Anti-Discrimination & Equal Opportunity Policy

1. Introduction & Commitment

This Anti-Discrimination & Equal Opportunity Policy (the "Policy") reflects Nexly Corporation's ("Nexly" or the "Company") unwavering commitment to providing a workplace free from discrimination and harassment and to promoting equal opportunity for all employees and applicants for employment. Located at 701 South Street Suite 100, Mountain Home, AR 72653, Nexly is dedicated to fostering a diverse, inclusive, and equitable environment where all individuals are treated with respect and dignity. We believe that a diverse workforce, representing a variety of backgrounds, perspectives, and experiences, is essential to our success. This Policy is designed to:

• Prohibit Discrimination and Harassment: Create a workplace where discrimination and harassment of any kind are strictly prohibited.
• Promote Equal Opportunity: Ensure that all employment decisions, including hiring, promotion, compensation, training, and termination, are based on merit and qualifications, without regard to protected characteristics.
• Foster a Diverse and Inclusive Workplace: Create a welcoming and inclusive environment where all employees feel valued, respected, and have the opportunity to succeed.
• Comply with All Applicable Laws and Regulations: Ensure compliance with all federal, state, and local laws and regulations related to anti-discrimination and equal opportunity.
• Provide a Clear Process for Reporting Complaints: Provide a safe and confidential process for employees to report incidents of discrimination or harassment.
• Take Prompt and Effective Action: Investigate all complaints of discrimination or harassment promptly and take appropriate corrective action.

This Policy applies to all Nexly employees, applicants for employment, contractors, vendors, and any other individuals who interact with Nexly in the workplace. This Policy is to be read in conjunction with the Nexly Corporation Code of Conduct and all other relevant internal policies.

2. Protected Characteristics & Prohibited Discrimination

Nexly Corporation prohibits discrimination based on any of the following protected characteristics:

• Race: Including traits associated with race, such as hair texture and protective hairstyles.
• Color:
• Religion: Including all aspects of religious belief, observance, and practice, as well as lack of religious belief.
• Sex: Including gender, gender identity, gender expression, and sexual orientation.
• Sexual Orientation:
• Gender Identity or Expression: This includes, but is not limited to, a person's gender-related identity, appearance, or behavior, whether or not that identity, appearance, or behavior is different from that traditionally associated with the person's sex assigned at birth.
• National Origin: Ancestry or place of birth.
• Age: (40 years or older).
• Disability: Including physical or mental impairments that substantially limit one or more major life activities; a record of having such an impairment; or being regarded as having such an impairment. Nexly will provide reasonable accommodations to qualified individuals with disabilities.
• Genetic Information: Information about an individual’s genetic tests, the genetic tests of family members, and information about the manifestation of a disease or disorder in a family member.
• Pregnancy, Childbirth, or Related Medical Conditions:
• Veteran Status: Including military service, protected veterans (e.g., disabled veterans, recently separated veterans, active duty wartime or campaign badge veterans), and their status.
• Marital Status: (As applicable under state and local law).
• Citizenship Status: (As permitted by law).
• Any other characteristic protected by applicable federal, state, or local law.

Discrimination includes any adverse employment action based on a protected characteristic, including, but not limited to:

• Failure or refusal to hire.
• Termination of employment.
• Discrimination in compensation or benefits.
• Denial of promotion or advancement opportunities.
• Unfair demotion or reassignment.
• Harassment.
• Unfavorable terms or conditions of employment.

3. Harassment Prevention

Nexly Corporation prohibits all forms of harassment, including but not limited to:

• Harassment Based on Protected Characteristics: Any unwelcome conduct based on an individual’s protected characteristics (listed in Section 2) that creates a hostile work environment. This includes verbal, physical, or visual conduct.
• Sexual Harassment: Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature. This can include:
  • Quid Pro Quo Harassment: When submission to or rejection of unwelcome sexual conduct is used as a basis for employment decisions (e.g., hiring, promotion, compensation).
  • Hostile Work Environment Harassment: When unwelcome sexual conduct is sufficiently severe or pervasive to create a hostile work environment.
• Bullying: Repeated and unreasonable behavior directed towards an employee or group of employees that creates a risk to health and safety. Bullying may include, but is not limited to, intimidation, threats, humiliation, or sabotage.
• Cyber Harassment: Harassment that occurs through electronic means, such as email, social media, text messages, or other online platforms.

