1.0 Policy

Solenis is committed to maintaining a work environment where people are treated with respect. In keeping with this commitment, Solenis will not tolerate the harassment of employees or applicants (male or female) by anyone, including any supervisor, co-worker, or non-employee.

1.1 Definition of Harassment

Harassment consists of unwelcome conduct, whether verbal, non-verbal or physical, that is based on a person’s age, disability, gender, national origin, race, color, religion, sexual orientation, veteran status, or other protected group status, and that affects an individual’s employment or creates an intimidating, hostile, or offensive working environment.

1.2 Definition of Sexual Harassment

Sexual harassment is a type of gender-based harassment that includes, but is not limited to:

• Making unwelcome sexual advances or requests for sexual favors or other verbal or physical conduct of a sexual nature as a condition of an employee’s continued employment;
• Making submission to or rejection of such conduct the basis for employment decisions affecting the employee; or
• Engaging in offensive or threatening behavior of a sexual nature.

1.3 Definition of Harassing Behavior

Harassing behavior can be verbal, nonverbal, or physical. Examples of inappropriate behaviors include:

• Verbal - sexual innuendo, suggestive or discriminatory comments, insults, threats, jokes about personal or physical traits, jokes of a sexual or demeaning nature, or sexual propositions. Solenis Confidential Page
• Nonverbal - suggestive or insulting noises, leering, whistling, obscene gestures, threatening gestures, and the posting or possession at the workplace of literature, calendars or pictures that are suggestive, revealing, demeaning or pornographic.
• Physical – unwelcome touching, pinching, brushing, rubbing or groping of the body, unnecessary closeness, threatening or intimidating actions, coercing sexual activity, and assault.

1.4 Workplace Relationships

A supervisor may not date or have any form of sexual relationship with an employee who reports through his or her management chain, even when the relationship is voluntary and welcome. Activity of this sort will subject all involved to disciplinary action, up to and including termination.

Reporting a Problem

It is every employee's responsibility to help maintain a work environment free from harassment. Employees who believe they have experienced or observed harassment must report the harassment immediately to their supervisor, their human resources representative and/or Solenis' Employee Hotline at 1-844- SOLENIS, Press #2 (1-844-765-3647, Press # 2) or submit a web form at www.lighthouse-services.com/solenis.

Each complaint will be investigated on a priority basis, with the investigation generally coordinated by the local human resources department. Although Solenis must collect all relevant information as part of a complete investigation, every effort will be made to conduct the investigation on a confidential basis, with disclosure made only where there is need to know. If an investigation confirms that harassment has occurred, Solenis will take prompt corrective action, including discipline up to and including termination. Decisions reached will be communicated to those involved

1.6 Retaliation of Prohibited

Solenis encourages employees to raise questions or concerns regarding discrimination or harassment with their local human resources department. Solenis will not authorize or permit any form of retaliation against any employee who has made a good faith claim or report of harassment, or against any employee who in good faith has provided information to Solenis during the investigation of a claim or report of harassment. Employees who believe that they have been retaliated against should immediately contact their supervisor, their human resources representative, or the Employee Hotline at 1-844-SOLENIS, Press #2 (1-844-765-3647, Press #2) or submit a web form at www.lighthouse-services.com/solenis.

2.0 Scope

This policy applies to Solenis except as follows:

• Employees who are subject to a collective bargaining agreement, to the extent the agreement contains provisions that conflict with this policy; or
• Employees who are not employed in the United States.

3.0 Owner

Solenis’ Chief Human Resources Officer is responsible for implementation of and amendments to, this policy.

4.0 Exceptions

There are no exceptions to this Policy.