Effective Date: 5/16/2017

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1 Old Page 1 of 8 1 PURPOSE The purpose of this policy is to establish the guidelines for the work environment by which Noblis maintains a qualified workforce. This policy emphasizes that Noblis is committed to zero tolerance for discrimination, zero accidents, zero incidents, less pollution and minimum waste. 2 APPLICABILITY This policy is applicable to all Noblis employees, subsidiaries or affiliates at all Noblis locations. Failure to adhere to this policy may result in disciplinary action up to and including termination. 3 POLICY DIRECTIVE 3.1 Equal Employment Opportunity (EEO) & Affirmative Action Noblis is committed to equal employment opportunity and fostering an inclusive workforce that reflects diversity through effective outreach, recruitment, hiring, and employee development. It is the policy of Noblis not to discriminate against any applicant or employee because of race, color, religion, national origin, age, gender, sexual orientation or preference, gender identity, physical or mental disability (including disabled veterans), or veteran status, including recently separated veterans, Armed Forces service medal veterans, or other protected veterans. Noblis is committed to employ, free of discrimination, persons who are, based on their education, training, skills and experience, competent and qualified to perform the work they are engaged to do. This policy applies to all terms, conditions and privileges of employment, including recruiting, hiring, training, placement, compensation, benefits, transfers, layoff, return from layoff, corporate-sponsored training, education, tuition assistance, social activities and recreation. Noblis will actively promote the spirit of EEO through a positive continuing program for affirmative action. In addition, Noblis will further the principal goals of EEO by encouraging the employment of females, minorities, individuals with disabilities, and persons in veteran status in all positions and levels of the work force. Noblis also prohibits retaliation against any employee, vendor, contractor or other thirdparty doing business with Noblis who in good faith reports a violation of this policy or otherwise opposes discrimination or harassment, participates in an investigation of a potential violation of this policy, or otherwise engages in protected activity under the law. All allegations of discrimination and reprisal will be taken seriously and promptly

2 Old Page 2 of 8 investigated. Appropriate remedial actions will be taken with respect to any substantiated allegations. In any instance in which an employee believes this policy has been violated, the employee must notify his manager, the Vice President, Human Resources and Organization Development; General Counsel or the Chief Ethics and Compliance Officer. Employees may also notify Noblis using the Compliance Helpline, at or Harassment Noblis is committed to providing and maintaining a productive work environment that is characterized by mutual respect and is free from any type of harassment or discrimination. Noblis is committed to respecting the dignity of every employee and expects every employee to show respect for all Noblis colleagues, applicants, clients, visitors, and vendors. Respectful, professional conduct furthers the Noblis mission, promotes productivity, minimizes disputes, and enhances Noblis reputation. Accordingly, this policy prohibits harassment in the workplace including any unwelcome or unsolicited speech or conduct that is based upon age, race, color, creed, gender, sexual orientation or preference, national origin, marital status, disability, or any other protected status of an individual or an individual s associates or relatives. Not only is harassment against Noblis policy and contrary to the creation and maintenance of a positive working environment, it is also against the law. Noblis considers harassment, intimidation, or retaliation of any kind to be unacceptable and such conduct will not be tolerated. Management will take action, as appropriate, to address any violations of law or Noblis policies, regardless of the manner in which Noblis becomes aware of the unlawful or inappropriate conduct. Noblis requires that employees who have experienced or witnessed any conduct that is inconsistent with this policy against harassment to promptly report such incidents. If an employee believes he has been harassed or has witnessed harassment, or has been discriminated against in any way, the employee should inform his manager, Human Resources, and/or General Counsel immediately to report any violation of Noblis policy, or incident of discrimination, including harassment, sexual harassment, noncompliance with this Section 3.2 of this or the Noblis Code of Ethics and Conduct Policy. Further, Noblis prohibits all forms of retaliation against any individual who has made, or cooperated with the investigation of, a harassment or discrimination complaint. Such retaliation is unlawful and will not be tolerated. The conduct prohibited by this policy, whether verbal, physical, or visual, includes any discriminatory employment action and any