Harassment is prohibited regardless of the relationship between the parties involved (e.g., supervisor/subordinate, co-worker/co-worker, vendor/employee).

4. Equal Opportunity in Employment Practices

Nexly Corporation is committed to providing equal opportunity in all aspects of employment, including:

• Recruitment and Hiring:
  • Fair Recruitment Practices: All recruitment and hiring decisions will be made based on merit, qualifications, and skills, without regard to any protected characteristic.
  • Equal Access to Opportunities: Nexly will take steps to ensure that all individuals have equal access to recruitment and hiring opportunities.
  • Non-Discrimination in Application Processes: Application forms, interview questions, and all other aspects of the hiring process will be designed to avoid any discriminatory impact.
  • Diversity in Hiring Panels: Hiring panels will be diverse whenever possible.
• Promotion and Advancement:
  • Objective Performance Evaluations: Promotions and advancement opportunities will be based on objective performance evaluations, qualifications, and skills, without regard to any protected characteristic.
  • Transparency in Promotion Processes: The promotion process will be transparent and clearly communicated to all employees.
  • Training and Development: Nexly will provide equal access to training and development opportunities to all employees.
• Compensation and Benefits:
  • Equal Pay for Equal Work: Employees will receive equal pay for equal work, regardless of their protected characteristics.
  • Fair Compensation Practices: Compensation and benefits will be determined based on job responsibilities, performance, and experience, without regard to protected characteristics.
• Training and Development:
  • Equal Access to Training: All employees will have equal access to training and development opportunities.
  • Diversity and Inclusion Training: Nexly will provide diversity and inclusion training to all employees to promote awareness and understanding of diversity and inclusion issues.
• Workplace Environment:
  • Creating a Respectful Workplace: Nexly will provide a workplace that is free from discrimination, harassment, and retaliation.
  • Reasonable Accommodations: Nexly will provide reasonable accommodations to qualified individuals with disabilities, unless such accommodations would cause undue hardship to the Company. Employees are encouraged to request reasonable accommodations by contacting Human Resources.
• Performance Evaluations: All performance evaluations will be based on job performance and should be free from bias.
• Layoffs & Terminations: Any layoff or termination decisions will be based on the needs of the business and made without regard to a protected characteristic.

5. Reporting Discrimination and Harassment

Nexly Corporation is committed to providing a safe and confidential process for reporting incidents of discrimination or harassment.

• Reporting Channels: Employees who believe they have been subjected to discrimination or harassment are encouraged to report it promptly through the following channels:
  • Immediate Supervisor: Report the incident to your immediate supervisor.
  • Human Resources Department: Report the incident to the Human Resources Department (Contact information: [Specify Contact Information, e.g., hr@nexlycorp.com or 555-1212]).
  • Ethics Hotline (If applicable): If the incident involves your supervisor or you feel uncomfortable reporting to your supervisor or Human Resources, you can report the incident through the Company's Ethics Hotline [Specify Contact Information, e.g., Phone number and/or website].
• Confidentiality: Nexly will make every reasonable effort to maintain the confidentiality of reports of discrimination or harassment, subject to legal requirements and the need to investigate the complaint. However, complete confidentiality cannot be guaranteed.
• Protection Against Retaliation: Nexly strictly prohibits retaliation against any employee who reports discrimination or harassment, or who participates in an investigation of a complaint. Retaliation is a separate violation of this Policy.
• Good Faith Reporting: Employees are encouraged to report incidents of discrimination or harassment in good faith. Nexly will not tolerate false or malicious reports.

6. Investigation Procedures

Nexly Corporation will conduct a thorough and impartial investigation of all reports of discrimination or harassment.

• Prompt Investigation: Investigations will be conducted promptly, typically within [Specify Timeframe, e.g., 10 business days] of receiving a complaint.
• Impartial Investigator: The investigation will be conducted by a trained and impartial investigator, typically from the Human Resources Department.
• Interviews: The investigator will interview the complainant, the alleged harasser, and any witnesses.
• Evidence Gathering: The investigator will gather any relevant evidence, such as documents, emails, or other communications.
• Findings and Recommendations: The investigator will prepare a written report of the investigation, including findings of fact, conclusions, and recommendations for corrective action.
• Communication of Results: The complainant and the alleged harasser will be informed of the outcome of the investigation, subject to any legal or privacy limitations.

