Page 10 - Delfi Diagnostics Handbook

● 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
DELFI 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 People
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 the People Team or the CEO (for
example, if they are the ones engaging in the prohibited conduct or if the employee is
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 the People Team 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.

Every reported complaint will be investigated thoroughly and promptly in accordance with
applicable law. Qualified personnel will conduct the investigation in a fair, timely, thorough and
impartial manner that will provide all parties with appropriate due process. Typically, the
investigation will include the following steps: an interview of the employee who lodged the
complaint to obtain complete details regarding the complaint; interviews of anyone who is
alleged to have committed the acts that are the subject of the complaint; and interviews of any
employees who may have witnessed, or who may have knowledge of, the alleged complaint.
DELFI expects all employees to cooperate in the investigation. The investigation will be
documented, tracked for reasonable progress and concluded in a timely manner. Reasonable
conclusions will be reached based upon the evidence collected. The People Team, or other
Company official responsible for the investigation, will notify the employee who lodged the

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