All policies are important. Those in this section not only are important, but relate to some very specific federal, state and local employment laws. Please read them closely.
Equal Employment Opportunity
Equal Employment Opportunity is a fundamental principle and policy at Gorilla 76, where employment is based upon your capabilities and qualifications without regard to race, color, religion, sex, age, national origin, disability, genetic information, sexual orientation, gender identity, citizenship status, marital status or any other legally protected characteristic.
This policy of Equal Employment Opportunity applies to all policies and procedures relating to recruitment and hiring, compensation, benefits, termination, and all other terms and conditions of employment.
Should someone violate this policy, disciplinary action will be taken. Jon and Joe have responsibility for this policy, and employee questions or concerns may be referred to either. This is something we take very seriously, per our core value of inclusivity.
Non-discrimination and anti-harassment policy
Gorilla 76 is committed to a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits discriminatory practices, including harassment. We expect that all relationships among persons in the workplace (both on and off-site) will be business-like and free of bias, prejudice and harassment.
In short, be kind and treat others as you’d want to be treated. It’s really pretty simple.
Definitions of harassment
Sexual harassment constitutes discrimination and is illegal under federal, state and local laws. Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when, for example:
- Submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment
- Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual
- Or such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment
If any harassment claim is investigated and found to be valid, disciplinary action will be taken up to and including employment termination.
Unlawful harassment is prohibited
Gorilla 76 is committed to providing a work environment that is free of discrimination and unlawful harassment. Actions, words, jokes or comments based on an individual’s sex, race, color, ethnicity, national origin, ancestry, age, religion, disability, sexual orientation, gender identity, genetic testing information or any other legally protected characteristic will absolutely not be tolerated from a Gorilla 76 employee or non-employee (client, vendor, etc.).
Per the Equal Employment Opportunity Commission’s (EEOC) definition of sexual harassment, it’s important to note that sexual harassment does not have to involve conduct of a sexual nature in order to constitute unlawful behavior. For example, abusive, offensive or demeaning behavior that is directed to members of one gender only may be deemed a form of sexual harassment, even though the conduct was not motivated by sexual desire or gratification. In addition, harassment of a male by another male or of a female by another female also constitutes unlawful form of sex discrimination.
Examples of the types of conducts which could be considered sexual harassment and which are explicitly prohibited by Gorilla 76 policy include, but are not limited to, the following:
- Unwelcome sexual advances, requests for sexual favors, or any sexual touching and gesturing
- Offering favorable employment benefits or conditions of employment in exchange for sexual favors
- Threatening or imposing less-favorable employment benefits or conditions of employment after receiving a negative response to sexual advances
- Comments, jokes, slurs, graphic verbal commentaries about an individual’s body or any other derogatory, offensive language or behavior of a sexual nature
- Sexually suggestive objects, notes/letters, books, magazines, photographs, cartoons, pictures, calendars, posters and electronic communications
Complaint and investigation procedure
If you have a complaint about an incident of harassment, immediately ask the offending party to stop, unless that makes you uncomfortable. You should also immediately report the matter to either Jon, Joe and/or Stephanie Hall regardless of whether you ask the offending party to stop or not. You can always raise concerns and make reports without fear of reprisal or retaliation.
Additionally, any manager who becomes aware of possible sexual or other unlawful harassment should promptly advise Jon or Joe who will handle the matter in a timely and confidential manner.
Investigation and discipline
All complaints will be thoroughly investigated and will be treated with the utmost confidentiality consistent with the resolution of the situation. If the allegations are found to be true following investigation, appropriate corrective action will be taken, up to and including the termination of the offending employee(s).
Gorilla 76 prohibits retaliation of any kind against individuals who have made good faith reports or complaints of violations of this policy or other known or suspected illegal or unethical conduct.
If you feel you have been subjected to harassment or witnessed harassment, bring it to our attention immediately.
Americans with Disabilities Act
We’re committed to complying with all applicable provisions of the Americans with Disabilities Act (ADA). It’s our policy to not discriminate against any qualified employee or applicant with regard to any terms or conditions of employment because of that individual’s disability, or perceived disability, so long as the employee can perform the essential functions of the job.
Consistent with this policy of nondiscrimination, Gorilla 76 will provide reasonable accommodations to a qualified individual with a disability, as defined by the ADA, who has made Gorilla aware of their disability, provided that such accommodation does not constitute an undue hardship on the team.
Employees with a disability who believe they need a reasonable accommodation to perform the essential functions of their job should contact either Jon or Joe. Gorilla 76 encourages individuals with disabilities to come forward and request a reasonable accommodation. It is our hope that you’d never feel this is something you’d need to hide. After all, Jon has been very vocal about his journey with multiple sclerosis.
Diversity, Equity, Inclusion and Belonging (DEIB) at Gorilla 76
Gorilla 76 has created, and will maintain, a workplace where everyone feels welcome. We don’t just invite different perspectives to the table, we ask them to be a part of the conversation as well.
We honor this in the following ways:
- We do not require a college degree for employment
- We are a remote workforce, removing barriers for many
- We accommodate religious needs and requests for employees (see “Time off” section of this handbook)
- We observe a company-wide day of service annually on Martin Luther King, Jr. Day
- We are committed to our partnership with City Academy and to teaching the youth about careers in marketing
- We review and address DEIB scores weekly via Workleap Officevibe in both leadership and employee success meetings
- We are a veteran-friendly employer – thank you to those who wear, and who have worn, the uniform
Code of conduct
Our success is built upon the principles of fair dealing and ethical conduct of our employees. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity. We even have our own code of ethics.
Our continued success is dependent upon our clients’ trust, something we’re dedicated to preserving. Employees owe a duty to Gorilla 76, its clients and colleagues to act in a way that will merit the continued trust and confidence of the public.
