Anti-harrasment Policy

I. PURPOSE

At Protex AI, we believe it is essential to provide Protex AI Personnel with a respectful and safe working environment. As a result, we do not tolerate harassment or any mistreatment of Protex AI Personnel in the workplace or work-related situations. The purpose of this Policy is to deter conduct that is unwanted, unreasonable, and demeaning.

II. DEFINITIONS

• Protex AI is explained here, including: All of Protex AI, including all subsidiaries and affiliates worldwide.
• Protex AI Personnel is defined here as members of the Board of Directors, officers, and employees of Protex AI, as well as contingent workers (including vendor workers, contractors, consultants).

III. SCOPE & APPLICABILITY

The expectations of this Policy apply to everyone who works for Protex AI and any of its subsidiaries. Everyone — including individual contributors, managers, and contingent workers — is responsible for following and upholding this Policy. Additionally, we do not tolerate harassment of Protex AI Personnel, nor do we tolerate harassment of non-Protex AI Personnel.

This Policy applies to conduct at work and at work-related social events, office parties, off-sites, client entertainment events, including online or through other methods of communication used by Protex AI Personnel. Protex AI Personnel are expected to be particularly careful about what they say and do in these circumstances.

In the event of any inconsistency between this Policy and local laws (including any definition of harassment), local laws will apply unless this Policy provides greater protection.

IV. INTRODUCTION

At Protex AI, we believe it is essential to provide all Protex AI Personnel with a respectful and safe working environment. As a result, we do not tolerate harassment or any mistreatment of Protex AI Personnel in the workplace or work-related situations, including unlawful harassment, on the basis of the following protected categories:

• race, colour, ethnic or national origin;
• age;
• religion or religious creed (or belief, where applicable);
• sex, including pregnancy, childbirth, breastfeeding, reproductive health decisions, or related medical conditions;
• sexual orientation;
• gender, gender identity, gender expression, transgender status, or sexual stereotypes;
• nationality, immigration status, citizenship, or ancestry;
• marital status;
• protected military or veteran status;
• physical or mental disability, medical condition, genetic information or characteristics (or those of a family member);
• political views or activity;
• status as a victim of domestic violence, sexual assault or stalking; or

• any other basis prohibited under relevant laws.

Harassment under this Harassment Policy (Policy) may include conduct that creates a disrespectful, intimidating, hostile, degrading, humiliating, or offensive environment for an individual. Engaging in such conduct is a violation of this Policy.

Because the intent of this Policy is to deter conduct that is unwanted, unreasonable, and demeaning, Protex AI may consider an individual's conduct to be in violation of this Policy even if it falls short of unlawful harassment under applicable law. When determining whether conduct violates this Policy, we consider whether a reasonable person could conclude that the conduct created an intimidating, hostile, degrading, or demeaning environment.

All Protex AI managers globally are required to attend our mandatory sexual harassment training, which includes a comprehensive review of this Policy and applicable law.

V. EXAMPLES OF HARASSMENT

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 refusing to talk to them.

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

• derogatory or insensitive jokes, pranks, or comments;
• slurs or epithets;
• unwelcome sexual advances or invitations;
• non-verbal behavior such as staring, leering, or gestures;
• ridiculing or demeaning comments;
• innuendos or veiled threats;
• intentionally excluding someone from normal workplace conversations and making them feel unwelcome;
• displaying or sharing (1) offensive images such as posters, videos, photos, cartoons, screensavers, emails, or drawings that are derogatory or sexual, or (2) symbols of hate directed at race, religion or other protected categories;
• offensive comments about appearance, or other personal or physical characteristics, such as sexually charged comments or comments on someone's physical disability;
• unnecessary or unwanted bodily contact such as groping or massaging, blocking normal movement, or physically interfering with the work of another individual; or
• threats or demands that a person submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment-related benefits in return for sexual favors.

This list of examples is not exhaustive, and there may be other behaviours that constitute unacceptable harassment under this Policy.

"I was joking" or "I didn't mean it that way" are not defences to allegations of harassment. Nor is being under the influence of alcohol or other substances.

