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VISITOR CODE OF CONDUCT

Visitors, Vendors, and Outside Company Representatives Engaged in Interaction with Seattle Times Employees and/or on Company premises are subject to the Seattle Times Visitor Code of Conduct, Consisting of the Policies listed below.

Identification Badge Policy
To ensure a safe and secure work environment for its employees and patrons, The Seattle Times requires anyone on Seattle Times property to display an appropriate Identification Badge (ID) as evidence that they are authorized to be on Seattle Times property. The purpose of this policy is to establish guidelines by which this can be accomplished. Employees and visitors must display their ID whenever they are inside on company property. Outside on company property employees must be able to produce their ID upon request.

Bias-Free Policy
The Seattle Times strictly forbids discrimination or harassment of any kind, whether based on race, color, national origin, religion, creed, sex, age, physical, mental or developmental disability, marital status, sexual orientation, political ideology or any other reason. Harassment may include unsolicited or unwelcome remarks, gestures, or physical contact, as well as the display or circulation of inappropriate or derogatory written materials or pictures.

This policy is strictly enforced and may result in disciplinary measures for employees up to and including termination. Vendors, Contractors or others may be barred from doing business with the company, regardless of whether or not the harassment is found to be unlawful.

Privacy and Confidentiality
The Seattle Times is committed to maintaining the confidentiality and privacy of personal information that is collected as a requirement for certain business activities. Examples of confidential information include, but are not limited to social security number, home address, home phone number and medical information. Anyone with access to this information in the course of business must maintain confidentiality. Confidentiality violations include but are not limited to sharing personal information with individuals who don't have a business need to know (orally or in writing) and failing to secure confidential information from unauthorized access. The Seattle Times practices are compliant with the Health Insurance Portability and Accountability Act (HIPAA) Privacy Rules as stated in the "Notice of Privacy Practices." The notice describes how health information may be used and explains how federal law provides employees with certain rights regarding their health information. The "HIPAA Privacy Notice" (PDF) may be obtained from the Employee Benefits department. The Seattle Times has a Privacy Officer, Arlene Junkers, Employee Benefits Manager, who is responsible for the Company's privacy plan and procedures that safeguard employee protected health information. An employee who believes his or her rights have been violated should contact the Employee Benefits department or Human Resources immediately.

Possession of Weapons Policy
It shall be a violation of Seattle Times policy for any individual, other than officers of the law, to bring any firearm or other weapon onto any company premises, either on his/her person or automobile or other vehicle or to have any firearm or other weapon on his or her person or vehicle during interactions with Seattle Times employees and/or representatives.

"Weapon" means any object subject to a "license to carry or own" such as Mace. "Weapon" may also mean pepper spray, sticks, tools, pocket knives or any object used in any act of violence or a threat of violence as outlined below.

Threats and Violence Policy
Of paramount importance to The Seattle Times is the safety and security of its employees and visitors. The Seattle Times is committed to providing a workplace that is free from threats or acts of violence.

In keeping with this commitment, The Seattle Times has established a policy that allows "zero tolerance" for threats, threatening behavior or acts of violence against employees or others on Seattle Times properties by any Seattle Times employee or by any individual with access to Seattle Times properties. Compliance with this policy is a condition of employment and/or access to company employees or premises. Any person who makes real or implied threats, exhibits threatening or violent behavior, or engages in threatening or violent acts on Seattle Times properties shall be removed from the premises as quickly as safety permits, and shall remain off Seattle Times premises pending the outcome of an investigation. Should an investigation substantiate that a violation of this policy has occurred, The Seattle Times will initiate an appropriate response. Although The Times views any violation of this policy as wholly unacceptable in the workplace setting and it will take strict action based on this view, the level of the discipline and/or response, will vary according the nature and manner of the violation. Action taken may include, but is not limited to, discipline up to and including termination of employment, and/or termination of any business relationship, and/or seeking arrest and prosecution of the person or persons involved. This policy reflects the values of The Seattle Times. No other existing Seattle Times policy, practice, or procedure should be interpreted to prohibit or limit actions or decisions designed to prevent a threat from being carried out, a violent act from occurring or a life-threatening situation from developing.

