Page 11 - nou Systems Employee Handbook Final

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))