Harassment in the Workplace: How to Respond to Complaints of Harassment

Third of a three part series: Harassment in the Workplace
Written by: The Deerfield Team

You did everything right. You read parts 1 and 2 of our series, so you know what harassment is and how to prevent it. You’ve disseminated a perfect anti-harassment policy, run fantastic trainings, and carefully vetted new hires. Then one day an employee walks into your office claiming that your best manager has been harassing her for weeks.

Prevention might be the best medicine, but it isn’t a cure-all. You must be prepared. Learn how to investigate harassment allegations—including conducting interviews, avoiding retaliation, and resolving the issue—before you hear that knock on your door.

The Art of Investigation

Once you are aware of a harassment complaint, you are responsible for conducting a prompt, thorough, and impartial investigation. This means interviewing the people involved to determine what happened and whether harassment occurred. Simple as it sounds, an effective investigation requires a lot of skill and wisdom.

Do:

  • Initiate stopgap measures to prevent harassment from continuing in the meantime. (Make sure these measures don’t burden the complainant.)
  • Choose an investigator who is not close with or a supervisor to the employees involved, knows the law about harassment, and is skilled in interview techniques.
  • Focus on behavior—what was done, said, and seen—not opinions during interviews.
  • Look for evidence: recovered emails, receipts, witnessed statements.
  • Keep detailed, fact-centered notes throughout the process.
  • Foster a sense of privacy during the interviews. Don’t conduct interviews over barriers like desks or tables.
  • Remind everyone involved that retaliation is strictly forbidden.
  • Be sensitive to the emotional pressures being felt by all parties. Remain open and gentle.
  • Ask the complainant what outcome they would like to see happen, without promising they will get the desired outcome.
  • Make sure you respond consistently to all harassment allegations, from the speed of the investigation to the disciplinary actions taken.
  • Document everything.

Don’t:

  • Ignore a third party or anonymous complaint.
  • Wait to start the investigation after a complaint has been filed.
  • Forget to familiarize yourself with EEOC guidelines before conducting an investigation.
  • Totally stop communication with complainant or alleged harasser during the process.
  • Ask the complainant to reach out to potential witnesses.
  • Expect straightforward evidence or perfectly accurate testimonies from either side.
  • Promise the interviewees total confidentiality, but do try to keep information as confidential as possible.
  • Express opinions or make assumptions about the complainant or alleged harasser until the investigation is finished.

The Biggest Don’t: Retaliation

Even employers and managers with the best intentions can do things that may appear as retaliation. Make sure to avoid negligent and accidental behaviors yourself and train everyone involved in the investigation to control their response as well. Make sure to manage resentment, prevent avoidance, deal with frustration, and ultimately avert a lawsuit. Read our blog post, Retaliation claims and what you need to be aware of to prevent them, for more information.

If the Investigation Was Inconclusive

If you couldn’t find evidence for or against the complainant’s allegation, let them know. Thank them for coming to you with the complaint and encourage them to report any future harassment. Make sure to keep up with this employee to make sure everything is all right. Let the accused also know that the allegations could not be substantiated, so they will not be subject to discipline. Remind them of your anti-harassment policy and invite them to share any evidence for their innocence they might find in the future.

If Harassment Did Not Occur

If you find out that harassment did not happen, assume that the accuser was mistaken, not lying, and let him or her know that unfortunately you could not substantiate the allegation. Inform the alleged harasser that they are no longer under investigation but that they are still beholden to the harassment policy in the future. In the rare case that you find irrefutable evidence that the accuser set up the alleged harasser intentionally, talk to an employment lawyer.

If Harassment Did Occur

If your investigation shows that harassment did occur, take action. Do whatever it takes to prevent it from happening again and make sure the victim is free from any negative effects of the harassment. Enact disciplinary measures against the harasser according to the seriousness of the harassment. This is determined by factors such as level of physicality, repetition of offense, how much authority and seniority the perpetrator had compared to the victim (the more, the harsher the punishment), and the effect on the harassed.

Conclusion

Unfortunately, prevention is not enough when it comes to harassment in the workplace. Conducting a prompt, thorough, and fair investigation with the appropriate follow-up is key to maintaining a safe environment and the trust of your employees. A well-documented investigation is also key to protecting yourself from vicarious employer liability.

