Equal Opportunity Employment

This Company is an equal opportunity employer and makes employment decisions on the basis of merit and business needs. The Company does not unlawfully discriminate on the basis of race, color, religion, sex (including pregnancy, childbirth or related medical conditions, gender identity/expression and transgender status), familial status, national origin or ancestry, citizenship, physical or mental disability (including gender dysphoria and being a certified medical marijuana patient), genetic information (including predisposing genetic characteristics), age (18 and over), veteran status, military status, sexual orientation, marital status, familial status, certain arrest or conviction records and domestic violence victim status or any other basis protected by local, state, or federal law. The Company will not tolerate discrimination or harassment based upon an employee’s membership in one or more of these protected categories, an employee’s known relationship or association with a member of one or more of these protected categories, or any other characteristic protected by applicable federal, state or local law. Improper interference with the ability of Company’s employees to perform their job duties may result in discipline up to and including discharge. For information about the types of conduct that constitute unlawful harassment and the Company’s internal procedures for addressing complaints of harassment, please refer to the Company’s Reporting and Investigation procedures contained in the Policy Prohibiting Discrimination, Harassment, and Retaliation.

Disability Accommodation

To comply with applicable laws ensuring equal employment opportunities to qualified individuals with a disability, the Company will make reasonable accommodations for the known physical or mental limitations of an otherwise qualified individual with a disability who is an applicant or an employee unless undue hardship and/or a direct threat to the health and/or safety of the individual or others would result would result. Employees or applicants who have questions about this policy or who wish to request a reasonable accommodation under this policy should contact Chief People Officer.

Pregnancy Accommodation

Employees and applicants for employment may request a reasonable accommodation for pregnancy-related conditions. A request for an accommodation may not be granted if the requested accommodation would cause undue hardship to the Company’s business operations or if the employee is not able to perform the essential functions of her job with an accommodation. Leave provided as a reasonable accommodation will run concurrent with the Family and Medical Leave Act (FMLA) to the extent leave under this policy also qualifies as leave under the FMLA. Employees or applicants who have questions about this policy or who wish to request a reasonable accommodation under this policy should contact Chief People Officer.

Religious Accommodation

The Company will provide reasonable accommodation for employees’ religious beliefs, observances, and practices when a need for such accommodation is identified and reasonable accommodation is possible. The Company has developed an accommodation process to assist employees. Through this process, the Company establishes a system of open communication between employees and the Company to discuss conflicts between religion and work and to take action to provide reasonable accommodation for employees’ needs. The intent of this process is to ensure a consistent approach when addressing religious accommodation requests. Any employee who perceives a conflict between job requirements and religious belief, observance, or practice should bring the conflict and his or her request for accommodation to the attention of Chief People Officer to initiate the accommodation process. The Company requests that accommodation requests be made in writing, and in the case of schedule adjustments, as far in advance as possible.

Discrimination on the Basis of Gender, Gender Identity or Transgender Status (New York City)

The Company prohibits discrimination against and/or harassment of applicants, employees, and interns on the basis of their actual or perceived gender or actual or perceived status as an individual who is transgender, gender non-conforming or intersex. For purposes of this policy, gender includes gender identity, self-image, appearance, behavior or expression. Harassment includes, but is not limited to, violence, threats of violence and similar conduct.

The Company evaluates all requests for accommodation (including requests for medical leaves) in a non-discriminatory manner.

Employees who engage with the public as part of their job duties are required to do so in a respectful, non-discriminatory manner by respecting gender diversity and ensuring that members of the public are not subject to discrimination (including discrimination with respect to single- sex programs and facilities).

Preferred Names, Titles and Pronouns

The Company allows employees to self-identify their names and genders and will use an individual’s preferred name, title (e.g., Mr./ Ms.) and pronoun (e.g., he/him/his; she/her/hers; they/them/theirs; or ze/hir). Requests to be addressed by a certain name and/or pronoun do not require supporting documentation.

If an employee is unsure what name, title or pronoun another individual prefers, that employee can ask the person how he or she would like to be addressed.

Dress and Grooming

The Company’s dress and grooming standards are gender neutral, meaning they do not differentiate or impose restrictions or requirements based on gender or sex.

Reporting and Anti-Retaliation

Employees with questions or concerns regarding their safety, gender discrimination and/or a request for a reasonable accommodation or who feel they have been subjected to discrimination or improperly denied an accommodation, should please refer to the Company’s Reporting and Investigation procedures contained in the Policy Prohibiting Discrimination, Harassment, and Retaliation in this Handbook. The Company prohibits and does not tolerate retaliation against employees who report issues or concerns of gender discrimination pursuant to this policy in good faith.

