an intimidating, hostile or offensive working environment.


Behavior and/or employment practices not in accordance with this policy are unacceptable in the workplace itself and in other work-related settings such as business trips, court appearances, and business-related social events.





Individuals Covered Under the Policy

This policy covers all employees and all levels of supervisors and management.  B.R.A will not tolerate, condone or allow discrimination and/or sexual or illegal harassment, whether engaged in by fellow employees, supervisors, managers, or by other non-employees who conduct business with this Company.  The Company encourages reporting of all incidents of discrimination and harassment, regardless of who the offender may be.


All employees, management, and support staff of the Company are expected to avoid any behavior or conduct that could be interpreted as discriminatory and/or improper harassment.  Any employee found to be engaging in any discriminatory conduct or other improper harassment will be subject to disciplinary action up to and including discharge.


It is recognized that harassment may result from the actions of non-employees (i.e., third parties such as clients, suppliers/vendors, service representatives, visitors, or other non-employees, etc. who interface with B.R.A employees during employment activities).  In these cases, the employee should report the incident immediately to their Manager for further action.  B.R.A will investigate all such complaints and take such action as may be appropriate.  B.R.A is totally committed to protecting its employees from sexual harassment or illegal harassment and does not condone this offensive behavior or conduct by anyone.



Procedures for Reporting Incidents of Illegal or other Harassment and/or Discrimination

B.R.A’s goal is to maintain a healthy work environment where all employees feel at ease.  Toward that end, the following action should be taken by any person who believes they have been the victim of illegal or other harassment and/or discrimination


  • If possible, make it known to the harasser/offender that the behavior in which they are engaging is unwelcome.  The best demonstration of this it to give a strong, negative response to the harasser/offender immediately.  Let the person know, in no uncertain terms, that you find the behavior offensive and you expect it to stop.  Even if you have tolerated the behavior in the past, you may still inform the harasser/offender that you are not willing to do so in the future.
  • Report the offending behavior to your supervisor, the next level of management, the Director of Human Resources, or to another member of management with whom you are comfortable. Any manager who becomes aware of possible discrimination, sexual or other unlawful harassment must promptly advise Human Resources, their Managing Director, or the CEO.
  • B.R.A will promptly conduct a comprehensive investigation in response to specific reported instances of illegal or other harassment and/or discrimination. 


Remember, the Company cannot take effective action unless it knows of the conduct.  You need not endure illegal harassment or discrimination, nor is it necessary for you to resolve the matter by yourself.  The Company shall conduct a prompt, thorough investigation and will take immediate action to remedy any conduct which is found to constitute illegal harassment or discrimination.  No employee will be subject to any form of retaliation or discipline for pursuing a harassment or discrimination complaint.

After the Company concludes its investigation, any person found to have engaged in illegal harassment or discrimination will be subject to corrective action.  Corrective action may include termination, even for the first offense. B.R.A will not tolerate illegal harassment or discrimination on the job or at Company-sponsored events. 


This procedure is also applicable with regard to any work-related harassment or discrimination by non-employees.  The Company cannot always control the conduct of non-employees but will attempt to remedy any such situations that arise.




Prohibition of Retaliation


No employee will be subject to any form of retaliation or discipline for pursuing, in good faith, harassment or discrimination complaint or for assisting in a complaint investigation.  Retaliation will not be tolerated, and should it occur, the individual who retaliated will be subject to disciplinary action, up to and including termination.


If you believe you have experienced retaliation for making a complaint or participating in an investigation, you should follow the reporting procedure outlined above. 


If you have questions or concerns about whether specific language or behavior is a violation of this policy, you should consult with your manager, your Managing Director, the Human Resources Director, or the CEO.   



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