Policy

The Company prohibits harassment of any kind, whether intentional or unintentional, based on protected characteristics such as race, color, religion, national origin, age, sex, gender identity, sexual orientation, marital status, military status, disability, or any other characteristic protected by law. Harassment by employees, supervisors, vendors, or any third party will not be tolerated. This policy applies in the workplace, on Company business, or while representing the Company.

Courteous, mutually respectful, pleasant, noncoercive interactions between employees that are appropriate in the workplace and acceptable to and welcomed by both parties are not considered to be harassment, including sexual harassment.

Harassment Defined

Harassment includes unwelcome verbal, visual, or physical conduct that demeans an individual based on protected characteristics or interferes with work performance or creates a hostile work environment. Examples include slurs, jokes, offensive visuals, threats, and unwelcome advances.

Sexual Harassment Defined

Sexual harassment involves unwelcome sexual advances, requests for favors, or other conduct of a sexual nature that affects employment decisions, performance, or creates an offensive work environment. This includes inappropriate comments, gestures, or behavior such as touching, leering, or sexual jokes.

Reporting Procedures

Employees should report any harassment to Human Resources or, if needed, the COO.

If no response is received within five business days, employees may contact a higher- level manager.

Investigation Procedures

Every report of perceived harassment will be fully investigated, and corrective action will be taken where appropriate. All complaints will be kept confidential to the extent possible, but confidentiality cannot be guaranteed. All employees must cooperate with all investigations conducted pursuant to this policy.

Retaliation Prohibited

In addition, the Company will not allow any form of retaliation against individuals who report unwelcome conduct to management or who cooperate in the investigations of such reports in accordance with this policy. If the employee has been subjected to any such retaliation, the employee should report it in the same manner in which the employee would report a claim of perceived harassment under this policy.

Violation of this policy including any improper retaliatory conduct will result in disciplinary action, up to and including termination.

Training

All employees shall complete sexual harassment training annually. If not directly provided, the Company will arrange for and cover the expense of such training.