Equality & non-Discrimination

Non-discrimination

It is Wren US Holding Inc’s policy to prohibit intentional and unintentional harassment of or against job applicants, contractors, interns, volunteers or employees by another employee, supervisor, vendor, customer or any third party on the basis of actual or perceived race, color, creed, religion, national origin, ancestry, citizenship status, sex or gender (including pregnancy, childbirth and pregnancy-related conditions0, gender identity or expression (including transgender status), sexual orientation, marital status, military service and veteran status, physical or mental disability, genetic information or any other characteristic protected by applicable federal, state or local laws (referred to as “protected characteristics”). Such conduct will not be tolerated by Wren US Holdings Inc.

The purpose of this policy is not to regulate our employees’ personal morality, but to ensure that no one harasses another individual in the workplace, including while on company premises, while on company business (whether or not on company premises) or while representing the company. In addition to being a violation of this policy, harassment or retaliation based on any protected characteristic as defined by applicable federal, state, or local laws also is unlawful. For example, sexual harassment and retaliation against an individual because the individual filed a complaint of sexual harassment or because an individual aided, assisted or testified in an investigation or proceeding involving a complaint of sexual harassment as defined by applicable federal, state, or local laws are unlawful.

Harassement defined

Harassment generally is defined in this policy as unwelcome verbal, visual or physical conduct that denigrates or shows hostility or aversion towards an individual because of any actual or perceived protected characteristic or has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.

Harassment can be verbal (including slurs, jokes, insults, epithets, gestures or teasing), visual (including offensive posters, symbols, cartoons, drawings, computer displays, text messages, social media posts or emails) or physical (including physically threatening another, blocking someone’s way, etc.). Such conduct violates this policy, even if it does not rise to the level of violation of applicable federal, state or local laws. Because it is difficult to define unlawful harassment, employees are expected to behave at all times in a manner consistent with the intended purpose of this policy.

Sexual harassment defined

Sexual harassment can include all of the above actions, as well as other unwelcome conduct, such as unwelcome or unsolicited sexual advances, requests for sexual favors, conversations regarding sexual activities and other verbal, visual or physical conduct of a sexual nature when:

• Submission to that conduct or those advances or requests is made either explicitly or implicitly a term or condition of an individual’s employment; or
• Submission to or rejection of the conduct or advances or requests by an invidiaul is used as the basis for employment decisions affecting the individual; or
• The conduct or advances or request have the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.

Examples of conduct that violate this policy include:

• Unwelcome flirtations, leering, whistling, touching, pinching, assault, blocking normal movement;
• Requests for sexual favors or demands for sexual favors in exchange for favorable treatment;
• Obscene or vulgar gestures, posters or comments;
• Sexual jokes or comments above a person’s body, sexual prowess or sexual deficiencies;
• Propositions or suggestive or insulting comments of a sexual nature’
• Derogatory cartoons, posters and drawings’
• Sexually-explicit emails, text messages or voicemails;
• Uninvited touching of a sexual nature;
• Unwelcome sexually-related comments’
• Conversation about one’s own or some else’s sex life;
• Conduct or comments consistently targeted at only one gender, even if the content is not sexual; and
• Teasing or other conduct directed toward a person because of the person’s

Reporting procedures

If the employee has been subjected to or witnessed conduct which violates this policy, the employee should immediately report the matter to the HR Department. If the employee is unable for any reason to contact this person, or if the employee has not received an initial response within five (5) business days after reporting any incident of what the employee perceives to be harassment, the employee should contact any member of management. If the person toward whom the complaint is directed is one of the individuals indicated above, the employee should contact any higher-level manager in the reporting hierarchy.

Investigation procedures

Every report of perceived harassment will be fully investigated, and corrective action will be taken where appropriate. All complaints will be kept confidential to the extent possible, but confidentiality cannot be guaranteed. All employees must cooperate with all investigations conducted pursuant to this policy.

Retaliation prohibited

In addition, the company will not allow any form of retaliation against individuals who report unwelcome conduct to management or who cooperate in the investigations of such reports in accordance with this policy. If the employee has been subjected to any such retaliation, the employee should report it in the same manner in which the employee would report a claim of perceived harassment under this policy.

Violation of this policy including any improper retaliatory conduct will result in disciplinary action, up to and including termination

Equal employment opportunities

Wren US Holdings Inc is an Equal Opportunity Employer that does not discriminate on the basis of actual or perceived race, color, creed, religion, national origin, ancestry, citizenship status, sex or gender (including pregnancy, childbirth and pregnancy-related conditions0, gender identity or expression (including transgender status), sexual orientation, marital status, military service and veteran status, physical or mental disability, genetic information or any other characteristic protected by applicable federal, state or local laws and ordinances. Wren US Holdings Inc’s management team is dedicated to this policy with respect to recruitment, hiring, placement, promotion, training, compensation, benefits, employee activities, access to facilities and programs and general treatment during employment.

The company will endeavor to make a reasonable accommodation of an otherwise qualified applicant or employee related to an individual’s: physical or mental disability; sincerely held religious beliefs and practices; and/or any other reason required by applicable law, unless doing so would impose an undue hardship upon the company’s business operations.

Any applicant or employee who needs an accommodation in order to perform the essential functions of the job should contact the HR Department to request such an accommodation. The individual should specify what accommodation is needed to perform the job and submit supporting documentation explaining the basis for the requested accommodation, to the extent permitted and in accordance with applicable law. The company then will review and analyze the request, including engaging in an interactive process with the employee or applicant, to identify if such an accommodation can be made. The company will evaluate requested accommodations, and as appropriate, identify other possible accommodations, if any. The individual will be notified of the company’s decision regarding the request within a reasonable period. The company treats all medical information submitted as part of the accommodation process in a confidential manner.

Any employee with questions or concerns about equal employment opportunities in the workplace are encouraged to bring these issues to the attention of the HR Department. The company will not allow any form of retaliation against individuals who raise issues of equal employment opportunity. If employees feel they have been subjected to any such retaliation, they should contact the HR Department. To ensure our workplace is free from artificial barriers, violation of this policy including any improper retaliatory conduct will lead to discipline, up to and including discharge. All employees must cooperate with all investigations conducted pursuant to this policy.