Page 24 - NWF November Updates

All persons to whom a complaint is made or who learn of a complaint as part of a Company
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 employees who have brought complaints or are accused of misconduct.

Employees must cooperate 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 the Company to fulfill its legal obligations to investigate and take prompt action to
end harassment.

Violations of this Policy

Any employee, regardless of position or title, whom NWF determines has subjected an individual to

behavior in violation of this policy, will be subject to discipline, up to and including termination of
employment.
The National Wildlife Federation may consider an employee’s job performance, prior violation
of work rules, and other relevant circumstances in determining whether to counsel, warn,
suspend or discharge an employee. It is up to the employee’s supervisor and the company’s
management to decide whether corrective action, up to and including dismissal, is
appropriate. The individual(s) conducting the investigation will make findings and
recommendations, but will not make the final determination regarding discipline or dismissal.

NWF seeks to create a safe workplace for our employees. To the extent any non-employee,

including but not limited to, affiliate members, volunteers, and vendors, whom NWF
determines had subjected a covered person to behavior in violation of this policy, NWF will
take corrective action to ensure our employees work in a safe environment.

No Retaliation

NWF prohibits any form of discipline, reprisal, intimidation or retaliation for reporting
incidents of any kind, pursuing a complaint or cooperating in related investigations.

NWF is committed to enforcing this policy. However, the effectiveness of our efforts depends
largely on employees telling us about all incidents that violate this policy, including potential
threats. Employees who witness any violation should report it immediately. In addition, if an

employee feels that they or someone else may have been subjected to conduct that violates
this policy, they should report it immediately. If employees do not report incidents, NWF may
not become aware of a possible violation of this policy and may not be able to take
appropriate corrective action.