Nondiscrimination & Anti-Harassment Policy

1. Equal Opportunity Commitment

Nexma is an equal-opportunity employer. We are committed to a workplace free of discrimination, harassment, and retaliation, where decisions about hiring, development, compensation, and advancement are based on merit, qualifications, and business needs. This policy reflects our obligations under applicable law, including US equal-employment laws (such as Title VII of the Civil Rights Act, the Americans with Disabilities Act, and the Age Discrimination in Employment Act), the EU equal-treatment directives, and the UK Equality Act 2010.

This policy applies to all employees, applicants, contractors, and others in our workplace, and to all aspects of the working relationship.

2. Protected Characteristics

We do not discriminate on the basis of any characteristic protected by applicable law. Depending on jurisdiction, these include race, color, ethnicity, national origin, religion or belief, sex, gender, gender identity or expression, sexual orientation, pregnancy, marital or family status, age, disability, genetic information, veteran or military status, and any other legally protected characteristic.

3. Prohibited Conduct

We prohibit discrimination, harassment, and retaliation in any form, including:

• Discrimination — treating someone less favorably because of a protected characteristic;
• Harassment — unwelcome conduct related to a protected characteristic that creates an intimidating, hostile, degrading, or offensive environment, including sexual harassment;
• Bullying and victimization that targets protected characteristics; and
• Retaliation against anyone who reports a concern, supports a complaint, or participates in an investigation in good faith.

4. Reasonable Accommodation

We provide reasonable accommodations to qualified individuals with disabilities and for sincerely held religious beliefs and other protected needs, as required by applicable law, unless doing so would impose an undue hardship. Requests can be made through the contact below or to your point of contact at Nexma.

5. Complaint Procedure

Anyone who experiences or witnesses conduct that may violate this policy is encouraged to report it promptly. Reports may be made to leadership, through Nexma's reporting channels, or to the contact below. You do not need to be certain a violation occurred to report a concern.

6. Investigation and Confidentiality

We take complaints seriously and investigate them promptly, fairly, and as confidentially as the circumstances allow. We share information only with those who need it to investigate or respond, and we act to stop and remedy conduct found to violate this policy.

7. Non-Retaliation

Retaliation against anyone who raises a concern, files a complaint, or assists an investigation in good faith is strictly prohibited and is itself a violation of this policy, regardless of whether the underlying concern is substantiated.

8. Enforcement

Violations of this policy may result in disciplinary action up to and including termination. Compliance with this policy is the responsibility of everyone at Nexma. We review the policy periodically and update it as needed.