2020 Settlement Highlights

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The Commission has the authority to assess fines and obtain monetary damages for those aggrieved by violations of the New York City Human Rights Law. Additionally, the Commission may negotiate additional remedies including rehiring, policy change, training, and modifications for accessibility.

May 2020

Employer, 1199 SEIU Child Care Fund, Pays $31,500 in Damages and Civil Penalties To Resolve Gender-Based Harassment Claims
Complainant, an employee of a labor union fund, filed a complaint alleging that her supervisor subjected her to a gender-based hostile work environment. Through its investigation, the Law Enforcement Bureau discovered evidence to support allegations that Complainant’s supervisor made inappropriate sexual comments and subjected Complainant to unwanted touching on multiple occasions. The Commission and the parties entered into a conciliation agreement requiring Respondent to pay Complainant $21,500 in emotional distress damages, pay $10,000 in civil penalties, provide all of the fund’s employees with anti-sexual harassment training, ensure that it has meaningful policies in place to address complaints of discrimination, post the Commission’s Stop Sexual Harassment Act Notice, and distribute the Commission’s Stop Sexual Harassment Act Fact Sheet.

Touro College Pays $69,914.00 for Failing To Provide a Reasonable Accommodation to Employee with Disability
Complainant sought a schedule adjustment from her employer, Touro College, related to her disability. Touro refused to grant the accommodation and terminated Complainant. After its investigation, the Law Enforcement Bureau credited Complainant’s allegation. Touro agreed to pay $45,000.00 in emotional distress damages, $20,000.00 in civil penalties, and $4,914.00 in back pay. Touro also agreed to modify its employee policies to comply with the NYC Human Rights Law as well as train its managers and supervisors on the NYC Human Rights Law.

NYC Fire Services and Guards LLC Pays $12,500 in Damages and Civil Penalties for Subjecting Applicants to Questions Which Violated the Fair Chance Act
A job applicant filed a complaint against of discrimination against NYC Fire Services and Guards LLC alleging that Respondents unlawfully inquired into his criminal history prior to a conditional offer of employment and improperly denied him employment on the basis of his criminal history. The Commission’s Law Enforcement Bureau conducted an investigation and concluded that there was probable cause to credit the complainant’s allegations that Respondents unlawfully inquired into his criminal history prior to a conditional offer of employment. The Commission, the Complainant and Respondent entered into an agreement for Respondent to pay Complainant $5,000 in emotional distress and a civil penalty of $7,500.

Alliance Building Services Pays $25,000 in Damages and Penalties for Violations of the Fair Chance Act
A job applicant filed a complaint against of discrimination against Alliance Building Services alleging that Alliance Building Services unlawfully inquired into his criminal history prior to a conditional offer of employment and improperly denied him employment on the basis of his criminal history. The Law Enforcement Bureau conducted an investigation and concluded that there was probable cause to credit the complainant’s allegations that Alliance Building Services unlawfully inquired into his criminal history prior to a conditional offer of employment. The Commission, the Complainant and Respondent entered into an agreement for Respondent to pay the complainant $15,000 in emotional distress and a civil penalty of $10,000.

NYC Department of Correction Agrees To Pay $6,000 and Put Up Postings to Settle Former Employee’s Race and Marital Status Discrimination Claim
Complainant, an investigator for the NYC Department of Corrections, alleged that during an interview for a specialized unit a supervisor asked about his marital status and stated that members of Complainant’s race never made it on to Respondent’s team. Complainant responded that he was engaged. Respondent then informed Complainant that Complainant not been chosen for the unit. As part of the conciliation, Respondents agreed to pay Complainant $6,000 in emotional distress damages and post the Commission's “Notice of Rights” poster.

Gristedes Agrees To Pay $11,000 in Damages, Retrain all NYC Employees, Revise Policies, and Post Notice of Rights in all NYC Stores
Complainant, who identifies as an intersex woman, filed a complaint against Gristedes alleging that she heard an employee tell another employee while she was shopping that Complainant was "really a man." After receiving the Complaint, Respondent conducted an internal investigation and took appropriate disciplinary action against the involved employees. To resolve the case, Respondent agree to pay Complainant $11,000 in emotional distress damages; train its New York City employees on protections against gender discrimination under the New York City Human Rights Law; update its anti-discrimination policies; and post the Commission’s Notice of Rights poster in all New York City places of business.