As always, we are here to help you any way we can. Please don’t hesitate to call or email if you need us.

The Deerfield Team
800.233.6428
info@deerfieldadvisors.com

 


Sources:

Cooper, Lauren M. “Top Ten Tips for Conducting an Effective Sexual Harassment Investigation.” http://www.hrhero.com/hl/articles/2012/07/31/top-10-tips-for-conducting-an-effective-sexual-harassment-investigation/

“Interviewing Techniques for Harassment Investigations.” http://reid.com/pdfs/hitpreview.pdf

“Investigating The Complaint.” University of Pittsburgh Office of the Provost. http://www.provost.pitt.edu/information-on/InvestigatingTheComplaint.html

“Questions and Answers for Small Employers on Employer Liability for Harassment by Supervisor.” The U.S. Equal Employment Opportunity Commission, April 1 2010. http://www.eeoc.gov/policy/docs/harassment-facts.html

Shea, Robin. “ ‘Must-haves’ for your harassment investigation no. 3: A prompt, thorough, and fair investigation.” Employment and Labor Insider, June 5, 2015. http://www.employmentandlaborinsider.com/harassment/must-haves-for-your-harassment-investigation/

Shea, Robin. “Harassment ‘must-have’ no. 4: The Determination.” Employment and Labor Insider, June 12, 2015. http://www.employmentandlaborinsider.com/harassment/harassment-must-have-no-4-the-determination/

Shea, Robin. “Harassment ‘must-have’ no. 5: No retaliation!” Employment and Labor Insider, June 19, 2015. http://www.employmentandlaborinsider.com/harassment/harassment-must-have-no-5-no-retaliation/

 

DISCLAIMER

This article is intended only as a general discussion of these issues & we cannot guarantee the accuracy thereof. It does not purport to provide legal, accounting, or other professional advice. If such advice is needed, please consult with your attorney, accountant, or other qualified adviser. The Views expressed here do not constitute legal advice. The information contained herein is for general guidance of matter only and not for the purpose of providing legal advice. Accordingly, the information provided herein is provided with the understanding that Deerfield Advisors is not engaged in rendering legal advice. Deerfield Advisors strongly advises that clients and/or the reader of this publication contact an attorney to obtain advice with respect to any particular issue or problem discussed here. Also, please know that discussions of insurance policy language is descriptive only. We strongly advise that one’s individual policy & one’s advisor be consulted regarding this subject matter before any action is taken in any way. Coverage afforded under any insurance policy issued is subject to individual policy terms and conditions. The Deerfield Advisor White Paper Series is a registered trademark of Deerfield Asset Management Inc. DBA, Deerfield Advisors and is produced by Deerfield Advisors for the benefit of its clients, and any other use is strictly prohibited. All rights reserved. Copyright © 2015

 

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Harassment in the Workplace: What Makes Good Policy and Training?

Second of a three part series: Harassment in the Workplace

rectangle-hr-compliance4In our previous article, we outlined what harassment is and how state laws govern most harassment related legislation. We also mentioned the conditions, outlined by the Supreme Court in Vance v. Ball State University, under which an employer in any state is liable for an employee’s harassment. The employer is liable if the perpetrator is the victim’s supervisor, i.e., a person who has authority over employment decisions or the daily work activities of an employee. The employer is also liable if the company has been negligent, i.e., has no process in place to prevent harassment.

Thankfully, the methods to avoid allegations of negligence and can go a long way toward protecting the business owner from lawsuit. In this article, we’ll discuss best practices for harassment prevention every employer should know.

Best practices: A well-reasoned anti-harassment policy

Creating and communicating a strict, clear policy on harassment is the best way to keep potential harassers in check and create a sense of safety among all employees. Though an employer is not automatically liable for not having an anti-harassment policy, not having a policy eliminates a potentially important defense against future harassment claims.

Essential elements

  • Specify the non-sexual basis for harassment (e.g. race, religion, national origin, age, disability, and genetic information).
  • Specify the types of behavior that violate your policy, and what the penalties for these behaviors are. Give examples.
  • Even if you do not have an HR department, designate people outside the chain of command to accept complaints. If a supervisor is the harasser or cannot be impartial, the employee needs to have other officials to report to. There should always be an available and impartial point of contact for any employee that wants to report harassment.
  • State intolerance for retaliation against anyone who complains of harassment or is involved in a proceeding related to harassment.
  • Clearly set out the investigation procedure.
  • Get acknowledgment. Have employees sign on paper or electronically for their policy (and store their signed copies in case of a future charge), and go over the policy verbally with any illiterate employees.