3 Old Page 3 of 8 unwelcome conduct that affects someone because of that individual s protected status. Among the types of unwelcome conduct prohibited by this policy are epithets, slurs, negative stereotyping, intimidating acts and the circulation or posting of written or graphic materials that show hostility toward individuals because of their protected status. Even where the conduct does not constitute harassment that is prohibited by law, Noblis prohibits any such conduct in the workplace or in carrying out one s duties for the organization. Employees should behave professionally at all times. Sexual harassment is a problem that deserves special mention. Harassing conduct based on gender often is sexual in nature, but sometimes is not. Sexual harassment is not limited to demands for sexual favors. This policy forbids harassment based on gender regardless of whether the offensive conduct is sexual in nature. Any unwelcome conduct based on gender is also forbidden by this policy regardless of whether the individual engaged in the harassment and the individual being harassed are of the same or are different genders. No employee, prospective employee, client, or prospective client should be subjected to unsolicited and unwelcome sexual overtures, nor should any employee or prospective employee be led to believe that an employment opportunity or benefit will in any way depend upon cooperation of a sexual nature. According to the U.S. Equal Employment Opportunity Commission ( EEOC ), unwelcome sexual advances, requests for sexual favors, and other verbal, physical or visual conduct based on sex constitute unlawful sexual harassment when: (1) submission to such conduct becomes either an explicit or implicit term or condition of employment; (2) submission to or rejection of the conduct is used as a basis for any employment decision; (3) the conduct has the purpose or effect of unreasonably interfering with the employee s work performance or creating an intimidating, hostile or offensive working environment. This policy forbids harassment based on gender regardless of whether it rises to the level of a legal violation. Sexual harassment is not limited to demands for sexual favors. Examples of gender-based harassment forbidden by this policy include: (1) sex-oriented verbal kidding, teasing, or jokes; (2) repeated unwanted sexual flirtations, advances, or propositions; (3) continued or repeated verbal abuse of a sexual nature; () graphic or degrading comments about an individual, his or her appearance or sexual activity;

4 Old Page of 8 (5) offensive visual conduct, including leering, making sexual gestures, the display of sexually suggestive objects or pictures, cartoons, or posters; (6) unwelcome pressure for sexual activity, even if subtle; (7) distributing, posting, or sending offensively suggestive or obscene letters, notes, or invitations; (8) offensive physical contact such as patting, grabbing, pinching, brushing against another s body, or impeding or blocking someone s movement; (9) transmitting offensive materials via Noblis computers (e.g., ) or accessing such information on the Internet while at work. All reports describing conduct that is inconsistent with this policy will be investigated promptly. Noblis may put reasonable interim measures in place, such as a leave of absence or a transfer, while the investigation proceeds. Noblis will take further appropriate action once the report has been thoroughly investigated. That action may be a conclusion that a violation occurred, as explained immediately below. Noblis might also conclude, depending on the circumstances, either that no violation of policy occurred or that Noblis cannot conclude whether or not a violation occurred. If an investigation reveals that a violation of this policy or other inappropriate conduct has occurred, Noblis will take corrective action, including discipline up to and including termination, as is appropriate under the circumstances, regardless of the job positions of the parties involved. If the person who engaged in harassment is not employed by Noblis, Noblis will take whatever corrective action is reasonable and appropriate under the circumstances. Consistent with this policy against workplace harassment, Noblis maintains posters on its bulletin boards that refer to legal definitions of harassment. These posters identify governmental agencies to contact for information on how and when to file administrative claims. Using Noblis complaint process does not keep any employee from filing a claim with a state governmental agency or with a federal agency such as the EEOC. Noblis policy provides for immediate notice of problems to the Noblis officials listed above so that Noblis may address and resolve any problems promptly and effectively. 3.3 Safe Work Environment Authorized Access For the safety and security of all employees and property, only employees and authorized visitors are allowed in Noblis facilities. Restricting access to Noblis facilities to only authorized individuals enables Noblis to maintain its safety standards; protects against theft of Noblis, client, and employee property; protects the security of equipment; protects