New York Institute of Technology Pays $45,000 in Damages, Penalties, and Attorneys’ Fees in Fair Chance Act Case, Revises Policies, Conducts Training, and Puts Up Postings
Complaint filed a complaint alleging that she was unlawfully denied a position due to her criminal history after receiving a conditional offer of employment, and that Respondent's application contained a question about criminal history several months after the passage of the Fair Chance Act. The Commission joined the action through a Commission-initiated complaint due to the presence of the illegal question on the application. Respondent quickly modified the application but disputed the reason for withdrawing the conditional offer of employment. The Commission's investigation revealed that Respondent's application was only distributed to a small subset of applicants. To resolve the case, NYIT agreed to pay $23,333.33 in emotional distress damages, $11,666.66 in attorney's fees, a $15,000 civil penalty, and to revise its policies to conform with the NYC Human Rights Law, provide anti-discrimination trainings to employees, and to post the Commission’s Notice of Rights Poster in every New York City location.

Landlord Pays $9,000 in Damages for Failing to Accommodate Tenant; Replaces Bathtub, Changes Policies, Posts Anti-Discrimination Notices in 14 Buildings, and Agrees to Training
A Bronx tenant requested an accommodation for her landlord to modify her bathtub in order to accommodate her disabilities.The tenant filed a complaint alleging that her landlord refused to replace the bathtub. During the Law Enforcement Bureau's investigation, the landlord replaced the tub, and the property manager attended an anti-discrimination training. Complainant, Respondents, and the Commission then entered into a conciliation agreement requiring Respondents to pay $9,000 in emotional distress damages to Complainant. Respondents also agreed to update their policies and procedure on reasonable accommodation requests, to post nondiscrimination notices across their 14 buildings, and for the landlord to also attend an anti-discrimination training.

Center for Behavioral Health Services Agrees to Remove Gender Distinctions from Dress Code
After reviewing the dress code policy for the Center for Behavioral Health Services (“CBHS”) as part of a Complainant-filed employment case, the Commission sent a cease and desist letter to CBHS informing it that gender distinctions in its dress code were in violation of the NYC Human Rights Law. CBHS revised its dress code and signed a stipulation and order agreeing to distribute the revised policy to its employees.

April 2020

Crunch Fitness Pays $60,000 in Damages and Penalties and Changes National Hiring Policy To Settle Two Fair Chance Act Cases
Crunch LLC (“Crunch”), the company that runs the national gym chain Crunch Fitness, has agreed to settle two cases filed by personal trainers who were rejected because of their criminal histories. An investigation by the Law Enforcement Bureau confirmed that Respondent Crunch properly waited until making a conditional offer of employment to do background checks, but then failed to give Complainants individualized assessments of their criminal histories. Instead, they used the same generic reasoning that improperly weighed the relevant factors, in violation of the Fair Chance Act. Crunch agreed to pay a total of $40,000 in compensatory damages to the Complainants and $20,000 as a civil penalty; to change its national hiring policy to prevent background checks before making conditional employment offers; to revise its New York City hiring policy to match the requirements of the Fair Chance Act and the Commission’s own guidance; to post the Commission’s Know Your Rights notices in its offices; and to train its staff.

Broker Pays Damages for Discriminating Against a Complainant’s Lawful Source of Income
A small broker, Vanguard Residential LLC, discriminated against a Complainant because she was seeking to use a housing voucher while applying for apartments. The Respondent cooperated with the Law Enforcement Bureau’s investigation and sought to mitigate damages to the Complainant. The Respondent agreed to attend training on the NYC Human Rights Law and pay the Complainant $2,500 in emotional distress damages.

Services for the Underserved, Inc. Settles Complaint Alleging Discrimination on the Basis of Criminal Conviction History for $35,500 in Damages and Penalties
Complainant, a prospective employee, filed a complaint against Services for the Underserved, Inc., a nonprofit agency providing services to individuals with disabilities, alleging that her job offer had been unlawfully rescinded after a required background check. The Law Enforcement Bureau’s investigation confirmed that Respondent failed to conduct a complete analysis of the Article 23-A factors under the New York State Corrections Law. Following the investigation, the parties agreed to enter into a settlement agreement in which Respondent Services for the Underserved, Inc. agreed to pay Complainant $21,000 in emotional distress damages; $500 in backpay damages; and pay a $14,000 civil penalty. The Respondent also agreed to create a comprehensive policy regarding assessment of applicants with criminal conviction histories' to provide training to human resources employees; and to display postings outlining its obligations under the NYC Human Rights Law.