Suggestions

  • Write the policy in plain language that all employees can understand. This means writing it in plain English and translating the policy into any other languages your employees speak.
  • Encourage employees to report harassment immediately, before it has become severe or pervasive.
  • Assure that harassment complaints will be handled with as much confidentiality as possible.
  • Consider prohibiting harassment based on sexual orientation or gender identity. It may be necessary in your state or if you’re a federal contractor.
  • As social media and smartphones are becoming ubiquitous in the workplace, blurring personal and professional lines, it’s increasingly important to address cyber harassment specifically.
  • If your policy includes protections beyond the legal requirements, include contract disclaimer language to prevent becoming legally liable for upholding these protections. See Marini vs. Costco for an example of how an excellent personnel manual citing very high standards might backfire in court.

Best practices: Effective training

Wouldn’t it be wonderful if simply publishing a thorough, clear policy were enough to educate employees on harassment? Unfortunately, most people need a little more guidance than that. The effective communication of your policies will take some strategizing, resource allocation, and consistency.

Guidelines for different types of employees

  • Supervisors. Managers and supervisors are your greatest liability and your greatest asset. Start with a very thorough training of 2.5 hours that covers specific examples and legal implications of harassment (with real life examples!), as well as details of your policy. A shorter session can follow every 12-18 months.
  • Pseudo-supervisors. Employees who don’t have the power to hire and fire other employees but are still seen as leaders in some way should also get special attention because they are likely to receive some harassment claims. Give them the management version of training, either as a separate session or as participants in the management training itself.
  • Non-management. Conduct training sessions every 12-18 months of about an hour which explain your policy, what harassment is, the consequences of harassment, how to report it, and what retaliation is.
  • Temps, independent contractors, and interns. Make sure to give all employees, especially those considered low in the hierarchy, your anti-harassment training.
  • Multilingual employees. If some (or even one!) of your employees is not fluent in English, invest in a translator.
  • New employees. Give new hires the first session of training as quickly as you can, even if it’s in the form of a recording of a previous session.

How to make the training “stick”

  • Make sure the speaker is engaging. Hire someone from outside your company if necessary.
  • Hold multiple sessions, so that everyone can attend and can engage better with each other and the speaker as a smaller group.
  • Have an HR representative at every session to answer specific questions. They might also gain some insight simply by attending the session about current or potential problems.
  • Illustrate harassment using live presentations and concrete examples.
  • Keep the training relevant by basing examples on recent cases.
  • Use multiple methods, such as live actors, discussion, quizzes, and videos, to keep employees engaged. A simple role-playing exercise practicing conversation between a potential harasser and someone who feels offended by them can demonstrate ways to prevent situations from spiraling out of control.

If you follow these steps, you’re well on your way to creating a safe work environment and protecting yourself from vicarious liability for an employee’s harassment. In the next article of this series, we’ll talk about what to do when even the best prevention methods fail and a harassment claim is made.

As always, we are here to help you any way we can. Please don’t hesitate to call or email if you need us.

The Deerfield Team
 800.233.6428
info@deerfieldadvisors.com

 


SOURCES:

Bridgeford, Lydell C. “Q&A: SOME TRICKY ASPECTS OF ANTI-HARASSMENT TRAINING, RETALIATION CLAIMS.” Bloomberg BNA Labor & Employment Blog, Jul 16 2013. http://www.bna.com/qa-tricky-aspects-b17179875217/

Bussing, Heather. “When Employers are Liable for Harassment.” HR Examiner, June 24 2013. http://www.hrexaminer.com/when-employers-are-liable-for-harassment/

Miller, Bridget. “What Should Be Included in Anti-Harassment Training?” HR Daily Advisor, May 23 2014. http://hrdailyadvisor.blr.com/2014/05/23/what-should-be-included-in-anti-harassment-training/#

