This policy is applicable to Testlio Inc. and to all other Testlio group affiliates (hereinafter “Testlio”). We expect every Employee, Contractor and Freelancer working for Testlio to know and follow our Anti Harassment Policy.

Employees who are found to have violated this policy are subject to discipline, including but not limited to: coaching, training, a verbal warning, a written warning, impact to performance ratings, impact to compensation, and/or termination of employment.

Contractors and Freelancers are also expected to abide by this policy and behave appropriately. Policy violations may result in actions such as termination of a business contract.

This policy applies to everyone who works for Testlio Inc. and any of its subsidiaries. Everyone - whether you work as an Employee, a Contractor or a Freelancer. Whether you are a member of the Board, a manager or an individual contributor.

Additionally, we don’t tolerate harassment of TestLions by non-Employees (e.g., contingent workers, guests, vendors, clients, or partners).

At Testlio we are committed to providing a positive work environment where everyone can feel safe and be treated with respect. As a result, we don’t tolerate harassment or any mistreatment of TestLions, in the workplace or work-related situations, including unlawful harassment on the basis of the following protected categories:

Harassment under this Anti Harassment Policy may include conduct that creates a disrespectful, intimidating, hostile, degrading, humiliating, or offensive environment for TestLions. Engaging in such conduct is a violation of this policy.

When determining whether conduct constitutes harassment or sexual harassment, we consider whether a reasonable person could conclude that the conduct created an intimidating, hostile, or offensive working environment.

If you observe behavior by a third party or interact with our TestLions that appears inappropriate or that otherwise violates this policy, please speak up via the channels outlined below (see Raising a concern).

Harassment is unwelcome conduct (physical, verbal or non-verbal) Harassment can range from extreme forms such as violence, threats, or physical touching to less obvious actions like ridiculing, teasing, or repeatedly bothering colleagues or subordinates, or even refusing to talk to them. Harassment can be one severe incident or a series of less severe incidents.

For example, harassment may include the following types of conduct:

This list of examples is not exhaustive, and there may be other behaviors that constitute unacceptable harassment under the policy.

“I was joking” or “I didn’t mean it that way” are not defenses to allegations of harassment. Nor is being under the influence of alcohol or other substances. This policy applies to conduct during work and via work-related social events, office parties, off-sites, and client entertainment events. TestLions are expected to be particularly mindful about their behavior in these circumstances.

Sexual harassment, which is harassment specifically based on sex, can take two forms:

Sexual harassment can happen regardless of the individuals’ gender, gender identity, or gender expression and does not require that the harassing conduct be motivated by sexual desire.

Discrimination is behavior affecting the workplace, which can take place between Employees, Contractors, Freelancers, clients, and/or customers, that results in the terms and conditions of an individual’s employment being adversely affected due to the individual’s protected status. Discriminatory conduct can include taking actions based on a person’s protected status, such as intentionally reducing someone’s performance score or bonus, not putting someone up for promotion, or putting someone on a performance improvement plan, just as examples.

Testlio does not tolerate abusive conduct, bullying or other intimidating or aggressive behavior among Employees or others covered by this policy, whether or not it is based on a protected category. If a TestLion is found to be mistreating his or her colleagues, we will take appropriate action to stop the behavior. If you would like to report behavior that you believe is bullying, you may use the same reporting procedures outlined below.

Any TestLion who believes he or she has been harassed, or has witnessed or heard about a potential violation of this policy, should promptly report the conduct so that Testlio can take steps to remedy any violations of the policy.

If you suspect harassment, discrimination, or retaliation has occurred, you are encouraged (and managers are required) to promptly provide a written or oral complaint to any of the following:

When possible, a complaint should include details of the incident or incidents, names of individuals involved, and names of any witnesses. Having more detailed information allows us to address your concern as comprehensively, effectively and quickly as possible - and we really do want to address your concerns.

If a complaint of prohibited conduct under this policy is substantiated, then appropriate disciplinary action, up to and including termination, will be taken.

If during the course of investigation the evidence shows that a claim has been made maliciously, with bad intentions, and deliberately to discredit a fellow TestLion, then appropriate disciplinary actions, up to and including termination, will be taken.

Our goal is to create a safe and respectful work environment, regardless of physical location, where everyone can do their best work. As we take it seriously it is our job and obligation to investigate when we learn about a potential violation of our policies.

We will keep all complaints confidential to the extent possible while still fulfilling our obligation to investigate and end any harassing conduct.

As a general procedure, all addressed concerns involving Employees and Contractors will be investigated by our People Ops team. All concerns on any of the Freelance network members will be investigated by the Testing Network team. In case the concern involves a member of the People & Culture team, the concern will be investigated by the member of the ELT to guarantee impartial investigation results.

During the investigation all relevant parties will be reached out to in a private and discreet manner.

All TestLions must cooperate and provide truthful information in an investigation.

As a good practice, all concerns will generally be investigated and responded to within 10 business days. In case the investigation takes longer the investigation lead must notify the TestLion who raised the concern of the new deadline and the grounds for a lengthening deadline. Our general policy is that all interviews with relevant parties will be recorded with a voice or a video call. In case the relevant party does not wish the interview to be recorded, notes only will be taken during this interview. After the interview notes are compiled and forwarded to parties for confirmation and comments only. All provided info, statements and evidence provided during the investigation will be documented accordingly. The final written decision will be made by the investigation lead and forwarded to TestLion who raised the concern. If a complaint of prohibited conduct under this policy is substantiated, then appropriate disciplinary action, up to and including termination, will be taken.

TestLion preserves the right to appeal the final decision within 10 business days. In case the decision has been appealed, the case will be escalated for review to the member of the ELT team or a member of the Board, who will work through all documented statements and other materials of the investigation and come to a final decision.
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Retaliation is when someone penalizes another person for any of the following:

It is against this policy for any TestLion to retaliate against another for his or her participation in the complaint process. Retaliating against another TestLion who made a complaint or otherwise participates in the investigation process is grounds for discipline, up to and including termination.

We recognize that TestLions may find it difficult to raise complaints about harassment. We want to encourage all TestLions to come forward with your concerns without having to fear retaliation.

If you have questions about this policy, please contact the People & Culture team.

For Californian Employees

The Federal Equal Employment Opportunity Commission (EEOC) and the California Department of Fair Employment and Housing (DFEH) investigate and prosecute complaints of prohibited harassment, discrimination and retaliation in employment. If you think you have been harassed or discriminated against, or that you have been retaliated against for resisting, complaining or participating in an investigation, you may file a complaint with the appropriate agency. The nearest office can be found by visiting the agency websites at www.dfeh.ca.gov and www.eeoc.gov.

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