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SCHULTZ CORPORATION ANTI-BULLYING AND DISCRIMINATION POLICY

Anti-Bullying and Discrimination Policy

Schultz Corporation values a safe and inclusive work environment for all staff and expects that
all staff and associates treat others with dignity and respect. This is reinforced in Values and
Behaviors which are embedded within the organization. Schultz Corporation has a policy of zero
tolerance of behavior that is discriminatory and harassing or bullying. This is the case for all
Schultz Corporation Officers & Staff - see Roles and Responsibilities below.

As an organisation, Schultz Corporation Inc. will:

 Provide a safe and inclusive workplace where all staff and associates are treated with dignity,
courtesy and respect;

 Provide a workplace where equality and inclusion are integral to how we work, which creates
a positive working environment and culture for us all;

 Provide a safe, effective and accessible procedure for complaints;

 Actively promote and support appropriate standards of workplace conduct at all times
supported by and in reference to the Schultz Corporation Values and Behaviours;

 Treat all complaints in a professional, sensitive, fair, timely and confidential manner; and will
take appropriate action when a complaint has been substantiated and proven to have occurred;

 Ensure any acts of victimization or retaliation are investigated and dealt with promptly; and
take immediate and appropriate action following confirmation and substantiation that a malicious
complaint had been lodged.

 This policy applies to all Schultz Corporation Staff and Associates.

 Schultz Corporation does not dictate the belief and value systems by which Schultz
Corporation Staff, Associates, or Managers conduct their personal lives. However, actions taken
by them outside of working hours (whether inside or outside of the office environment) that are
seen to contradict (or breach) this policy (or its intent) may be considered a violation of this
policy.

 This policy supersedes all prior policies, guidelines and practices that pertain to bullying and
discrimination.

 This policy should be read in conjunction with local legislation (where possible), however local
legislation will take precedence over this policy in the event of a conflict.

 This policy should also be read in conjunction with the following associated policies, as may
be amended from time to time:

o Grievance Policy

o Disciplinary Policy

o Whistleblowing Policy

o Child Protection Policy (Global)

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SCHULTZ CORPORATION ANTI-BULLYING AND DISCRIMINATION POLICY

o Code of Conduct (Global)

o Gender Equality and Inclusion Policy (Global)

POLICY STATEMENT

Inclusion: Schultz Corporation is ensuring all staff are valued, respected and supported. It
focuses on the needs of every individual and ensuring the right conditions are in place for each
person to achieve his or her full potential.

DEFINITIONS

Bullying: may be described as repeated and unreasonable behavior directed toward a person,
or a group of people, that creates a risk to health, safety and well-being. Repeated behavior
refers to the persistent nature of the behavior and refers to a range of behaviors over time.

Unreasonable behavior is behavior that a reasonable person, having regard to circumstances,

may see as unreasonable (in other words, it is an objective test). Bullying hampers productivity
by creating dysfunction and damaging morale within working environments. It includes
behaviour (generally a pattern of behavior) that intimidates, offends, degrades or humiliates
another person, including by electronic devices including email, blogs, notice boards, social
networking sites and websites.

Examples of behaviors that may constitute bullying include, but are not limited to:

 Intimidation;

 Victimization;

 Verbal abuse or threats, including yelling, screaming, offensive language;

 Excluding or isolating people from workplace activities;

 Assigning impossible tasks or dead-lines, meaningless tasks unrelated to their job, or giving
someone the majority of unpleasant tasks;

 Undermining responsibility;

 Withholding information essential to complete a task properly;

 Copying (“Cc”) emails that are critical about someone to others, who do not need to know;

 Using blind copy (“Bcc”) on emails inappropriately;

 Making threats or comments about job security without foundation;

 Changing workplace arrangements (i.e. leave) to inconvenience a particular employee;

 Excessive scrutiny of work;

 Spreading malicious rumours;

 Cyber bullying; or
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SCHULTZ CORPORATION ANTI-BULLYING AND DISCRIMINATION POLICY

 Physical, intellectual or emotional abuse

Discrimination: refers to treating a person, or a group of people less favorably than another
person or group and can be on the grounds or situations listed below.

Discrimination on the grounds of:

 Gender or Gender identity

 Sexual orientation;

 Marital status, or pregnancy;

 Family/carer responsibilities;

 Language;

 Race, nationality, ethnicity; skin color;

 Class, caste, social origin;

 Level or type of education;

 Religious beliefs (or lack of);

 Health status (dependent on role requirements);

 Disability or impairment;

 Age;

 Trade union activity (or lack of).

