It is against Company policy for any employee, supervisor, manager, or executive to sexually harass or engage in other unlawful harassment.

Sexual harassment has been defined as unwelcome sexual advances, request 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 as a term or condition of an individual's employment, (2) submission to or rejection of such conduct by an individual is used on the basis for employment decisions affecting such individual, or (3) such conduct has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile, or offensive work environment.

Points (1) and (2) mean that sexual favors -- solicited, granted or rejected -- should play no role in the hiring and personnel decisions of management.

Points (3) prohibits conduct, based on sex, that makes it unreasonably difficult for an individual to do work. It is important to understand that this prohibition falls equally on those in both supervisory and non supervisory positions.

Sexually-oriented "kidding around," which includes telling off-color jokes, making suggestive comments, or using raunchy language, can be considered offensive and is sometimes viewed as sexually harassing by others. Even if these statements were not directed at those offended, having to listen to sexually-oriented remarks can sometimes be harassment.

Be aware that what one person considers "having fun" can sometimes rise to the level of sexual harassment.

Sexual harassment can take forms other than offensive language. Written examples include suggestive or obscene letters, notes, and illustrations. Physical examples include assault, touching, impeding or blocking movements, sexually-oriented gestures, or display of sexually suggestive objects. See also "Trinity Forge Information and Communications System Policy" below for more information dealing with use of e-mail and other information systems.

All managerial and non-managerial employees of the Company are expected to avoid any behavior or conduct toward any other employee which could be interpreted as harassment.

Managers and supervisors are prohibited from dating any subordinates and calls for disciplinary action up to and including termination.

Harassment of employees by non-employees of the Company, such as vendor personnel and others having dealings with the Company also will not be tolerated.

COMPLAINTS

If any employee observes or experiences any form of harassment, the employee has a duty to provide a written complaint to his or her supervisor or any manager as soon as possible. The complaint should be specific and should include the names of the individuals involved and the names of any witnesses who will be interviewed in confidentiality. The company, with the assigned investigators, will immediately undertake an effective, thorough, and objective investigation and attempt to resolve the situation. If the complaint relates to the employee's supervisor, the employee has a duty to provide a complaint to the HR Manager so that appropriate action can be taken. If management determines that an individual has violated this policy, that individual will be subject to disciplinary action up to and including termination.

The company will not retaliate against any who file a legitimate complaint, nor will the company or management retaliate in any way against the falsely accused. Also the company will treat false complaints as harassment.

The Company desires to protect the confidentiality of an employee who believes this policy has been violated, and it also desires to protect the reputation of any employee against whom a complaint is wrongfully made. The company however, cannot guarantee confidentiality. Consequently, it is the intention of this policy that information about a complaint not be released by management of the Company to third parties or to anyone within the Company who is not involved in the investigation.

TRINITY FORGE INFORMATION AND COMMUNICATION SYSTEMS POLICY

This is the Company's policy on access to and disclosure of electronic mail messages sent or received by company employees who use the electronic mail system and on the proper use of the electronic mail system generally. This policy may be changed at any time. The electronic mail and other information systems of the Company are not to be used in a way that may be disruptive, offensive to others or harmful to morale.

There is to be no display or transmission of sexually explicit images, messages, or cartoons. There is to be no transmission or use of e-mail communications that contain ethnic slurs, racial epithets, or anything that may be construed as harassment or disparagement of others based on their race, national origin, sex, sexual orientation, age, disability, or religious or political beliefs. Violation of this policy will result in appropriate disciplinary action up to and including termination.

In general, employees should use the information systems for Company business, however, limited personal use within the bounds of this policy is also allowed. The e-mail system should not be used to solicit or proselytize other for commercial ventures, religious or political causes, outside organizations, or other non-job-related solicitations.

All messages are Company records. The Company reserves the right to access and disclose all messages sent over its electronic mail system for any purpose. By using e-mail access provided, every employee agrees that he or she is aware of this policy. Also, for privacy reasons, employees should not attempt to gain access to another employee's personal file of e-mail messages without the latter's permission. However, Company management reserves the rights to enter an employee's e-mail files whenever there is a business need to do so.