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  1. Prohibition of Sexual and Discriminatory Harassment

    It is the policy of Cleveland Construction, Inc. to promote the realization of equal employment opportunity through a positive continuing program of specific practices designed to ensure the full realization of equal employment opportunity without regard to race, color, religion, sex, national origin, union affiliation, status as a Vietnam Veteran, status as a Disabled Veteran or status as a recently separated Veteran.

    To implement these policies, the company will:

    1. Recruit, hire, train and promote persons in all job classifications without regard to race, color, religion, sex, national origin, union affiliation, status as a Vietnam Veteran, status as a Disabled Veteran or status as a recently separated Veteran;

    2. Base decisions on employment so as to further the principle of equal employment opportunity;

    3. Ensure that promotion decisions are in accordance with the principles of equal employment opportunity by imposing only valid requirements for promotional opportunities; and

    4. Ensure that all personnel actions (including, but not limited to, compensation, benefits, transfers, layoffs, return from layoff, company sponsored training, education, social and recreational programs) are administered without regard to race, color, religion, sex, national origin, union affiliation, status as a Vietnam Veteran, status as a Disabled Veteran or status as a recently separated Veteran.


    Cleveland Construction, Inc. provides a working environment free from any form of sexual or discriminatory harassment. Each individual has the right to work in an environment which promotes equal opportunities and prohibits discriminatory practices, including sexual harassment.

    Specifically, Cleveland Construction, Inc. expressly prohibits any form of unlawful employee harassment based on sex, race, color, religion, national origin, age, disability, marital status or veteran status. Sexual harassment and other forms of discriminatory harassment are unacceptable conduct, whether in Cleveland Construction, Inc.'s offices or in other work-related settings, and will not be tolerated by Cleveland Construction, Inc. Discriminatory harassment in the workplace is also prohibited by law.

    Equal employment opportunity is not only the law, but it is a principle of our company's operation. Each employee is expected to cooperate in achieving this goal and stand behind this principle.

  2. Definition and Examples of Harassment

    For the purpose of this policy, the term "sexual harassment" includes any unwelcome or unwanted sexual attention, sexual advances, requests for sexual favors, and other verbal, visual or physical conduct of a sexual nature or other offensive behavior directed toward an employee because of or on account of his or her gender, whether by a person of the opposite or same gender, when:


    1. submission to or rejection of such conduct by an individual is used as a basis or factor in decisions affecting the terms or conditions of employment of any individual; or

    2. submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment; or

    3. such conduct has the purpose or effect of unreasonably interfering with an individual's work performance; or

    4. such conduct creates an intimidating, hostile or offensive work environment.

    5. Examples of the types of conduct that constitute sexual harassment include, but are not limited to: threatening adverse employment actions if sexual favors are not granted; unwanted and unnecessary physical contact; demands for sexual favors in exchange for favorable treatment or continued employment; display of pornographic material; excessively offensive remarks, including unwelcome graphic or suggestive comments about an individual's body, appearance or dress, obscene jokes or other inappropriate use of sexually explicit or offensive language; the display in the workplace of sexually suggestive objects or pictures which create an intimidating or hostile work environment; unwelcome sexual advances if condoned, explicitly or implicitly, by the Company; and other unwelcome and unwanted conduct of a sexual nature, such as leering, name calling and sexual innuendos.

  3. Coverage

    This policy covers all employees without exception. All who work at Cleveland Construction, Inc. are responsible for ensuring that the workplace is free from all forms of discrimination and/or discriminatory harassment. Cleveland Construction, Inc. will not tolerate, condone or allow discrimination or discriminatory harassment in any form, whether engaged in by fellow employees, supervisors, managers, customers, vendors or other non-employees who conduct business with Cleveland Construction, Inc. We encourage the reporting of all incidents of harassment, regardless of who the offender may be.

  4. Open Door Complaint Procedure

    While Cleveland Construction, Inc. encourages individuals who are being discriminated against or harassed to firmly and promptly notify the offender that his or her behavior is unwelcome, Cleveland Construction, Inc. also recognizes that power and status disparities between an alleged discriminator or harasser and a target may make such confrontation extremely difficult. In the event that such informal, direct communication between individuals is either ineffective or too difficult, the following steps should be followed in reporting a harassment complaint.

    If you have been subjected to discriminatory harassment or experience any other job-related discrimination based on your race, color, religion, national origin, age, disability, marital status or veteran status, or believe you have been treated in an unlawful, discriminatory manner, or have been retaliated against for making a report of harassment or discrimination or for providing information concerning an act of harassment or discrimination, whether by a co-worker, superior, client or vendor of Cleveland Construction, Inc. or other non-employee who conducts business with Cleveland Construction, Inc. promptly report the incident, either verbally or in writing, to your supervisor. In the event you feel uncomfortable for any reason with discussing such matter with your supervisor, or in the event you are not satisfied after bringing the matter to the attention to your department manager, promptly report it directly to the President or any Vice President of the Company at 440-255-8000.

    Cleveland Construction, Inc., under the direction of its President, Vice President, or other senior management official, will investigate all allegations of discrimination or harassment in as thorough, prompt, and confidential a manner as is reasonably possible. Cleveland Construction, Inc. will undertake all investigations with due regard to the privacy of all parties involved consistent with a thorough and appropriate investigation. The full and complete cooperation of the complainant is vitally necessary for the prompt and effective investigation and remediation of all harassment, discrimination or retaliation complaints. Where necessary, Cleveland Construction, Inc. will engage a lawyer or consultant to investigate the complaint and provide guidance in handling the matter.

  5. Resolving the Complaint

    Upon completing the investigation of a harassment complaint, Cleveland Construction, Inc. will communicate its findings and intended action to the complainant and person alleged to have committed the discrimination or harassment. If Cleveland Construction, Inc. determines that an employee is guilty of harassing or discriminating against another individual, appropriate disciplinary action will be taken, commensurate with Cleveland Construction, Inc.'s judgment as to the seriousness of the particular offense, up to and including termination of employment. Disciplinary action may include one or more of the following: a verbal and written reprimand; referral to counseling; withholding of a promotion; reassignment; temporary suspension without pay; financial penalties; and termination.

    Although Cleveland Construction, Inc.'s ability to discipline a non-employee discriminator or harasser is limited by the degree of control, if any, that Cleveland Construction, Inc. has over the alleged discriminator or harasser, any employee who has been subjected to work related discriminatory harassment by a non-employee should file a complaint and be assured that appropriate action will be taken.

  6. Retaliation Prohibited

    Cleveland Construction, Inc. will not in any way retaliate against an individual who makes a report of harassment or discrimination or provides information concerning an act of harassment or discrimination, nor permit any other employee to do so. Retaliation is a serious violation of this policy and should be reported immediately. Any person found to have retaliated against another individual for reporting harassment will be subject to appropriate sanctions, including all of the same disciplinary actions noted above for offenders. If you believe you have been subject to any acts of retaliation or threatened with retaliation, you should promptly report the same pursuant to the open-door complaint procedure outlined in this Policy.