Policy Prohibiting Discrimination, Harassment, and Retaliation

The Company is committed to providing a work environment that is free of discrimination and harassment. In keeping with this policy, the Company strictly prohibits discrimination and harassment of any kind, including discrimination and harassment on the basis of race, color, religion, sex (including pregnancy, childbirth or related medical conditions, gender identity/expression and transgender status), familial status, national origin or ancestry, citizenship, physical or mental disability (including gender dysphoria and being a certified medical marijuana patient), genetic information (including predisposing genetic characteristics), age (18 and over), veteran status, military status, sexual orientation, marital status, familial status, certain arrest or conviction records and domestic violence victim status or any other basis protected by local, state, or federal law.

Definitions

1. Harassment may take many forms, but the most common forms include:
2. Verbal harassment – such as jokes, epithets, slurs, negative stereotyping, and unwelcome remarks about an individual’s body, color, physical characteristics, or appearance, questions about a person’s sexual practices, or gossiping about sexual relations;
3. Physical harassment – such as physical interference with normal work, impeding or blocking movement, assault, unwelcome physical contact, leering at a person’s body, and threatening, intimidating, or hostile acts that relate to a protected characteristic;
4. Visual harassment – such as offensive or obscene photographs, calendars, posters, cards, cartoons, e-mails, drawings, and gestures, display of sexually suggestive or lewd objects, unwelcome notes or letters, and any other written or graphic material that denigrates or shows hostility or aversion toward an individual, because of a protected characteristic, that is placed on walls, bulletin boards, or elsewhere on the employer’s premises or circulated in the workplace.
5. Sexual harassment – There are two distinct categories of sexual harassment:

1. 1. Quid Pro Quo- When an individual’s submission to or rejection of unwelcome sexual conduct is used as a basis for employment decisions affecting that individual, including granting of employment benefits; and
   2. Hostile Environment – When unwelcome sexual conduct unreasonably interferes with an individual’s job performance or creates an intimidating, hostile, or offensive working environment, even if it does not lead to tangible or economic job consequences.

Sexual harassment includes harassment of women by men, of men by women, and same- sex harassment. Sexual harassment is unlawful whether it involves co-worker harassment, harassment by a supervisor or manager, or by persons doing business with or for the Company.

The Company prohibits any and all conduct that may reasonably be interpreted as harassment as defined above whether or not such conduct is pervasive enough or severe enough to meet the technical legal requirements of harassment.

Reporting and Investigation

If you believe you have been subject to harassment of any kind or conduct that violates this policy, you must immediately report the facts of the conduct to your supervisor or the Chief People Officer, or both. If, for any reason, you do not feel comfortable discussing the matter with your supervisor, you should bring the matter to the attention of the Chief People Officer, or where you feel unable to do that, to the Chief Executive Officer. The important thing is that you bring the matter to the Company’s attention promptly so that any concern of harassment can be investigated and addressed appropriately.

All complaints will be promptly and thoroughly investigated, and all information disclosed during the course of the investigation will remain confidential, except as necessary to conduct the investigation and take any remedial action, and in accordance with applicable law. All employees and supervisors have a duty to cooperate in the investigation of alleged harassment. In addition, failing to cooperate or deliberately providing false information during an investigation shall be grounds for disciplinary action, including termination of employment. At the conclusion of its investigation, if the Company determines a violation of policy has occurred, it will take effective remedial action commensurate with the severity of the offense. This action may include disciplinary action against the accused party, up to and including termination. Steps will be taken, as reasonable and necessary, to prevent any further violations of policy.

Retaliation

Retaliation for reporting any incidents of harassment or discrimination, or perceived harassment or discrimination, for making any complaints of harassment or discrimination, or participating in any investigation of incidents of harassment or discrimination, or perceived harassment or discrimination, is strictly prohibited.

Any report of retaliation by the one accused of harassment or discrimination, or by coworkers, supervisors, or managers, will also be promptly and thoroughly investigated in accordance with the Company’s investigation procedures outlined above. If a complaint of retaliation is substantiated, appropriate disciplinary action, up to and including discharge, will be taken.

Additional Enforcement Information

In addition to the Company’s internal complaint procedure, employees should also be aware that the federal Equal Employment Opportunity Commission (EEOC) and the New York State Division of Human Rights (NYSDHR) investigate and prosecute complaints of harassment, discrimination, and retaliation in employment. You may contact the EEOC and the NYSDHR directly. Their phone numbers are listed in the telephone book and can also be found on the internet.

Modification

This policy can be modified unilaterally by the Company at any time without notice. Modification may be necessary to maintain compliance with local, state, and federal laws and/or accommodate organizational changes within the Company.