1. Introduction & Purpose

This Diversity, Equity & Inclusion (DEI) Policy (the "Policy") reflects Nexly Corporation's ("Nexly" or the "Company") fundamental commitment to building and sustaining a diverse, equitable, and inclusive workplace. Located at 701 South Street Suite 100, Mountain Home, AR 72653, Nexly recognizes that creating a workplace where all individuals feel valued, respected, and have equal opportunities to succeed is not only the right thing to do, but also essential to our innovation, creativity, and overall business success. This Policy is designed to:

• Define Diversity, Equity, and Inclusion: Provide clear definitions of diversity, equity, and inclusion within the context of Nexly.
• Foster a Culture of Belonging: Create an environment where all employees feel a sense of belonging and are empowered to bring their whole selves to work.
• Promote Diversity: Actively seek to build a workforce that reflects the diversity of the communities in which we operate and the customers we serve.
• Ensure Equity: Provide fair and equitable access to opportunities, resources, and advancement for all employees, addressing systemic barriers and historical disadvantages.
• Cultivate Inclusion: Create a workplace culture where all employees are valued, respected, and have the opportunity to contribute their unique perspectives and talents.
• Promote Accountability: Establish clear lines of accountability for DEI initiatives and their impact.
• Comply with Laws and Regulations: Ensure that all DEI initiatives are in compliance with all applicable laws and regulations.
• Measure and Track Progress: Track and measure the Company’s progress towards its DEI goals and objectives.

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 other Company policies, including, but not limited to, the Anti-Discrimination & Equal Opportunity Policy, the Code of Conduct, and the Recruitment and Hiring Policy.

2. Definitions

For the purposes of this Policy, the following definitions apply:

• Diversity: The presence of differences within a group or organization. At Nexly, diversity encompasses a wide range of individual characteristics, including, but not limited to, race, color, ethnicity, national origin, sex, gender identity and expression, sexual orientation, age, religion, disability, veteran status, and socioeconomic background, as well as differences in perspectives, experiences, and skills.
• Equity: Fairness in access to opportunities, resources, and advancement, taking into account systemic barriers and historical disadvantages. Equity recognizes that individuals may start from different points and may require different levels of support to achieve success. This is distinct from equality, which means providing the same opportunities and resources to everyone.
• Inclusion: Creating a workplace culture where all individuals feel valued, respected, and have a sense of belonging. Inclusion means actively seeking, valuing, and integrating diverse perspectives, experiences, and ideas. Inclusion requires creating environments that support individuals’ needs.
• Belonging: A sense of feeling safe, accepted, respected, and supported in the workplace. Individuals experience a sense of belonging when they are able to be their authentic selves and fully participate in the workplace without fear of judgment or discrimination.
• Underrepresented Groups: Groups of people who are underrepresented in a particular industry or organization. At Nexly, this includes, but is not limited to, women, racial and ethnic minorities, people with disabilities, LGBTQ+ individuals, and veterans.

3. Key Principles

Nexly Corporation’s DEI Policy is guided by the following core principles:

• 3.1. Leadership Commitment: Leadership at all levels, including the Board of Directors and senior management, is fully committed to the principles of diversity, equity, and inclusion and will actively champion DEI initiatives.
• 3.2. Inclusive Culture: Nexly will foster an inclusive culture where all employees feel safe, respected, valued, and have a sense of belonging.
• 3.3. Equitable Practices: Nexly will implement equitable practices in all aspects of employment, including recruitment, hiring, promotion, compensation, training, and performance management.
• 3.4. Transparency and Accountability: Nexly will be transparent about its DEI goals, progress, and initiatives and will hold itself accountable for achieving its DEI objectives.
• 3.5. Continuous Improvement: Nexly will continuously assess and improve its DEI efforts, based on data, feedback, and best practices.
• 3.6. Intersectionality: Nexly recognizes that individuals often have multiple intersecting identities (e.g., race, gender, sexual orientation, and disability). The Company is committed to understanding and addressing the unique challenges and experiences faced by individuals with intersecting identities.
• 3.7. Respect and Civility: All employees are expected to treat each other with respect and civility, regardless of their differences.