 Political or particular belief (or lack of).

It is important that all staff ensure that discrimination does not occur during business activity
such as recruitment. The following could be deemed to be discriminatory and are included as
examples:

 Failing to hire a job applicant or terminating employment on any of the above grounds;

 Failing to reasonably accommodate reasonable adjustments for job applicants and

employees

(e.g. with a disability).

 Unfair treatment of an applicant or an employee for a position in the organisation on one of

the above listed grounds.

 Following formal or informal policies/practices that deprive people of employment or

advancement opportunities or adversely affect employees that possess a protected
characteristic.

 Retaliating against an employee who has filed a complaint.

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SCHULTZ CORPORATION ANTI-BULLYING AND DISCRIMINATION POLICY

 Treating an employee unfairly or unequally in situations with respect to their compensation.

The above list and examples are not exhaustive and includes actual, potential, alleged,
assumed and perceived status.

Workplace bullying or discrimination must not be confused with legitimate comments and advice
(including negative or constructive feedback or comment) from managers and supervisors on
work performance or work related behaviour of an individual or group.

The process of providing feedback to workers during a formal (or informal) performance
appraisal or review, or counselling workers regarding their work performance, will not always be
free of stress or tension.

Managers should manage these processes with sensitivity and respect; however, they should
not avoid their responsibility to provide full, candid and honest feedback to workers.

The following behaviours do NOT constitute workplace bullying and discrimination:

Gender identity refers to how an individual feel about their own gender. Individuals may identify
as male, female or as something else and their gender identity may or may not be the same as
the sex that they were assigned at birth. Everyone has a gender identity and expresses their
gender in a unique and personal way.

 Reasonable management practices, including performance management and disciplinary

action and/or procedures;

 A direction to carry out reasonable and lawful duties and instructions; and A direction to
comply with the company policies, procedures and guidelines.

All staff, management and associates are responsible for maintaining a working environment
free from any form of bullying and discrimination. Schultz Corp staff must value and respect the
full diversity of our colleagues’ experiences and strive for inclusion. Staff and associates agree
to abide by the policy in the workplace and in relation to all beneficiaries of company programs.

ALL STAFF AND ASSOCIATES WILL:

 Demonstrate compliance to, and support of this, and any prevailing policies and procedures;
at all times, by signing a copy of this policy when they join any part of the company and, if
requested to do so again as part of any refresher training or updated policy release;

 Be aware of the issue of bullying and discrimination, and the forms it can take and of the
damage it can do to individuals and to the company

 Not engage in any types of behaviour which constitute bullying or discrimination as indicated
in this policy;

 Report any potential breaches of this policy to their immediate manager, Human Resources
or

 Comply fully and confidentially with any investigation relating to potential breaches of the
policy;
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SCHULTZ CORPORATION ANTI-BULLYING AND DISCRIMINATION POLICY

 Contribute to building an environment free from Bullying and Discrimination;

 Behave in accordance with the company’s Purpose, Values and Code of Conduct;

 Speak out against bullying or discrimination if and when witnessed.

The International Board, CEO and Executive Management (incl. Regional Directors, Country

Directors, and Other Directors) will:

 Escalate proven breaches of this policy to the relevant external authorities as

appropriate/deemed necessary and appropriate.

 Establish and support high standards of professional behaviour in the workplace; and

 The company’s Executive and Management Teams should take all reasonable steps to
monitor, and prevent any form of bullying and discrimination from arising in the workplace.

Managers will:

 Establish and support high standards of professional behaviour in the workplace;

 Ensure the workforce is aware and informed of this policy and its application;

 Monitor the workplace and take action to stop discrimination, bullying and immediately if it is
observed or reported;

 Encourage staff to report instances and respond promptly, seriously and with respect and
sensitivity to every complaint;

 Advise the Human Resources/ People and Culture team of any potential breach and/or
complaint within 24 hours of becoming aware;

 Communicate any changes to this policy to the workforce.

ROLES AND RESPONSIBILITIES

Human Resources will:

 Ensure that this policy is published and available to all staff so that the company’s workforce
is aware and informed;

 Provide advice, guidance and ongoing support to managers, staff and associates in relation
to the policy and on the complaint and resolution processto ensure managers are prepared to
conduct investigations into potential non-compliances of this policy;

 Participate, and provide independent investigations as required; and

 Keep abreast of any changes to local law requirements that may impact this policy or
operation.

