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CUNA MUTUAL: It’s Not Enough to say Your CU Doesn’t Tolerate Harassment
Monday, June 17, 2013 6:20 AM

According to the CUNA Mutual Group, just saying your credit union doesn’t tolerate harassment isn’t enough. Credit unions need to have a written policy that will actually work and protect employees. The CUNA Mutual Group offers some basic guidelines for an anti-harassment policy:

It must be professionally written.
Your anti-harassment policy should be part of an overall employment practices policy that is approved by the board. This policy must be written by a human resources professional and/or employment attorney who ensures it complies with federal and state laws. The entire employment practices policy, including harassment elements, should be read and signed by all employees annually. Among other things, this protects your credit union from charges that employees who violate the policies were unaware of them.

Employees must have the opportunity to report harassment to someone other than the alleged harasser.
An anti-harassment policy must document how employees can bypass their harasser to lodge a complaint. This means at least two people should be designated to accept these complaints.
You may need to offer employees the option to lodge harassment complaints with a neutral third party, if you can’t otherwise guarantee that employees have a safe avenue.

Prohibit retaliation against an employee who reports harassment.
Your written policy should state that reports of harassment will be investigated promptly. It should also state that retaliation—by firing or other means—is not permitted against the person who complained or those who participate in the investigation, such as witnesses to the harassment.

EEOC lawsuits can require employers to pay extra punitive damages and back-pay for firing employees who lodged harassment complaints. You may be liable for damages for firing an employee who complains, even when the complaint is proved to be unfounded.

Be clear about work-related harassment off-premises or by non-employees.
Work-related harassment doesn’t always happen at work, and it isn’t always committed by other employees. Your policy should prohibit harassment at work-related functions held outside the workplace, such as a holiday party at local establishment. And your policy must protect employees from being harassed by directors, contract employees, third-party vendors, or others with whom the employees interact as part of their job.

Helpful Resources: TCUL’s Compliance & Regulation team offers a vast array of resources for Texas credit unions, including a training DVD on harassment and CU Policy Pro, which features more than 200 policies developed and written by regulatory experts specifically for credit unions that can be customized. Other resources available to credit unions include InfoSight-an online compliance manual and Information Central. Learn more by visiting the Compliance & Regulation section of TCUL’s website, at www.tcul.coop .