4. Roles and Responsibilities

Implementing this DEI Policy requires clearly defined roles and responsibilities across the organization.

• 4.1. Board of Directors:
  • Provides oversight of the Company's DEI strategy and performance.
  • Approves the DEI Policy and reviews its effectiveness.
  • Monitors the Company's progress towards its DEI goals and objectives.
  • Ensures that the Company's leadership is committed to DEI.
  • Receives regular reports on DEI initiatives and outcomes.
• 4.2. DEI Council (or equivalent): (If applicable, or alternatively, a designated senior management group).
  • Develops and implements the Company's DEI strategy and action plans.
  • Provides guidance and support to the Company's DEI initiatives.
  • Champions DEI across the organization.
  • Monitors and measures the Company's progress towards its DEI goals and objectives.
  • Recommends and implements DEI programs and initiatives.
  • The DEI Council will be comprised of [Specify Members and their Titles, e.g., the CEO, the Head of HR, representatives from various departments, employee resource group (ERG) representatives, and an external DEI consultant (if applicable)]. The Chair of the DEI Council will be [Specify Title, e.g., the CEO or a designated senior leader].
• 4.3. Chief Executive Officer (CEO):
  • Provides overall leadership and direction for the Company's DEI efforts.
  • Demonstrates personal commitment to DEI and champions DEI initiatives.
  • Ensures that the Company's DEI Policy is integrated into all business activities.
  • Supports the DEI Council (or equivalent) in its efforts.
  • Sets the tone for an inclusive culture.
  • Allocates resources to support DEI initiatives.
• 4.4. Chief Human Resources Officer (CHRO) (or equivalent):
  • Leads the implementation of the Company's DEI strategy.
  • Develops and implements DEI programs and initiatives.
  • Oversees the collection and analysis of DEI data.
  • Provides training and education on DEI topics.
  • Works with the DEI Council (or equivalent) to achieve the Company's DEI goals.
  • Ensure the company follows all relevant EEO and non-discrimination laws.
• 4.5. Department Heads & Business Unit Managers:
  • Create and foster inclusive teams within their departments.
  • Implement DEI initiatives within their areas of responsibility.
  • Support and encourage their employees' participation in DEI programs.
  • Ensure that all employment decisions, including hiring, promotion, and performance evaluations, are based on merit and qualifications, without regard to protected characteristics.
  • Promote a culture of respect and inclusion within their teams.
  • Participate in DEI training and awareness programs.
• 4.6. All Employees:
  • Comply with this DEI Policy and all related Company policies.
  • Treat all colleagues with respect and dignity.
  • Participate in DEI training and awareness programs.
  • Report any incidents of discrimination, harassment, or bias.
  • Support and promote a diverse and inclusive workplace.
  • Actively contribute to creating a culture of belonging.

5. DEI Initiatives & Programs

Nexly Corporation will implement a variety of DEI initiatives and programs to achieve its DEI goals and objectives.

