EEO, Harassment and Discrimination

Equal Employment Opportunity

It is the policy of Graham Holdings Company to provide equal employment opportunity in full compliance with all federal, state and local employment opportunity laws and regulations.

Discrimination and Harassment Prohibited

The Company is committed to providing a work environment where all employees work free from discrimination and harassment. In accordance with applicable law, we prohibit discrimination and harassment against any applicant or employee based on any legally-recognized basis, including, but not limited to: veteran status, uniformed service member status, race, color, religion, sex, sexual orientation, gender identity, age, pregnancy (including childbirth, lactation and related medical conditions), hairstyle based on race, national origin or ancestry, citizenship status, physical or mental disability, genetic information (including testing and characteristics) or any other consideration protected by federal, state or local law. Our commitment to equal opportunity employment applies to all persons involved in our operations and prohibits unlawful discrimination by any employee, including supervisors and coworkers. The Company will not tolerate harassment or discrimination in any form.

What Constitutes Harassment and Sexual Harassment

All harassment – including verbal or physical conduct, visual displays, threats, demands and retaliation – is prohibited.

With respect to sexual harassment, the Equal Employment Opportunity Commission has guidelines that define sexual harassment as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when:

  • Submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment, or used as the basis for employment decisions affecting such individual; or
  • Such conduct creates an intimidating, hostile or offensive working environment.

Sexual harassment can involve either a tangible employment action or a hostile work environment. Sexual harassment includes more than overt physical or verbal intimidation. Lewd or vulgar remarks, suggestive comments, posters, pictures and calendars, pressure for dates and sexual favors, and unacceptable physical contact are examples of what can constitute harassment.

It is important to realize that what may not be offensive to you may be offensive to others. Employees should consider carefully the effect of their words and actions on others, and should not assume that another employee’s failure to object means that the employee welcomes the behavior at issue.

The Company as a general matter does not seek to regulate the private social behavior of employees. However, intimate relationships between supervisors and employees whom they directly supervise are discouraged. Because of the undesirable workplace repercussions that they may have, any such relationship should be disclosed to the supervisor’s department head. All employees should understand that no one at the Company has the authority to offer job benefits or threaten job disadvantages based on the provision of sexual favors.

Sexual harassment also can occur among co-workers or result from behavior by contractors or other non-employees who have reason to interact with Company employees. Our policy extends to these circumstances as well.

Obligation to Report

Any employee who has knowledge of harassment or has reason to believe that he/she is being harassed must promptly report the harassment. The official procedure for reporting violations or suspected violations of this policy is located in in the back of this Code under the heading “How to Report a Violation.” Do not allow an inappropriate situation to continue by not reporting it, regardless of who is creating the situation.

Investigations

The Company will promptly investigate allegations of harassment. Such investigations will be conducted consistent with all legal requirements and the Company’s obligation to investigate, report and correct any misconduct. Any employee who is found to have violated the Company’s policies on equal employment opportunity and harassment is subject to discipline, including discharge.

No Retaliation

The Company will not tolerate retaliation in any form against an employee who has, in good faith, reported an incident of discrimination or harassment, and no employee should fear that making such a report will endanger his/her job.

Revised June 2020


— The Following Applies to Employees in New York —

New York Employees

Sexual Harassment – New York

Graham Holdings Company is committed to providing a work environment that is free of illicit sexual harassment and strictly prohibits sexual harassment against any individuals involved in company operations, including employees, applicants for employment, interns, vendors, contractors, sub-contractors and consultants. Harassment by any employee of the Company, regardless of position, and harassment by third parties involved in company operations is also prohibited. If harassment in the workplace is perpetrated by an employee or by someone not employed by the Company, the procedures in this policy should be followed. The workplace includes:

  • Actual worksites;
  • Any setting in which work-related business is being conducted (whether during or after normal business hours);
  • Company-sponsored events; and
  • Company-owned/controlled property.

Sexual harassment is also prohibited as a form of gender-based discrimination under the New York State Human Rights Law, Title VII of the federal Civil Rights Act of l964, and The New York City Human Rights Law. A Stop Sexual Harassment Act Fact Sheet is posted alongside our other employment postings and provided to employees upon hire. Virtual employees receive supplemental notices electronically.

All employees are also expected to comply with the Equal Employment Opportunity, Harassment and Sexual Harassment policy, as set forth in the  Graham Holdings Code of Business Conduct.

Sexual Harassment Defined

Sexual harassment is unwelcome verbal or physical behavior based upon a person’s gender and includes unwanted verbal or physical sexual advances, requests for sexual favors or visual, verbal or physical conduct of a sexual nature when:

  • Submission to such conduct is made a term or condition of employment; or
  • Submission to, or rejection of, such conduct is used as a basis for employment decisions affecting the individual; or
  • Such conduct has the purpose or effect of unreasonably interfering with an employee’s work performance or creating an intimidating, hostile or offensive working environment.