March 2020

Fashion Retailer Zara Agrees to Pay $30,000 in Emotional Distress Damages, Train Its Employees, and Work With Community Organizations to Create Employment Opportunities for Transgender, Gender Non-Conforming, and Non-Binary New Yorkers
Complainant, who identifies as gender non-binary, filed a complaint against Zara alleging that they faced gender-based discrimination and harassment while trying to use fitting rooms at Zara stores in New York City. Following the Law Enforcement Bureau’s investigation, the Commission, Complainant, and Zara entered into a conciliation agreement requiring Zara to pay Complainant $30,000 in emotional distress damages; train its New York City employees on the New York City Human Rights Law and the Commission’s Gender Identity and Gender Expression Legal Enforcement Guidance; post in its New York City places of business the Commission’s Notice of Rights poster, the Commission’s Equal Bathroom Access Poster, and a policy explaining that patrons can use the fitting room that most closely aligns with their gender identity; and partner with the New York City LGBT Community Center, and at least one community-based organization dedicated to serving the transgender, gender non-conforming, and non-binary communities, to create employment opportunities for these communities. Read more about the settlement here.

Restaurant Pays Damages in Private Settlement for Sexual Orientation Workplace Harassment
Complainant, a server at a large Manhattan restaurant with a single location, alleged that he was harassed by coworkers and improperly terminated because of his sexual orientation, in violation of the New York City Human Rights Law. Complainant alleged that after his coworkers learned that he was bisexual, he was ridiculed, groped, and teased on a regular basis, including in front of an owner of the restaurant. Ultimately, Complainant alleged that he attempted to report hostile work environment, but that no steps were taken by the owners to address the unlawful conduct. The Law Enforcement Bureau issued a finding of probable cause against the Respondent restaurant and its owners, and thereafter Complainant and Respondents entered into a private settlement agreement resolving the case for $30,000 in damages to Complainant.

Swatch Pays Damages, Civil Penalties, and Undertakes Affirmative Relief in Stop Credit Discrimination in Employment Act Case
Complainant alleged that he visited a Swatch Group (US) Inc. store location to apply for a retail position, where he was presented with a paper application requesting that he authorize the employer to check his credit report, in violation of the New York City Human Rights Law's Stop Credit Discrimination in Employment Act protections. He was dissuaded from applying for the job due to his credit history, and filed a complaint with the Law Enforcement Bureau. Upon investigating, the Law Enforcement Bureau discovered that the Respondent's application form also requested authorization to conduct criminal background checks in violation of the Fair Chance Act. During the pendency of the investigation, Respondent updated its application form to come into compliance with the New York City Human Rights Law. Complainant, Respondent, and the Law Enforcement Bureau entered into a conciliation agreement requiring the payment of $17,750 in damages to complainant, including attorneys' fees, a $17,250 civil penalty, and affirmative relief including conducting training for all personnel involved in hiring and posting of the Commission's materials on the use of criminal conviction history and credit reporting in hiring.

NYC Department of Education Agrees to Pay $100,000, Conduct Training, and Put Up Postings to Settle Former Employee’s Religious Discrimination Claim
Complainant, who worked for an adult career center run by the New York City Department of Education, alleged that her employer discriminated against her by failing to reasonably accommodate her need for leave to observe a religious holiday, causing her constructive termination. Complainant had taken the same leave for three years in a row, but in her fourth year, her new manager stated Complainant would only be approved for a portion of the time she requested. Despite Complainant’s explanation that the shorter time was insufficient for her to fulfill her religious obligations, and her repeated requests for reconsideration, Respondents denied her request without explanation. As a result, Complainant resigned from her job so she could comply with the obligations of her faith. Through the parties’ conciliation, Respondents agreed to pay Complainant $80,000 in back pay and $20,000 in emotional distress damages; conduct anti-discrimination training, including a focus on NYC Human Rights Law protections for religious accommodations; and post the Commission's “Notice of Rights” poster.

