Equal Employment Opportunity & Policy Against Harassment

EQUAL EMPLOYMENT OPPORTUNITY It is the Company’s policy to provide equal employment opportunity for all applicants and employees. The Company does not discriminate and prohibits harassment on the basis of race, color, religion, sex (including pregnancy, childbirth or related medical conditions), national origin, ancestry, age, physical disability, mental disability, medical condition, family care status, military or veteran status, marital status, domestic violence, sexual assault, or stalking victim status, sexual orientation or any other characteristic protected by law. The Company also will make reasonable accommodations for qualified individuals with known disabilities unless doing so would result in an undue hardship. This policy governs all aspects of employment, including selection, job assignment, compensation, promotion, discipline, termination, and access to benefits and training. This policy governs all aspects of employment, including recruitment, hiring, training, promotion, compensation, benefits, transfer, and social and recreational programs. It is the responsibility of every manager and employee to conscientiously follow this policy. Employees with questions or concerns about any type of discrimination in the workplace are encouraged to bring these issues to the attention of the Compliance Office. Employees may raise concerns and make reports without fear of reprisal. Anyone found to be engaging in any type of discrimination, harassment or unlawful retaliation will be subject to disciplinary action, up to and including termination of employment.

POLICY AGAINST HARASSMENT Sexual harassment is illegal. The Company is committed to providing a workplace free of sexual harassment (which includes harassment based on gender, pregnancy, childbirth, or related medical conditions), as well as harassment based on such factors as race, color, religion, national origin, ancestry, age, physical disability, mental disability, medical condition, marital status, domestic violence, sexual assault, or stalking victim status, sexual orientation, family care leave status, military or veteran status or any other characteristic protected by law. The Company strongly disapproves of and will not tolerate harassment of employees by managers, supervisors, or co-workers. Similarly, the Company will not tolerate harassment by its employees of non-employees with whom Company employees have a business, service, or professional relationship. The Company also will attempt to protect employees from harassment by non-employees in the workplace. Harassment includes verbal, physical, and visual conduct that creates an intimidating, offensive, or hostile working environment or that interferes with work performance. Such conduct constitutes harassment when (1) submission to the conduct is made either an explicit or implicit condition of employment; (2) submission to or rejection of the conduct is used as the basis for an employment decision; or (3) the harassment interferes with an employee’s work performance or creates an intimidating, hostile, or offensive work environment. Harassing conduct can take many forms and includes, but is not limited to, derogatory comments, epithets, slurs, jokes, statements, leering, gestures, pictures, or cartoons regarding an employee’s sex, race, color, national origin, religion, age, physical disability, mental disability, medical condition, ancestry, marital status, domestic violence, sexual assault, or stalking victim status, sexual orientation, family care leave status, military or veteran status or any other characteristic protected by law.

Sexually harassing conduct in particular includes all of these prohibited actions, as well as other unwelcome conduct such as requests for sexual favors, physical conduct (e.g., touching, assault, blocking movements), conversation containing sexual comments, offering employment benefits in exchange for sexual favors, graphic verbal comments about an individual’s body, suggestive or obscene letters or notes, and unwelcome sexual advances. All such harassment, regardless of form, is a violation of the Company’s policies, which may subject the harasser to disciplinary action (up to and including termination) and/or personal liability for any such unlawful conduct under State and federal laws. Harassing behavior is unacceptable in the workplace itself as well as in other work-related settings, such as business trips, business-related social events, and other Company-related circumstances. Any incident of harassment, including work-related harassment by any Company personnel or any other person, should be reported promptly to the employee’s supervisor or manager (or to any other member of management) or to the Compliance Office, who is responsible for investigating the matter. Managers who receive complaints or who observe harassing conduct should inform the Compliance Office immediately. The Company emphasizes that an employee is not required to complain first to his or her supervisor if that supervisor is the individual who is harassing the employee. Prompt reporting of any harassing conduct enables the Company to respond promptly and take appropriate action, and helps the Company maintain an environment free of harassment for all employees. Every reported complaint of harassment will be investigated thoroughly, promptly, and in a confidential manner. The Company will not reveal the names of participants, the facts of an investigation, or any written information regarding an investigation to anyone not directly involved in the investigation, except to the extent required by law or appropriate to resolve the matter.

Upon completion of the investigation, the Company will communicate its findings and intended actions to the complainant and alleged harasser as expeditiously as possible. If the investigator finds that harassment occurred, the harasser will be subject to appropriate instructive and/or disciplinary procedures. In the case of Company employees, disciplinary action for a violation of this policy may range from verbal or written warnings up to and including immediate termination, depending upon the circumstances. With regard to acts of harassment by customers or vendors, corrective action will be taken after consultation with the appropriate management personnel. The Company will not tolerate retaliation against any employee for cooperating in an investigation or for making a complaint of harassment. Retaliation itself is a serious violation of this policy and should be reported immediately. Any person who engages in retaliatory conduct towards any employee who cooperated in an investigation or made a complaint regarding harassment will be subject to discipline, up to and including termination.

Employees who believe they have been harassed or discriminated against may contact state or federal agencies to file a complaint. Employees who wish to contact the California Department of Fair Employment and Housing (“DFEH”) may do so by calling (800) 884-1684 (or, TTY, (800) 700-2320). For more information about or from the DFEH, visit www.dfeh.ca.gov. Employees who wish to contact the U.S. Equal Employment Opportunity Commission (“EEOC”) may do so by calling (800) 669-4000 (or, TTY, (800) 669-6820). For more information about or from the EEOC, visit www.eeoc.gov. Both the DFEH Confidential 3 and EEOC will investigate complaints of discrimination or harassment, and may attempt to resolve such complaints either by prosecuting, conciliating or settling the matter on the employee’s behalf. If the DFEH believes that a complaint is valid and settlement efforts fail, the DFEH may seek an administrative hearing before the California Fair Employment and Housing Commission (“FEHC”) or file a lawsuit in court. Both the FEHC and the courts have the authority to award monetary and non-monetary relief in meritorious cases. The Company will not retaliate against any employee who files a complaint with, or otherwise participates in an investigation, proceeding or hearing conducted by, the DFEH or EEOC.