1 Lincoln Financial Group Equal Employment Opportunity, Discrimination & Harassment Policies The Company and its business units are committed to a policy of Equal Employment Opportunity. Discrimination or harassment based upon race, color, religion, sex (including pregnancy), age, national origin, disability, sexual orientation, gender identity, veteran's status or genetic information is strictly forbidden. This commitment guides our daily operations and is clearly stated in LFG s Equal Employment Opportunity Policy Statement. The following behaviors, communications, etc. are inappropriate and prohibited regardless of whether they are protected by any federal, state or local statute: Derogatory comments about an individual's membership in or affiliation with any protected group; visual displays including signs, cartoons, pictures, and computer print-outs which are degrading to or reflect negatively upon any protected group; vocal commentary such as jokes, comments, stories, speeches or derogatory statements which stereotype, demean, or make fun of any protected group; slurs used to describe a protected group; nicknames or other offensive references relating to a person's membership in any protected group; verbal or nonverbal innuendo which relates to or reflects negatively upon any protected group; symbols which suggest the inferiority of any protected group; threats or hostile behavior directed at an Employee because of their membership in any protected group; stereotypic slurs about a protected group; and any other inappropriate behavior regarding or directed towards any protected group. This listing of prohibitions is not exclusive and they apply to all forms of communication no matter what the media, or medium, including , voice mail, and Internet communications and searches. They apply to the workplace itself and to any work-related settings such as meetings at customer work sites, business trips or business-related social functions. It is every Employee's responsibility to report any incidents of harassment or discrimination. Indefensible Stance Prohibited behavior will not be tolerated or condoned at any time, under any circumstance, or in any situation. To state there was no bad intent, it was only a joke, it was done to curry favor, or was not directed toward an individual is indefensible.
2 Sanctions for Violations of the Company's Equal Employment Opportunity Policy Any Officer, Manager, Supervisor, Employee, Agent or Non-Employee who, after appropriate investigation, has been found to have unlawfully discriminated against, harassed or retaliated against another person will be subject to appropriate disciplinary or corrective actions, up to and including termination of their employment or other relationship with our Company. Even if conduct does not constitute discrimination, harassment, or retaliation in the legal sense, an Officer, Manager, Supervisor, Employee, Agent or Non-Employee who engages in inappropriate behavior inconsistent with this policy will be subject to appropriate disciplinary or corrective action, up to and including termination of their employment or other relationship with our Company. Sexual and Other Types of Harassment Lincoln strives to keep its workplace free of all forms of harassment. Harassment based on any protected status, e.g. race, color, religion, sex (including pregnancy), age, national origin, disability, sexual orientation, gender identity, veteran's status or genetic information will not be tolerated. It is the Company's policy to recruit, hire, promote, train, compensate and apply all other terms, conditions and benefits of employment based upon job related qualifications without regard to an individual's uniquity. Sexual Harassment Discrimination against an Employee or applicant based on sex or gender (including pregnancy) will not be tolerated. The Company's policy is to recruit, hire, train, promote, compensate and apply all other terms, conditions, and benefits of employment based on job related qualifications without regard to an individual's sex or gender. This policy applies to all aspects of employment and applies to interactions with visitors and nonemployees. Types of Sexual Harassment are: Quid Pro Quo Harassment; and Hostile Work Environment. Sexual harassment is illegal and a form of sex discrimination, which the Company will not tolerate. The following behaviors exhibited by either a man or woman are prohibited: Threats, insinuations, or demands, expressed or implied, that sexual favors are a condition of employment, continued employment, or benefit of employment;
3 implications that refusals to submit to sexual advances will adversely impact an Employee's state of employment; basing employment decisions on a person's submission to or refusal to submit to sexual advances; engaging in unwelcome sexually-oriented or hostile behavior which impacts another Employee's work performance; and creating an intimidating, hostile, abusive, or offensive working environment. Social Relationships Social relationships can develop at work, but unwelcomed or unsolicited advances from Officers, Managers, Supervisors, co-workers, Agents, peers, or non-employees are not to be tolerated. If you feel inappropriate advances are being made toward you or a coworker you should follow the complaint procedure described in Reporting Discrimination and Harassment. The Company assumes any relationship is consensual unless and until we are made aware through our reporting process. Other Types of Harassment Harassment based on any protected status, e.g. race, color, religion, sex (including pregnancy), age, national origin, disability, sexual orientation, gender identity, veteran's status or genetic information will not be tolerated. This includes and applies to interactions with non-employees. Age Any employment decision or treating an Employee differently based upon stereotyped assumptions about abilities, traits or performance of individuals age 40 and older is unlawful and is in violation of the Age Discrimination in Employment Act of Race/Color Any employment decision or treating an Employee differently based upon stereotyped assumptions about abilities, traits, race, color or performance of various racial groups is unlawful and is in violation of Title VII of the Civil Rights Act of National Origin Employment decisions or treating an Employee differently based on national origin is unlawful and in violation of Title VII of the Civil Rights Act of Treating someone less favorably because he or she comes from a particular place, because of his or her ethnicity or accent, or because it is believed that he or she has a particular ethnic background is prohibited unless a job related or business related reason can be shown as the basis for the decision.