Monsees, Paul R. “Employer’s Super Anti-Harassment Policy May Increase Its Liability.” Labor & Employment LawPerspectives, Dec 8 2014.  http://www.laboremploymentperspectives.com/2014/12/08/employers-super-anti-harassment-policy-may-increase-its-liability/

“Questions and Answers for Small Employers on Employer Liability for Harassment by Supervisor.” The U.S. Equal Employment Opportunity Commission, April 1 2010. http://www.eeoc.gov/policy/docs/harassment-facts.html

Shea, Robin. “5 Harassment Must-Haves for Employers.” Employment and Labor Insider, May 29, 2015.http://www.employmentandlaborinsider.com/harassment/5-harassment-must-haves-for-employers/

Wilkie, Dana. “Anti-Harassment Training Following the Supreme Court’s Vance Ruling.” Society for Human Resource Management, July 16 2013. http://www.shrm.org/hrdisciplines/employeerelations/articles/pages/anti-harassment-training-following-supremecourt-vance-ruling.aspx

“Workplace Harassment Benchmark Survey Demonstrates How Organizations are Addressing New and GrowingEmployment Law Challenges.”  NAVEX Global, May 20 2013. http://www.navexglobal.com/company/press-room/workplace-harassment-benchmark-survey-demonstrates-how-organizations-are

 


DISCLAIMER

This article is intended only as a general discussion of these issues & we cannot guarantee the accuracy thereof. It does not purport to provide legal, accounting, or other professional advice. If such advice is needed, please consult with your attorney, accountant, or other qualified adviser. The Views expressed here do not constitute legal advice. The information contained herein is for general guidance of matter only and not for the purpose of providing legal advice. Accordingly, the information provided herein is provided with the understanding that Deerfield Advisors is not engaged in rendering legal advice. Deerfield Advisors strongly advises that clients and/or the reader of this publication contact an attorney to obtain advice with respect to any particular issue or problem discussed here. Also, please know that discussions of insurance policy language is descriptive only. We strongly advise that one’s individual policy & one’s advisor be consulted regarding this subject matter before any action is taken in any way. Coverage afforded under any insurance policy issued is subject to individual policy terms and conditions. The Deerfield Advisor White Paper Series is a registered trademark of Deerfield Asset Management Inc. DBA, Deerfield Advisors and is produced by Deerfield Advisors for the benefit of its clients, and any other use is strictly prohibited. All rights reserved. Copyright © 2015

 

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HSA Plans for Business – Why you may want to consider it

sketch1With all of the recent media hype regarding federal health insurance reform and the state of the health insurance industry, you have no doubt heard the term HSA. HSA stands for Health Savings Account. It is a form of consumer directed health coverage which pairs a high-deductible health plan with a tax-free savings account for medical expenses. These plans are designed to reduce healthcare insurance costs for employers and employees alike & causes people with an HSA qualified policy to have a little skin in the game.

These are the main advantages of this strategy:

  • Individual plans are 100% portable, meaning that they are not tied to the employer’s business. The employees can take the coverage with them, wherever they go, as well as deal with the grunt work involved, thus removing it off of your plate and allowing you to concentrate on running your business.

  • Contributions from the business are expendable, so you can create an attractive & deductible employee benefit.
  • HSA accounts qualify for year to year “rollovers,” which enable the employee to create a sizeable health insurance cushion.

Saving for the Future:

Proponents of HSAs believe that it is an important reform that will help reduce the growth of health care costs and increase the efficiency of the health care system. They contend that HSAs encourage savings for future health care expenses, allow the patient to receive needed care without a gatekeeper to determine what benefits are allowed, and make consumers more responsible for their own health care choices through the required high deductible health plan options which they will choose. Funds in an HSA account can be used to meet your deductible as well as other non-covered legitimate medical expenses including vision and dental expenses. Funds in an HSA can be used for any family member’s eligible medical expenses even though HSA accounts are individual accounts. Small businesses need a creative solution to health insurance that will enable them to retain their valued employees and not “break the bank”. Like any health care option, health savings accounts have advantages and disadvantages. When considering a health savings account, think about your anticipated health care expenses, your financial situation and how much control you want over your health care spending. If you’re generally healthy and want to save for future health care expenses, an HSA may be an attractive choice. On the other hand, if you anticipate needing expensive medical care in the next year and would find it hard to meet a high deductible, an HSA might not be your best option. Therefore you will need to determine what works best for you.

