Friends of Cypress Waters Trail

Equity Statement

Equal Employment Opportunity, Non-Discrimination, and Non-Harassment Policy

Non-Discrimination

Billingsley is an equal opportunity employer and does not unlawfully discriminate against employees and applicants for employment based on race, color, sex (including childbirth, pregnancy, or pregnancy related conditions), gender, gender identity or expression, sexual orientation, religion, national origin, citizenship status, age, genetic information, physical or mental disability of an otherwise qualified individual, active military or veteran status, engaging in legally protected activity, or any other characteristic protected under applicable federal, state, or local law. Billingsley also provides reasonable accommodation to applicants and employees in accordance with applicable law. Subject to Billingsley’s legitimate business requirements, all personnel actions, such as recruitment, hiring, training, promotion, transfer, layoff, recall, compensation and benefits, discipline, termination, and educational, recreational, and social programs, are based solely on an individual’s qualifications, merit, and performance. No person is authorized to act in a manner contrary to this commitment to nondiscrimination.

Non-Harassment

Billingsley is fully committed to providing a workplace free from offensive or harassing conduct. To meet that commitment, Billingsley depends on all employees to conform their conduct to its expectations of a harassment-free work environment and to cooperate with investigations of non- compliance with this policy.

Harassment on the basis of race, color, sex (including childbirth, pregnancy, or pregnancy-related conditions), gender, gender identity or expression, sexual orientation, religion, national origin, age, physical or mental disability, genetic information, citizenship status, active military or veteran status, engaging in legally protected activity, or any other characteristic protected under applicable federal, state or local law will not be permitted or condoned.

Slurs, insults, or stereotypical comments related to those characteristics are wholly inappropriate, violate this policy, and may also violate applicable federal, state, or local laws.

In addition, certain types of conduct intended to be inoffensive social exchanges may be perceived as offensive and may be used as a basis for a harassment claim on any of the above grounds. Such conduct does not necessarily violate the law. Rather, all employees should be aware that certain conduct holds the potential for supporting claims of harassment even if no offense was intended. Conduct that may be appropriate or inoffensive in a purely social setting may be wholly inappropriate or offensive in a work setting.

Sexual harassment is a form of sex discrimination prohibited by this policy and applicable federal, state, and local law. Sexual harassment means any harassment based on someone's sex or gender. It includes unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature by an employee or supervisor when (i) submission to the conduct is made either explicitly or implicitly a term or condition of an individual’s work; (ii) submission to or rejection of the conduct by an individual is used as the basis or as a threatened basis for work decisions affecting that individual; or (iii) the conduct has the purpose or effect of unreasonably interfering with an individual’s work performance, creating an intimidating, hostile, or offensive work environment, or otherwise adversely affecting an individual’s work opportunities. It does not matter whether the harasser and the employee to whom the harassment is directed are of the same or opposite sex.

Racial harassment is a form of race discrimination prohibited by this policy and the law. It includes racial jokes or remarks, insults relating to race, and race related words or actions that interfere with a person’s work performances or create an intimidating, hostile, or offensive work environment.

It is not practical to list all the specific types of conduct that might violate this policy or the law. Some conduct, however, is strictly prohibited by this policy whether or not the conduct is directed at or offends others:

• Offensive or unwelcome sexual flirtations, advances, or propositions; demands for sexual favors.

• Physical assaults or offensive touching of a sexual nature.

• Verbal abuse of a sexual, racial, or ethnic nature, or concerning religion, age, disability, or any other legally protected characteristic.

• Slurs or epithets based on sex, race, ethnicity, religion, age, disability or any other legally

protected characteristic.

• Degrading or abusive stereotypes based on sex, race, ethnicity, religion, age, disability, or any other legally protected characteristic.

• Graphic verbal commentaries about an individual’s body or dress.

• Degrading or hostile words used to describe an individual or his or her personal characteristics based on sex, race, ethnicity, religion, age, disability, or any other legally protected characteristic.

