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APPENDIX 1 - Anti-discrimination and Anti-harassment Policy

Purpose

Kenyon is committed to providing an environment which is conducive to work, safe and free from discrimination and harassment. It is the Company’s policy to treat everyone in Kenyon and everyone with whom we come into contact with respect, fairness and dignity.

Application

This policy applies to all employees of Kenyon.

Rights and responsibilities of employees

All employees are entitled to:

• recruitment and selection decisions based on merit and not affected by irrelevant personal characteristics
• training, task allocation and promotion
• work free from discrimination and harassment
• the right to raise complaints in a reasonable and respectful manner

All employees are entitled to:

• treat everyone with dignity, courtesy and respect
• be empathetic and offer support to others who experience discrimination or harassment

Medical tests

• Kenyon does not require any employee to undertake medical tests except where required by the Ministry of Manpower and/or other governmental authorities or where required as a safety measure before working in a particular environment
• Employee will be notified if a test is required and the reason such test will be explained to the employee. The employee will have to provide consent for the test. The original results of tests will be returned to the employee for his safe keeping
• If a medical test is required the test fees shall be borne by Kenyon
• The original results of tests will be returned to the employee for his safekeeping
• Unless required by law, Kenyon will not keep copies of medical reports

Additional responsibilities of managers and supervisors

Managers and supervisors must also:

• ensure that recruitment decisions are based on merit; the skills and abilities of the candidates as measured against the requirements of the position
• take steps to educate employees on their obligations under this policy and the law
• intervene quickly and appropriately when they become aware of inappropriate behavior
• act fairly to resolve issues and enforce behavioral standards, ensuring all relevant parties are heard
• ensure employees who raise an issue or make a complaint are not retaliated against

Unacceptable workplace conduct

Any employees found to have engaged in inappropriate conduct may be counseled, warned or disciplined. Severe or repeated breaches can lead to formal discipline up to and including dismissal.

Discrimination

Discrimination is treating, or proposing to treat, someone unfavorably because of a personal characteristic including but not limited to:

• race
• color
• age
• sex
• religion
• sexual orientation
• marital status
• political opinion
• medical record

Harassment

Harassment includes jokes, teasing, emails, pictures, text messages, unconstructive criticism, sarcasm or demeaning language, ignoring people, or unfair work practices. It can be physical, spoken or written and can cause distress, intimidate or humiliate another party. It can happen at work or outside of work.

Just because a person does not object to inappropriate behavior at the time, does not mean that he/she is consenting to the behavior.

The Company recognizes that comments and behavior that may not offend one person can offend another. This policy therefore requires all employees to respect other people’s limits.

Resolving issues at Kenyon

The Company strongly encourages any employee who believes he has been discriminated against or harassed to take appropriate action by requesting a copy of the Company’s whistle blower policy and following the procedure outlined within to make a report. The complaint hierarchy is described below:

Alternatively, the employee may choose to send a message to report@kenyon.com.sg. All reports shall be kept confidential and investigated following the process listed in the company’s whistle blower policy. Employees are assured that they shall not be punished for making reports in good faith.

On the other hand, all employees should be reminded that knowingly making a false report of discrimination or harassment can in turn lead to disciplinary action, including dismissal.