Page 9 - Lupin Employee Handbook and Supplements - July 2018

Lupin Employee Handbook

do not like the conduct. The offensive conduct may have been thoughtless or based on a mistaken
belief that it was welcome. In any event, we suggest that you respond immediately and do not
ignore the problem. If the inappropriate behavior does not stop or you are not satisfied with the
result of your discussion with the offender, or if you are not comfortable speaking to the offender
directly, you should notify one of the appropriate people listed below in the Open Door Policy as
soon as possible. It is important that you inform us about the inappropriate conduct as soon as
possible, because we cannot do anything to remedy the problem if we do not know that it exists.

Any employee (or any other person performing services for us) who believes that he or she has
been the subject of prohibited harassment, retaliation, or discrimination should report the matter
immediately in accordance with the procedures listed below in the Open Door Policy. Any such
reports will be investigated promptly and be kept confidential within the bounds of our
investigation and the law. Please retain any notes, letters, or other written material that relate to
your complaint.

This policy reinforces Lupin’s tradition of developing and maintaining a professional environment
comprised of people who respect one another and who believe in Lupin’s high ideals. It is the
responsibility of all of us to uphold that tradition.

Open Door Policy

Lupin maintains an “open door” policy to encourage open communication between employees and
their supervisors or manager. Any employee who has a job-related question or problem, ideas and
concerns about their job or work environment, or believes he/she has not been treated properly
with respect to a matter arising out of his/her employment has the opportunity to discuss his/her
concern with their immediate supervisor/manager. This is usually the easiest and most effective
way to deal with a problem.

If the immediate supervisor/manager is unable to answer the questions, he or she may refer you to
the next level of management. Likewise, if you are uncomfortable with discussing the matter with
your supervisor/manager (including if the concern directly involves the supervisor/manager), if
you do not receive a timely response (typically, no more than 5 business days), or if your
supervisor/manager is unable to resolve your problem or concern, we recommend that you escalate
your problem to the next level of management.

If you are uncomfortable with discussing the matter with the next level of management above your
supervisor/manager, if you do not receive a timely response (typically, no more than 5 business
days), or if the next level of management is unable to resolve your problem or concern, we
recommend that you escalate your problem to HR, which you can do by contacting HR directly or
reporting your problem or concern to HR through Lupin’s hotline 1-844-549-2508 (toll free) or
email LupinPLEDGE@GetInTouch.com. Additionally, at any time an employee may address their
concerns with HR. Once escalated to HR, the Vice President of Human Resources will provide the
final response to the matter, unless the matter involves this individual in which case Lupin’s Chief
Executive Officer will provide the final response.

If you raise a concern through this procedure and you do not appeal it beyond a particular step,
Lupin will presume that the resolution provided at the last step was acceptable to you.

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