Trust in the Workplace – Our Commitment to Our Colleagues

We are committed to fostering a high trust work environment for our colleagues, which is the kind of environment where people do their best work. Unlawful harassment, discrimination and threats to health and safety all undermine our high trust environment, and make it harder for people to excel. Therefore, it is our policy to provide a safe work environment, free of unlawful harassment, intimidation and discrimination.

All the guidelines regarding our workplace extend beyond the physical premises of 21CF companies to include anyone conducting Company business or representing the Company, wherever they may be, as well as attendance at Company-sponsored events.

Equal Opportunity: We maintain a strong policy of equal opportunity for all of our employees and applicants for employment, and are committed to complying with all of our obligations under applicable laws.

Non-Discrimination: We make all employment related decisions (hiring, promotion, compensation, etc.) without unlawful regard to a person’s race, color, religion, age, nationality, gender, sexual orientation, pregnancy, disability, military or veteran’s status, marital status or any other characteristic prohibited from consideration by the laws of the countries, states and cities in which we do business.

Harrassment-Free: We endeavor to ensure that the workplace is free of bullying and unlawful harassment, whether that harassment is sexual in nature, or is based on an employee’s sex, race, religion or any other characteristic protected by applicable law. It is our policy to investigate promptly and thoroughly any 21CF colleague complaint of discrimination or harassment, and to take remedial measures, if the Company determines that there has been a violation of the Company’s policy against such conduct.

As Employees: We understand that if we witness or experience harassment or discrimination, we have an affirmative obligation to report such conduct to a manager in Human Resources or an attorney in the Legal Department.

Health and Safety: We observe all applicable health, safety, environmental and labor laws, and strive for a safe and healthy work environment.

Accommodations for Individuals with Disabilities: We make reasonable accommodations for qualified individuals with disabilities in accordance with the applicable laws.

Drug-Free Workplace: We maintain a workplace free of alcohol abuse and the use of illegal drugs.

Data Privacy: We respect the privacy rights of employees in how the Company handles personal data, consistent with the Electronic Communications Policy applicable to your business unit.

Crisis Management: We work to prepare appropriate crisis management plans, and participate in any emergency drills and planning that our business units may institute.

On Site Security: We follow the procedures established at each Company site for access and security.

What is harassment? Harassment can take many forms. Harassing conduct may include, but is not limited to, offensive jokes, slurs, epithets or name calling, physical assaults or threats, intimidation, ridicule or mockery, insults or put-downs, offensive objects or pictures, and interference with work performance. Sexual harassment can include 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 unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.