The Ikoku Holdings is committed to creating and maintaining conditions, environments and spaces free from discrimination and harassment.

Therefore, persons engaged in any activity involving, referring to, relating to, or otherwise pertaining to The Ikoku Holdings are expected to uphold the following:

— that The Ikoku Holdings ensure there is no discrimination based on real or perceived age, caste, disability, ethnicity, gender, gender identity, genetic information, marital status, medical condition, mental or physical ability, national origin, political affiliation, pregnancy or reproductive ability, choice or commitments, race, religion, sex, sexual orientation, veteran status, or any other real or perceived characteristic, class, or status protected by applicable law or regulation.

— that The Ikoku Holdings ensure there is no harassment, including but not limited to coercion or extortion, following, stalking, targeting or unconsented tracking, harsh or inhumane treatment, hazing, humiliation or bullying, threats, trespassing, hacking or vandalism, confidentiality or privacy violations, and any harassment that is ethnic- or gender-based, mental, physical, psychological, racial or sexual, or conducted by auditory, cyber, electronic, noise, telecommunications or verbal means.

— that The Ikoku Holdings ensure there is no improper, unconsented, undue, unnecessary or extreme recruitment, testing or vetting practices, including but not limited to conducting interviews or questioning that violate privacy or confidentiality, practicing forms of conversion therapy and their equivalent, and requiring drug, medical or pregnancy tests not mandated by applicable laws or regulations.

— that The Ikoku Holdings ensure there is no discrimination or harassment based on the results of such tests, even where they are approved, mandated, recommended or unregulated by law, regulation, or supervision.

— that The Ikoku Holdings ensure persons subject to the above forms of discrimination or harassment are protected, are provided effective response and remedy in a timely manner, and their own responses to the above are not themselves claimed, recognized or treated as forms of discrimination or harassment.

— that The Ikoku Holdings make every reasonable effort to ensure the attainment and maintenance of the most robust interpretation of due process rights, standards and laws during any hearing, interview, investigation, questioning or equivalent process.

— that all persons and entities involved honor the Duty to Report, especially when any such hearing, interview, investigation, questioning or equivalent process is being conducted.

— that The Ikoku Holdings ensure following any and all of the above principles further remains in accordance with the Codes and Policies and especially the Founding and Governing Code of Ethics.

— that The Ikoku Holdings ensure following any and all of the above principles further remains in accordance with the founding mission and purposes of The Ikoku Holdings and The Ikoku Group, without incompatibility, as described and delineated in the Codes and Policies and the Founder’s Agreement.

The Ikoku Holdings strongly recommends you develop and maintain your knowledge of all the Codes and Policies, and so asks that you read, understand, and regularly visit this section and other communications regarding the Policy on Discrimination and Harassment, as well as the Codes and Policies. The Ikoku Holdings takes your continued access, activity, communication, engagement, operation, participation, and other use or visiting of the Products and Services, as active indication of your knowledge, understanding, and legally binding acceptance of and agreement to this Policy as well as the Codes and Policies.

And you further legally accept and agree that no application, interpretation, judgment, or other compliance, proceeding, or reading from, of, with, or otherwise relating to the Founding Ethics, the Codes and Policies, or any equivalent code, policy, or other document or material shall, in any way, entail any abrogation, diminishment, interference, or violation pertaining to any of the terms, conditions, principles, requirements, rights — including the attendant properties and protections — of company and organizational integrity.

Please contact policies@ikokuholdings.com with any feedback, issues, or questions — to be addressed to and by the President, CEO and Chair, Alvan Azinna Chibuzo Ikoku.

If you detect, notice, become aware of, or are informed of a possible breach or violation of this Policy or any of the Codes and Policies, please contact policies@ikokuholdings.com with any details you have — to be addressed to and by the President, CEO and Chair, Alvan Azinna Chibuzo Ikoku.

As with all official documents, materials, policies, and statements of The Ikoku Group, definitions for terms used here can be found in the main Codes and Policies section.