United States

Employment & The Law

We work hard to ensure that InterWorks is a fair and supportive place for everyone who works here, as well as for those seeking to join our ranks. Quite frankly, we believe that inclusion, fairness and diversity make us a stronger and more vibrant organization. You’ll find our official policies below are in keeping with state and federal laws, but our commitment extends beyond what the law requires.

We are constantly striving to excel in this regard, and we need your help to keep InterWorks a welcome and equitable place for years to come. Read through our policies below, then reach out to HR@interworks.com for questions or to learn more about additional efforts.

Equal Employment Opportunity

We firmly believe that you and your coworkers should receive equal employment opportunities from InterWorks without regard to your race, creed, color, gender, gender identity, age, national origin, religion, physical or mental disability, medical condition, marital status, pregnancy, citizenship, veteran’s status and sexual orientation — particularly as mandated by state and federal laws. This commitment applies to all aspects of your employment relationship, including recruitment, selection, placement, transfers, training and development, promotions, salaries, benefits, compensation practices, and all other privileges, terms, and conditions of your employment.

We do not tolerate acts of discrimination or harassment by anyone. You’re expected to treat your coworkers with respect and dignity all the time. If you don’t, we will take appropriate disciplinary action, which could include termination of your employment.

At-Will Employment

As described in your offer letter, everyone at InterWorks in the United States is an “at-will” employee. This means that there is no employment contract between you and InterWorks. You are free to terminate your employment at any time, with or without reason. Similarly, InterWorks has the right to terminate your employment, or otherwise discipline, transfer or change your position at any time, with or without reason, consistent with applicable state and federal law.

Code of Ethics

Simply put: We will conduct our business honestly and ethically. We will constantly improve the quality of our services, products and operations and will create a reputation for honesty, fairness, respect, responsibility, integrity, trust and sound business judgment. No illegal or unethical conduct on the part of officers, directors, employees or affiliates is in the company’s best interest. InterWorks will not compromise its principles for short-term advantage. The ethical performance of this company is the sum of the ethics of the people who work here. Thus, we are all expected to adhere to high standards of personal integrity.

Conflicts of Interest

All employees should avoid any situation which involves or may involve a conflict between their personal interest and the interest of InterWorks. As in all other facets of our duties, dealing with customers, suppliers, contractors, competitors or any person doing or seeking to do business with us are to act in the best interest of the company.

If a situation arises which may involve a conflict of interest, you should make a prompt and full disclosure in writing to your manager. We must be careful to avoid representing InterWorks in any transaction where any outside business affiliation or relationship is at play. Alternatively, we should avoid using our InterWorks contacts to advance private business or personal interests at the expense of the company, its clients or affiliates.

Bribes and Kickbacks

No bribes, kickbacks or other similar payment or consideration should be given to any person or organization in order to attract or influence business activity. Gifts, favors and payments may be given to others at InterWorks’ expense, if they meet all of the following criteria:

Payments, commissions or other compensation to or for the benefit of employees of customers (or their family members or associates) not required by written contract are contrary to this policy.

Receiving Gifts

Similarly, none of us should ever seek or accept any gifts, favors, entertainment or payments from any person or business that does or seeks to do business with or is a competitor of InterWorks. It is never permissible to accept a gift in cash or cash equivalent such as stocks or other forms of marketable securities of any amount. Finally, managers should not accept gifts from those under their supervision of more than limited value.

You may accept for yourself, and members of your family, common courtesies usually associated with customary business practices.


The act or intent to cheat, steal, deceive or lie is both unethical and, in most cases, criminal. Fraud in every form, (e.g., submitting false expense reports; forging or altering financial documents or certifications; misappropriating assets or misusing company property; making any untrue financial or non-financial entry on records or statements) is prohibited.

Insider Trading

Federal and state securities laws make it illegal for anyone to trade in a company’s securities while in possession of material, nonpublic information relating to that company, known as “insider information”.

Because of the work we do, it is possible that you may come to possess “insider information” about a client, partner, or other business in the course of your employment. Such information is subject to the terms of your Employee Confidentiality Agreement, and may not be disclosed. You may not trade, including by placing a purchase or sell order, or recommend that another person trade, in any securities (including making initial elections, changes in elections or reallocation of funds relating to retirement plan accounts) when you have knowledge of material, nonpublic information concerning such securities.