7. Corrective Action

If an investigation finds that discrimination or harassment has occurred, Nexly Corporation will take prompt and appropriate corrective action.

• Disciplinary Action: Disciplinary action may be taken against any employee found to have engaged in discrimination or harassment, up to and including termination of employment.
• Remedial Measures: Nexly will take appropriate remedial measures to address the situation, which may include:
  • Training and Education: Requiring the harasser to attend training on anti-discrimination and harassment prevention.
  • Counseling: Providing counseling to the harasser and/or the complainant.
  • Transfer or Reassignment: Transferring or reassigning the harasser or the complainant, if appropriate and feasible.
  • Other Corrective Measures: Implementing any other corrective measures deemed necessary to prevent further incidents of discrimination or harassment.
• Protecting the Complainant: Nexly will take steps to protect the complainant from further harassment or retaliation.
• Follow-up: The Human Resources Department (or other designated department) will monitor the situation to ensure that the corrective action is effective and that no further incidents of discrimination or harassment occur.

8. Training and Education

Nexly Corporation is committed to providing all employees with training and education on this Anti-Discrimination and Equal Opportunity Policy.

• Mandatory Training: All employees will be required to complete training on this Anti-Discrimination and Equal Opportunity Policy.
• Training Frequency: Training will be provided [Specify Frequency, e.g., annually] or more frequently as needed.
• Training Content: Training will cover the following topics:
  • The Anti-Discrimination and Equal Opportunity Policy and its key principles.
  • Definitions of discrimination and harassment.
  • Examples of prohibited conduct.
  • The reporting process for discrimination and harassment.
  • The investigation process.
  • Employee responsibilities.
• Supervisory Training: Supervisors and managers will receive additional training on their responsibilities for preventing and addressing discrimination and harassment.
• Ongoing Awareness Campaigns: Nexly will conduct ongoing awareness campaigns to reinforce the importance of a respectful and inclusive workplace.

9. Policy Review & Amendments

This Anti-Discrimination and Equal Opportunity Policy will be reviewed and updated regularly to ensure its continued relevance, effectiveness, and compliance with all applicable laws and regulations in Mountain Home, AR.

• Review Frequency: This Policy will be reviewed at least [Specify Frequency, e.g., annually] or more frequently as needed.
• Review Process: The review process will involve:
  • Input from Stakeholders: Seeking input from relevant stakeholders, including Human Resources, Legal Counsel, employee representatives, and management.
  • Legal and Regulatory Review: Reviewing the Policy to ensure compliance with all applicable federal, state, and local laws and regulations.
  • Benchmarking: Reviewing best practices in anti-discrimination and equal opportunity policies.
  • Effectiveness Assessment: Assessing the effectiveness of the Policy and its implementation.
• Policy Updates and Communication: Any amendments to this Anti-Discrimination and Equal Opportunity Policy will be approved by [Specify Approving Authority, e.g., the Board of Directors or the Executive Leadership Team] and communicated to all employees through [Specify Communication Channels, e.g., company-wide email, intranet posting, training sessions]. All employees are responsible for being aware of and adhering to any changes.
• Policy Ownership: The Human Resources Department, with support from Legal Counsel, is responsible for maintaining and updating this Policy.

10. Policy Accessibility

Nexly Corporation will make this Anti-Discrimination and Equal Opportunity Policy readily accessible to all employees and applicants for employment.

• Availability: This Policy will be readily accessible to all employees through:
  • The Nexly Corporation Intranet at [Insert Intranet Link].
  • The Company's Employee Handbook.
  • Upon request from the Human Resources Department.
• Distribution: This Policy will be provided to all new employees during their onboarding process.
• Acknowledgment: Employees will be required to acknowledge that they have read and understood this Policy.
• Updates: All updates to this Policy will be communicated to employees through the established communication channels (e.g., email, intranet postings, training sessions).

11. Non-Retaliation

Nexly Corporation prohibits retaliation against any employee who, in good faith, reports a violation of this Policy, participates in an investigation, or opposes any practice made unlawful by this policy or applicable law. Retaliation includes any adverse action taken against an employee because the employee exercised their rights under this Policy or applicable law.

**Acknowledgement:** By accepting employment with Nexly Corporation, all employees are deemed to acknowledge and agree to abide by the terms and conditions outlined in this Anti-Discrimination & Equal Opportunity Policy.