We’ll comply with all applicable laws and regulations and expect all employees to conduct business in accordance with the letter, spirit and intent of all relevant laws and to refrain from any illegal, dishonest or unethical conduct.
Business dealings that appear to create a conflict between the interests of the Company and an employee are unacceptable. Special care must be taken to avoid even the impression of a conflict of interest.
In general, the use of good judgment, based on the highest ethical principles, will guide you. If a situation arises where it is difficult to determine the proper course of action, the matter should be discussed with either Joe or Jon.
Compliance with this policy of business ethics and conduct is the responsibility of every employee. Disregarding or failing to comply with this standard of business ethics and conduct could lead to disciplinary action, up to and including termination of employment.
AI policy for content
Clients who provide confidential information throughout the course of a normal business relationship hold the reasonable expectation that their information will not be shared with third parties — and we are bound to that expectation when that information is explicitly protected by an NDA. However, clients should also understand that their information is shared within our company and the third-party contractors with whom we engage, including Dropbox, Rev, Loom, Zoom and ChatGPT, among others. We already follow strict confidentiality practices to protect all sensitive information in these platforms. This policy reinforces existing protocols and applies to all employees of Gorilla 76 and to all work that its employees perform.
Given the novel application of traditional guidelines covering data privacy and protection with generative AI, our approach must be cautious and conservative. The force of this caution depends on the platform’s security. The following advisories address paid and free generative AI use separately.
All tools will be documented in our internal employee software tracking sheet.
Paid generative AI
Unless you have received explicit permission for an alternative LLM (large language model), Gorilla 76 employees are to use paid versions of ChatGPT and ChatGPT Teams. Per its own policies, these secure conversations are not used to train Open AI’s LLM. Since the platform’s security measures are engineered to safeguard sensitive data, Gorilla 76’s exposure to liability is significantly reduced. However, we must still exercise due diligence in managing and controlling access to sensitive data in order to ensure compliance with legal standards.
Each department director’s approval grants limited use of generative AI chatbots. Company email addresses, credentials or phone numbers can be used to create accounts with these platforms.
Employees wishing to use generative AI must inform their director. Directors must approve or deny requests within ten (10) days. Directors will seek approval from co-founders when necessary. All AI-generated content must be reviewed for accuracy before relying on it for work purposes. If factual information cannot be verified by a reliable source, that information cannot be used.
Acceptable uses include but are not limited to:
- Brainstorming
- Building outlines or summaries
- General knowledge building to enhance your grasp of complex topics
- Rephrase headlines, metadata, sentences or content personalization
- Clarifying highly technical, rambling exchanges in SME (subject matter expert) interviews
- Thematic analysis for product market canvas and positioning preparation
- Creating formulas for Excel spreadsheets or similar programs
- Foreign language translations
- Spreadsheet calculations
- Coding development or debugging
Unacceptable uses include but are not limited to:
- Using direct, AI-generated content without intervening to verify that it meets ethical and operational standards
- Inputting client information explicitly shielded by “off the record” requests
If you do not know whether an application is acceptable or not, contact your director.
Unpaid generative AI
Feeding data into free versions of generative AI may release it into an LLM (large language model) knowledge pool with uncertain permanence. Employees must avoid inputting “unanonymized” data that could be sensitive or proprietary. Due to its extensive learning capabilities, future renditions of AI could de-anonymize data.
The department director’s approval grants limited use of generative AI chatbots. Company email addresses, credentials or phone numbers can be used to create accounts with these platforms. Personal or sensitive company data of any kind must not be submitted to these platforms.
Employees wishing to use generative AI chatbots must inform their director how the chatbot will be used. Directors must approve or deny requests within ten (10) days. Directors will seek approval from co-founders when necessary.
Acceptable uses include:
- Brainstorming
- Building outlines or summaries
- General knowledge queries to enhance your grasp of complex topics
- Prompting to rephrase anonymized headlines, metadata, sentences or content personalization
- Foreign language translations
- Spreadsheet calculations
- Coding development or debugging
Unacceptable uses include:
- Using direct, AI-generated content without intervening to verify that it meets ethical and operational standards
- Using AI-created text without a thorough review of factual verification
- Inputting client information, even in an anonymized form, that is vulnerable to de-anonymization
- Names, phone numbers, email addresses, proprietary engineering information (as vague as verbal descriptions to CAD models and everything in between) or anything explicitly protected by an NDA or “off the record” request
If you do not know whether an application is acceptable or not, contact your director.
Training
All managers will be trained on the nuances of data privacy and protection in the context of generative AI to reinforce a comprehensive understanding of the risks involved.
Ethical use
Whether free or paid, employees must use generative AI while respecting the confidentiality and privacy of client information, in accordance with our understanding of data protection laws and expectations. Employees must also use generative AI in accordance with all of Gorilla 76’s conduct and anti-discrimination policies. These technologies cannot be used to create content that is inappropriate, discriminatory or otherwise harmful.
Employees agree to abide by all company policies regarding generative AI and the like.
Confidential nature of work
Our customers trust us with very confidential information. All Gorilla 76 records and information relating to Gorilla 76 or its customers are confidential and employees must treat all matters accordingly. That’s why we ask you to sign a Confidentiality Agreement.
Employees who are unsure about the confidential nature of specific information should ask Joe or Jon for clarification.
Health and safety
The health and safety of everyone at Gorilla is very important to us.
With our current work-from-wherever environment, we’ve greatly limited face-to-face contact – and we intend to continue this arrangement. However, there will be times when meetings and in-person gatherings happen.
Please, do not attend any Gorilla-related events if you’re feeling sick. Additionally, if visiting a client office or worksite, Gorilla employees are expected to honor any health and safety policies the client or their business has in place.
This guidance applies to all employees of Gorilla 76.
