AIRVANA LLC
SEXUAL HARASSMENT AND OTHER DISCRIMINATORY HARASSMENT
Introduction
Airvana’s policy is to provide its employees with a work environment free from all forms
of harassment, whether physical or verbal, that is based on an employee’s race, color, sex, age,
religion, national origin, marital status, ancestry, pregnancy, physical or mental disability, sexual
orientation, genetic information, or other characteristic protected by applicable law.
This policy extends to each and every level of the Company’s operations. Accordingly,
harassment, or unwelcome conduct, whether by a fellow employee, manager, supervisor or nonemployee doing business with the Company, will not be tolerated. In furtherance of the
Company’s policy to provide each employee with a work environment free from harassment, the
Company requires that each of its supervisors and managers be responsible for the prevention
and elimination of all forms of harassment within their respective departments.
Examples of Harassment
Sexual harassment is a form of sex discrimination and is against the law. Acts which are
considered to constitute sexual harassment include, but are not limited to, unwelcome sexual
advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature
where:

Submission to such conduct is either an express or implied term or condition of
employment;

Submission to or rejection of such conduct is used as a basis for an employment decision
affecting the harassed person; or
The purpose or effect of such conduct is to substantially interfere with the affected
individual’s work performance or to create an intimidating, hostile or offensive work
environment.

Specific examples of sexual harassment may include the following conduct where it is
unwelcome to the recipient-employee:

Verbal comments, jokes or propositions of a sexual nature;

The display or circulation of sexually suggestive or explicit visual or printed material; or

Physical conduct of a sexual nature.
In addition to prohibiting sexual harassment, the Company prohibits unwelcome conduct,
whether verbal or physical, that is based upon an employee’s race, color, sex, age, religion,
national origin, marital status, ancestry, pregnancy, disability, sexual orientation, genetic
information or other characteristic protected by law. Such conduct is a form of unlawful
discrimination and will not be tolerated. Examples of such behavior include:

Epithets, slurs, insults or negative stereotyping;

Acts or jokes that are hostile or demeaning, or are threatening or intimidating, with
regard to a characteristic described above; and

Written or graphic material that demeans, ridicules or shows hostility toward an
individual or group because of a characteristic described above.
Complaints
All employees are expected to be aware of this policy and of the types of conduct that may
constitute unlawful harassment, as well as of the avenues of assistance provided by the Company
for addressing complaints of harassment. Harassment, sexual or otherwise, serves no legitimate
purpose and has a disruptive effect on an employee’s ability to perform his or her job properly.
The Company takes allegations of harassment very seriously and will actively investigate all
complaints.
Employees are encouraged to report any incidents of harassment immediately, before such
incidents become severe or pervasive. The Company’s policy is to prevent and stop harassment
before it rises to the level of a violation of law. Any employee who believes that he or she has
witnessed or been subjected to sexual harassment or any other harassment described above
should bring his or her concerns to the attention of management immediately in any of the
following ways:

Report the conduct to your immediate supervisor.

Report the conduct to your supervisor’s manager.

Report the conduct to any member of management with whom you feel comfortable.
IMPORTANT NOTE: IF THE PARTICULAR CIRCUMSTANCES MAKE A DISCUSSION
WITH OR A COMPLAINT TO AN EMPLOYEE’S OWN SUPERVISOR INAPPROPRIATE
(FOR EXAMPLE, THE COMPLAINT INVOLVES THE EMPLOYEE’S SUPERVISOR, OR
THE EMPLOYEE FEARS RETALIATION BY HIS OR HER SUPERVISOR), THE
EMPLOYEE SHOULD NOT HESITATE TO BRING THE MATTER IMMEDIATELY TO
THE ATTENTION OF THE CHIEF FINANCIAL OFFICER, OR ANY OTHER MEMBER OF
MANAGEMENT.
It is the Company’s policy that all such matters will be handled with appropriate care and
discretion and receives a thorough investigation. When an employee brings a complaint to the
attention of any member of management, the Vice President of Human Resources will be
notified and the Company will promptly undertake an investigation of the allegations. Such
investigation generally shall include, at a minimum, interviews with persons identified as having
direct and personal knowledge of the incident(s) in question. During the investigation, the
Company will protect the confidentiality of harassment allegations to the extent possible. The
Company cannot guarantee complete confidentiality, because it cannot conduct an effective
investigation without revealing certain information to the alleged harasser and potential
witnesses. However, the Company will attempt to keep such disclosures to the minimum
required under the circumstances, on a “need to know basis.”
If the investigation reveals that the allegations are valid, management will take prompt and
appropriate remedial action against the offending person. Such measures are designed to put an
immediate stop to the harassment as well as prevent its recurrence. Therefore, management
retains the right to take whatever action it believes appropriate under the circumstances, up to
and including termination of the offending person.
Retaliation Prohibited
Retaliation against employees for reporting or complaining of sexual or other unlawful
harassment (or for cooperating in the investigation of a report or complaint) is unlawful and will
not be tolerated. Any act of retaliation will warrant disciplinary action, up to and including
termination of the offending person.
Legal Information
Sexual harassment and the other forms of harassment described above are unlawful under both
federal and state law. The federal agency, which enforces the law in Massachusetts, is the Equal
Employment Opportunity Commission (EEOC). The EEOC’s local office is located at: John F.
Kennedy Federal Building, 475 Government Center, Boston, MA 02203. The state agency,
which enforces the law, is the Massachusetts Commission Against Discrimination (MCAD).
The MCAD’s offices are located at: Boston Office -- One Ashburton Place, 6th Floor, Boston,
MA 02108; and Springfield Office – 436 Dwight Street, Room 220, Springfield, MA 01103.
Generally, the time period for filing a complaint of discrimination with these agencies (counting
from the last date of unlawful harassment) is as follows: MCAD -- 300 days; EEOC -- 180 days.
Employees who wish to file formal charges of sexual or other unlawful harassment can
contact both of these government agencies. However, the Company is committed to responding
quickly and effectively to any report of harassment, and hopes that all employees will feel
comfortable coming forward and allowing the Company to pursue a resolution of the matter
internally. We believe that the Company has created a flexible and fair complaint resolution
process, and that we will be able to work together to avoid the unnecessary escalation of any
situation, which has created an offensive or hostile work environment for any employee.