We recommend that the Chairman: (a) incorporate a specific harassment-free culture standard into the Performance Management Program and Bonus Criteria for all staff; (b) incorporate harassment prevention into the bonus criteria for managers and executives; (c) develop and implement a process that considers violations of the anti-harassment policy when determining whether an employee should serve in a supervisory or managerial capacity; and (d) develop and implement a process that considers violations of the anti-harassment policy when determining whether an employee is eligible to receive a bonus.