TRANSFORM VC Policy & Code of Conduct Against Harassment

Anyone engaging with or on behalf of TRANSFORM VC in any manner—including managers, employees, visitors, entrepreneurs, clients, customers, and vendors—is required to adhere to—and should expect to receive the protections of—this policy to ensure a safe, respectful, and inclusive environment for all.

We do not tolerate harassment. To report an issue or concern, please contact us by email: [email protected]

STATEMENT OF POLICY

TRANSFORM VC is committed to providing a workplace free of sexual or other unlawful harassment. As part of this commitment, TRANSFORM VC strictly prohibits harassment of employees in the workplace based on race, color, religion, religious creed, national origin, ancestry, age, sex, gender, gender identity or expression, physical disability, mental disability, medical condition, genetic information, marital status, sexual orientation, family care or medical leave status, veteran or military status, or any other basis protected by federal or state laws.

Consistent with state and federal law, this anti-harassment policy applies to all employees of TRANSFORM VC, including managers, supervisors, and co- employees. This policy also applies to non- employees at the workplace or interacting outside the workplace with our employees on TRANSFORM VC related business—including but not limited to entrepreneurs, visitors to our facilities, clients, customers, and vendors. As such, TRANSFORM VC will attempt to protect employees from any third person in the workplace who it knows or should have known is violating this policy. Similarly, TRANSFORM VC will not tolerate harassment by its employees of non-employees with whom TRANSFORM VC has a business, service, or professional relationship, which, for the avoidance of doubt, includes entrepreneurs with whom we are evaluating the establishment of an investment relationship.

DEFINITION OF HARASSMENT

Harassment occurs when conduct interferes with an employee’s work performance or creates an intimidating or offensive work environment, based upon an employee’s race, color, religion, religious creed, national origin, ancestry, age, sex, gender, gender identity or expression, physical disability, mental disability, medical condition, genetic information, marital status, sexual orientation, family care or medical leave status, veteran or military status, or any other basis protected by federal or state laws. Harassing conduct can take many forms and may include, but is not limited to, the following: slurs, jokes, statements, gestures, assault, impeding or blocking another’s movement or otherwise physically interfering with normal work, pictures, drawings, and/or cartoons.

Sexual harassment in particular may include all of the above mentioned prohibited actions, as well as other unwelcome conduct, such as requests for sexual favors, conversations containing sexual comments, and unwelcome sexual advances, when:

  1. submission to the conduct is made either an explicit or implicit condition of employment or business;

  2. submission or rejection of the conduct is used as the basis for an employment or business decision; or

  3. the harassment has the purpose or effect of unreasonably interfering with an employee’s work performance or creates an intimidating, hostile or offensive work environment.

Harassment based on gender, pregnancy, childbirth or related medical conditions may also constitute sexual harassment. Sexually harassing conduct can be by a person of either the same or opposite gender, and need not be motivated by sexual desire.

REPORTING HARASSING CONDUCT

To report an issue or concern, please contact TRANSFORM VC by email: [email protected]

Reports will be reviewed promptly and handled in confidence, as well as investigated and/or otherwise escalated and acted upon as appropriate.

CORRECTIVE ACTION

If TRANSFORM VC determines that harassment has occurred, effective remedial action will be taken in accordance with the circumstances involved. Any employee determined by TRANSFORM VC to be responsible for discrimination or harassment in violation of this policy will be subject to appropriate disciplinary action, up to and including termination. Because a hostility-free work environment is so important, TRANSFORM VC may take disciplinary action against an employee who exhibits poor judgment or engages in inappropriate behavior, even if it falls short of being severe or pervasive.

 

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