5 Old Page 5 of 8 classified, proprietary and sensitive information; and can avoid unnecessary disturbances. Noblis may use human or technology-assisted means to deter, detect, identify, and track possible threats and/or unauthorized entry to Noblis facilities Occupational Safety Noblis provides and manages a work environment to promote productivity and achieve conformity to the standards of excellence Noblis represents to clients. It is Noblis policy to maintain a safe and healthy work environment. The goal of Noblis management is to prevent occupational accidents, injuries, illnesses or unnecessary environmental damage. As such, Noblis will comply strictly with all mandatory and generally accepted work practices and procedures for the protection and promotion of the safety and health of its employees and others, who may be affected by Noblis activities. Employees will adhere to all site safety and health standards, and site work rules and procedures. Employees at all levels are directed to work conscientiously and diligently to execute this policy of maintaining the highest occupational health and safety to prevent any unsafe practices. Employees must immediately communicate any safety, health or environmental concerns related to their Noblis activities to their immediate manager, the Wellness Resource Center, or to the Facility Security Officer (FSO). Note: Individual state laws vary and Noblis will enforce this policy to the extent it is consistent with state law. Additionally, any potentially work-related injury and/or illness must also be reported as soon as practicable after its occurrence to the Safety Committee at Noblis will evaluate employee concerns and incidents in a timely manner and will put in place any necessary corrective actions to address the concerns or remove unsafe conditions. All investigation results and corrective actions taken will be appropriately communicated to affected personnel Violence in the Workplace; Items Prohibited in the Workplace Noblis promotes a secure environment for employees and visitors. As such, Noblis is committed to working with its employees to maintain a work environment free from violence, threats of violence, harassment, intimidation and other disruptive behavior. Violent behavior is defined as the use of physical force or violence to restrict the freedom of action or movement of another person or to endanger the health and safety of another person or property of Noblis. Violence, threats, harassment, intimidation, and other disruptive behavior in Noblis workplace will not be tolerated. Any employee who engages in such conduct will be subject to disciplinary action which may include termination of employment. All employees, visitors or contractors of Noblis are prohibited from possessing firearms, explosives or any other item which has a primary function to cause damage or death to a

6 Old Page 6 of 8 person or property (hereafter referred to as weapons ) on all of Noblis property without the explicit authorization from the Director, Corporate Security, whether or not a federal or state license to possess the same has been issued to the possessor. Employees, tenants, and visitors are not allowed to bring animals (except for special assistance animals) into Noblis facilities or property. Employees are also not permitted to introduce into the same facilities or property, any device, substance, or vehicle that may constitute a health or safety hazard, including without limitation, firearms, explosives, weapons or other potentially dangerous items. Noblis reserves the right to inspect employee work areas, lockers, computer and electronic files and personal effects, including persons, briefcases and other like items for the protection of others and Noblis Drug-Free Workplace In accordance with Noblis commitment to providing a safe and healthy workplace, and in compliance with the federal Drug-Free Workplace Act of 1988, it is the policy of Noblis to maintain a drug-free workplace. The use, possession, purchase, sale, manufacture, distribution, dispensation, or transfer of illicit drugs (including excessive quantities of prescription or over-the-counter drugs that have been obtained illegally and/or are not being used for the prescribed purpose), being under the influence of illicit drugs or alcohol, and possessing or consuming alcohol is prohibited while employees are working, present on Noblis premises, at Noblis site offices, and while an employee is present in any other location performing services for Noblis. Employees shall not report to work while under the influence of illicit drugs or alcohol. This policy applies to all employees. The term illicit drugs", as used in this policy is defined as follows: Illegally-used controlled substances (encompasses narcotic and non-narcotic drugs, including prescription drugs used abusively) and non-controlled substances (overthe-counter medicines if they render one unfit for duty). Noblis will permit alcoholic beverages to be served at functions on Noblis premises or at Noblis sponsored events that are off-premises (such as client entertainment) if properly authorized by a Noblis Officer. At all such functions, however, all employees and their guests are expected to act responsibly and to drink moderately (not to the point that they are under the influence). This policy does not prohibit employees from the lawful possession and use of prescribed medications or over-the-counter medications. Employees have the responsibility to consult with their doctors or other licensed medical practitioners about the effect of prescribed medications on their ability to perform their specific job duties in a safe manner,