The following is a non-exhaustive list of the types of conduct prohibited by this policy:

  • Unwanted sexual advances or propositions (including repeated and unwelcome requests for dates);
  • Offers of employment benefits in exchange for sexual favors;
  • Making or threatening reprisals after a negative response to sexual advances;
  • Visual conduct including leering, making sexual gestures, displaying pornographic or sexually suggestive images, objects, pictures, cartoons, graffiti, posters or websites on computers, emails, cell phones or bulletin boards;
  • Verbal conduct including making or using sexist remarks or derogatory comments based on gender, innuendos, epithets, slurs, sexually explicit jokes, or lewd or sexual comments about an individual’s appearance, body or dress, whistling or making suggestive or insulting sounds;
  • Verbal and/or written abuse of a sexual nature, graphic verbal and/or written sexually degrading commentary about an individual’s body or dress, sexually suggestive or obscene letters, notes, invitations, emails, text messages, tweets or other social media postings;
  • Physical conduct including unwelcome or inappropriate touching of employees or customers, assault or impeding or blocking normal movements; and
  • Retaliation for making reports or threatening to report sexual harassment.

Sexual harassment can occur between males and females, or between persons of the same sex. Harassment on the basis of someone’s gender, including transgender status, or on the basis of someone’s sexual orientation is a form of sexual harassment that is also prohibited.

Protection Against Retaliation

Retaliation is prohibited against any person by another employee or by Graham Holdings

Company for:

  • Using the complaint procedure described below;
  • Reporting proscribed harassment;
  • Objecting to, opposing or speaking out against sexual harassment; or
  • Filing, testifying, assisting or participating in any manner in any investigation, proceeding or hearing conducted by a governmental enforcement agency.

Prohibited retaliation includes, but is not limited to:

  • Termination, demotion, suspension, failure to hire or consider for hire;
  • Failure to give equal consideration in making employment decisions:
  • Failure to make employment recommendations impartially:
  • Adversely affecting working conditions or otherwise denying any employment benefit, as well as more subtle behaviors such as increased workload or transfer to a less desirable location.

Individuals who believe they have been subjected to retaliation, or believe that another individual has been subjected to retaliation, should report this concern using the complaint procedure set forth below.

Complaint Procedure

Any applicant for employment, employee or intern who believes he or she has been subjected to sexual harassment, or who believes another individual has been subjected to sexual harassment, should as soon as possible, provide a written or verbal report to his or her manager, department manager, or your Human Resources department. An employee may also

contact the Ethics Hotline via the web at https://ghco.alertline.com or by toll-free call to 866-687-

8972. To submit a complaint in writing, employees can use the sexual harassment complaint form attached to the sexual harassment policy.

Employees are not required to raise a complaint with their immediate supervisor, manager or person who has engaged in the reported conduct. Supervisors and managers who receive complaints of misconduct must immediately report such complaints to corporate Human Resources who will attempt to resolve issues internally. Supervisors or managers who knowingly allow misconduct to continue may be subject to discipline, up to and including termination of employment.

After the Company receives a report of alleged harassment, it will undertake a fair, timely, thorough and objective investigation in an effort to reach reasonable conclusions based on the information collected. The Company will maintain confidentiality surrounding the investigation to the extent possible, consistent with a thorough and objective investigation and to the extent permitted under applicable federal and state law. The investigation will be completed and a determination made and communicated to the employee as soon as practical.

All employees are expected to fully cooperate with any investigation into a complaint of proscribed sexual harassment or retaliation.

Employees have the right to file a formal complaint with the federal Equal Employment Opportunity Commission (EEOC), the New York State Division of Human Rights (NYDHR), the New York City Commission on Human Rights (NYCCHR) or in a court of law. The EEOC,

NYDHR and NYCCHR will accept and investigate charges. To report sexual harassment to the NYCCHR, visit www1.nyc.gov to obtain information about how to file a complaint or report discrimination. To file a complaint with the New York State Division of Human Rights, you can visit the Division’s website at www.dhr.ny.gov. To file a charge with the EEOC you can visit the EEOC’s website at www.eeoc.gov. Additional information, including the physical location of

agency offices, can also be found on these websites. Information regarding federal, state and

city courts is also available online.

Discipline

If the Company determines that this policy has been violated, prompt remedial action will be taken, commensurate with the severity of the offense, up to and including termination of employment. Appropriate action will also be taken to deter any such conduct in the future.

Good Faith Reporting

The initiation of a good faith complaint of harassment or retaliation will not be grounds for disciplinary or other retaliatory action, even if the allegations cannot be substantiated or the employee was mistaken about the illegality of the conduct. Any individual who makes a complaint that is demonstrated to be intentionally false may be subject to discipline, up to and including termination of employment.