• 5.1. Recruitment and Hiring:
  • Diverse Candidate Pools: Nexly will actively seek to build diverse candidate pools by partnering with diverse recruitment sources (e.g., Historically Black Colleges and Universities, Hispanic-Serving Institutions, women's professional organizations, disability-focused recruitment agencies).
  • Blind Resume Reviews: Nexly will use blind resume reviews to minimize bias in the initial screening process.
  • Structured Interview Processes: Standardized interview questions and evaluation criteria will be used to ensure fairness and consistency.
  • Diverse Interview Panels: Interview panels will be diverse whenever possible, to provide a range of perspectives.
  • Inclusive Job Descriptions: Job descriptions will be written in inclusive language and will avoid gendered or biased terms.
  • Training for Recruiters: Recruiters and hiring managers will receive training on unconscious bias and inclusive hiring practices.
• 5.2. Employee Resource Groups (ERGs):
  • Support for ERGs: Nexly will support the establishment and maintenance of Employee Resource Groups (ERGs) for underrepresented groups (e.g., Women, LGBTQ+, Black/African American, Hispanic/Latinx, Asian/Pacific Islander, Veterans, Employees with Disabilities).
  • Resources for ERGs: Nexly will provide resources to ERGs, such as funding, meeting space, and executive sponsorship.
  • ERG Activities: ERGs will provide opportunities for networking, mentorship, professional development, and community engagement. ERGs can also provide support for DEI initiatives.
• 5.3. Training and Education:
  • Unconscious Bias Training: All employees will receive training on unconscious bias to raise awareness of biases and to promote more inclusive decision-making.
  • Diversity and Inclusion Training: Training on diversity and inclusion topics, such as microaggressions, allyship, and inclusive communication.
  • Inclusive Leadership Training: Training for leaders on how to create inclusive teams and support DEI initiatives.
• 5.4. Mentorship and Sponsorship Programs:
  • Mentorship Programs: Nexly will provide mentorship programs to support the career development of employees from underrepresented groups.
  • Sponsorship Programs: Nexly will provide sponsorship programs to help employees from underrepresented groups gain access to opportunities for advancement.
• 5.5. Inclusive Communication & Policies:
  • Inclusive Language Guide: Nexly will maintain an inclusive language guide.
  • Inclusive Policies: Nexly will review and update its policies to ensure that they are inclusive and equitable, and that they promote diversity and belonging. This includes policies related to benefits, leave, performance evaluations, and flexible work arrangements.
• 5.6. Community Engagement:
  • Partnerships: Nexly will partner with community organizations to support diversity, equity, and inclusion.
  • Volunteer Opportunities: Nexly will provide employees with opportunities to volunteer in the community.
  • Philanthropic Support: Nexly will support organizations that promote diversity, equity, and inclusion through financial contributions.
• 5.7. Data Collection & Analysis: Collecting and analyzing data to measure progress towards its DEI goals.
  • Demographic Data: Collecting demographic data (e.g., race, gender, age, disability status, veteran status, sexual orientation) from employees on a voluntary basis, to track progress on DEI goals.
  • Engagement Surveys: Conducting regular employee engagement surveys to assess employee experiences, including perceptions of inclusion, belonging, and fairness.
  • Exit Interviews: Conducting exit interviews to gather feedback from departing employees.
  • Data Analysis: Analyzing the data collected to identify areas for improvement and to measure the impact of DEI initiatives.
  • Reporting: Publicly reporting on progress toward the Company’s DEI goals, as applicable.
• 5.8. Performance Management: Integrating DEI into performance management processes.
  • DEI Goals: Setting DEI-related goals for managers and incorporating performance on these goals into performance evaluations.
  • 360 Feedback: Using 360-degree feedback to provide employees with feedback on their contributions to DEI.

6. Measuring and Tracking Progress

Nexly Corporation will regularly measure and track its progress towards its DEI goals and objectives.

