Zero Tolerance Policy

Relay Ventures (the “Firm”) is committed to providing a work environment in which all workers, Entrepreneurs and other individuals are treated with respect and dignity.

The Firm recognizes that Workplace Violence and Workplace Harassment can arise from many sources, including Workers, managers, supervisors, customers, vendors, contractors and any other person present at a Workplace, including persons associated with a company or business in which any of the Firm’s funds under management has invested in or is considering investing in. Violence and harassment in the Workplace, in any form, whether by or against a Worker, or by a Worker against any other person in connection with work-related activities on behalf of the Firm, is unacceptable and will not be tolerated by the Firm.

In this regard, this policy applies to all Workers and extends to and includes all persons with whom a Worker is engaged in a working relationship on behalf of the Firm, including all persons associated with a former, existing or potential portfolio company investment, or where any working relationship on behalf of the Firm may otherwise be involved.

Definitions

As used in this policy:

“Worker” means persons who perform services for the Firm, including all employees, contractors, advisors, consultants and interns.

“Workplace” includes any place where Workers engage in Firm business, activities or social events.

“Workplace Harassment” means engaging in a course of vexatious comment or conduct against a Worker, or other person in connection with business on behalf of the Firm, in a Workplace that is known or ought reasonably to be known to be unwelcome or Workplace Sexual Harassment. Workplace Harassment may (but does not necessarily) relate to the prohibited grounds of discrimination as set out in applicable human rights legislation.

Note: Reasonable action taken by the Firm relating to the management and direction of Workers or the Workplace is not Workplace Harassment. This is the case even if there are sometimes unpleasant consequences for a Worker.

“Workplace Sexual Harassment” means:

1. Engaging in a course of vexatious comment or conduct against a Worker, or other person in connection with business on behalf of the Firm, in a Workplace because of sex, sexual orientation, gender identity or gender expression, where the course of comment or conduct is known or ought reasonably to be known to be unwelcome; or
2. Making a sexual solicitation or advance where the person making the solicitation or advance is in a position to confer, grant or deny a benefit or advancement to the Worker, or other person in connection with business on behalf of the Firm, and the person knows or ought reasonably to know that the solicitation or advance is unwelcome.

“Workplace Violence” includes:

1. The exercise of physical force by a person against a Worker, or other person in connection with business on behalf of the Firm, in the Workplace, that causes or could cause physical injury to the Worker or such person;
2. An attempt to exercise physical force against a Worker, or other person in connection with business on behalf of the Firm, in the Workplace, that could cause physical injury to the Worker or such person; and
3. A statement or behaviour that is reasonable for a Worker or other person, as applicable, to interpret as a threat to exercise physical force against the Worker or such person, in a Workplace, that could cause physical injury to the Worker or such person.

Workers Responsibilities

All Workers are responsible for ensuring that that their conduct in the Workplace is appropriate and that they do not engage in Workplace Harassment or Workplace Violence. Workers are also responsible for reporting incidents of Workplace Harassment or Workplace Violence that they witness or experience in accordance with this policy, whether involving another Worker or another person in connection with business on behalf of the Firm.

Complaint Process

Any Worker who believes that he or she is the subject of Workplace Violence and/or Workplace Harassment, or who has witnessed Workplace Violence and/or Workplace Harassment, is encouraged to report such incidents to the Worker’s manager as soon as possible after the incident. Alternatively, if the incident appears to have involved the Worker’s manager, the Worker should report such incident to a Managing Partner instead.

Complaints or information relating to Workplace Harassment and/or Workplace Violence may be made orally or in writing. When submitting a written complaint under this policy, the complaint should contain the following information (to the extent known by the Worker making the complaint): Name(s) of complainant(s) and contact information;

Name of person alleged to have committed the harassment, his or her position and contact information;

• Names of any witnesses or other persons with relevant information regarding the incident and contact information;
• Details of what happened including the date, frequency, and location; and
• Supporting documentation, if any, that the complainant has and a list of documentation the alleged harasser or witnesses may have.

