Run: Anti-Bullying Policy

This policy establishes expectations for respectful workplace conduct and prohibits bullying behavior that interferes with work performance, employee well-being, or a safe and productive work environment. It also explains reporting, investigation, and corrective action procedures. This policy is intended to support compliance with applicable laws, including **Title VII of the Civil Rights Act of 1964**, the **NLRA Section 7** protections for concerted activity, and any applicable state or local anti-retaliation or workplace conduct requirements.

This policy applies to all employees, managers, supervisors, officers, contractors, interns, temporary workers, and any other individuals performing work on behalf of the company. It applies to conduct that occurs: - On company premises - During working time or work-related events - In remote or hybrid work settings - In communications using company systems, personal devices used for work, email, chat, text, video meetings, or social media when work-related **California employees:** This policy must be applied consistently with California anti-discrimination, anti-retaliation, and workplace safety obligations, and any applicable local requirements. **New York employees:** Reports involving whistleblower concerns must be handled consistently with **NY Labor Law Section 740** where applicable.

**Bullying** means repeated, unreasonable, or unwelcome behavior that a reasonable person would consider intimidating, demeaning, humiliating, or abusive. Examples may include: - Yelling, insulting, or using demeaning language - Spreading rumors or intentionally excluding someone from work-related information - Public criticism designed to embarrass rather than correct performance - Threatening job status, assignments, or schedules to intimidate - Sabotaging work, withholding needed information, or setting someone up to fail - Repeated offensive jokes, gestures, or electronic messages Bullying does **not** include: - Good-faith performance management - Constructive feedback delivered professionally - A documented warning, coaching, or a PIP based on legitimate business needs - Lawful discipline or supervision - Protected concerted activity under the NLRA **Retaliation** includes any adverse action taken because an employee made a good-faith report, participated in an investigation, or engaged in protected activity.

Bullying is prohibited. Employees must treat coworkers, customers, vendors, and visitors with professionalism and respect. Managers and supervisors have a heightened responsibility to model appropriate conduct, intervene when they observe bullying, and escalate concerns promptly. The company will not tolerate retaliation against any person who reports bullying in good faith, participates in an investigation, requests a reasonable accommodation, or otherwise engages in protected activity.

Employees should report bullying as soon as possible, even if they are unsure whether the conduct violates this policy. Reports may be made to: - A direct manager, unless the manager is involved in the concern - HR - A designated compliance or ethics contact - An anonymous reporting channel, if available Reports should include, when possible: - Names of the people involved - Dates, times, and locations - A description of what happened - Witnesses, messages, screenshots, or other relevant evidence Employees are encouraged to report in good faith. False reports made knowingly or maliciously may result in discipline. If the concern involves a manager, HR, or a conflict of interest, the report must be escalated to an alternate reporting channel.

The company will review reports promptly and conduct a good-faith, impartial investigation as appropriate. Investigation steps may include: - Acknowledging the report and assessing immediate risk - Interviewing the reporting employee, the accused employee, and witnesses - Reviewing documents, messages, recordings, schedules, or system logs - Taking interim measures when needed to prevent further harm - Documenting findings and determining whether the policy was violated Investigations will be handled as confidentially as possible, consistent with the need to conduct a thorough review and comply with legal obligations. The company may adjust reporting lines, schedules, work locations, or access to preserve safety and prevent retaliation during the investigation.

If the company determines that bullying or retaliation occurred, it will take corrective action based on the severity, frequency, impact, prior history, and any legal or contractual obligations. Corrective action may include: - Coaching or counseling - A documented warning - A performance improvement plan (PIP) where appropriate - Mandatory training - Removal from supervisory duties - Suspension or termination of employment - Other remedial measures reasonably necessary to stop the conduct The company may also take action when conduct does not rise to the level of bullying but still violates standards of professional conduct.

**Employees** must treat others respectfully, report concerns in good faith, and cooperate with investigations. **Managers and supervisors** must address concerns promptly, avoid retaliation, and escalate reports to HR or Compliance. **HR / Compliance** must review reports, coordinate investigations, maintain documentation, and recommend corrective action. **Policy holder** is responsible for maintaining this policy, ensuring training is completed, and reviewing the policy at least annually.

This policy does not restrict employees from engaging in protected activity, including concerted activity under **NLRA Section 7**, reporting discrimination or harassment, requesting a reasonable accommodation through the interactive process, or exercising rights under applicable wage-and-hour, leave, safety, or whistleblower laws. Nothing in this policy should be interpreted to interfere with rights under the **FLSA**, **FMLA**, **ADA**, **EEOC**-enforced laws, OSHA protections, or applicable state laws. Where a state or local law provides greater protection or imposes additional requirements, the company will follow the law that provides the greater employee protection.

This policy will be reviewed at least annually and updated as needed to reflect legal, operational, or organizational changes. Any revisions must be approved by the policy holder, HR leadership, and legal counsel as appropriate.