TestMu AI Global Anti-Harassment & Respectful Workplace Policy

1. Our Commitment: A Culture of Belonging

TestMu's commitment extends beyond compliance with applicable law: the Company seeks to build a culture in which everyone belongs. Harassment is incompatible with our core value of mutual respect. This Policy is our commitment that the safety of everyone who works with us (physical, digital and psychological) is a priority.

TestMu is committed to a safe, inclusive and respectful working environment in which all individuals are treated with dignity and fairness. This Global Anti-Harassment & Respectful Workplace Policy sets out our approach to harassment, including sexual harassment, and the standards of conduct expected across every location where we operate. It reflects our commitment to human rights and dignity at work, international best practice, ethical conduct, and compliance with applicable local law.

2. Scope

This Policy applies to everyone connected with TestMu, wherever they are: the workplace is not just an office; it is every message thread, every video call, every code commit and every social event where our people gather. It covers:

• Senior leadership, directors and officers
• All employees: permanent, temporary, probationary and contractual
• Interns, trainees, apprentices and volunteers
• Consultants, contractors, vendors, customers, service providers and visitors
• Any individual interacting with TestMu in connection with work

It applies to conduct at company workplaces, during work-related travel, meetings or events, and in virtual and digital environments including email, messaging platforms and video calls.

3. Zero-Tolerance Commitment

TestMu maintains zero tolerance for harassment of any kind: every substantiated breach is acted on. Any substantiated violation may result in appropriate corrective or disciplinary action, up to and including termination of employment or contractual engagement. Protection against retaliation is set out in section 9.

4. What We Mean by Harassment

Harassment is unwelcome conduct that a reasonable person in the complainant's position would find offensive, intimidating, hostile or humiliating; intent is not determinative. It may be a single incident or repeated behavior, and it may be physical, verbal, non-verbal, written or digital.

• Sexual harassment: unwelcome advances, suggestive comments, or inappropriate content including images or AI-generated media.
• Discriminatory harassment: treating someone poorly because of race, color, ethnicity, national origin, caste, religion or belief, sex, gender, gender identity or expression, sexual orientation, pregnancy or parental status, marital status, age, disability, genetic information, veteran status, political opinion, trade-union membership, or any other characteristic protected under applicable law.
• Bullying: repeated or unreasonable behavior directed at a person or group that creates a risk to health, safety or dignity, including abuse of authority, persistent unjustified criticism, deliberate exclusion or humiliation.
• Personal or character attacks: insulting, demeaning or intimidating comments or gestures intended to humiliate or undermine dignity.
• Threats, violence or endangerment: causing, encouraging, threatening or glorifying harm, intimidation or violence.
• Breach of confidentiality or privacy: sharing or misusing another person's personal or confidential information without authority or consent.

5. Sexual Harassment

Sexual harassment includes any unwelcome conduct of a sexual nature, including unwelcome physical contact or advances; requests or demands for sexual favors; sexually colored remarks or jokes; display or circulation of sexually explicit content; repeated unwanted attention, invitations or communications and any conduct that creates a hostile or intimidating environment. In India this Policy operates together with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 ("the POSH Act"), through the Prevention of Sexual Harassment (POSH) Statement and a statutory Internal Committee. Complaints within the Internal Committee's statutory jurisdiction are handled by the Committee under the Prevention of Sexual Harassment (POSH) Statement; all other complaints are handled under the Global Anti-Harassment & Respectful Workplace Policy.

6. Responsibilities

6.1 All Individuals

Everyone is expected to treat others with dignity and respect, to refrain from engaging in, encouraging or tolerating harassment, to speak up or seek support when conduct is unwelcome, and to cooperate honestly in any investigation.

6.2 Leadership and Management

Managers and leaders model respectful and inclusive behavior, act promptly on concerns brought to their attention, ensure issues are escalated through the right channels, prevent retaliation, and support training and awareness that reinforce a safe, respectful workplace.

7. How to Speak Up

We encourage early reporting and have designed a process that is safe, confidential and supportive. Concerns may also be raised with a manager or a member of Human Resources. A concern raised with any manager is routed to the appropriate resource. In India, complaints of sexual harassment within the Internal Committee's statutory jurisdiction may be made directly to the Internal Committee constituted under the POSH Act, as described in the Prevention of Sexual Harassment (POSH) Statement.

