POLICY AGAINST UNLAWFUL HARASSMENT

POLICY STATEMENT

BrownBag Pictures, LLC (hereinafter "BBP ") is committed to providing a work environment that is free of unlawfulharassment. BBP's policy prohibits sexual harassment and harassment or discrimination based on race, gender, color, religion, sex, pregnancy, national origin, ancestry, age, marital status, physical or mental disability, medical condition, sexual orientation, gender identity, gender expression, citizenship, genetic information, military status, status as a veteran or disabled veteran, or any other basis protected by applicable federal, state or local law or ordinance or regulation. All such harassment is unlawful.

This policy also applies to harassment against employees and interns by third parties, such as vendors, consultants,visitors and guests, and it applies as well to harassment by BBP employees or interns toward any such third parties. In short, all employees, interns and individuals performing services for the BBP are expected to comply with this policy and to cooperate with investigations into complaints of harassment.

PROHIBITED CONDUCT

Conduct which is prohibited at BBP, whether or not it rises to the level of unlawful harassment, includes:

• Verbal conduct such as epithets, derogatory jokes or comments, slurs, negative stereotyping or unwanted sexual advances, invitations or comments.

• Visual conduct such as posters, photography, cartoons, drawings on BBP premises or circulated in theworkplace that denigrate or show hostility or aversion towards an individual or group because of any characteristic identified above.

• Physical conduct such as intimidation, threats, assault, unwanted touching, blocking normal movement orinterfering with work because of any characteristic identified above.

• Threats and demands to submit to sexual requests as a condition of continued employment, or to avoid someother loss, and offers of employment benefits in return for sexual favors.

• Favoritism in granting any benefit of employment because of a romantic or sexual relationship between a supervisor and an employee.

• Retaliation for having reported, or threatening to report harassment.

Whether or not the offending employee means to give offense or believed his or her comments or conduct were welcome is not determinative. Rather, the BBP policy is violated when another employee, whether the recipient or a mere observer, is in fact offended by comments or conduct which are based on the characteristics identified above.

It is a violation of this policy for males to sexually harass females or other males and for females to sexually harassmales or other females. Sanctions will be enforced against individuals engaging in sexual harassment, as well as against supervisory and management employees who knowingly allow such behavior to continue. The prohibition against sexual harassment applies with equal force where the harasser and the victim are of the same gender/genderidentity. Sexual harassment on the job is prohibited whether committed by a co-worker, a supervisor or manager, or b ypersons doing business with or for BBP.

COMPLAINT PROCESS

Individuals who believe they have been harassed on the job must, as soon as possible, provide a written or verbalcomplaint to their own or any other supervisor, to Production Administration or to a Human Resources representative.The complaint should include details of the incident(s, names of the individuals involved, and the names of any witnesses. In accordance with applicable law, a complaint form is provided with this policy; however, employees are not required to use that form in order to bring a matter to BBP's attention. Rather, an employee may lodge a complaintverbally or in writing, in any manner sufficient to provide notice to the BBP of the employee’s concerns.

Supervisors and managers must immediately refer all harassment complaints to the Human Resources Department orto Production Administration and will be subject to discipline if they fail to do so.

All incidents of harassment that are reported will be investigated. The Human Resources Department or BBP's designee will promptly undertake an effective, thorough and impartial investigation of the harassment allegations that provides appropriate due process and reaches reasonable conclusions based on the evidence collected. If BBP determines that documents, e- mails or phone records exist that are relevant to the allegations, BBP will take steps to obtain, review and preserve them. Reports will be documented and tracked. Investigations will be concluded in a timely manner. BBP will keep complaints under this policy and any resulting investigation as confidential as possible.However, in the course of an investigation and/or resolving a concern, some dissemination of information to others may be necessary, appropriate, and/or required by law. If BBP determines that a violation of this policy has occurred, it will take appropriate action to deter any future harassment. Where appropriate, disciplinary action up to and including termination will also be taken.

