HARASSMENT, SEXUAL HARASSMENT & SEXUAL EXPLOITATION

Uphold the Law: [COMPANY NAME]’s commitment to integrity begins with complying with laws, rules and regulations where we do business. Further, each of us must have an understanding of the company policies, laws, rules and regulations that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or the Company policy, we should seek the advice from the resource expert. We are responsible for preventing violations of law and for speaking up if we see possible violations. Because of the nature of our business, some legal requirements warrant specific mention here. [Note to employer: Insert any applicable industry-specific laws here].

Competition: We are dedicated to ethical, fair and vigorous competition. We will sell the Company’s products and services based on their merit, superior quality, functionality and competitive pricing. We will make independent pricing and marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services for the Company or the sales of its products or services, nor will we engage or assist in unlawful boycotts of particular customers.

Proprietary Information: It is important that we respect the property rights of others. We will not acquire or seek to acquire improper means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in unauthorized use, copying, distribution or alteration of software or other intellectual property.

Selective Disclosure: We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations, proposals or otherwise) any material nonpublic information with respect to the Company, its securities, business operations, plans, financial condition, results of operations or any development plan. We should be particularly vigilant when making presentations or proposals to customers to ensure that our presentations do not contain material nonpublic information.

Health and Safety: The Company is dedicated to maintaining a healthy environment. A safety manual has been designed to educate you on safety in the workplace. If you do not have a copy of this manual, please see the HR department.

HARASSMENT, SEXUAL HARASSMENT & SEXUAL EXPLOITATION

[COMPANY NAME] will not tolerate harassment or sexual harassment of any applicant, employee or customer by a managing partner, fellow employee, or independent contractor on the Company premises or at "on location" sites, nor will the Company tolerate sexual exploitation and abuse of any member of the communities in which the Company operates by any staff member, employee or independent contractor of the Company or of our partners or portfolio companies.

Harassment on the basis of any protected characteristic is also strictly prohibited. Under this policy, harassment is verbal, written or physical conduct that denigrates or shows hostility or aversion toward an individual because of his or her race, color, religion, sex, sexual orientation, gender identity or expression, national origin, age, disability, marital status, citizenship, genetic information, or any other characteristic protected by law, or that of his or her relatives, friends or associates, and that: a) has the purpose or effect of creating an intimidating, hostile or offensive work environment, b) has the purpose or effect of unreasonably interfering with an individual’s work performance, or c) otherwise adversely affects an individual’s employment opportunities.

Harassing conduct includes epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion toward an individual or group that is placed on walls or elsewhere on the employer’s premises or circulated in the workplace, on company time or using company equipment by email, phone (including voice messages), text messages, social networking sites or other means.

Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when (1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment, (2) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual or (3) such conduct has the purpose or effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.

Sexual harassment can take two distinct forms: “quid pro quo” and “hostile work environment.” Quid pro quo harassment occurs when submission to sexual conduct is made a condition of employment or employment benefits. Hostile work environment occurs when sexual conduct unreasonably interferes with an employee’s work performance or creates an intimidating, abusive or offensive work environment. Sexual harassment includes verbal harassment, such as epithets, derogatory comments or slurs; physical harassment, such as assault, impeding or blocking movement, or any physical interference with normal work movement; and visual harassment, such as derogatory posters, cartoons, or drawings.

Sexual exploitation is defined as actual or attempted abuse of a position of vulnerability, power, or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. Sexual abuse is defined as actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. Sexual exploitation and abuse are distinct from sexual harassment. Sexual exploitation and abuse occur when a position of power is used for sexual purposes against a beneficiary (whether of [COMPANY NAME]’s products or services, or of [COMPANY NAME]’s partners or portfolio companies) or vulnerable member of the communities in which [COMPANY NAME] operates, whereas sexual harassment is directed against a colleague, employee or other person in the workplace.

In addition, the Company will not tolerate harassment on other grounds, including race, color, national origin, religion, age, disability, and any other basis prohibited by applicable law. Harassment includes jokes, verbal abuse and epithets, degrading comments, the display of offensive objects and pictures, and other physical or verbal conduct that the individual might reasonably find to be offensive or that creates a hostile work environment.

Incidents of alleged harassment/sexual harassment, or sexual exploitation and abuse, will be taken seriously by the Company and will be promptly investigated when such allegations are made. Appropriate corrective action, up to and including termination, will be taken if claims are determined to be true. Any individual who believes that he/she has been subject to harassment/sexual harassment or sexual exploitation and abuse, or has reason to believe harassment/sexual harassment or sexual exploitation and abuse may be taking place towards other individuals, either within [COMPANY NAME] or externally in related organizations or settings (such as in our portfolio companies, Chigign Tobiya or other [COMPANY NAME]-led initiatives), whether or not it directly affects that individual, should report the circumstances as soon as possible to the Operations Manager or a managing partner. All complaints will be