Concerns may be raised through any of the following channels:

Reports to the ethics and whistleblower channel are received by Human Resources, which may engage Legal, Governance, Risk & Compliance or external advisers. Reports are acknowledged normally within five business days where contact details are provided, assessed for severity and conflict of interest, investigated independently of the business area concerned, and closed with a recorded outcome and tracked corrective action. Serious matters and matters involving senior leadership are investigated independently of management and overseen by the Information Security & Compliance Steering Committee (ISCSC). Nothing in this document prevents any person from reporting a concern to a government, regulatory or law-enforcement authority, and no confidentiality obligation owed to the Company restricts such a report.

8. Our Resolution Process

Once a report is made we follow a clear and consistent path:

• Initial discussion: we listen and explain the options, including informal resolution or a formal inquiry.
• Guiding principles: every complaint received is taken seriously, addressed promptly, and investigated fairly and impartially in accordance with natural justice.
• Interim measures: where needed, interim measures may include adjusting reporting lines, remote working or leave, so that a reporter need not interact with the person concerned during the process.
• The inquiry: a neutral team examines the facts; investigators must declare and recuse themselves from any conflict of interest.
• Decision: findings are made on the balance of probabilities (preponderance of the evidence) (unless local law requires otherwise), with corrective action where a complaint is substantiated, and internal review or appeal where appropriate and lawful.

Minimum standards of fairness, confidentiality and non-retaliation apply globally; local procedures may add to them. Human Resources owns this Policy and conducts or commissions investigations (in India, complaints within the Internal Committee's statutory jurisdiction are handled by the Committee under the POSH Statement, as described in section 5); matters involving senior leadership are investigated independently of management; outcomes and trends are reported to the ISCSC for governance oversight.

9. Protection Against Retaliation

We do not tolerate retaliation. TestMu prohibits retaliation of any kind against any person who, in good faith, raises a concern, reports a suspected breach or assists an investigation, whether or not the concern is substantiated. Retaliation is itself a breach of the Code of Business Conduct & Ethics and is subject to disciplinary action following investigation. Knowingly making a false report is also a breach. Retaliation includes penalizing someone for speaking up (through unfair reviews, exclusion or cold-shouldering) regardless of the outcome of the original complaint.

10. Confidentiality and Data Protection

Information relating to complaints, investigations, evidence and outcomes is treated as strictly confidential and shared only on a need-to-know basis. Records are stored securely with restricted access, and personal data is processed and retained in accordance with applicable data-protection law and the Privacy Policy published on the Trust Page.

11. Action and Discipline

Where harassment is substantiated following due process, action may include a written warning, mandatory counseling or training, suspension or termination of employment, or termination of contract and withdrawal of access for third parties, proportionate, reasoned and lawful. Good-faith reporting is encouraged; an inability to substantiate a complaint is not, by itself, evidence of bad faith, but a deliberately false or malicious complaint may result in disciplinary action.

12. Support and Assistance

We provide supportive, complainant-centered assistance, which may include counseling or other support resources, interim protective measures, and referral to external services. Seeking support does not oblige anyone to file a formal complaint or take part in a formal inquiry.

13. Jurisdiction-Specific Provisions

This global Policy operates alongside local anti-harassment law where TestMu engages workers, including the following. Where local law provides additional protection or procedure, it applies through local procedures; in the event of conflict, the higher standard of protection prevails.

• United States: Title VII of the Civil Rights Act of 1964, the Americans with Disabilities Act of 1990 and the Age Discrimination in Employment Act of 1967, together with applicable state and local law.
• United Kingdom: the Equality Act 2010, including the duty on employers to take reasonable steps to prevent sexual harassment introduced by the Worker Protection (Amendment of Equality Act 2010) Act 2023, and the Protection from Harassment Act 1997.
• European Union: Directive 2000/43/EC (equal treatment irrespective of racial or ethnic origin), Directive 2000/78/EC (equal treatment in employment and occupation) and Directive 2006/54/EC (equal treatment of men and women in employment, recast), as implemented in the national law of each Member State in which we engage workers.
• India: the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (the POSH Act), applied through the Prevention of Sexual Harassment (POSH) Statement (see section 5).

14. Training, Governance and Review

We conduct regular training and awareness so that everyone understands their rights and responsibilities, and we meet state-mandated training requirements where applicable. This Policy is reviewed at least annually and whenever there is a legal, organizational or best-practice change. It is reviewed by the ISCSC and approved by the Chief Executive Officer on behalf of Executive Leadership, and applies across the organization, subject to the jurisdiction-specific provisions in section 13. It is read together with the Code of Business Conduct & Ethics, the Whistleblower Policy, the Global Diversity, Equity & Inclusion Policy, the Prevention of Sexual Harassment (POSH) Statement and any local procedures. Where provisions differ, the one affording the higher level of protection prevails. Nothing in this Policy limits any legal right a person may have under applicable law.