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One of the major objectives of ²ÝÁñÉçÇø. is to follow both the spirit and the letter of the law and to maintain a reputation for high standards of business. Creative, enthusiastic employees are our most important resource and the basis for our success. We seek an environment characterized by respect for each individual, where cultural and ethnic diversity are blended by teamwork into a harmonious work force.

1.0 GUIDELINES

1.1 Equal employment opportunity is adopted to ensure the rights and dignity of each person.

1.2 Personnel actions, including recruitment, selection, training, compensation, corrective counseling, promotions, transfers, staff reductions and terminations shall be based upon individual initiative, interests, ability, performance results, and needs of the business.

1.3 All personnel actions referenced in paragraph 1.2 shall be administered free from harassment, intimidation, threats, coercion or discrimination on the grounds of race, religious creed, color, national origin, ancestry, physical or mental disability, medical condition, marital status, gender, sexual orientation, gender identity, age, or veteran status. ²ÝÁñÉçÇø also prohibits retaliation against employees and applicants for filing a complaint, opposing any discriminatory act or practice, assisting or participating in any manner in a review, investigation or hearing regarding ²ÝÁñÉçÇø¡¯ employment practices, or otherwise seeking to exercise their legal rights under and federal, state, or local law requiring equal employment opportunity.

1.4 For known limitations of qualified individual applicants or employees with disabilities, reasonable accommodation will be provided, except where the accommodation would impose an undue hardship on operation of the business. Additionally, all job decisions will be made based on valid job requirements.

1.5 ²ÝÁñÉçÇø. does not discriminate on the basis of national origin or citizenship status as provided under the Immigration Reform and Control Act of 1986.

1.6 ²ÝÁñÉçÇø. is also committed to abiding with the Pay Transparency Nondiscrimination Provisions and therefore, will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant. ²ÝÁñÉçÇø.¡¯s employees who have access to the compensation information of other employees or applicants as part of their essential job functions are informed and trained to not disclose the pay of other employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is (a) a response to a formal complaint or charge; (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer, or (c) consistent with ²ÝÁñÉçÇø.¡¯s legal duty to furnish the information.

1.7 We will work cooperatively with governmental agencies, educational institutions and community action groups concerned with employment opportunities for women, minorities, veterans, or individuals with a disability, as well as with suppliers in sustaining and perpetuating equal employment opportunities.

2.0 RESPONSIBILITIES

2.1 Jill Larsen, Chief People Officer, is appointed the Equal Employment Opportunity (EEO) Officer for ²ÝÁñÉçÇø, with the support of all management including the COO, and is responsible for implementation of ²ÝÁñÉçÇø¡¯ Affirmative Action Program (AAP). The EEO Officer also is responsible for establishing and maintaining an internal audit and reporting system that tracks and measures the effectiveness of ²ÝÁñÉçÇø¡¯ AAP and shows where additional action is needed to meet ²ÝÁñÉçÇø¡¯ objectives.

2.2 All members of management are responsible for maintaining a discrimination-free work environment by inspirational leadership and personal example.

2.3 All employees share the responsibility for mutual understanding, a spirit of cooperation and high standards of non-discriminatory behavior.