POLICY PROHIBITING RETALIATION

 BBP's policy and applicable law prohibit retaliation against an individual for using this complaint procedure in good faith or for filing, testifying, assisting, or participating in any manner in any investigation, proceeding or hearing conducted by BBP or a federal or state enforcement agency. Retaliation will result in disciplinary action up to and including termination of employment. Employees who believe they have been retaliated against in violation of thispolicy should report the facts to their supervisor, Production Administration, or a Human Resources representative.

Please note that an adverse employment action is not retaliatory merely because it occurs after an employee reportsharassment or assists in an investigation. An adverse employment action is not retaliatory unless it was motivated bythe employee’s report of harassment or participation in an investigation. After having reported harassment or assisted in an investigation, employees continue to be subject to the BBP's workplace policies, procedures and expectations.Employees who report harassment or assist in an investigation will not be immune from corrective action motivated by legitimate factors unrelated to retaliation.

ADDITIONAL ENFORCEMENT INFORMATION

In New York, a variety of federal, state and local laws protect individuals from certain types of conduct also proscribed by this policy. Under certain circumstances, an individual may be entitled to monetary and injunctive relief in connection with a legal or administrative action to adjudicate a claim of sexual harassment. Among other agencies, the Federal Equal Employment Opportunity Commission, the New York State Division of Human Rights, and the New York City Commission on Human Rights, investigate and prosecute complaints of prohibited harassment, discrimination and retaliation in employment. If you think you have been harassed or discriminatedagainst, or that you have been retaliated against for complaining or participating in an investigation, you may file acomplaint with the appropriate agency. The nearest office can be found by visiting the agency websites, including https://www.eeoc.gov/;https://dhr.ny.gov/; and https://www1.nyc.gov/site/cchr/index.page.

In addition to BBP's internal complaint procedure, the California Civil Rights Department (CRD) investigates and prosecutes complaints of unlawful harassment in employment. Individuals who believe that they have beenunlawfully harassed may file a complaint with the CRD within one (1) year of the alleged harassment. TheCRD serves as a neutral fact finder and attempts to help the parties voluntarily resolve disputes. If the CRD finds evidence of harassment and settlement efforts fail, the CRD may file a formal accusation against the employer and harasser. The accusation may lead to either a public hearing before the Fair Employment and Housing Commission or a lawsuit filed on the complainant's behalf by the CRD. If the Commission finds that harassment has occurred, it can order remedies including hiring or reinstatement, back pay, and changes in the practices of the involved employer. The address and telephone number of the local office of the CRD will be provided onrequest.  Employees of BBP who work outside of California should consult their local state agencycharged with administering harassment complaints.

California-based employees may learn more about sexual harassment by reviewing the California Civil Rights Department website (https://calcivilrights.ca.gov/aboutcrd/). New York-based employees may review the StopSexual Harassment Act Factsheet published by the New York City Commission on Human Rights for additional information.

COMPLAINT FORM FOR REPORTING SEXUAL HARASSMENT

If you believe that you have been subjected to sexual harassment, you are encouraged to complete this form and submit it promptly to a member of Human Resources or Production Administration. You are not required to usethis form to report sexual harassment, however. You may instead report the situation verbally or in another manner your supervisor, a member of Human Resources, or to Production Administration, if you are more comfortable doing so.

Please be as specific as possible in responding to the following questions, to facilitate BBP's

investigation of the events giving rise to your concerns.

1.      Your full name, job title and primary work location:

2.     Your supervisor’s name:

3.     Please identify the individual(s) against whom this complaint is made, and their relationship to you (e.g., supervisor, subordinate, coworker, or third party):

4.     Date(s) sexual harassment occurred:

5.     Is the sexual harassment continuing?           Yes                         No

6.     Please describe the conduct or incident(s) that is the basis of this complaint and your reasons for concluding that the conduct is sexual harassment. Please use additional sheets of paper if necessary and attach any relevant documents or evidence.

7.     Have you previously complained about the conduct that you have described in response to Question #6 above? If so, to whom did you complain, and when?

8.     Please list the name and contact information of any witnesses or individuals who may have information related to your complaint.

9.     Please provide a phone number and/or email address at which you can be reached regarding this matter:

By signing and submitting this complaint form, you certify that the information you have provided above is true and accurate to the best of your knowledge. Providing knowingly false information in connection with a complaint ofsexual harassment may result in corrective action.

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