{
  "$schema": "https://clarusclm.com/schemas/policy-rollout/v1.json",
  "template_id": "harassment",
  "version": {
    "body_text": "ANTI-HARASSMENT AND REPORTING POLICY\n\n1. ZERO TOLERANCE\nThe company prohibits harassment, discrimination, and retaliation in any form. Prohibited conduct includes unwelcome conduct based on race, color, religion, sex (including pregnancy, sexual orientation, gender identity, gender expression), national origin, age, disability, genetic information, military or veteran status, or any other category protected by applicable law.\n\n2. SCOPE\nThis policy applies to all employees, contractors, vendors, customers, and visitors. It applies to in-person interactions, phone, email, video, chat, and any work-related setting.\n\n3. REPORTING CHANNELS\nReports may be made to: (a) any manager, (b) the People team via people@example.com, (c) the anonymous compliance hotline at the published number, (d) the General Counsel directly. Reports may be made anonymously and will be investigated to the extent possible without identifying the reporter.\n\n4. INVESTIGATION PROCEDURE\nAll reports are documented and investigated promptly. The investigator interviews the reporter, the respondent, and material witnesses. Investigation findings are documented and a determination is made within 30 days, or sooner if the conduct is severe.\n\n5. INTERIM MEASURES\nDuring an open investigation, the company may separate the reporter and respondent (schedule changes, reassignment, paid leave) to protect the reporter without prejudging the outcome.\n\n6. RETALIATION PROHIBITION\nRetaliation against any person who reports in good faith, participates in an investigation, or opposes prohibited conduct is itself a violation of this policy and may result in termination.\n\n7. TRAINING\nAll employees complete anti-harassment training within 30 days of hire and annually thereafter. Managers complete additional supervisor training within 30 days of becoming a manager and annually thereafter.\n\n8. CONSEQUENCES\nViolations may result in discipline up to and including termination. The severity of the response is calibrated to the severity of the conduct.",
    "change_summary": "Initial 2026 anti-harassment policy."
  },
  "rollout": {
    "audience": {
      "jurisdiction_codes": [],
      "department_ids": [],
      "employee_group_scope": "all"
    },
    "mandatory": true,
    "acknowledgment_required": true,
    "comprehension_check": {
      "enabled": true,
      "questions": [
        {
          "prompt": "Reports may be made anonymously.",
          "answer_type": "single_choice",
          "options": ["True", "False"],
          "expected_index": 0
        },
        {
          "prompt": "What is the maximum window for completing investigation findings (or sooner for severe conduct)?",
          "answer_type": "single_choice",
          "options": ["7 days", "14 days", "30 days", "90 days"],
          "expected_index": 2
        },
        {
          "prompt": "Retaliation against a person who reports in good faith is prohibited and may result in termination.",
          "answer_type": "single_choice",
          "options": ["True", "False"],
          "expected_index": 0
        }
      ]
    },
    "ai_classification_hints": {
      "summary": "Prohibited conduct, multiple reporting channels including anonymous, 30-day investigation window, interim measures, retaliation prohibition, and annual training requirement.",
      "regulatory_citations": [
        "Title VII of the Civil Rights Act of 1964",
        "CA Government Code 12950.1 (CA mandatory training)",
        "NY Labor Law 201-G (NY mandatory training)",
        "IL Workplace Transparency Act",
        "CT Public Act 19-16",
        "DE Discrimination in Employment Act",
        "ME Maine Human Rights Act",
        "WA Senate Bill 5258"
      ],
      "key_terms": ["protected class", "reporting channels", "interim measures", "retaliation", "annual training"],
      "manager_briefing": "Take every report seriously and document immediately. Do not investigate yourself; route to People or General Counsel. Implement interim measures if requested by the reporter or warranted by severity. Complete supervisor training within 30 days of promotion.",
      "exception_examples": ["accommodation request for confidential reporting", "third-party complaint involving a contractor", "anonymous report with limited details"]
    }
  }
}