Discrimination and Harassment Prevention Policy

Introduction and Purpose

Unique is committed to providing a work environment free from discrimination, harassment, and retaliation, where all individuals are treated with dignity, respect, and equity. This policy formalizes our commitment to fostering a diverse and inclusive workplace that promotes equal opportunities for all employees.

This Discrimination and Harassment Prevention Policy outlines our approach to preventing, identifying, addressing, and remedying discriminatory or harassing behavior within our organization. It complements our Code of Conduct and Human Rights Policy, establishing clear standards and procedures that uphold our values and legal obligations.

Scope and Application

This policy applies to all Unique employees, contractors, temporary workers, interns, volunteers, and applicants, regardless of position or status. It extends to all work-related settings and activities, including off-site events, business trips, and electronic communications. We also expect our clients, suppliers, and other business partners to adhere to the principles outlined in this policy when interacting with our employees.

Our Commitment to Equal Opportunity

Unique is committed to providing equal employment opportunities to all individuals. Our commitment includes:

• Recruiting, hiring, training, and promoting based on qualifications, skills, and merit

• Making employment decisions without regard to protected characteristics

• Ensuring fair and consistent application of employment policies and practices

• Providing reasonable accommodations when necessary

• Creating advancement opportunities based on performance and potential

• Maintaining pay equity for comparable work

• Fostering a culture that values diversity and inclusion

Prohibited Conduct

Discrimination

Unique prohibits discrimination based on:

• Gender or gender identity

• Race, ethnicity, or national origin

• Age

• Religion or beliefs

• Disability or health status

• Sexual orientation

• Family or marital status

• Any other legally protected characteristic

Discrimination may include, but is not limited to:

• Unequal treatment in hiring, promotion, compensation, or termination

• Denial of training or development opportunities

• Inequitable allocation of work assignments

• Exclusion from meetings, communications, or work-related social activities

• Application of policies or practices with disproportionate adverse impact

Harassment

Unique prohibits all forms of harassment, including:

• Unwelcome comments, jokes, slurs, or stereotypes

• Intimidation or bullying

• Inappropriate physical contact

• Creation of a hostile or offensive work environment

• Unwanted sexual advances or comments

• Persistent unwelcome behavior

• Microaggressions (subtle, often unintentional comments or actions that communicate negative attitudes)

• Display or sharing of offensive materials

• Threats or coercion related to employment actions

Sexual Harassment

Sexual harassment is a specific form of harassment that warrants particular attention. It may include:

• Unwelcome sexual advances or propositions

• Requests for sexual favors, especially when linked to employment decisions

• Sexually suggestive comments, jokes, or innuendos

• Unwanted physical contact of a sexual nature

• Display or sharing of sexually explicit materials

• Persistent unwanted attention of a romantic or sexual nature

• Sexual assault or other physical conduct of a sexual nature

Retaliation

Unique strictly prohibits retaliation against any individual who:

• Reports discrimination or harassment in good faith

• Participates in an investigation

• Supports another employee who has reported concerns

• Requests a reasonable accommodation

Reporting

Manager Responsibilities

Managers who observe or receive reports of potential discrimination or harassment must:

• Take all complaints seriously

• Report the matter to People & Culture or Compliance immediately

• Maintain confidentiality to the extent possible

• Protect the reporting employee from retaliation

• Cooperate fully with investigations

Investigation Process

Initial Response

Upon receiving a report, Unique will:

• Acknowledge receipt promptly

• Assess the need for immediate interim measures

• Designate an impartial investigator

• Inform relevant parties about the investigation process

Investigation

The investigation will be conducted promptly, thoroughly, and impartially. The process typically includes:

• Interviewing the complainant, the accused, and relevant witnesses

• Reviewing relevant documents and evidence

• Documenting all aspects of the investigation

• Determining whether policy violations occurred

Confidentiality

All investigations will be conducted with as much confidentiality as possible while still allowing for a thorough investigation. Information will be shared only on a need-to-know basis.

Resolution and Remedial Action

If an investigation confirms policy violations, Unique will take appropriate remedial action, which may include:

• Disciplinary action up to and including termination

• Training or coaching

• Reassignment or adjustment of reporting relationships

• Organizational changes to prevent recurrence

• Monitoring to ensure the behavior has stopped

• Support services for affected individuals

• Legal actions if necessary

Reasonable Accommodations

Unique will provide reasonable accommodations to qualified individuals with disabilities, for religious practices, and for pregnancy, childbirth, or related medical conditions, unless doing so would create an undue hardship.

Responsibilities

Employee Responsibilities

• Treat all colleagues, customers, and business partners with dignity and respect

• Refrain from engaging in discrimination, harassment, or retaliation

• Report observed or experienced policy violations

• Cooperate fully in investigations

Manager Responsibilities

• Model appropriate behavior

• Monitor the work environment for signs of discrimination or harassment

• Address inappropriate behavior promptly

• Report policy violations to People & Culture or Compliance

• Support diversity and inclusion initiatives

People & Culture and Compliance Responsibilities

• Implement and administer this policy

• Conduct prompt, thorough investigations

• Provide guidance on reasonable accommodations

• Maintain appropriate records

• Review and update this policy as needed

Monitoring and Review

Unique will regularly assess the effectiveness of this policy through:

• Analysis of complaint data and resolution outcomes

• Employee feedback

• Regular policy reviews to ensure alignment with legal requirements

• Integration of lessons learned from investigations