February 2020

Dolphin Fitness Agrees to Change Policies to Allow Transgender Patrons to Use Proper Facilities
After receiving credible information that Dolphin Fitness, a Bronx gym, said that transgender people could not use the facilities that accorded with their gender identities unless they had surgery, the Commission sent a cease and desist letter and ultimately came to an agreement with Strong Pelham Fitness, Inc. (“SPF”), the gym’s owner, which also owns and operates another Dolphin Fitness in Brooklyn. SPF signed a stipulation and order agreeing to revise its policies to apply equally to all genders and to allow people to use the sex-segregated facilities that accord with their gender identities. PSF will also post the Commission’s Notice of Rights, Single-Sex Facilities Notice, and “Pink and Blue” campaign posters at both Dolphin Fitness locations, and a member of PSF’s management will attend training at the Commission.

XSport Fitness Agrees to Change Policies to Allow Transgender Patrons to Use Proper Facilities
After receiving credible information that XSport Fitness, which runs a Bronx gym, said that transgender people could not use the facilities that accorded with their gender identities unless they had surgery, the Commission sent a cease and desist letter and ultimately came to an agreement with CF Management-NY, LLC (“CFM”), the gym’s owner. CFM signed a stipulation and order agreeing to revise its policies to apply equally to all genders and to allow people to use the sex-segregated facilities that accord with their gender identities. CFM will also post the Commission’s Notice of Rights, Single-Sex Facilities Notice, and “Pink and Blue” campaign posters at its Bronx location, and a member of its management will attend training at the Commission.

Securitas Security Services Settles Disability Discrimination Case for $15,000 in Damages and Penalties and Agrees to Training, Policy Revisions and Legal Postings
Complainant filed a disability discrimination complaint against Securitas Security Services alleging that Respondents failed to accommodate her disability, constructively terminated her employment, and retaliated against her based on her disability. Respondents agreed to pay $3,600 in backpay, $6,400 in emotional distress damages, $5,000 as a civil penalty and to conduct anti-discrimination training, create a reasonable accommodation policy that places an obligation on Respondents to initiate a cooperative dialogue in accordance with the requirements of the New York City Human Rights Law, submit to monitoring for one year, and post the Commission’s notice of rights in their branch office.

InDinero, Inc. Agrees to Pay $65,000 in Damages, Penalties, and Attorney’s Fees After Job Applicant was Denied a Position Because of His Criminal History
A prospective employee filed a complaint against InDinero, Inc., an accounting software and services company, alleging that Respondent had offered him a job, then suddenly withdrew the offer based on his criminal history. The employer had failed to properly apply the Article 23-A analysis pursuant to the Fair Chance Act. InDinero, Inc. agreed to pay $11,666.67 in back pay, $18,333.33 in attorney’s fees, $25,000 in emotional distress damages, and $10,000 in civil penalties, and to revise their hiring policies and practices.

Cosmopolitan Club Agrees to Gender-Neutral Admissions and Dress Policies
After receiving credible information that The Cosmopolitan Club (the “Club”), a members-only, full-service club on the Upper East Side had different admissions and dress policies for men and women, the Commission sent a document demand seeking more information. The Club signed a stipulation and order agreeing to create a new anti-discrimination policy that set the same standards for all genders. The Club will also post the Commission’s Notice of Rights and a member of its management will attend training on the New York City Human Rights Law at the Commission.

Colonial Road Associates LLC and Rosario Parlanti Agrees to Pay $10,000 in Civil Penalties and to Set Aside Units for Voucher Holders
In a Commission-initiated case, Respondents, who are landlords, were found to have refused a Section 8 voucher holder in violation of the New York City Human Rights Law. The Commission and Respondents reached a settlement agreement that required them to pay $10,000 in civil penalties; make changes to ensure their policies were compliant with the source of income provisions of the Law; attend training; send notices about the Law to Respondents’ agents; and post notices of rights in the buildings they own throughout New York City. The Respondents also agreed to place two voucher holders in immediate need of housing in “set aside” units as part of the agreement.

New York City Management, LLC and Besen & Associates Pay $40,000 in Damages for Refusing Section 8 Voucher Holder, Changes Policies and Agrees to Training
A prospective tenant who received rental assistance through Section 8 filed a complaint alleging that a broker would not allow her to apply for an apartment because of her rental voucher. At the time, Complainant was a homeless mother. Respondents cooperated fully with the Commission’s investigation. Complainant and Respondents entered into a conciliation agreement requiring Respondents to pay $25,000 in emotional distress and lost housing opportunity damages to Complainant and $15,000 in civil penalties to the general fund of the City of New York. Respondents also updated their policies on source of income discrimination and agreed to attend an anti-discrimination training.

