LAST UPDATED 27 APRIL2025

Equal Opportunity, Anti-Harassment, and Workplace Behaviour Policy

1. Purpose

Bale Capital is committed to providing a safe, respectful, inclusive, and equitable workplace. This Policy outlines our expectations for workplace conduct and sets out our commitment to:

  • Equal opportunity in employment

  • A work environment free from harassment, bullying, and discrimination

  • Professional and respectful interpersonal behaviour

This document combines our Equal Opportunity Policy, Anti-Harassment Policy, and Workplace Behaviour Policy into one comprehensive framework.

2. Scope

This Policy applies to:

  • All Bale Capital employees, directors, and officers

  • Contractors, consultants, interns, and temporary workers

  • Third parties interacting with Bale Capital personnel (e.g. clients, suppliers)

It applies to all work-related activities, whether conducted on-site, off-site, during work hours, or at work-sponsored events.

3. Equal Opportunity Commitment

Bale Capital is an equal opportunity employer. We recruit, hire, train, and promote individuals based on merit and capability. We do not tolerate discrimination on the basis of:

  • Race, colour, nationality, or ethnic origin

  • Gender, sex, sexual orientation, or gender identity

  • Marital, parental, or family status

  • Age or disability

  • Religion or belief

  • Political or trade union affiliation

  • Any other attribute protected under applicable law

All employment decisions must be fair, consistent, and based solely on lawful and non-discriminatory criteria.

4. Workplace Behaviour Standards

We expect all individuals to maintain high standards of professional behaviour. This includes:

  • Treating colleagues, clients, and stakeholders with courtesy, respect, and dignity

  • Cooperating with others and promoting a collaborative workplace culture

  • Acting honestly and ethically in all interactions

  • Respecting cultural, gender, and individual differences

  • Communicating professionally and constructively, including in emails and digital platforms

Unacceptable workplace behaviour includes but is not limited to:

  • Aggressive, rude, or abusive conduct

  • Undermining, gossiping, or exclusionary behaviour

  • Intimidation, humiliation, or threats

  • Deliberate misuse of authority or position

5. Harassment and Bullying

Bale Capital strictly prohibits all forms of harassment, sexual harassment, and workplace bullying. This includes conduct that:

  • Is unwelcome, offensive, or demeaning

  • Creates an intimidating, hostile, or humiliating environment

  • Interferes with work performance or wellbeing

Examples of Prohibited Conduct:

  • Unwanted physical contact or advances

  • Sexually suggestive comments, jokes, or images

  • Derogatory remarks based on personal attributes

  • Repeated insults, exclusion, or public criticism

  • Threatening gestures or physical intimidation

Such conduct may be verbal, physical, visual, written, or online.

6. Responsibilities

All employees and representatives must:

  • Treat others with respect and fairness

  • Not engage in any discriminatory, harassing, or bullying behaviour

  • Report incidents or concerns in accordance with this Policy

  • Cooperate fully in investigations

Managers and supervisors have additional responsibilities to:

  • Lead by example and foster a respectful workplace culture

  • Respond promptly and appropriately to misconduct

  • Ensure staff understand their obligations under this Policy

  • Escalate reports of serious misconduct to the Compliance or HR Officer

7. Reporting and Complaints

Any individual who believes they have been subjected to discrimination, harassment, bullying, or other inappropriate behaviour may:

  • Speak directly to the person involved if safe to do so

  • Report the matter to their manager or the HR/Compliance Officer

  • Use the confidential reporting mechanism

All complaints will be taken seriously and investigated fairly, confidentially, and without bias.

8. Protection Against Retaliation

Bale Capital strictly prohibits retaliation against any person who:

  • Makes a complaint in good faith

  • Participates in an investigation

  • Supports another individual raising concerns

Any act of reprisal will be treated as a serious breach of this Policy and may result in disciplinary action.

9. Consequences of Breach

Breach of this Policy may lead to:

  • Formal warnings

  • Suspension or termination of employment or engagement

  • Reporting to external regulatory or enforcement bodies (if required)

Third-party service providers or suppliers who breach this Policy may have their contracts reviewed or terminated.

10. Training and Communication

All staff will receive regular training on workplace behaviour, equal opportunity, and anti-harassment obligations. This Policy will be:

  • Communicated at induction

  • Accessible via the Company’s internal systems or website

  • Referenced in contractor and supplier onboarding processes

11. Review and Continuous Improvement

This Policy will be reviewed annually or as needed to reflect legal developments, feedback, and evolving best practices. Updates will be communicated to all personnel.

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