• 6.1. Key Performance Indicators (KPIs):
  • Employee Representation: Tracking the representation of underrepresented groups at all levels of the organization, including leadership.
  • Hiring Rates: Tracking the hiring rates of underrepresented groups.
  • Promotion Rates: Tracking the promotion rates of underrepresented groups.
  • Employee Retention Rates: Tracking the retention rates of employees from underrepresented groups.
  • Employee Engagement: Measuring employee engagement through surveys and other feedback mechanisms.
  • Pay Equity: Conducting regular pay equity analyses.
• 6.2. Data Collection and Analysis:
  • Voluntary Self-Identification: Encouraging employees to voluntarily self-identify their demographic information, which will be used to track diversity and inclusion metrics.
  • Data Privacy: All data collection will be conducted in compliance with applicable data privacy laws and regulations.
  • Regular Reporting: Regularly analyzing the data collected to identify trends and progress.
  • Third-Party Data: May use third-party data to track industry benchmarks.
• 6.3. Reporting and Communication:
  • Internal Reporting: Reporting on DEI progress to the Board of Directors, the DEI Council (or equivalent), and all employees.
  • External Reporting: Publishing information about its DEI initiatives and progress in its annual reports and on its website, where appropriate.
  • Transparency: Maintaining transparency about its DEI goals, progress, and initiatives.
  • Feedback Solicitation: Soliciting feedback from employees on its DEI efforts.

7. Compliance & Accountability

Nexly Corporation is committed to complying with all applicable laws and regulations related to diversity, equity, and inclusion.

• 7.1. Legal Compliance:
  • Compliance with Laws: Nexly will comply with all applicable federal, state, and local laws and regulations related to equal opportunity, anti-discrimination, and affirmative action (where applicable), including, but not limited to, Title VII of the Civil Rights Act of 1964, the Equal Pay Act, the Age Discrimination in Employment Act (ADEA), the Americans with Disabilities Act (ADA), and state and local anti-discrimination laws.
  • Review and Updates: This Policy will be reviewed and updated regularly to ensure compliance with all applicable laws and regulations.
• 7.2. Accountability:
  • Individual Responsibility: All employees are responsible for upholding the principles of diversity, equity, and inclusion.
  • Leadership Accountability: Leaders are responsible for creating inclusive teams and for holding their teams accountable for achieving DEI goals.
  • Performance Evaluation: Performance on DEI-related goals will be included in performance evaluations for managers.
• 7.3. Reporting and Investigations:
  • Reporting Mechanisms: Employees are encouraged to report any concerns about discrimination, harassment, or any other violation of this Policy through the channels described in the Anti-Discrimination and Equal Opportunity Policy.
  • Investigation of Complaints: All complaints will be investigated promptly and thoroughly.
  • Corrective Action: Nexly will take appropriate corrective action, up to and including termination of employment, for any violations of this Policy.
• 7.4. Third Party Compliance: Suppliers and Vendors are expected to align with Nexly Corporation’s DEI principles.

8. Policy Review & Amendments

This Diversity, Equity & Inclusion (DEI) Policy will be reviewed and updated regularly to ensure its continued relevance, effectiveness, and compliance with all applicable laws and regulations.

• Review Frequency: This Policy will be reviewed at least [Specify Frequency, e.g., annually] or more frequently as needed, such as in response to changes in the business environment, legal requirements, or industry best practices.
• Review Process: The review process will involve:
  • Input from Stakeholders: Seeking input from relevant stakeholders, including the DEI Council (or equivalent), Human Resources, Legal Counsel, employee resource groups (ERGs), and other employees.
  • Performance Evaluation: Assessing the effectiveness of the DEI program, including the Company's progress towards its goals and objectives.
  • Legal and Regulatory Review: Reviewing and updating the Policy to ensure compliance with all applicable federal, state, and local laws and regulations.
  • Benchmarking: Reviewing industry best practices in DEI.
• Policy Amendments and Communication: Any amendments to this DEI 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, in collaboration with the DEI Council (or equivalent) and Legal Counsel, is responsible for maintaining and updating this Policy.

9. Policy Accessibility

Nexly Corporation will make this Diversity, Equity & Inclusion (DEI) 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).

10. Commitment to Action

Nexly Corporation is committed to ongoing action to fulfill the promises and practices outlined in this Diversity, Equity & Inclusion (DEI) Policy.

**Acknowledgement:** By accepting employment with Nexly Corporation, all employees are deemed to acknowledge and agree to support and abide by the terms and conditions outlined in this Diversity, Equity & Inclusion (DEI) Policy.