Anti-harassment policy.

2. Protected Characteristics

Harassment or discrimination based on any of the following is prohibited:

Race (including traits historically associated with race, such as hair texture and protective hairstyles), color, religion and religious creed (including dress and grooming practices), national origin, ancestry, citizenship or immigration status, physical or mental disability, medical condition, genetic information, marital status, sex (including pregnancy, childbirth, breastfeeding, and related medical conditions), reproductive health decisionmaking, gender, gender identity, gender expression, sexual orientation, age (40 and over), military or veteran status, and any other characteristic protected by applicable federal, state, or local law. It also covers harassment based on the perception that a person has any of these characteristics, or that a person is associated with someone who does.

3. What Sexual Harassment Is

Sexual harassment includes unwelcome sexual advances, requests for sexual favors, and other unwelcome verbal, visual, or physical conduct of a sexual nature. It takes two general forms:

• Quid pro quo. Submission to or rejection of the conduct is made, explicitly or implicitly, a condition of employment, compensation, assignment, advancement, or any other term of work.
• Hostile work environment. The conduct is severe or pervasive enough to alter the conditions of a person's employment and create an abusive working environment.

Prohibited conduct includes, without limitation:

• Unwanted sexual advances, propositions, or repeated requests for dates after a person has declined
• Offering a benefit, assignment, review, or promotion in exchange for sexual conduct, or threatening a detriment for refusing
• Sexual or derogatory comments, jokes, slurs, innuendo, catcalls, or comments about a person's body, appearance, or sexual activity
• Displaying, sending, or sharing sexually suggestive images, messages, memes, or links, including in chat channels, email, screen shares, and video call backgrounds
• Unwanted touching, hugging, massaging, brushing against, blocking a person's path, or invading personal space
• Leering, staring, obscene gestures, or graphic verbal commentary about a person
• Spreading sexual rumors, or making harassing comments about a person's gender identity, gender expression, or sexual orientation, including intentional and repeated misgendering
• Sexual assault, coercion, stalking, or intimidation

Harassment does not have to be sexual in nature or motivated by sexual desire to violate this policy. Conduct that is hostile, abusive, or degrading toward a person because of any protected characteristic in Section 2 is equally prohibited. Harassment can occur between people of any gender, including people of the same gender, and can be committed by a supervisor, a coworker, a subordinate, or a non-employee such as a client or vendor.

4. How to Report

If you experience or witness conduct that may violate this policy, report it. You are not required to confront the person responsible first, and you are not required to report to your own supervisor or to the person you believe is responsible. Any of the following channels is a valid way to make a report:

Reports may be made verbally or in writing. There is no required form and no deadline for making an internal report, though we ask you to report as promptly as you are able so that we can act while the facts are fresh. Personnel of a client, subcontractor, or vendor who wish to raise a concern about the conduct of Horus personnel may use any channel above.

5. No Retaliation

Retaliation against anyone who reports harassment in good faith, refuses to participate in prohibited conduct, assists another person in reporting, or participates in an investigation is strictly prohibited and is itself a violation of this policy and of law.

Retaliation includes termination, demotion, pay or hour reduction, reassignment to less desirable work, removal from an engagement, exclusion from meetings or opportunities, negative reviews that depart from the record, and informal freeze-out or hostility.

A report made in good faith is protected even if the investigation ultimately does not substantiate a policy violation. Good faith means you honestly believed the facts you reported. Knowingly making a false report is a separate matter and may itself result in discipline, but an unsubstantiated report is not a false report.

6. Investigation Process

Every report is taken seriously and acted on. Our commitments:

• Acknowledgement within 2 business days. The person reporting receives confirmation that the report was received and information about what happens next.
• Impartial, qualified investigator. The investigation is conducted by someone with no stake in the outcome and no reporting relationship to the people involved. Where the subject of the report is the Chief Executive Officer, a member of leadership, or anyone the internal investigator reports to, the investigation is referred to outside employment counsel.
• Timely and documented. Investigations are completed promptly, ordinarily within 30 days, and are documented with the allegations, the evidence gathered, the witnesses interviewed, the findings, and the reasoning.
• Fair process. The person reporting and the person accused each have an opportunity to be heard and to identify witnesses and evidence.
• Interim measures. Where appropriate, we take steps to separate the people involved or otherwise prevent further harm while the investigation proceeds. Interim measures are not imposed as a penalty on the person who reported.
• Written closure. Both the person reporting and the person accused are informed of the outcome and of any corrective action affecting them.

Investigations are kept as confidential as the circumstances and the need for a thorough investigation allow. We do not promise absolute confidentiality, because we cannot investigate without disclosing some information to the people who need to respond to it, but information is shared only with those who have a legitimate need to know.

7. Corrective Action

If the investigation determines that this policy was violated, we take corrective action proportionate to the conduct, up to and including immediate termination of employment or of a contractor or subcontractor engagement.

Corrective action may also include written warning, required training, removal of supervisory responsibility, reassignment, removal from a client engagement, or changes to team structure or process. Where the person responsible is not a Horus employee, we will take the action available to us, which may include removing the individual from the engagement, escalating to their employer, or terminating the relationship.

8. Responsibilities of Supervisors

Anyone who supervises others at Horus has heightened obligations under this policy. Supervisors must:

• Escalate any report or observation of possible harassment immediately under Section 4, whether or not the person affected asks them to, and whether or not they personally believe the conduct was serious
• Not attempt to investigate, mediate, or resolve a report informally on their own
• Take reasonable steps to prevent harassment in the environments they control, including client sites and team channels
• Never subject a person to any detriment for having raised a concern

9. Training

California law (Government Code section 12950.1) requires employers with five or more employees to provide sexual harassment prevention training: two hours for supervisory personnel and one hour for non-supervisory personnel, within six months of assuming a role and every two years thereafter. The training must be interactive and must cover harassment based on gender identity, gender expression, and sexual orientation.

Horus Technology provides this training to personnel in accordance with these requirements and maintains records of training completion.

10. External Agencies

Using this policy is not a precondition to exercising your legal rights, and nothing here limits them. You may file a complaint with a government agency instead of, or in addition to, reporting internally. Both agencies below investigate at no cost to the complainant.

11. Third Parties, Clients, and Public Sector Engagements

We expect the same standard on engagements that we hold internally. Where a client, public agency, or prime contractor requires disclosure of our harassment policies as a condition of doing business, this policy is the document we provide, and we will complete required disclosure forms and certifications accurately.

If Horus personnel are harassed by a client's staff or by another vendor while working on an engagement, report it through Section 4. We will address it with the client or vendor and will not require anyone to keep working in an environment we have not addressed.

12. Distribution and Review

This policy is published here, is provided to all personnel at onboarding with acknowledgement of receipt recorded, and is redistributed when materially revised. It is reviewed by the Chief Executive Officer at least annually and upon any material change in applicable law or company structure.

This policy sets our standards and obligations. It is not an employment contract and does not alter the at-will nature of employment with Horus Technology.

13. Contact

Questions about this policy, or to request a copy for a procurement or audit file: