HUMAN RIGHTS POLICY

Step2 is committed to maintaining a corporate culture that respects the principles aimed at promoting, protecting and supporting all internationally recognized human rights. We recognize our responsibility to respect human rights and avoid complicity in human rights abuses.

Purpose

Respect for human rights is a fundamental value of the Company. Step2 strives to respect and promote human rights in our relationships with our employees, customers, communities, other business stakeholders.

Step2 believes that employees should be treated with respect and dignity and work in an environment that is free from harassment and unlawful discrimination. The Company’s commitment to respect human rights in the workplace is manifested in our Code of Business Conduct and policies, standards and practices. These policies state, among other things, that we value and promote workforce diversity and do not tolerate unlawful discrimination or harassment. We maintain an ethical work environment that reflects the core values of our Company, and we provide a safe and secure workplace.

Our employees have access to an Ethics Hotline (Lighthouse), the Step2 Hot Line (1-877-710-0099) and online reporting (www.lighthouse-services.com/step2), through which concerns and questions can be raised anonymously and resolved effectively. Employees are strongly encouraged to raise ethics, discrimination or harassment matters, and to report suspected violations of applicable laws, policies and/or our Code of Business Conduct. Retaliation for raising concerns in good faith is prohibited per our Internal Reporting and Non-Retaliation Policy per our Employee Handbook.

Step2 strives to respect human rights through its supply chain by encouraging actions that are consistent with and further the objectives of our code of Business Conduct, and by using suppliers whose corporate values are consistent with ours. Specifically, the Company encourages suppliers to follow best practices in the areas of freely chosen employment; working hours; respect in the workplace; wages and benefits; and health and safety.

Step2 seeks to do business with customers who share our values with respect to human rights. We strive to carry out appropriate due diligence and encourage our customers to maintain high ethical standards and practices. Through our customer relationships we have an ability to share best practices, which we believe will help further the respect of human rights around the world.

Step2 recognizes and accepts our responsibility to the communities we serve, through acting as a good neighbor and through involvement and support for community activities. We respect the rights of people in communities in which we operate. The Company will seek to identify adverse human rights impacts and take appropriate steps to avoid, minimize and/or mitigate them. Step2 will strive to ensure that our communications with governments, regulatory bodies and public authorities are consistent with our human rights commitments, as stated herein.

We recognize and accept our responsibility to the communities we serve, through acting as a good neighbor and through involvement and support for community activities.

Step2 is fully committed to the health and safety of our work force and to the protection of our neighbors, the environment and our assets. Step2 will exercise reasonable care in providing each employee a workplace free of recognized hazards, including violent acts or threats of violent acts against employees or third parties within Company workplaces. The Company will not tolerate violence or threats of violence and takes reasonable measures to provide a safe workplace. The Company will take reasonable efforts to provide a safe and healthy workplace and comply with applicable safety and health laws and regulations, as well as internal requirements.

Step2 values and advances diversity and inclusion in the workplace. The Company is committed to equal opportunity and is intolerant of discrimination and harassment. We work to maintain workplaces that are free from discrimination or harassment on the basis of race, sex, color, national origin, ethnicity, religion, age, disability, sexual orientation, gender identification or expression, or any other status protected by applicable law. Qualifications, performance, skills and experience are the basis for recruitment, hiring, placement, development, training, compensation and advancement at the Company.

Step2 is dedicated to creating a workplace that respects and values all employees and maintains an environment of open and direct communication. The Company strives to develop mutually rewarding relationship with employees through fairness, trust and integrity. Due to the direct partnership with employees, the Company does not believe in the need for an outside group to speak on behalf of employees. However, the Company respects freedom of association without fear of reprisal, intimidation or harassment.

Adherence to Polices is mandatory. Non-compliance may result in disciplinary action, up to and including termination. A violation, or suspected violation, of this policy or standard should be reported to your manager, your Human Resources Business Partner or the Business Ethics Hotline.

The Company reserves the right to interpret, modify, terminate, or revise this policy or standard, in whole or in part, without notice.  Statements within this policy or standard regarding conduct that may result in discipline do not limit, in any way, the Company’s right to discipline employees for conduct not specifically described above.  In addition, this policy or standard shall not be construed as an employment contract or to alter any employee’s at-will status.  Employees and the Company remain free to terminate the employment relationship at any time, with or without cause or notice. Similarly, the Company reserves the right to terminate an employee with or without the use of progressive discipline.