Sexual Harassment

Sexual harassment is harassment specifically based on sex, and/or unwanted conduct of a sexual nature and may include: ‍

• ‍Hostile Work Environment: Conduct that has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile, or offensive working environment; and ‍
• Quid Pro Quo Harassment: Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment, or when submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting that individual.

Sexual harassment can happen regardless of the individuals' gender, gender identity, or gender expression and can, for example, occur between same-sex individuals as well as between opposite-sex individuals, and does not require that the harassing conduct be motivated by sexual desire.

VI. BULLYING

Protex AI does not tolerate bullying. Bullying may include abusive conduct, or other intimidating, aggressive, offensive, malicious or insulting behaviour. Bullying includes an abuse of power which is intended to undermine, exclude, humiliate, or demean an individual covered by this Policy, whether or not it is based on a protected category. If an individual is found to be bullying their colleagues, we will take appropriate action to stop the behaviour.

If you would like to report behaviour that you believe is bullying, you may use the same reporting procedures outlined below.

VII. REPORTING PROCEDURES

Managers at Protex AI are required to promptly (ideally, within 24 hours) report any violation or suspected violation of this Policy. Managers who receive a complaint of, or learn of, information that suggests this Policy may have been violated are required to promptly (ideally within 24 hours) forward that complaint to the Founders or Chief of Staff (or other member of the Leadership team as appropriate), and will be subject to discipline for failing to timely report. As soon as reasonably possible, the Company will investigate any allegations and take appropriate remedial action.

Any employee who believes they have been harassed, discriminated, bullied or retaliated against or has witnessed or heard about a potential violation of this Policy, should report the conduct so that Protex AI can take steps to remedy any violations of the Policy.

When possible, a complaint should include details of the incident or incidents, names of individuals involved, and names of any witnesses.

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

VIII. INVESTIGATIONS PROCESS

Protex AI has an ethical obligation to promptly investigate and respond to all complaints regarding potential violations of this Policy. Upon learning of conduct requiring further review, company investigators will complete thorough investigations in a timely and impartial manner.

All persons to whom a complaint is made or who learn of a complaint as part of a Protex AI investigation must do everything reasonably possible to keep the complaint confidential in order to preserve the integrity of the investigation while it is ongoing, to ensure fairness to all involved, and to protect the privacy of Protex AI Personnel who have brought complaints or are accused of misconduct.

Protex AI Personnel must cooperate, be respectful, and provide truthful information in an investigation.

Nothing in this Policy is to be construed as a guarantee of absolute confidentiality or intended to curtail employee rights under the law to discuss work-related matters. Disclosure of information learned through the complaint process and the investigation will be limited to disclosures that are necessary for Protex AI to fulfil its legal obligations to investigate and take prompt action to end harassment.

IX. POLICY PROHIBITING RETALIATION

We recognize that employees may find it difficult to raise complaints about harassment, discrimination and/or other violations of this Policy, so we have a policy meant to encourage employees to come forward with their concerns without fear of retaliation.

It is against Protex AI policy (and may be unlawful) for any employee to retaliate against another for their participation in the complaint process or opposition to harassment or discrimination.

Retaliation is when someone penalises another person for any of the following:

• Reporting what they believe in good faith to be harassment, discrimination and/or a violation of this Policy;
• Expressing an intent to report what they believe in good faith to be harassment, discrimination and/or a violation of this Policy;
• Assisting another employee in an effort to report harassment, discrimination and/or a violation of this Policy;
• Participating in any investigation under this Policy; or
• Opposing conduct that they believe in good faith to be harassment, discrimination and/or a violation of this Policy.
• Retaliating against Protex AI Personnel who made a complaint or otherwise participates in the investigation process or opposes harassment or discrimination is grounds for discipline, up to and including termination.
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If you have questions about this Policy, please contact the Founders, the Chief of Staff or Head of HR (as appropriate).

X. STANDARD LANGUAGE ENFORCEMENT

A violation of this Policy or law may result in disciplinary action up to and including termination of employment for Protex AI employees or removal from Protex AI’s account for contingent workers, subject to applicable law. For Protex AI managers, please be aware of

your responsibilities to report compliance concerns and alleged or known policy or legal violations to the Founders and/or Chief of Staff or Head of HR.