Every verbal or physical threat of violence will be treated seriously. All Seattle Times employees are responsible for notifying their supervisor, manager or HR manager of any threats they have witnessed, received, or know that another person has witnessed or received. Vendors witnessing threatening behavior must inform the manager of the department their products or service supports. Even absent an actual threat, employees and vendors are to alert management to any behavior they have witnessed, on or off our premises, that they regard as posing a threat to themselves or others within the company. This report must be made regardless of the nature of the relationship between the individual who initiated the threat or threatening behavior and the person or persons who were threatened or were the focus of the threatening behavior.

If an employee or vendor becomes aware of any actual or imminent violence, obtaining emergency assistance must be a matter of first priority. The employee or vendor should immediately contact the security office and, if appropriate for the safety of employees, visitors and/or others, contact the local law enforcement authorities by dialing 9-911. Immediately after contacting the authorities for emergency assistance, the employee or vendor must report the incident to his or her supervisor, or for vendors, the manager for the department their products or service supports. If the appropriate manager or supervisor is not available, the employee or vendor should then contact Human Resources immediately after contacting the law enforcement authorities. The notified supervisor or manager must then immediately notify the Human Resources manager.

In the case of threats of violence, employees must contact their supervisor(s) immediately. The supervisor must then notify the Human Resources manager. Employees may report any incident of violence or threat of violence without fear of reprisal of any kind.

Full cooperation by all employees and vendors is necessary for The Seattle Times to accomplish its goal of providing a safe workplace and protecting employees and patrons from threats to their safety. The Seattle Times must be informed about individuals who have been ordered by the courts or other legally constituted entities to stay away from Seattle Times company locations.

Individuals who apply for or obtain a protective or restraining order that lists company locations as being protected areas are required to provide their managers or the manager in charge of the security staff a copy of the petition as well as the declarations used to seek the order. They must also provide a copy of any temporary protective or restraining order which is granted and a copy of any protective or restraining order that is made permanent. The Seattle Times understands the sensitivity of the information requested and will take steps to protect the privacy of the reporting individual(s).

Substance Abuse Policy
The Seattle Times is committed to providing a safe, healthful and productive work environment and believes maintaining a drug and alcohol-free workplace is essential to that objective. The Seattle Times seeks to minimize safety related, on-the-job accidents by employees and visitors through a company-wide substance abuse policy. This means that anyone on the premises of any Seattle Times facility, operating any equipment owned or leased by The Seattle Times, or working for The Seattle Times regardless of location, is expected to be free of any mood altering substance, whether legal or illegal, that can negatively affect job performance or risk the health and safety of themselves, employees or the general community.

It is the firm position of The Seattle Times that alcoholic beverages or other drugs are not to be brought on The Seattle Times property nor consumed there at any time, except as prescribed in writing by a licensed physician. The employee's supervisor must be notified if an employee is reporting for work under the influence of any medication (over-the-counter or prescribed by a physician) that could cause impaired performance.

The sale, purchase, transfer, use or possession of alcoholic beverages or drugs on the property of The Seattle Times is prohibited. When probable suspicion exists, The Seattle Times may search company property, including lockers and desks, to confirm the presence of such items. All confiscated drugs or contraband will be turned over to appropriate law enforcement authorities. Violators shall be subject to disciplinary action up to and including discharge, and appropriate law enforcement officials will be notified when deemed appropriate by The Seattle Times.

The Seattle Times supports providing assistance to individuals with substance abuse problems through the Employee Assistance Program and treatment coverage under the medical insurance plans for eligible employees. However, employees who have received or are receiving care for substance abuse problems are expected to be free of any mood altering substances at work. Employees failing to adhere to this policy will be subject to discipline, including discharge. It is the intent of this policy to encourage and support employee recovery from substance abuse through the Employee Assistance Program. The Seattle Times will vigorously pursue the purpose of this policy.

Smoking Policy
Smoking is not permitted in any Seattle Times facility or anywhere on the company premises. Smoking is also not permitted in any Seattle Time's branch, dispatch or distribution vehicle passenger area, cargo box or trailer. Smoking means the possession of a lighted cigarette, cigar, pipe or any other lighted tobacco product.