4 Religion Employment decisions or treating an Employee differently based on religion, or for failure to comply with a work requirement that conflicts with the worker's bona fide religious belief, is prohibited by Title VII of the Civil Rights Act of Religious, moral or ethical beliefs sincerely held will be reasonable accommodated, unless such an accommodation would create an "undue hardship" on the Company's business. Disability Any employment decision or treating an Employee differently based upon an individual's physical or mental disability without regard for requisite skills, experience, education and other job related qualifications is in violation of the Rehabilitation Act of 1973 and the Americans with Disabilities Act of The Company provides, to the maximum extent feasible, facilities that are accessible and usable by individuals with disabilities. This policy is not to be interpreted as a modification to the current Employee's Short-Term or Long-Term Disability Plans. Sexual Orientation Employment decisions or treating an Employee differently based on sexual orientation are prohibited by the Company. Gender Identity Employment decisions or treating an Employee differently based on gender identity or expression are prohibited by the Company. Veterans Status Employment decisions or treating an Employee differently based upon a veteran's status is prohibited by the Company. Genetic Information Employment decisions or treating an employee differently based upon genetic information is a violation of Title VII of the Genetic Information Nondiscrimination Act of Non-Employees The prohibitions stated in these policies against discrimination and harassment apply equally to non-company Employees as well as Company Employees. Any discrimination or harassment perpetrated by a non-employee in connection with your employment should be reported immediately. Conversely, the prohibitions against unlawful
5 discrimination and harassment set forth in this policy apply to your conduct relative to non-employees with whom you do business. Americans With Disabilities Act If you need an on the job accommodation due to a disability, you may qualify for protection under the Americans With Disabilities Act (ADA). When you make your request known, documentation will be obtained from your attending physician to establish the nature of the disability and the accommodations required. The Company will determine if the request qualifies under the ADA and if the accommodations appear to address the work related limitations and restrictions caused by the disability. The Company will make reasonable accommodations unless it is determined that making the accommodation imposes an undue hardship on the Company. Your HR representative will work with you and your Manager to implement the accommodation(s). If you feel you need an on-the-job accommodation due to a disability, please speak with your HR Representative. If you do not know who your HR Representative is, refer to the list of HR Representatives. Reporting Discrimination and Harassment Discrimination or harassment based upon race, color, religion, sex (including pregnancy), age, national origin, disability, sexual orientation, gender identity, veteran's status or genetic information is strictly forbidden. It is every Employee's responsibility to report any incidents of harassment or discrimination. This includes incidents that directly affect you, as well as others observed or witnessed by you. If you have reason to believe an Officer, Manager, Supervisor, co-worker, Agent, peer, or non-employee has discriminated against you, harassed, or retaliated against you with regard to any term or condition of your employment, you should report the alleged violation(s) immediately. Also, if you observe or are witness to an Officer, Manager, Supervisor, co-worker, Agent, peer, or non-employee who's behavior may be perceived as discriminatory, harassing or retaliatory you should report the alleged violation(s) immediately to any of the following: Company Equal Employment Opportunity Officer; your HR Representative (If you do not know who this is, refer to the list of HR Representatives); or a representative of management. Please speak with the person you feel the most comfortable, whatever your reasons. While it is not a requirement, you are encouraged to tell the offending party(ies) of their unwelcome behavior and request them to stop. If this informal approach proves
6 ineffective, or if it is one with which a person feels uncomfortable, for whatever reason, please contact one of the persons named above. No Employee is compelled to confront directly the individual who has made him or her uncomfortable. All complaints will be investigated promptly, and the existence and nature of your complaint will be disclosed only to the extent necessary to make a prompt and thorough investigation or as may be necessary to take appropriate corrective measures. Coercion, retaliation, intimidation, or harassment against an Employee who registers a complaint in good faith or serves as a witness in good faith on behalf of another Employee will not be tolerated. If, for whatever reason, you are not entirely satisfied with how your complaint has been handled initially, contact the Company's Equal Employment Opportunity Officer in writing, immediately.