Nondiscrimination/Anti-Harassment Policy

and Complaint Procedure

Objective

Blount Fine Foods is committed to a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore, Blount Fine Foods expects that all relationships among persons in the office will be business-like and free of explicit bias, prejudice and harassment. Blount Fine Foods has developed this policy to ensure that all its employees can work in an environment free from unlawful harassment, discrimination and retaliation. Blount Fine Foods will make every reasonable effort to ensure that all concerned are familiar with these policies and are aware that any complaint in violation of such policies will be investigated and resolved appropriately.

Any employee who has questions or concerns about these policies should talk with the Human Resources department.

These policies should not, and may not, be used as a basis for excluding or separating individuals of a particular gender, or any other protected characteristic, from participating in business or work-related social activities or discussions. In other words, no one should make the mistake of engaging in discrimination or exclusion to avoid allegations of harassment. The law and the policies of Blount Fine Foods prohibit disparate treatment on the basis of sex or any other protected characteristic, with regard to terms, conditions, privileges and prerequisites of employment. The prohibitions against harassment, discrimination and retaliation are intended to complement and further those policies, not to form the basis of an exception to them.

Equal employment opportunity

It is the policy of Blount Fine Foods to ensure equal employment opportunity without discrimination or harassment on the basis of race, color, religion, sex, sexual orientation, gender identity or expression, age, disability, marital status, citizenship, national origin, genetic information, or any other characteristic protected by law. Blount Fine Foods prohibits any such discrimination or harassment.

Retaliation Blount Fine Foods encourages reporting of all perceived incidents of discrimination or harassment. It is the policy of Blount Fine Foods to promptly and thoroughly investigate such reports. Blount Fine Foods prohibits retaliation against any individual who reports discrimination or harassment or participates in an investigation of such reports.

Sexual harassment Sexual harassment constitutes discrimination and is illegal under federal, state and local laws. For the purposes of this policy, “sexual harassment” is defined, as in the Equal Employment Opportunity Commission Guidelines, as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when, for example: a) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment, b) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or c) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.

Title VII of the Civil Rights Act of 1964 recognizes two types of sexual harassment: a) quid pro quo and b) hostile work environment. Sexual harassment may include a range of subtle and not- so-subtle behaviors and may involve individuals of the same or different gender. Depending on the circumstances, these behaviors may include unwanted sexual advances or requests for sexual favors; sexual jokes and innuendo; verbal abuse of a sexual nature; commentary about an individual’s body, leering, whistling or touching; insulting or obscene comments or gestures; display in the workplace of sexually suggestive objects or pictures; and other physical, verbal or visual conduct of a sexual nature.

Harassment

Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal, written or physical conduct that shows hostility or aversion toward an individual because of his or her race, color, religion, sex, sexual orientation, gender identity or expression, national origin, age, disability, marital status, citizenship, genetic information, or any other characteristic protected by law, or that of his or her relatives, friends or associates, and that: a) has the purpose or effect of creating an intimidating, hostile or offensive work environment, b) has the purpose or effect of unreasonably interfering with an individual’s work performance, or c) otherwise adversely affects an individual’s employment opportunities. Harassing conduct includes epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; degrading jokes; and written or graphic material that shows hostility or aversion toward an individual or group that is placed on walls or elsewhere on the employer’s premises or circulated in the workplace, on company time or using company equipment by e-mail, phone (including voice messages), text messages, social networking sites or other means.

Individuals and Conduct Covered

These policies apply to all applicants and employees, whether related to conduct engaged in by fellow employees or by someone not directly connected to Blount Fine Foods (e.g., an outside vendor, consultant or customer).

Conduct prohibited by these policies is unacceptable in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business- related social events.

Reporting an Incident of Harassment, Discrimination or Retaliation

Blount Fine Foods encourages reporting of all perceived incidents of discrimination, harassment or retaliation, regardless of the offender’s identity or position. Individuals who believe that they have been the victim of such conduct should discuss their concerns with their immediate supervisor, and the human resources department. See the complaint procedure described below. In addition, Blount Fine Foods encourages individuals who believe they are being subjected to such conduct to promptly advise the offender that his or her behavior is unwelcome and to request that it be discontinued. Often this action alone will resolve the problem. Blount Fine Foods recognizes, however, that an individual may prefer to pursue the matter through complaint procedures.

Complaint Procedure

Individuals who believe they have been the victims of conduct prohibited by this policy or believe they have witnessed such conduct should discuss their concerns with their immediate supervisor, and human resources.

Blount Fine Foods encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken before relationships become irreparably strained. Therefore, while no fixed reporting period has been established, early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment.

Any reported allegations of harassment, discrimination or retaliation will be investigated promptly. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge.

Blount Fine Foods will maintain confidentiality throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action.

Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of a claim of harassment or discrimination is a serious violation of this policy and, like harassment or discrimination itself, will be subject to disciplinary action. Acts of retaliation should be reported immediately and will be promptly investigated and addressed.

Misconduct constituting harassment, discrimination or retaliation will be dealt with appropriately. Responsive action may include, for example, training, referral to counseling or disciplinary action such as a warning, reprimand, withholding of a promotion or pay increase, reassignment, temporary suspension without pay, or termination, as Blount Fine Foods believes appropriate under the circumstances.

If a party to a complaint does not agree with its resolution, that party may appeal to Blount Fine Foods’s Senior Director of Corporate HR or Executive Vice President.

False and malicious complaints of harassment, discrimination or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) may be the subject of appropriate disciplinary action

Legal Remedies

Harassment is unlawful under United States federal and state law. The federal agency that enforces the law is the Equal Employment Opportunity Commission (EEOC).

EEOC’s Massachusetts office location:
Boston Area Office
John F. Kennedy Federal Building
Government Center
4th Floor, Room 475
Boston, MA 02203
Phone: (617)-565-3200

The state agency that enforces the law is the Massachusetts Commission Against Discrimination (MCAD) in Massachusetts and the Commission for Human Rights in Rhode Island. The offices are located at:

EEOC’s Massachusetts office location:
Massachusetts Commission Against Discrimination (MCAD)
One Ashburton Place
6th Floor, Room 601
Boston, MA 02108
Phone: (617)-994-6000
http://www.state.ma.us/mcad/

EEOC’s Rhode Island office location:
Rhode Island Commission for Human Rights
180 Westminster Street, 3rd Floor
Providence, RI 02903
Phone: (401)-222-2661
http://www.richr.state.ri.us/frames.html

The state agency that enforces the law is Bureau of Labor & Industries (BOLI) in Oregon and the Dallas District Office in Texas. The offices are located at:

EEOC’s Oregon office location:
Bureau of Labor & Industries (BOLI)
800 NE Oregon Street, Suite 1045
Portland, OR 97232
Phone: (971)-673-0761
https://www.oregon.gov/boli/civil-rights

EEOC’s Texas office location:
Dallas District Office
207 S. Houston Street, 3rd Floor
Dallas, TX 75202
Phone: (972)-918-3580
https://www.eeoc.gov/field-office/dallas/location

Employees who wish to file formal charges of harassment can contact either the federal or state agency where they work, or both of these government agencies. However, the Company is committed to responding quickly and effectively to any report of harassment and encourages employees to come forward and allow us to pursue a resolution of the matter internally. We believe that we have created a flexible and fair complaint resolution process, and that we will be able to work together to avoid the unnecessary escalation of any situation, which has created a sexually offensive work environment for any employee