Officers, directors and employees will refrain from gathering competitor intelligence by illegitimate means and refrain from acting on knowledge which has been gathered in such a manner. The officers, directors and employees of InterWorks will seek to avoid exaggerating or disparaging comparisons of the services and competence of their competitors.

Officers, directors and employees agree to disclose unethical, dishonest, fraudulent and illegal behavior, or the violation of company policies and procedures, directly to management. Violation of this policy can result in discipline, including possible termination. The degree of discipline relates in part to whether there was a voluntary disclosure of any ethical violation and whether or not the violator cooperated in any subsequent investigation. Remember that good ethics is good business.


We are all individually responsible for compliance with these rules, standards and principles. In the area of ethics, legality and propriety, you have an obligation to the company that transcends normal reporting relationships. You should stay alert to possible violations of the code anywhere at InterWorks and are encouraged to report such violations promptly.

Reports should be made to the employee’s supervisor, the appropriate People Ops, Sec Ops, or Legal department personnel, or elsewhere as the circumstance dictates. You will be expected to cooperate in an investigation of any violations reported. All cases of questionable activity involving this code of ethics or other potentially improper actions will be reviewed for appropriate action, discipline or corrective steps. Whenever possible, InterWorks will keep confidential those involved in reported violations until it has been determined that a violation has occurred.

You will be required to notify InterWorks within five days of a conviction of any criminal statute violation occurring while on the job. In addition, anyone convicted of a felony, whether related to these rules or not, should report that fact.

Appropriate disciplinary penalties for violations of this policy may include counseling, reprimands, warnings, suspensions (with or without pay), demotions, dismissals and restitution. Disciplinary action may also extend to a violator’s manager when InterWorks determines that the violation involved either the participation of the supervisor or reflected the supervisor’s lack of diligence in seeking compliance, including the failure to report the violation on a timely basis. Anyone who takes any action whatsoever in retaliation against an employee who has in good faith raised any question or concern about compliance with this code of ethics will be subject to serious sanctions, which may include dismissal.

Employees who have questions about this policy should contact our General Counsel for guidance without fear of retaliation. If you have reason to believe that an actual or potential violation of this policy is occurring or has occurred, you should contact our General Counsel immediately, again without fear of retaliation.

ADA and Reasonable Accommodation

We are committed to the fair and equal employment of individuals with disabilities under the Americans with Disabilities Act (ADA). It is our policy to provide reasonable accommodation to qualified individuals with disabilities unless the accommodation would put an undue hardship on our company.

We want to make sure our team members with disabilities can do their jobs and enjoy all the perks of working here. If you’ve got a disability and need some help, just send a request over to HR@. Let them know what you need to really flow into your job, and if you can, share some info to back it up, in line with the rules of ADA.

We’ll look into it, chat with you about it, and see what we can do to make things work better for you. If we need it, we might ask for some medical info about your disability and what can help. But don’t worry, we’ll keep it super confidential, just like the law says.

As stated in many ways throughout this handbook, we put a great deal of weight on how people treat each other here. To us, it’s all about respect. We won’t tolerate any bullying or discrimination because of a disability or because you asked for help. If this happens to you, we’ve got your back. If you ever see or experience any of this, check out our Complaint Procedure (keep reading) to report it.

Harassment Policy

We will always strive to create and maintain a work environment in which people are treated with dignity, decency and respect. The environment of this company should be characterized by mutual trust and the lack of intimidation, oppression and exploitation.

You should be able to work and learn in a safe yet stimulating atmosphere.

The accomplishment of this goal is essential to the mission of the company. Therefore, InterWorks will not tolerate unlawful discrimination or harassment of any kind. Through enforcement of this policy and by the education of each of us, InterWorks will seek to prevent, correct and discipline behavior that violates this policy.

We require each employee to complete annual training through our Paylocity system. You’ll complete this training in your first weeks, then you’ll receive notifications each year when it’s time to update.

Each of us, regardless of position, are covered by and are expected to comply with this policy and take steps to ensure that prohibited conduct does not occur. Appropriate disciplinary action will be taken against anyone who violates this policy. Based on the seriousness of the offense, disciplinary action may include verbal or written reprimand, suspension or termination of employment.

