Equal Employment Opportunity

Entercom is an Equal Opportunity and Affirmative Action Employer. Entercom is committed to providing equal employment opportunities in all of our employment programs and decisions, and to ensuring that all employment decisions are based only on valid job requirements. Discrimination, harassment, or retaliation on the basis of any classification protected under federal, state or local law is a violation of our policy. Specifically, Entercom offers equal employment opportunities to qualified individuals regardless of their race, color, religion or religious creed, sex/ gender (including pregnancy, childbirth, breastfeeding, or  related medical conditions), sexual orientation, gender identity, gender expression, national origin, ancestry, age (over 40), physical or mental disability, medical condition, genetic information, marital status, military or veteran status, or other classification protected by applicable federal, state, or local law. This policy applies to all terms and conditions of employment, including, but not limited to, recruitment and hiring, placement, promotion, demotion, termination, reductions in force, recall, transfer, leaves of absence, compensation and training. Any applicant or employee who needs a reasonable accommodation to apply for employment or to perform the essential functions of his/her job should contact the Human Resources Department.

Affirmative Action Policy

Entercom has developed and maintains a written Affirmative Action Program (AAP). The company’s Chief Executive Officer supports the AAP and urges each employee to commit to carrying out the intent of this policy. The Company maintains an audit and reporting system to determine overall compliance with its equal employment opportunity mandates. Entercom’s Vice President of Human Resources oversees the development and implementation of the AAP, including audit and reporting related to the AAP. Entercom’s AAP is available for inspection upon request during normal business hours, and any questions regarding this policy or the AAP should be directed to the Human Resources Department.

Anti-Harassment Policy

Statement of Philosophy

Entercom has a firm commitment to a work environment that respects the dignity and worth of each individual. The purpose of the policy set forth below is to foster a work environment that is free from all forms of harassment, whether that harassment is on the basis of race, color, religion or religious creed, sex/ gender (including pregnancy, childbirth, breastfeeding, or related medical conditions), sexual orientation, gender identity, gender expression, national origin, ancestry, age (over 40), physical or mental disability, medical condition, genetic information, marital status, military or veteran status, or other classification protected by applicable federal, state, or local law.

Discriminatory Harassment Prohibited

Discriminatory harassment, including sexual harassment, by supervisors, managers, coworkers, and third parties over whom the Company has control is strictly prohibited and will not be tolerated by the Company. This policy applies to all harassment affecting the work environment, whether on Company premises or in any Company related setting, and applies regardless of the gender (or other protected class) of the individuals involved. This policy covers all employees of the Company, as well as applicants for employment, interns, contractors, volunteers, and third parties over whom the Company has control.

Definitions of Harassment

Sexual Harassment Defined

For purposes of this policy, sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and/or other verbal or physical conduct of a sexual nature when:

  • Submission to such conduct is either explicitly or implicitly made as a term or condition of employment;
  • Submission to or rejection of such conduct is used as the basis for employment decisions; or
  • Such conduct unreasonably interferes with work performance or creates an intimidating, hostile or offensive working environment.

Some examples of conduct that may constitute sexual harassment are: threatening to take or taking employment actions such as discharge, demotion or reassignment, if sexual favors are not granted; demanding sexual favors in exchange for favorable or preferential treatment; unwelcome and repeated flirtations, propositions or advances; unwelcome physical contact; whistling; leering; improper gestures; horseplay; use of stereotypes; offensive, insulting, derogatory or degrading remarks; unwelcome comments about appearance; sexual jokes or use of sexually explicit or offensive language; gender or sex based pranks; and the display of sexually suggestive objects or pictures, including electronically, in the workplace. The above list of examples is not intended to be all inclusive. Care should be taken to comply with this policy in informal business situations as well, including but not limited to Company parties, conferences, retreats, and business trips.

Other Harassment Defined

For purposes of this policy, other harassment is defined as verbal or physical conduct that denigrates or shows hostility or aversion toward an individual because of his or her race, color, religion or religious creed, sex/ gender (including pregnancy, childbirth, breastfeeding, or related medical conditions), sexual orientation, gender identity, gender expression, national origin, ancestry, age (over 40), physical or mental disability, medical condition, genetic information, marital status, military or veteran status, or other classification protected by applicable federal, state, or local law and that:

  • creates an intimidating, hostile or offensive work environment; or
  • unreasonably interferes with an individual’s work performance.

Some examples of such harassment are: using epithets or slurs; mocking, jokes, pranks, ridiculing or mimicking another’s culture, accent, appearance or customs; threatening, intimidating or engaging in hostile or offensive acts because an individual has made a complaint or engaged in other protected activity; or displaying on walls, bulletin boards, or elsewhere on Company premises, or circulating in the workplace, written or graphic material that denigrates or shows hostility or aversion toward a person or group because of his/her or their membership in a protected class. The above list of examples is not intended to be all inclusive.

Retaliation is Prohibited

In accordance with Entercom’s Anti-Retaliation Policy, an employee who reports an incident that he or she, in good faith believes to be in violation of this policy, or who is involved in the investigation of harassment, will not be subject to reprisal or retaliation. Retaliation is a serious violation of this policy and should be reported immediately. Any person found to have retaliated against an individual for reporting discriminatory harassment or participating in an investigation of allegations of such conduct will be subject to appropriate disciplinary action.

Complaint Procedure

Reporting an Incident of Harassment, Discrimination or Retaliation

Entercom will make every effort to stop alleged harassment, but can only do so with the cooperation of its staff/employees. Therefore, the Company requires supervisory and management employees to promptly report to Human Resources all incidents of discriminatory harassment observed by them or brought to their attention by others. If an employee believes that he or she is being harassed or has observed workplace harassment, the Company encourages him or her to promptly notify their supervisor or, if they prefer not to advise their supervisor: the local Market Manager, the local Human Resources contact, or the Company’s Senior Vice President of Human Resources.

Investigation

When an employee reports an incident of harassment as specified above, the Company will undertake a timely, fair, complete, and impartial investigation appropriate to the circumstances. The steps to be taken during the investigation cannot be fixed in advance, but will vary depending upon the nature of the allegations. Confidentiality will be maintained throughout the investigative process to the extent practicable and consistent with the Company’s need to undertake a full investigation and take effective remedial action.

Responsive Action

Upon completion of the investigation, appropriate remedial action will be taken, if necessary and supported by the facts. Remedial action may include verbal or written counseling, referral to formal counseling, disciplinary suspension or probation, or discharge from the Company.

Anti- Retaliation Policy

Entercom strictly prohibits any form of retaliation against any employee or applicant because he or she has filed a complaint related to, assisted or participated in an investigation, compliance evaluation, hearing, or proceeding related to, or opposed any act or practice that he or she reasonably believes to be in violation of Entercom’s Code of Business Conduct and Ethics Policy or other policies (including, without limitation, the EEO Policy, Affirmative Action Policy, or Anti-Harassment Policy), or any applicable law or regulation, including, but not limited to, any applicable federal, state or local law requiring equal opportunity for individuals with disabilities. The Company will ensure that employees and applicants shall not be subjected to any harassment, intimidation, threats, coercion or discrimination because they have engaged in or may engage the conduct described above or exercised any other right protected by applicable law. Any complaint or concern about a possible violation of this policy should be reported to Human Resources.