As always, we are here to help you any way we can. Please don’t hesitate to call or email if you need us.

The Deerfield Team
800.233.6428
info@deerfieldadvisors.com

 


DISCLAIMER

This article is intended only as a general discussion of these issues & we cannot guarantee the accuracy thereof. It does not purport to provide legal, accounting, or other professional advice. If such advice is needed, please consult with your attorney, accountant, or other qualified adviser. The Views expressed here do not constitute legal advice. The information contained herein is for general guidance of matter only and not for the purpose of providing legal advice. Accordingly, the information provided herein is provided with the understanding that Deerfield Advisors is not engaged in rendering legal advice. Deerfield Advisors strongly advises that clients and/or the reader of this publication contact an attorney to obtain advice with respect to any particular issue or problem discussed here. Also, please know that discussions of insurance policy language is descriptive only. We strongly advise that one’s individual policy & one’s advisor be consulted regarding this subject matter before any action is taken in any way. Coverage afforded under any insurance policy issued is subject to individual policy terms and conditions. The Deerfield Advisor White Paper Series is a registered trademark of Deerfield Asset Management Inc. DBA, Deerfield Advisors and is produced by Deerfield Advisors for the benefit of its clients, and any other use is strictly prohibited. All rights reserved. Copyright © 2015

 

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Harassment in the Workplace: An Overview

First of a three part series: Harassment in the Workplace

An elderly employee is called “grandpa” by his coworkers. A young employee complains that the art on the office walls makes her uncomfortable. A supervisor jokes that a female employee might get a promotion if she gets a drink with him after work. A white employee sends derogatory emails to an African American employee. A female supervisor reprimands a male employee for being late to work three times in a row.

Which of these instances are forms of harassment? What legal responsibility does an employer have in these cases? This is the first article in a series that aims to answer these questions. Understanding what constitutes harassment, as well as how to prevent and respond to allegations of unlawful harassment, is essential to maintaining a healthy work environment and protecting your business’ reputation.

Harassment: A Definition

Harassment is generally defined as repeated, unwelcome behavior that threatens, annoys, intimidates, scares, demeans, or offends the victim.

Federal laws prohibit harassment related to discrimination. To qualify as such, the behavior must first be based on race, color, sex, religion, or national origin (Title VII); on age (ADEA); on disability (ADA); or on genetic information (GINA). Second, the victim must consider the actions abusive. Finally, the actions must be severe and pervasive enough to create a hostile environment by the standards of any reasonable person.¹  The line between teasing and harassment, between a healthy and a hostile work environment, is determined on a case-by-case basis. Importantly, harassment initiated against an employee because they opposed discrimination or participated in an investigation related to EEO statuses—called retaliation—also violates federal law.

Harassment based on the victim’s protected status can lead to an investigation by the Equal Employment Opportunity Commission. Claims of discrimination-based harassment have risen tremendously in recent years. In 2014, there were 26,820 harassment charges filed with the EEOC, resulting in $93.9 million in monetary benefits (down from $129 million in 2013). Of course, many more cases of harassment occur than are successfully charged. In a 2013 Huffington Post/You Gov poll, only 30% of respondents who experienced being sexually harassed in the workplace actually reported the harassment to their employer.

Outside discrimination, state laws are primarily responsible for governing harassment. In Texas, behavior that qualifies as harassment must involve obscenity; threatening to cause bodily harm or commit a felony against the victim or their family or property; conveying a false report that someone has suffered bodily harm or death; anonymous or offensive telephone calls; or repeated electronic communications “reasonably likely to harass, annoy, alarm, abuse, torment, embarrass, or offend another.” ²

Actions that may be considered harassment
Derogatory comments or slurs
Obscene propositions
Assault
Unwelcome touching
Physical interference with work or movement
Derogatory posters, cartoons, or art
Threats
Sexual demands

Actions that would not be considered harassment
A hug between mututally consenting friends
A compliment on physical appearance
A single off-color joke
Failing to refill the office coffee pot

Employer Liability

There are two cases in which employers are legally responsible for harassment.