• The workplace display, distribution (such as by email), or accessing (such as through the Internet) of racially or sexually explicit, graphic, suggestive, offensive, or demeaning jokes, cartoons, photographs, images, books, magazines, or objects based on sex, race, ethnicity, religion, age, disability, or any other legally protected characteristic.

• Hostile, derogatory, or offensive comments or communications based on sex, race, ethnicity, religion, age, disability, or any other legally protected characteristic; or

• Acts of physical and/or verbal aggression, intimidation, hostility, or unequal treatment based on sex, race, ethnicity, religion, age, disability, or any other legally protected characteristic.

No person has the authority to condition employment or continued employment, advancement, or other terms and conditions of employment or association with Billingsley on the submission to sexual advances or acceptance of conduct that violates this policy, whether the promised or threatened conduct would favorably or adversely affect the person involved.

Complaint Procedure

Complaints concerning any violation or possible violation of this policy (even if the complainant is not or does not perceive themselves to be a victim) should be reported immediately to Human Resources. If an employee believes that a complaint of this nature has not been or cannot be addressed by Human Resources for any reason, the employee should contact an Officer of the Company.

No employee who in good faith reports an alleged violation of this policy in an appropriate manner or who in good faith participates in an investigation of a complaint will be subject to any adverse employment action for filing a complaint or participating in an investigation. Billingsley recognizes, however, that false accusations of harassment or other unlawful behavior can be damaging to an accused employee and disruptive to Billingsley’s operations. Thus, knowingly made false accusations may be misconduct for which disciplinary action, up to and including termination of employment, may be imposed. If you believe that you have suffered an adverse action because of having made a complaint or participated in an investigation, you should immediately report the issue using the complaint procedure described above.

Investigation Procedure

In response to a complaint, Billingsley will take appropriate action, which may involve interviewing the person who reported the conduct, the person who is reported to have engaged in the conduct, and witnesses, if applicable. All employees must cooperate fully with and assist Billingsley in any investigation. While the process may vary from case to case, the investigation process may also include the following:

• Take interim measures as appropriate, depending on the nature of the allegations (e.g., instructing the respondent to refrain from communications with the complainant).

• Take steps to obtain and preserve documents, emails, or phone records if they are relevant to the investigation.

• Request and review all relevant documents, including all electronic communications.

• Notify the individual who reported and the individual(s) about whom the complaint was made of the final determination and implement any corrective actions identified in the written document.

If the Company determines that there has been a violation of this policy, the Company will take corrective action, up to and including termination of employment.

The investigation will be conducted in such a way as to maintain confidentiality to the extent practicable under the circumstances. While confidentiality cannot be guaranteed, all actions taken to investigate and resolve complaints will be conducted with as much privacy and discretion as possible without compromising the thoroughness and fairness of the investigation. All individuals involved are to treat the situation with respect.

Disciplinary Action

This policy covers all employees and members of management. Any person found to have violated this policy will be subject to appropriate disciplinary action, up to and including termination of employment.

Application

This policy applies to all employees, at all Billingsley premises, and at all other locations where a Billingsley employee is performing services on behalf of the Company. All employees are expected to comply with this policy in their interactions with the Company’s business partners, customers, vendors, and visitors. All business partners, customers, vendors, and visitors are expected to comply with this policy when on Company premises and in their interactions with Company personnel. “Premises” includes all work locations and all events sponsored by the Company at other locations.

No Retaliation

Any employee may be required to cooperate as needed in an investigation of alleged unlawful harassment, discrimination, or sexual harassment. Billingsley will not tolerate retaliation against employees who, in good faith, file complaints, support another’s complaint or participate in an investigation regarding a violation of this policy. Retaliation against individuals who, in good faith, report harassment or discrimination or who assist in an investigation of alleged harassment or discrimination is unlawful and expressly prohibited by the Company. Reports of retaliation will be investigated, and individuals found to have violated the prohibition on retaliation will be subject to corrective action, up to and including separation of employment with the Company.