Design House and Luxury Retailer Prada USA Corp. Agrees to Groundbreaking Settlement and Commits to Restorative Justice Measures Including Creating a Scholarship Program, Hiring a Diversity and Inclusion Officer, Undergoing Racial Equity and Training, and Increasing Staff Diversity
In December 2018, the Commission's Law Enforcement Bureau issued a cease and desist letter and launched an investigation into Prada’s display and sale of its “Pradamalia” merchandise. The monkey figurine from the collection evoked images of Sambo, a caricature that, over generations, has been used to mock and dehumanize Black people. A Complainant also filed a complaint against Prada in January 2019. Following the Law Enforcement Bureau’s investigation, the Commission, Complainant, and Prada entered into a conciliation agreement requiring Prada to ensure that its New York City employees and certain Milan-based executives receive racial equity training and training on the New York City Human Rights Law; develop a scholarship program for people historically underrepresented in fashion; appoint a senior, director-level diversity and inclusion officer who will review Prada’s advertising and products sold in the United States, as well as review and monitor Prada’s anti-discrimination policies; maintain Prada’s Diversity and Inclusion Council, launched by Prada in February of 2019, with a minimum of three to five members for a period of at least six years, with regular reporting by Prada on the council’s progress to the Commission; and commit to increasing the diversity of its staff; and submit to two years of monitoring by the Commission.

Press Release  | New York Times Story

Shin Gallery Agrees to Settle Disability Discrimination Claim by Creating Reasonable Accommodation Policy and Undergoing Training
Complainant alleged discrimination by Respondent Shin Gallery for refusing to grant Complainant’s request for a reasonable accommodation for his disabilities, i.e., CART services, in order for Complainant to attend a public event at the gallery. The parties agreed to settle the matter using the Commission’s pre-complaint intervention process. Respondent Shin Gallery agreed to create a policy in accordance with its obligations under the New York City Human Rights Law to provide reasonable accommodations and to attend training on the Law.

January 2020

Securitas Security Services Settles Disability Discrimination Case by Paying $15,000 in Backpay, Damages, and Penalties; Agrees to Training, Policy Revisions, and Postings
Complainant filed a disability discrimination complaint against Securitas Security Services alleging a failure to accommodate her disability, constructively terminating her employment, and retaliating against her based on her disability. Respondents agreed to pay $3,600 in backpay, $6,400 in emotional distress damages, $5,000 in civil penalties to the general fund of the City of New York and to conduct anti-discrimination training, create a reasonable accommodation policy that places an obligation on Respondent to initiate a cooperative dialogue in accordance with the requirements of the New York City Human Rights Law, submit to monitoring for one year, and post the Commission’s notice of rights in their office.

Bloomsbury Publishing Settles Salary History Discrimination Claim, Pays $5,000 Civil Penalty; and Agrees to Policy Changes, Training, and Postings
After receiving credible information that Bloomsbury Publishing was asking job applicants for salary history, in violation of the New York City Human Rights Law, the Commission filed a Commission-initiated complaint. The parties agreed to a settlement in which Bloomsbury paid $5,000 as a civil penalty to the City; revised its policies to prohibit discrimination based on salary history, credit, and criminal history; and revised its job application template to comply with the revised policies. Bloomsbury will also post the Commission’s Notice of Rights and Salary History Ban posters in its offices and a member of its management will attend training at the Commission.

Pacific Street Hospitality Agrees to Policy Changes, Training, and Postings for Discriminatory Admission Policies at Ethyl’s Alcohol and Food
After receiving credible information that Ethyl's Alcohol and Food, a Manhattan bar, had different standards for admitting people based on gender and on sexual orientation, the Commission sent a cease and desist letter and ultimately came to an agreement with Pacific Street Hospitality (“PSH”), the hospitality group that owns the bar. PSH signed a stipulation and order agreeing to revise its admission policies to apply equally to people of all genders and sexual orientations. PSH will also post the Commission’s Notice of Rights and a member of its management will attend training at the Commission.