Protex AI’s Approach to the Workplace Investigations Process

Below we are sharing our internal FAQ for employees on Protex AI’s investigations process:

We have an obligation to do the right thing for everyone we serve, including our employees, contingent workers, customers and investors.

Why Do We Conduct Workplace Investigations?

When we learn about a potential violation of Protex AI policy or law, it’s our job and obligation to investigate, and when a violation of Protex AI policy or law is found, to stop the misconduct. Our goal is to create a safe and respectful environment where everyone can come and do their best work.

What Do We Investigate?

A few examples of the types of matters we investigate include complaints about harassment and discrimination, disclosure of confidential or proprietary information, improper conflicts of interest, and abuse of company resources.

Some of these topics are sensitive, and we want people to feel as comfortable as possible coming to us with concerns. To that end, we try to keep matters as confidential as possible.

How Do I Report a Potential Violation of Law or Policy?

If you see or hear of something that might be a violation of Protex AI policy or law, we encourage you to speak up. If you are a manager, you are required to report any potential violations to the Founders and/or the Chief of Staff or Head of HR. Protex AI provides a variety of channels for people to report concerns:

Should I Be Concerned About Retaliation?

No. We have a zero-tolerance policy when it comes to unlawful retaliation. Specifically, Protex AI’s Harassment Policy encourages employees to come forward with their concerns and participate in the investigations process, all without fear of retaliation.

Who Conducts the Investigation?

Once a concern has been raised, the Founders in conjunction with the relevant Senior Managers, conducts a prompt and thorough investigation to determine facts. Each investigation is tailored to the specific issues being investigated and is also documented and tracked to ensure reasonable progress and timely closure of the investigation. Findings are then shared with a very small group of people, generally folks in HR and Legal, on a need-to-know basis.

How are employees involved in investigations?

If you’re asked to participate in an investigation, here’s what you can expect:

1. ‍Prior to the meeting: Founders and/or Chief of Staff will reach out to you by email to schedule a meeting. You do not need to prepare for the meeting unless specifically requested to do so. Given the sensitive nature of an investigation, you will be asked to keep this information as confidential as possible. ‍
2. During the meeting: There will likely be two people from the Leadership team in the room during the meeting. One will be there to take notes. You’ll be asked a variety of questions about a particular topic. It’s important that you be open and honest in your responses. The Leadership team are committed to being respectful, impartial, and professional during the meeting. ‍
3. Following the meeting: To protect confidentiality and to ensure fairness to everyone involved, we may not be able to answer specific questions about an investigation, but the Investigations Team will reach out to you to inform you that the matter has been addressed and closed.

Do I Have to Participate in an Investigation if Asked?

Yes. Our people have an obligation to participate in an investigation.

Do I Have to Report a Protex AI Policy Violation?

We ask everyone who works for Protex AI to report a potential violation of policy or law, but if you are a manager, you are required to report anything that comes to your attention. If you have questions about what that might look like, refer to our Corporate Policies, which includes our Harassment Policy.

Will This Meeting Be Recorded?

No, but notes may be taken.

Who Can I Talk to About This Investigation?

Contact the lead investigator who reached out to you initially. To protect the confidentiality of the investigation, you should not speak to anyone else, including your manager, about this investigation. As a result we may not be able to answer specific questions about an investigation but are happy to talk to you about the process.

What Are the Outcomes of an Investigation?

Outcomes range from no action to education, coaching or counselling, warnings, and other disciplinary actions up to and including termination. Outcomes are usually determined by business leaders with input from HR and Legal.

Why Do You Ask That I Keep the Investigation Confidential?

In order to preserve the integrity of the investigation while it is ongoing, to ensure fairness to all involved, and to protect the privacy of employees who have brought complaints or are accused of misconduct. Additionally, keeping things confidential helps minimise retaliation against participants and minimises disruption in the workplace. Our request for confidentiality is not meant or intended to curtail your rights under the law to discuss work-related matters.