InterWorks, in compliance with all applicable federal, state and local anti-discrimination and harassment laws and regulations, enforces this policy in accordance with the following definitions and guidelines:


It is a violation of our policies and ethics to discriminate in the provision of employment opportunities, benefits or privileges; to create discriminatory work conditions; or to use discriminatory evaluative standards in employment if the basis of that discriminatory treatment is, in whole or in part, the person’s race, color, national origin, age, religion, disability status, gender, sexual orientation, gender identity, genetic information or marital status.

Discrimination of this kind may also be strictly prohibited by a variety of federal, state and local laws, including Title VII of the Civil Rights Act 1964, the Age Discrimination Act of 1975 and the Americans with Disabilities Act of 1990. This policy is intended to comply with the prohibitions stated in these anti-discrimination laws.

Discrimination in violation of this policy will be subject to disciplinary measures up to and including termination.


For purposes of this policy, harassment is any verbal or physical conduct designed to threaten, intimidate or coerce an employee, coworker or any person working for or on behalf of InterWorks. Verbal taunting (including racial and ethnic slurs) that, in the employee’s opinion, impairs his or her ability to perform his or her job is included in the definition of harassment.

The following examples of harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

Sexual Harassment

Sexual harassment is a form of unlawful employment discrimination under Title VII of the Civil Rights Act of 1964 and is prohibited under InterWorks’ anti-harassment policy. According to the Equal Employment Opportunity Commission (EEOC), sexual harassment is defined as “unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature . . . when . . . submission to or rejection of such conduct is used as the basis for employment decisions . . . or such conduct has the purpose or effect of . . . creating an intimidating, hostile or offensive working environment.”

here are two types of sexual harassment:

Sexual harassment occurs when unsolicited and unwelcome sexual advances, requests for sexual favors, or other verbal or physical conduct of a sexual nature:

Sexual harassment may take different forms. The following examples of sexual harassment are intended to be guidelines and are not exclusive when determining whether there has been a violation of this policy:

Courteous, mutually respectful, pleasant, non-coercive interactions between all InterWorkers, that are appropriate in the workplace and acceptable to and welcomed by both parties are not considered to be harassment, including sexual harassment.


No hardship, loss, benefit or penalty may be imposed on any employee in response to:

Retaliation or attempted retaliation in response to lodging a complaint or invoking the complaint process is a violation of this policy. Any person who is found to have violated this aspect of the policy will be subject to sanctions up to and including termination of employment.

Consensual Romantic or Sexual Relationships

We strongly discourage romantic or sexual relationships between a manager or other supervisory employee and his or her staff (an employee who reports directly or indirectly to that person). It should go without saying that these relationships tend to create conflicts of interest or the appearance of such conflicts. Legal words aside: It gets messy.

Such relationships may give rise to the perception that there is favoritism or bias at play. Moreover, given the uneven balance of power within such relationships, “consent” may be seen as suspect and may be viewed by others or, at a later date, by the staff member as having been given as the result of coercion or intimidation. The atmosphere created by such appearances of bias, favoritism, intimidation, coercion, or exploitation undermines the spirit of trust and mutual respect that is essential to a healthy work environment. If there is such a relationship, all involved need to be aware that one or both may be moved to a different department, or other actions may be taken when necessary.

If anyone here enters into a consensual relationship that is romantic or sexual in nature with a member of their team (one who reports directly or indirectly to him or her), or if one of the parties is in a supervisory capacity in the same department in which the other party works, the parties must notify the HR director or other appropriate corporate officer. Because of potential issues regarding quid pro quo harassment, InterWorks has made reporting mandatory. This requirement does not apply to those who do not work in the same department or to parties who do not supervise or otherwise manage responsibilities over the other. Again, don’t let it get messy.

Once the relationship is made known, we’ll review the situation with HR in light of all the facts (e.g., reporting relationship between the parties, effect on coworkers, job titles, etc.) and determine whether someone should be moved to another job or department. If it is determined that one must be moved and given that there are jobs in other departments available, all involved may decide who will be the one to apply for a new position. If an amicable decision cannot be made, or if the target department is not open to the change, the group will meet again with HR to find the best solution. That decision will be based on which move will be least disruptive to the organization as a whole. If it is determined that someone must be moved, but no other jobs are available for any involved, the parties will be given the option of terminating their relationship or resigning.
We told you it can get messy. However, we are all human and romantic relationships are an essential part of that human experience. It’s simply worth understanding the potential outcomes and knowing the process to keep everything from, well, getting messy.

