Complaint Procedure

Any individual who believes that they or another individual has been subjected to discrimination, sexual harassment, any other form of prohibited harassment or retaliation should, as soon as possible, report it to their supervisor, People Business Partner, or any member of management with whom the employee feels comfortable; or report the matter through our anonymous third-party vendor, Work Shield, by completing an Incident Report Form online, verano.workshieldportal.com, or they may also call the 24/7 toll-free Call Center at 866.946.5558. If the employee makes a complaint under this policy and has not received a satisfactory response, the employee should contact their local People Business Partner.

Employees are not required to report any prohibited conduct to a supervisor or manager who may be hostile, who has engaged in such conduct, who is a close associate of the person who has engaged in such conduct, or with whom the employee is uncomfortable discussing such matters.

Every supervisor who learns of any employee’s concern about conduct in violation of our Equal Employment Opportunities Policy or our Sexual and Other Prohibited Harassment Policy, whether in a formal complaint or informally, or who otherwise is aware of conduct that may be in violation of those policies must immediately report the issues raised or conduct their local People Business Partner.

Employees are encouraged, but not required, to communicate to the offending person that their conduct is offensive and unwelcome. Individuals who observe any behavior directed at others that may violate this policy are encouraged to take reasonable action to defuse such behavior, if possible, such as intervening directly, alerting a supervisor or The People Team to assist, or making a report under this policy. Physical confrontation, violence, or assault is not an appropriate method of intervention. The intervening person must act in accordance with the Company’s policies.

Investigation

After a report is received, or the Company otherwise has reason to believe discrimination, prohibited harassment or retaliation is occurring, a timely, thorough and objective investigation by the Company will be undertaken. During the investigation, the Company generally will interview the complainant and the accused, conduct further interviews as necessary, and review any relevant documents or other information. The Company will maintain confidentiality surrounding the investigation to the extent possible, consistent with a thorough and objective investigation, and to the extent permitted or required under applicable law.

Once the investigation is completed and a determination is made, the complaining party will be advised that the investigation has been completed and may be informed of the resolution. The Company complies with the law in conducting investigations and employees are expected to provide truthful information when participating in an investigation.

Discipline

If the Company determines that this policy has been violated, including in the event that a supervisor or manager knowingly allows the policy to be violated without reporting it, prompt remedial action will be taken, up to and including termination of employment.

Good Faith Reporting

The initiation of a good faith complaint of discrimination, prohibited harassment, sexual harassment or retaliation will not be grounds for disciplinary or other retaliatory action, even if the allegations cannot be substantiated or the employee was mistaken about aspects of the complaint. Any individual who makes a complaint that is demonstrated to be intentionally false may be subject to discipline, up to and including termination.