97 Euclid Realty Pays $35,000 in Damages and Civil Penalties, Agrees to Affirmative Relief to Resolve Retaliation Claim
A tenant filed a complaint alleging that her building’s superintendent sexually assaulted her and that her landlord increased her rent after she obtained an order of protection against the superintendent. The Commission’s Law Enforcement Bureau conducted an investigation and found probable cause that Respondents raised Complainant’s rent in retaliation for seeking the order of protection. After the Law Enforcement Bureau issued probable cause and referred the case to the Office of Administrative Trials and Hearings, Respondents agreed to pay Complainant $15,000 in damages, pay a $20,000 civil penalty to the general fund of the City of New York, update its anti-discrimination policies, conduct trainings on the New York City Human Rights Law, and post the Commission’s Fair Housing poster on its premises.

HFF Realty LLC and Manager Agree to Policy Changes, Training, and Postings After Refusing to Accommodate Emotional Support Animals
Testing conducted by the Commission revealed that HFF Realty refused to reasonably accommodate emotional support animals for tenant applicants. The Commission sent a cease and desist letter and ultimately came to an agreement with both HFF and an HFF manager, who both signed a stipulation and order agreeing to revise its policies on service and emotional support animals. HFF will also post the Commission’s Notice of Rights and the manager will attend training at the Commission.

Richard Sandoval Hospitality Agrees to Training and Notice of Rights Postings for Discriminatory Questions about Immigration at a Manhattan Restaurant
After receiving credible information that Zengo, a restaurant in Manhattan, was making inappropriate inquiries regarding the immigration status of its customers, the Commission sent a cease and desist letter and ultimately came to an agreement with Richard Sandoval Hospitality (“RSH”), the restaurant’s corporate owner. RSH submitted its policy for review and signed a stipulation and order agreeing to post the Commission’s Notice of Rights and Protections Based on Immigration Status and National Origin posters at Zengo and its co-located bar, La Biblioteca de Tequila. A member of RSH’s management will also attend training at the Commission.

Uptown Dance Academy Agrees To Revise Hair Policy to Allow Braids
After receiving reports that Uptown Dance Academy was not allowing its students to perform with braided hair, the Commission sent a cease and desist letter and ultimately came to an agreement with the Academy. The Academy signed a stipulation and order agreeing to revise its policy to make clear that natural hairstyles and hairstyles commonly associated with Black people or with other racial, ethnic, or cultural identities, including, but not limited to, braids, shall be allowed, and that any safety or other restrictions on hairstyle shall not discriminate based on racially protected characteristics. The Academy will also post the Commission’s Notice of Rights and natural hair posters along with its new policy, and a member of its management will attend training at the Commission.

Yodle Inc. Settles Case for $5,000 in Civil Penalties After Using Unlawful Language in their Employment Applications
A prospective job applicant used Yodle’s online employment application system to apply for a sales position at the company. The online application contained language authorizing Yodle to contact law enforcement and credit agencies. The Commission’s Law Enforcement Bureau (“LEB”) conducted an investigation, including a review of the allegations and Yodle’s employment applications. LEB found that the authorization form used by Yodle in their employment applications was in violation of the New York City Human Rights Law (“NYCHRL”). Yodle and the Commission entered into a conciliation agreement requiring Yodle to pay $5,000 in civil penalties and to continue to comply with the NYCHRL in its employment applications.

NYC Health + Hospitals Corporation Pays $140,000 in Emotional Distress Damages To Resolve Gender-Based Harassment Claims
An employee of the New York City Health and Hospitals Corporation (“H+H”) filed a complaint alleging that a senior manager within the Equal Employment Opportunity office at H+H sexually harassed her over a period of several years, attempting to kiss her, making comments about her body, attire, and appearance, and routinely making sexual innuendos and advances towards her. The Law Enforcement Bureau’s investigation established that the same manager engaged in similar harassing conduct towards other employees and issued a finding of probable cause. The Commission and the parties entered into a conciliation agreement requiring H+H to pay the Complainant $140,000 in emotional distress damages, post the Commission’s Notice of Rights and distribute the Stop Sexual Harassment Act factsheet, and establish an additional avenue for Equal Employment Opportunity staff to report allegations of harassment and discrimination. The former manager, no longer employed with H+H, was required to attend the Commission’s Anti-Sexual Harassment Training.