Discrimination Policy

---

                              Policy Prohibiting Discrimination, Harassment, and Retaliation

                                         Company: World of Girls and Boys Leadership Inc.

                                                  Date of Implementation: January 1st, 2021

     The Company is committed to providing a safe, respectful, and lawful workplace that

promotes equality and is free of any form of discrimination, harassment, and retaliation.

In furtherance of this commitment, the Company has implemented this Policy Prohibiting

Discrimination, Harassment, and Retaliation.

This Policy prohibits all discrimination and harassment, including, but not limited to:

discrimination or harassment on the basis of sex (including pregnancy, childbirth or

related medical condition, or breastfeeding), gender, gender identity or expression

(including transgender identity or expression), sexual orientation, race, religious creed,

color, national origin, ancestry, physical disability, mental disability, protected medical

condition (including genetic characteristics), genetic information, marital status, age,

military or veteran status, citizenship status, and any other category protected by

applicable state or federal law.

The Company does not permit any instance of harassment, discriminatory conduct, or

retaliation by or towards anyone. Sexual harassment is considered a form of employee

misconduct and sanctions will be enforced against individuals engaging in sexual

harassment and against supervisory and managerial personnel who knowingly allow

such behavior to continue. Retaliation against individuals who complain of sexual

harassment or who testify or assist in any proceeding under the law is unlawful.

This Policy applies to all employees, including managers, officers, and directors, as well

as, if applicable, temporary staff, volunteers, or interns (all listed here will be collectively

referred to as). Employees are prohibited from harassment, discrimination, or retaliation towards other employees, independent contractors, vendors, suppliers, or any others doing business with the Company. Any employee in violation of this Policy will be subject to immediate and severe disciplinary action, up to and

including termination.

The Company also prohibits third parties doing business with the Company from

engaging in harassment, discriminatory conduct, or retaliation against its employees.

Employees who believe that they have been the victim of discrimination, harassment, or

retaliation from any third party doing business with the Company, such as the

Company''s independent contractors, vendors, suppliers, or others, should contact their immediate supervisor as soon as possible. Any complaints made in this regard will be dealt with in a prompt and confidential manner.

Training: All employees are required to undertake the Company comprehensive

training on discrimination, harassment, and retaliation. New employees will not be

permitted to begin in their roles until this training is complete. For any questions

regarding the training, please see your direct supervisor.

Sexual Harassment: Sexual harassment includes a range of conduct that is unwelcome

and offensive. Sexual harassment is conduct that is so pervasive or offensive that it

interferes with an employee performance. Sexual harassment is also conduct that

creates an intimidating or hostile environment.

Sexual harassment can be based on sex, gender, gender identity or expression, and

sexual orientation. Sexual harassment may include in-person interactions or those that

occur via text message or the Internet, and violations of this Policy are not only those

which occur on the Company physical premises or during working hours. Sexual

harassment can be physical or psychological.

A single instance of conduct that may, on its own, not be considered sexual harassment

can become so if several incidents are perpetrated against the same individual by the

same person or persons.

Sexual harassment can include any of the following examples (sexual harassment can

also be conduct that is not on the below list, which are intended as non-exhaustive

examples only):

- unwanted sexual comments, sexual advances, or propositions

- requests offered in exchange for benefit or advancement

- non-verbal conduct, such as sexual gestures or displaying suggestive visuals

- threatening an employee for rejecting sexual advances

- sending sexually suggestive or derogatory text messages, videos, emails, or social

media posts

- making degrading remarks about an individual, their body, or their gender, gender

identity, or gender expression

- sexual assault, including touching or groping

How to Make a Complaint: Employees who feel they have been subject to harassment

or discrimination are encouraged to document such conduct and should immediately

report the incident to their supervisor or, if the complaint is concerning their supervisor,

to a superior supervisor. 

Those acting on behalf of employer who have received a report of such conduct are advised to document everything thoroughly.  Employees can also file a complaint with a government agency or in court under federal, state or, local anti-discrimination laws.

If employees are not comfortable bringing a complaint to their supervisor or someone

directly above their supervisor, employees may report to any senior member of the

Company they feel comfortable with. Employees should be aware, however, that the

senior member they report to may bring the complaint to employee's direct supervisor or other senior employees in the Company.

The Company encourages all employees to report violations of this Policy, no matter

against whom. No individual member of the Company is exempt from this Policy.

Investigation: The Company will promptly and thoroughly investigate all complaints

reported under this Policy. The investigation will be completed in a timely manner.

Investigations may involve interviews, examination of physical evidence, and the

involvement of qualified personnel to assist, such as Human Resources or Legal

Counsel.

The investigation will be kept confidential and disclosed only on a need-to-

know basis. Please note, however, that the respondent may be made aware of the

complainant's identity. The Company will also keep a record of the investigation,

including documenting all interviews and evidence, so that the complainant may track its progress.

Upon completion of the investigation, the Company will take any action deemed fit,

based on the evidence collected, including termination of the offending employee or

reports to law enforcement.

If the Company finds that the behavior does not rise to the level of legally-actionable

discrimination or harassment, but may do so if left unchecked, the Company will respond

appropriately.

If any employee reporting a complaint under this section believes the Company's

response has not been adequate, that employee may involve law enforcement as they

deem necessary in their sole and exclusive discretion.  Additional Recourse: Sexual harassment is not only prohibited by the Company but is also prohibited by state, federal, and, where applicable, local law.

Along with or instead of filing a complaint with the Company, employees may choose to

pursue legal remedies with the following governmental entities.  State Human Rights Law (HRL) - The Human Rights Law (HRL), codified as N.Y.Executive Law, art. 15, § 290 et seq., applies to all employers in New York State with regard to sexual harassment, and protects employees, paid or unpaid interns and non-employees, regardless of immigration status. A complaint alleging violation of the Human Rights Law may be filed either with the Division of Human Rights (DHR) or in New York State Supreme Court.

Civil Rights Act of 1964 - The United States Equal Employment Opportunity

Commission (EEOC) enforces federal anti-discrimination laws, including Title VII of the

1964 federal Civil Rights Act (codified as 42 U.S.C. § 2000e et seq.). An individual can

file a complaint with the EEOC anytime within 300 days from the harassment.

Local Protections - Employees can also contact the county, city, or town in which they

live to find out if additional laws against sexual harassment or discrimination may be

applicable.

If the employee has been subject to unwanted physical contact, coerced physical

confinement or coerced sex acts, the conduct may constitute a crime. You may also

contact your local police department.

Anti-Retaliation Policy: The Company prohibits retaliation against any employee who

has reported a violation under this Policy, any employee who has participated in an

investigation that came about as a result of a reported violation, or the family member of

any such employee. Retaliation is prohibited for the following (by way of example only):

- Filing a complaint with the Company

- Filing a complaint with a government agency

- Testifying in any capacity

- Cooperating or participating in a government agency & investigation

Communication: It is critical that all Employees communicate with the Company

regarding any instances of discrimination, harassment, or retaliation. We are only able to

assist Employees if we are made aware of the problem. It is your responsibility to bring

these concerns to us.

No Limitation: Nothing in this Policy is designed to replace or limit any legal rights

employees may have to seek remedies under applicable law or rule.