SCFHC believes in respecting the dignity of every employee and expects every employee to show respect for all our  employees, clients, vendors and other third parties with whom we do business. Respectful, professional conduct  furthers the Company’s mission, promotes productivity, minimizes disputes, and enhances our reputation.  

SCFHC is committed to providing a workplace free of discrimination, harassment and retaliation in all forms, including  sexual harassment and harassment based on race (and traits historically associated with race, including, but not limited  to, hair texture and protective hairstyles), religious creed (including religious dress and grooming practices), color,  national origin, ancestry, physical disability, mental disability, reproductive health decision-making, medical condition,  genetic information, marital status, sex (including pregnancy, childbirth, breastfeeding, and related medical conditions),  gender, gender identity, gender expression, age (40 and over), sexual orientation, veteran or military status, or any  other legally recognized protected basis under federal, state or local laws, regulations or ordinances.  

This policy applies whether the individual has or is perceived to have any of the characteristics protected by law or is  associated with a person who has or is perceived to have any of the characteristics protected by law.  

This policy extends to all employees, supervisors, temporary employees, leased employees, independent contractors,  volunteers, vendors, customers, clients, and other professional service providers. Furthermore, it prohibits harassment  in any form including verbal, non-verbal and physical harassment.  

SCFHC will not tolerate harassment of any individuals by co-workers, supervisors, managers, third parties or non employees. In keeping with this commitment, all employees of the Company are responsible for assuring that the  workplace is free of harassment. This policy prohibits harassment of any kind, including sexual harassment, and applies  to all employees of the Company. The Company prohibits all employees from sexually harassing co-workers, clients,  customers, vendors, suppliers, independent contractors and others doing business with the Company. In addition, the  Company prohibits clients, customers, vendors, suppliers, independent contractors and others doing business with the  company from sexually harassing the Company’s employees.  

Sexual harassment and other unlawful forms of harassment may take many forms, but the most common forms include:  

any racial, ethnic, and/or religious group(s); and/or verbal abuse or insults directed to or made in the presence  of any member of a racial, ethnic, or minority group; 

effectiveness of any Employee;  

because of sex, race or any other protected basis; o Unwelcome sexual advances, request(s) for sexual favors  and other verbal and/or physical contact that may be sexual in nature. Sexual harassment undermines the  employment relationship by creating an intimidating, hostile or offensive work environment and will not be  tolerated.  

Unwanted sexual advances;  

Offering employment benefits in exchange for sexual favors; 

Making or threatening reprisals after a negative response to sexual advances;  

Visual conduct, including leering, making sexual gestures, displaying of sexually suggestive  objects or pictures, cartoons or posters;  

Verbal conduct, including making or using derogatory comments, epithets, slurs, and jokes;  Verbal sexual advances or propositions;  

Verbal abuse of a sexual nature, graphic verbal commentaries about an individual’s body,  

sexually degrading words used to describe an individual, suggestive or obscene letters, notes or  invitations;  

Using nicknames or terms of endearment with a racial or sexual connotation.  

Examples of sexual harassment include, but are not limited to: (a) an Employee being fired or denied a job or an  employment benefit because the Employee refused to grant sexual favors or because the employee complained about  the harassment; or (b) an Employee being exposed to a hostile work environment. It should be noted that sexually harassing conduct need not be motivated by sexual desire.  

1.1.1 Abusive Conduct  

Abusive conduct also violates this policy.  

Examples of abusive conduct may include:  

Repeated infliction of verbal abuse, such as the use of derogatory remarks, insults and epithets;  Verbal or physical conduct that a reasonable person would find threatening, intimidating or  humiliating; or  

The gratuitous sabotage or undermining of a person’s work performance.  

Managers and supervisors are prohibited from providing favorable treatment to Employees with  whom they are involved in a consensual sexual relationship.  

1.1.2 Corrective Action  

In order to maintain a positive and productive work environment, each SCFHC Manager, Supervisor and/or Human  Resources, shall promptly take the necessary action to halt any harassment of which the employee may become aware  by enforcing and reminding other personnel of SCFHC policy, when appropriate SCFHC will direct disciplinary action up  to and including termination for violating this policy.  

Supervisors and managers have an obligation to report sexual harassment and other forms of harassment,  discrimination, or retaliation of which they become aware. Supervisors and managers who observe such conduct or who  receive any complaints of such misconduct must report the conduct or complaint to the Human Resources department  so that an investigation can be made and corrective action taken, if appropriate.  

1.1.3 Discrimination and Harassment Complaint Procedure  

Any individual who believes has been subjected to discrimination or harassment from either a co-worker or a Supervisor  must advise the offender that such behavior is offensive and should immediately report the incident, either orally or in writing, to the appropriate Manager/Supervisor, Corporate Compliance Officer and/or Human Resources. The complaint  should include detail(s) of incident(s), names of individuals involved, if any, and names of any witnesses.  

Any and all allegation(s) of discrimination or harassment will be immediately investigated by the Compliance  Department and/or Human Resources Department. It is important for any Employee who believes that has been  harassed to immediately report any incident(s) to his/her immediate Supervisor and/or management.  

Any individual who wishes to speak with management personnel (other than his/her Manager/Supervisor or a  representative of Human Resources) may request a meeting with the CEO, who will designate someone to conduct an  independent inquiry into any allegation(s) of discrimination and/or harassment.  

1.1.4 Formal Investigation  

When SCFHC receives a complaint of misconduct pursuant to this policy, it will provide the complaining individual with a  timely response acknowledging the complaint. The Company will then conduct a fair, timely and thorough investigation  that provides all parties appropriate due process and reaches reasonable conclusions based on the evidence collected.  All investigations will be conducted by impartial and qualified personnel. If no such impartial and qualified person is  available within the Company to conduct an investigation, or if there is a conflict of interest involving the Company’s in house investigator or the appearance of a conflict of interest, the Company may retain the assistance of an outside  investigator who is qualified to conduct workplace investigations pursuant to applicable law. Confidentiality will be kept  by the Company to the extent possible, but no investigation will be completely confidential. All investigations will take  appropriate measures to document and track the reasonable progress of the investigation, and to ensure a timely  closure to the investigation.  

The Company will inform the complainant and the accused of the results of the investigation. If, at the end of the  Company’s investigation, misconduct is found, appropriate remedial measures shall be taken in accordance with the  circumstances involved. If the Company determines that an employee has violated the policy against harassment,  discrimination and retaliation, the employee will be subject to appropriate disciplinary action, up to and including  termination. With regards to acts of misconduct by customers, vendors or other third parties, corrective action will be  taken after consultation with the appropriate management personnel.  

1.1.5 Prohibition Against Retaliation  

SCFHC will not tolerate retaliation against any individual for cooperating in an investigation or for making a  complaint. 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 up to and including termination of employment.  

External Complaints  

In addition to notifying the Company about harassment, discrimination and retaliation complaints, employees may also  direct their complaints to the federal Equal Employment Opportunity Commission (EEOC) (1-800-669-4000) or the  California Civil Rights Department (1-800-884- 1684), which have the authority to conduct investigations of the facts.