(September 2019)

Odyssey is committed to providing a workplace that is free from sexual harassment. Sexual harassment in the workplace is against the law and will not be tolerated. When Odyssey determines that an allegation of sexual harassment is credible, it will take prompt and appropriate corrective action.

What Is Sexual Harassment?

While it is not possible to list all those additional circumstances that may constitute sexual harassment, the following are some examples of conduct which if unwelcome, may constitute sexual harassment depending upon the totality of the circumstances including the severity of the conduct and its pervasiveness. 

Sexual harassment is defined as and consists of sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature either explicitly or implicitly when:

1.    Submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment; and

2.     Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or

3.    Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or altering the terms and conditions of the individual’s employment by creating an intimidating, hostile or offensive working environment.

4.    Unwelcome actions such as the following are inappropriate and, depending on the circumstances, may in and of themselves meet the definition of sexual harassment or contribute to a hostile work environment. Specific behaviors and particular patterns of behavior that the company considers inappropriate (and which could potentially constitute unlawful sexual harassment) include, but are not limited to, the following:

•   Attempted or actual sexual assault;

•   Inappropriate touching of any kind or repeatedly standing too close to or brushing up against a person;

•   Propositions or any sexual advance that is unwelcome;

•   Sexually oriented comments about an employee’s body or appearance;

•  Sexual pranks, derogatory remarks, repeated sexual teasing, jokes, or innuendo, sexually obscene language or offensive gestures, threats, comments about an employee’s body or appearance made in person, through email or other written communication, or through social media postings;

•   Improper questioning of an employee about their personal or private life;

•   Comments or jokes of a lewd, offensive or sexual nature;

•   Spoken or written abuse related to an employee’s gender;

•   Inappropriate staring or leering;

•   Gender-related names, titles or references;

•  Showing or displaying pictures, drawings, materials, or objects of a sexual or offensive nature in the workplace;

•  Repeatedly asking an employee for a date or to socialize during off-duty hours, after the employee has said “No” or has indicated he or she is not interested (supervisors, in particular, should be careful not to pressure their employees to socialize);

•  Any other sexual conduct deemed inappropriate by Odyssey that interferes with an employee's job performance, the work environment or other conditions of employment.

Sexual harassment can involve males or females being harassed by members of either sex. Sexual harassment can occur in the workplace, anywhere Odyssey work is performed, or outside the workplace during non-working hours. Sexual harassment can be perpetrated by managers, supervisors, co-workers, and third parties, such as customers and vendors. All Odyssey employees are strictly forbidden to engage in any form of sexual harassment and will be disciplined, up to and including immediate termination of employment.

Under these definitions, direct or implied requests by a supervisor for sexual favors in exchange for actual or promised job benefits such as favorable reviews, salary increases, promotions, increased benefits, or continued employment constitutes sexual harassment.

The legal definition of sexual harassment is broad and in addition to the above examples, other sexually oriented conduct, whether it is intended or not, that is unwelcome and has the effect of creating a workplace environment that is hostile, offensive, intimidating, or humiliating to male or female workers may also constitute sexual harassment.

All employees should take special note that, as stated above, retaliation against an individual who has complained about harassment, sexual harassment, or discrimination, and retaliation against individuals for cooperating with an investigation of a sexual harassment complaint is unlawful and will not be tolerated by Odyssey.

Odyssey’s Responsibilities Under This Policy

If Odyssey receives an allegation of sexual harassment or has reason to believe sexual harassment is occurring, it will take the necessary steps to ensure that the matter is promptly investigated and addressed. If the allegation is determined to be credible, Odyssey will take immediate and effective measures to end the unwelcome behavior. Odyssey is committed to take action if it learns of possible sexual harassment, even if the individual does not wish to file a formal complaint.

The Manager of Labor and Employment Law Compliance is the main contact point for questions or concerns about sexual harassment. The Manager of Labor and Employment Law Compliance is responsible for investigating or overseeing investigations of alleged sexual harassment. Odyssey is committed to ensuring that all investigations of sexual harassment are conducted in a prompt, thorough, and impartial manner. The Manager of Labor and Employment Law Compliance may be contacted at (781) 327-5867, or by addressing a letter to this person at Odyssey Systems Consulting Group, 201 Edgewater Drive, Suite 270, Wakefield, MA 01880, or through submission of a Helpdesk ticket at

Supervisors and other responsible Odyssey officials who observe are informed of, or reasonably suspect incidents of possible sexual harassment must immediately report such incidents to the Manager of Labor and Employment Law Compliance, who will either initiate or oversee a prompt investigation. Failure to report such incidents to the Manager of Labor and Employment Law Compliance will be considered a violation of this policy and may result in disciplinary action. The Manager of Labor and Employment Law Compliance will provide guidance as needed on investigating and handling the alleged harassment. With the advice of the Manager of Labor and Employment Law Compliance, Supervisors should take effective measures to ensure no further apparent or alleged harassment occurs pending completion of an investigation.

Odyssey will seek to protect the identities of the alleged victim and harasser, except as reasonably necessary (for example, to complete an investigation successfully). Odyssey will also take the necessary steps to protect from retaliation those employees who in good faith report incidents of potential sexual harassment. It is a violation of both federal and state laws and this policy to retaliate against someone who has reported possible sexual harassment. Violators may be subject to discipline.

Employees who have been found by Odyssey to have subjected another employee to unwelcome conduct of a sexual nature, whether such behavior meets the legal definition of sexual harassment or not, will be subject to discipline or other appropriate management action. Discipline will be appropriate to the circumstances, ranging from a verbal admonishment to a written reprimand through suspensions without pay of varying lengths to termination for cause. 

Employees’ Rights and Responsibilities Under This Policy

Any employee who believes he or she has been the target of sexual harassment is encouraged to inform the offending person orally or in writing that such conduct is unwelcome and offensive and must stop.

If the employee does not wish to communicate directly with the offending person, or if such communication has been ineffective, the employee has multiple avenues for reporting allegations of sexual harassment and/or pursuing resolution.

Employees are encouraged to report the unwelcome conduct as soon as possible to a responsible Odyssey official which includes their Odyssey team lead, supervisor or manager. It is usually most effective — although it is not required–that the Odyssey team lead, supervisor or manager be within the employee’s supervisory chain.  Other responsible Odyssey officials include the offending person’s supervisor or the Odyssey Manager of Labor and Employment Law Compliance.

In addition to reporting sexual harassment concerns to a responsible Odyssey official, employees who believe they have been subjected to sexual harassment may elect to file a verbal or written complaint. If you would like to file a complaint you may do so by contacting Odyssey’s Manager of Labor and Employment Law Compliance at (781) 327-5867, or by addressing a letter to this person at Odyssey Systems Consulting Group, 201 Edgewater Drive, Suite 270, Wakefield, MA 01880, or you can submit a ticket through the Help Desk at The Manager of Labor and Employment Law Compliance or designee is also available to discuss any concerns you may have and to provide information to you about our policy on sexual harassment and our complaint process.

All Odyssey employees, including but not limited to staff, supervisors, and senior officials, are required to comply with this policy. Employees are also expected to behave professionally and to exercise good judgment in work-related relationships, whether with fellow employees, business colleagues, or members of the public with whom they come into contact in the course of official duties. Further, all employees are expected to take appropriate measures to prevent sexual harassment. Unwelcome behavior of a sexual nature should be stopped before it becomes severe or pervasive and rises to a violation of law.