Page 11 - nou Systems handbook Draft Rev13 (2021) (1)

There are other behaviors that constitute or contribute to evidence of bullying in the
workplace. Legitimate, reasonable and constructive criticism of performance or behavior,
or reasonable instructions given in the course of employment, does not amount to bullying
on their own. Bullying is unacceptable.

Retaliation
The Company will not tolerate, nor does the law allow retaliation against any employee
for making a complaint of misconduct or for cooperating in an investigation. Retaliation
means adverse conduct taken because an individual participated in the activities
described above.

• shunning and avoiding an individual who reports harassment, discrimination or
retaliation.
• express or implied threats or intimidation intended to prevent an individual from
reporting harassment, discrimination or retaliation.
• denying employment benefits because an applicant or employee reported
harassment, discrimination or retaliation or participated in the reporting and
investigation process; or
• interfering with or tampering with due process of an investigation into complaints
or grievances.

Complaint Process
nou Systems understands that victims of harassment, discrimination, bullying or
retaliation are often embarrassed and reluctant to report such prohibited acts for fear of
being blamed, concern about being retaliated against, or because it is difficult to discuss
such matters openly with others. However, no employee should have to endure such
prohibited conduct, and the Company therefore encourages employees to promptly report
any incidents to a member of the Human Resource team or Chief Executive Officer, who
are generally responsible for investigating complaints of misconduct under this policy, so
that investigation and, if merited then also corrective action, may be taken.

Employees are not required to report incidents to a member of Human Resources or the
CEO (for example, if they are the ones engaging in the prohibited conduct or if they are
uncomfortable doing so for any other reason); employees may instead report the matter
to their immediate manager or any other member of management.

Managers who receive complaints (verbal or written) of prohibited conduct or who
observe or otherwise become aware of prohibited conduct must act to stop the conduct,
if appropriate, and immediately inform Human Resources or other appropriate Company
official so that an investigation may be initiated, and the Company can try to resolve the
claim internally. To the full extent permissible under applicable law, in addition to being
subject to discipline if they engage in the type of misconduct described in this policy
themselves, managers may be subject to discipline for failing to report suspected
misconduct or otherwise knowingly allowing misconduct to continue.

nSI Employee Handbook 11 Rev. 4 (2021))