The Supreme Court held that employers have “vicarious liability” for harassment by supervisors in two cases decided in 1998, Burlington Industries, Inc. v. Ellerth and Faragher v. City of Boca Raton. In 2013, the Court clarified in Vance v. Ball State University that an employer is not liable for its employee’s discriminatory harassment unless the harasser is a supervisor of the victim—with “supervisor” newly defined as someone who has the ability to hire, fire, demote, promote, transfer, discipline or change the employee’s job duties. The EEOC addresses vicarious employer liability in detail.

The Court also decided that the employer is also liable for harassment, even when the harasser is not a supervisor, when the employer is found to be “negligent.” Negligence means 1) failing to have a strategy for preventing harassment, or 2) knowing about the conduct and failing to take appropriate steps.

In the next articles in this series, we will address best practices for harassment prevention and following up on harrassment allegations. Apart from hiring trustworthy supervisors, there is no better protection from costly, detrimental harassment charges than implementing wise policies and processes before a complaint is ever made. Seeking legal counsel from a qualified employment lawyer is advised if you discover there is a problem or potential problem.

As always, we are here to help you any way we can. Please don’t hesitate to call or email if you need us.

The Deerfield Team
800.233.6428
info@deerfieldadvisors.com

 


 

References:

1.“What do I need to know about… workplace harassment.” United States Department of Labor. http://www.dol.gov/oasam/programs/crc/2011-workplace-harassment.htm

2.“TEX PE. CODE ANN. § 42.07 : Texas Statutes – Section 42.07: HARASSMENT.” http://codes.lp.findlaw.com/txstatutes/PE/9/42/42.07#sthash.3xQkEMaY.dpuf

SOURCES:

“Enforcement Guidance on Vicarious Employer Liability for Unlawful Harassment by Supervisors: Notice 915.002.” The U.S. Equal Employment Opportunity Commission, June 18 1999. http://www.eeoc.gov/policy/docs/harassment.html

“Harassment Definition.” Law.com. http://dictionary.law.com/Default.aspx?selected=853

“Harassment Law & Legal Definition.” USLegal.com. http://definitions.uslegal.com/h/harassment/

“Questions and Answers for Small Employers on Employer Liability for Harassment by Supervisor.” The U.S. Equal Employment Opportunity Commission, April 1 2010. http://www.eeoc.gov/policy/docs/harassment-facts.html

“Supreme Court makes it harder to sue businesses for retaliation and discrimination.” CBS News, June 24 2013. http://www.cbsnews.com/news/supreme-court-makes-it-harder-to-sue-businesses-for-retaliation-and-discrimination/

“TEX PE. CODE ANN. § 42.07 : Texas Statutes – Section 42.07: HARASSMENT.” /PE/9/42/42.07#sthash.3xQkEMaY.dpuf

“What do I need to know about… workplace harassment.” United States Department of Labor. http://www.dol.gov/oasam/programs/crc/2011-workplace-harassment.htm

Bussing, Heather. “When Employers are Liable for Harassment.” HR Examiner, June 24 2013. http://www.hrexaminer.com/when-employers-are-liable-for-harassment/

Eugene Volokh, What Speech Does “Hostile Work Environment” Harassment Law Restrict?, 85 Geo. L.J. 627 (1997). http://www2.law.ucla.edu/volokh/harass/breadth.htm

 

DISCLAIMER

This article is intended only as a general discussion of these issues & we cannot guarantee the accuracy thereof. It does not purport to provide legal, accounting, or other professional advice. If such advice is needed, please consult with your attorney, accountant, or other qualified adviser. The Views expressed here do not constitute legal advice. The information contained herein is for general guidance of matter only and not for the purpose of providing legal advice. Accordingly, the information provided herein is provided with the understanding that Deerfield Advisors is not engaged in rendering legal advice. Deerfield Advisors strongly advises that clients and/or the reader of this publication contact an attorney to obtain advice with respect to any particular issue or problem discussed here. Also, please know that discussions of insurance policy language is descriptive only. We strongly advise that one’s individual policy & one’s advisor be consulted regarding this subject matter before any action is taken in any way. Coverage afforded under any insurance policy issued is subject to individual policy terms and conditions. The Deerfield Advisor White Paper Series is a registered trademark of Deerfield Asset Management Inc. DBA, Deerfield Advisors and is produced by Deerfield Advisors for the benefit of its clients, and any other use is strictly prohibited. All rights reserved. Copyright © 2015

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