What to Expect When Filing a Complaint

We commit to courteously and respectfully treating any person who invokes this complaint procedure and will handle all complaints swiftly and confidentially to the extent possible. Lodging a complaint will in no way be used against or have an adverse impact on the individual’s employment status. Because of the damaging nature of harassment to the victims and to the entire workforce, aggrieved employees are strongly urged to use this procedure. However, filing groundless or malicious complaints is an abuse of this policy and will be treated as a violation.


During the complaint process, the confidentiality of the information received, the privacy of the individuals involved, and the wishes of the complaining person will be protected to as great a degree as is possible. The expressed wishes of the complaining person for confidentiality will be considered in the context of the company’s legal obligation to act on the charge and the right of the charged party to obtain information. In most cases, however, confidentiality will be strictly maintained by the company and those involved in the investigation. In addition, any notes or documents written by or received by the person(s) conducting the investigation will be kept confidential to the extent possible and according to any existing state or federal law.

Complaint Procedure

InterWorks has established the following procedure for lodging a complaint of harassment, discrimination or retaliation. The company will treat all aspects of the procedure confidentially to the extent reasonably possible.

  1. An individual who feels harassed, discriminated against or retaliated against may initiate the complaint process by filing a complaint in writing with InterWorks’ People Operations Lead. No formal action will be taken against any person under this policy unless People Ops has received a written and signed complaint containing sufficient details to determine if the policy may have been violated. If a supervisor or manager becomes aware that harassment or discrimination is occurring, either from personal observation or as a result of an employee’s coming forward, the supervisor or manager should immediately report it to the People Ops Lead.
  2. Upon receiving a complaint or being advised by a supervisor or manager that violation of this policy may be occurring, the People Ops Lead will notify the company and review the complaint with the company’s legal counsel.
  3. Within five working days of receiving the complaint, the People Ops Lead will notify the person(s) charged [hereafter referred to as “respondent(s)”] of a complaint and initiate the investigation to determine whether there is a reasonable basis for believing that the alleged violation of this policy occurred.
  4. During the investigation, the People Ops Lead, will interview the complainant, the respondent and any witnesses to determine whether the alleged conduct occurred.
  5. Within 15 business days of the complaint being filed (or the matter being referred to the People Ops Lead), the People Ops Lead or other person conducting the investigation will conclude the investigation and submit a written report of his or her findings to the company.
  6. If it is determined that harassment or discrimination in violation of this policy has occurred, the People Ops Lead will recommend appropriate disciplinary action. The appropriate action will depend on the following factors: a) the severity, frequency and pervasiveness of the conduct; b) prior complaints made by the complainant; c) prior complaints made against the respondent; and d) the quality of the evidence (e.g., firsthand knowledge, credible corroboration).
  7. If the investigation is inconclusive or if it is determined that there has been no violation of policy but potentially problematic conduct may have occurred, the People Ops Lead may recommend appropriate preventive action.
  8. Within five days after the investigation is concluded, the People Ops Lead will meet with the complainant and the respondent separately, notify them of the findings of the investigation and inform them of the action being recommended.
  9. The complainant and the respondent may submit statements to the People Ops Lead challenging the factual basis of the findings. Any such statement must be submitted no later than five working days after the meeting with the People Ops Lead in which the findings of the investigation are discussed.
  10. Within 10 days from the date the People Ops Lead meets with the complainant and respondent, the company will review the investigative report and any statements submitted by the complainant or respondent, discuss results of the investigation with the People Ops Lead and other management staff as may be appropriate, and decide what action, if any, will be taken. The People Ops Lead will report the company’s decision to the complainant, the respondent and the appropriate management assigned to the department(s) in which the complainant and the respondent work. The company’s decision will be in writing and will include findings of fact and a statement for or against disciplinary action. If disciplinary action is to be taken, the respondent will be informed of the nature of the discipline and how it will be executed.

The tasks and timeframes outlined above should be considered guidelines; investigatory tasks and conversations may be undertaken by such other people appropriately assigned by the People Ops Lead, and timeframes may be adjusted as circumstances warrant.

Alternative Legal Remedies
Nothing in this policy may prevent the complainant or the respondent from pursuing formal legal remedies or resolution through local, state or federal agencies or the courts.

Labor and Employment Notices

All of the InterWorks offices in Oklahoma have labor and employment law posters hung in the kitchen or breakroom areas for employees to review. For our remote folks who don’t have a physical worksite or break room wall, you’ll find these and other legally-required notices in The Library here.