7 Old Page 7 of 8 and to promptly disclose any work restrictions to their supervisors or the Wellness Resource Center. Noblis reserves the right to inspect all parts and aspects of its premises for illicit drugs, alcohol, or other contraband. All employees and visitors may be asked to cooperate in inspections of their persons, work areas and property (such as purses, tool boxes, lunch boxes, water coolers, thermos bottles, flasks, briefcases, cabinets, desks, lockers or cars) that might conceal illegal drugs, alcohol or other contraband. In furtherance of this policy, and as permitted by law, drug and alcohol testing will be conducted in accordance with individual state laws, in particular those of Maryland and Minnesota Safe Operation of Vehicles Noblis requires the use of safety belts by all employees and their passengers while operating or traveling in a Noblis-owned vehicle or in a personally owned or rental vehicle on Noblis business. Employees are required to comply with laws regarding the use of electronic devices such as cell phones and other hand-held devices while driving on Noblis business Tobacco Free Workplace In accordance with Noblis commitment to providing a safe and healthy workplace for all employees, Noblis has implemented a no tobacco policy within Noblis facilities as well as in Noblis owned or leased vehicles. For the purpose of this policy, facilities include all property owned, operated, leased or maintained by Noblis, and include all surrounding parking lots, walkways, lawns and similar areas. All occupants in such facilities are required to comply with this policy. Anyone who wishes to use tobacco can do so outside Noblis facilities in designated areas. 3. Damage to Personal Property Employees and third parties may be eligible for reimbursement of losses when damage to personal property occurs at Noblis facilities. In general, reimbursement is limited to situations in which the damage results from conditions beyond the individual s control or conditions determined to be Noblis responsibility. Reimbursement does not apply to losses resulting from theft or disappearance of an employee s or a third party s personal property. Claims are subject to investigation by the Noblis FSO. 3.5 Energy and Environmental Sustainability Noblis is sensitive to energy and environmental sustainability in the way Noblis does business every day, in every way. All employees are encouraged to conduct Noblis business in an environmentally friendly and sustainable manner that emphasizes green business practices.

8 Old Page 8 of 8 From the acquisition and use of green products and recyclable materials, to the delivery of professional services to clients, Noblis thoughtfully considers the energy and environmental impacts of Noblis and employee actions. Noblis drives environmental sustainability in the conduct of its business. As part of Noblis commitment to sustainability, it is Noblis goal to conduct business in a way that: conserves nature and the earth s resources; protects the workplace and the community; meets or exceeds legal requirements pertaining to sustainability; continuously improves Noblis energy efficiency. Noblis regularly monitors its operations and considers programs to improve its impact on the environment, including measuring and reducing Noblis carbon footprint. The Noblis Director of Facilities is responsible for the implementation of this policy. Employees may submit suggestions for improving Noblis impact on the environment to the Noblis Employee Suggestion Box located on the Compliance Page on the KNOW or by directly contacting the Noblis Director of Facilities. DEFINITIONS Additional terms and definitions required by this policy may be found in the QMS Manual. 5 RESPONSIBILITIES It is the responsibility of every employee to adhere to this policy. 6 RELATED DOCUMENTS Noblis Code of Ethics and Conduct Policy