Bullying and Discrimination are regarded seriously and, in some countries is unlawful. It may
be treated as grounds for disciplinary action under the company’s Disciplinary Policy.
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SCHULTZ CORPORATION ANTI-BULLYING AND DISCRIMINATION POLICY

Informal stage of process:

In line with the above Roles and Responsibilities, complainants are encouraged to talk to
someone they can trust if they feel they have experienced any form of bullying or discrimination.
This may be a colleague, a line manager, a trade union representative (if locally applicable) a
family member or a friend.

The process of talking through what has happened with someone else can help to determine
what action should be taken. The company encourages staff to stand up and challenge others
when they see wrong doing, and encourage a climate of feedback and accountability.
Therefore, where appropriate the complainant should provide direct feedback, to the person
causing the problem, making it clear that they find their behaviour towards them unacceptable.

If the above approach does not feel appropriate then the guidance is to raise concerns,
confidentially to Line Manager or Human Resources.

It is important for any complainants to keep a record of the details of any alleged and relevant
incidents which cause distress, particularly, if an individual feels unable to talk to the
person/people concerned, or if having raised the issue, the issue persists.

Staff should be aware that if concerns are raised to any member of the Human Resources or
Management teams that appears to be extremely serious in nature, then under the company’s
obligations to safeguard all employees, there may occasions when a decision may be made to
investigate the allegations, regardless of whether the individual wishes to raise a ‘formal
complaint’

FORMAL STAGE OF PROCESS

If the informal stage, if used, has not resolved the issues, the complainant should communicate
their complaint in writing to their manager or their local HR representative under the company’s
Grievance Policy as mentioned below.

The company will undertake to investigate the complaint seriously, promptly and objectively.
The manager or local HR representative will assign an appropriate level of manager to fully
investigate the complaint and ensure that the correct communications and records are retained
as applicable. The appointment

THE PROCESS

The manager will be impartial and have been trained in carrying out investigations. All
information should remain confidential unless a criminal office has occurred or there is a risk of
personal danger. In cases which appear to involve serious misconduct, and there is reason to
separate the parties, a short period of suspension or re-assignment of the alleged bully/harasser
may need to be considered while the case is being investigated. This is not a sanction and
normal employment terms continue. The purpose of a suspension is to facilitate a fair and
objective investigation for all.

As an outcome of raising a grievance, the company may conclude that the matter is a
disciplinary issue which needs to be dealt with formally at the appropriate level to the company’s
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SCHULTZ CORPORATION ANTI-BULLYING AND DISCRIMINATION POLICY

Disciplinary Policy, this could be a result of either substantiated allegation under this policy; or
allegations that are found to be malicious.

Staff: refers to employees of the company

Managers/Supervisors: refers to the company’s Staff who have responsibility for line
managing or supervising the work of Staff or Associates.

Associates: refers to contractors and consultants engaged by the company, and volunteers
and unpaid individuals who work with the company and who agree to abide by this policy.

Workplace: can be defined as including “the place where work is carried out, or where there is
a sufficient connection to the workplace, including working in the field, in local communities,
emergency deployments, and any online activity which relates to work”. Under this definition,
the workplace may encompass on and off-site work related events including meetings;
conferences; business travel, training; social events; work functions, conferences, seminars,
webinars, emailing, texting, skype, tweeting or other social media postings; and any other
activities that have a connection to the workplace and/or that your participation is because you
work for, or are undertaking work for the company.

A workplace investigation: is a process instituted by the company to gather information and

determine remedial action (if appropriate) in response to an alleged or suspected breach of
policy, procedure or practice, any workplace grievance or dispute or any other issue or incident
which the company determines requires a workplace investigation.

Complainant: is the individual (staff or associate) notifying the company of a workplace issue
requiring resolution and/or investigation.

Respondent: is an individual (staff or associate) against whom an issue or incident is raised or

a complaint or grievance is made

Victimization: involves treating someone unfairly (or threatening them) because they have
made, or intend to make, a discrimination, bullying complaint. This also includes those who
have supported another person in making a complaint. Immediate action will be taken against
another staff member or associate who retaliates or victimizes a person for making a complaint
(the ‘complainant’).