Note: In the case of an emergency, where there is immediate danger, to a Worker, the Worker or anyone who witnesses the incident should call building security and/or 911 immediately.

Investigation Process

The Firm will ensure that all concerns, complaints or incidents of Workplace Violence and/or Workplace Harassment are investigated in an appropriate, fair and timely manner while respecting the privacy of its Workers as much as possible.

The Firm’s CFO will determine who will conduct the investigation into the incident or complaint under this policy. If necessary due to the nature of the incident or the individuals involved (for example, in the case of a complaint involving a Managing Partner), an external person qualified to conduct an impartial investigation will be retained to conduct the investigation.

The steps taken by the investigator will vary depending upon the nature of the allegations, but will generally involve private interviews with the Worker making the complaint, with the person alleged to have engaged in the inappropriate behaviour, and with any witnesses, as well as a review of any documents relevant to the complaint. The person alleged to have engaged in inappropriate conduct will be given the opportunity to respond to the specific allegations.

During the investigation, interim measures may be taken by the Firm. In addition, the Firm may choose to suspend the Worker alleged to have breached this policy. Within a reasonable period following the completion of the investigation, the Worker who made the complaint and the person against whom the complaint was made (if he or she is an employee of the Firm) will be informed in writing of the results of the investigation and any corrective action taken or that will be taken by the Firm.

The Firm will keep records of the investigation for 2 years.¹

¹ The following records be kept for at least two (2) years: (a) a copy of the complaint or details about the incident; (b) a record of the investigation including notes; (c) a copy of the investigation report (if any); (d) a summary of the results of the investigation that was provided to the Worker who allegedly experienced the Workplace Harassment/Workplace Violence and the alleged harasser, if a Worker of the employer; (e) a copy of any corrective action taken to address the complaint or incident.

Confidentiality

Information obtained about an incident or complaint of Workplace Harassment or Workplace Violence, including identifying information about any individuals involved, will be kept confidential to the extent possible and will not be disclosed unless disclosure is necessary to protect Workers, to investigate the complaint or incident, to take corrective action or otherwise as required by law.

All individuals involved in a complaint or investigation will be advised to keep all information related to the complaint, incident and investigation strictly confidential and not to discuss the incident or investigation with each other, witnesses or other parties (unless necessary to obtain advice about their rights).

Consequences of Non-Compliance

Instances of Workplace Violence and/or Workplace Harassment will not be tolerated. Any Worker who engages in Workplace Harassment or Workplace Violence will be subject to corrective action which, depending on the circumstances, may range from a warning up to and including termination of employment for cause without further notice.

Workers will not be penalized or disciplined for reporting in good faith an incident or for participating in an investigation involving Workplace Harassment and/or Workplace Violence. However, if the Firm believes that a false or malicious accusation of harassment or violence was knowingly made by a Worker, that Worker may also be subject to corrective action, up to and including termination of employment for cause without further notice.

Other Remedies

A Worker does not forfeit the right to pursue any other legal avenues that may be available by virtue of participating in the Firm’s investigatory process. For example, this policy does not prevent or discourage a Worker from filing an application with the Human Rights Tribunal, or any other applicable governmental agency, on a matter relating to applicable human rights legislation.

The Firm also reserves the right to take action as necessary for the protection of its Workers or its business without following the investigation process set out in this Policy.

Retaliation

Workers are protected by applicable law from retaliation for opposing unlawful discriminatory practices, for having in good faith reported instances of Workplace Harassment or Workplace Violence, for assisting another employee in reporting Workplace Harassment or Workplace Violence, or for otherwise participating in any investigation or legal proceeding. Retaliation will not be tolerated. Retaliation will result in discipline, up to and including termination for cause without further notice.

Relay Ventures Harassment Policy — July 17, 2017