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Our Zero Tolerance Policy

Background

Creandum is committed to maintain an inclusive and safe workplace that promotes respect, integrity, equal opportunity and openness. To this end, Creandum has adopted a zero-tolerance approach against any kind of discrimination and harassment. The purpose of this policy is to describe behavior and activity falling under the zero-tolerance concept. It also includes how to report violations of this policy and remedial actions.

Scope

This policy applies to all individuals involved, engaged or associated with Creandum, including Creandum employees, fund portfolio company founders and employees, partners and vendors and other stakeholders. We expect everyone to adhere to this policy in all settings associated with Creandum such as offices, video and telephone conferences, media and online communication, events and social outings. The behaviors falling under the zero-tolerance concept include discrimination, harassment, sexual harassment and other unwanted behavior which are described in more detail below. The conducts and acts mentioned are not exhaustive. There may be other behavior, which by either nature or context will fall within the scope of this policy.

Discrimination

Discrimination is when an individual is treated unfavorably or when an individual's dignity is violated. There are several grounds of discrimination including sex, transgender identity or expression, ethnicity, religion or other belief, disability, age or other basis protected by law ('protected characteristics').

Direct discrimination occurs when someone is treated less favorable because of having one or more of the protected characteristics, compared to someone who does not have the same protected characteristic. Indirect discrimination occurs when a conduct or act appears neutral but in fact disadvantages certain individuals and can't be objectively justified. Discrimination also occurs if an individual with a disability is disadvantaged due to not getting the same access as someone without the same disability.

Discriminatory behavior may include limiting opportunities to work for non-objective reasons, deliberate exclusion attendance in a way that may constitute indirect discrimination and instructing someone else to discriminate against another individual.

Harassment

Harassment is an unwanted conduct or act which an individual is subjected to, that relates to a protected characteristic, and violates the victim's dignity or creates an intimidating, hostile, degrading or offensive environment.

Harassment may include statements or remarks that are derogatory or demeaning about an individual, degrading images or material portraying stereotypes of an individual or marginalized group, racist or ethnic slurs, obscene or abusive language or outing individuals against their will, e.g. sexual orientation and religion.

Sexual harassment

Sexual harassment is harassment of a sexual nature or related to gender. Sexual harassment can take many forms and does not need to be motivated by sexual desire. Some acts may be considered as sexual harassments by nature, while some acts may be considered as sexual harassment based on the context.

Sexual harassment may include misogynist comments or behavior, deliberate or persistent misgendering, sexual jokes, advances, propositions and touching, gestures, written and verbal abuse of sexual nature or sexually degrading ways to describe an individual.

A conduct or act by an individual in significant power over the recipient, such as a senior staff member or a person who influences funding decisions towards a person seeking funding, are specifically included under this section.

Other unacceptable conducts and acts

The above-mentioned conducts and acts are not exhaustive. Other behavior that the recipient may perceive as unwanted may also be considered as falling under the zero-tolerance concept such as: - non-sexual physical touch, restraint, assault or threats, retaliation or the threat of retaliation against someone; - minimising, excusing and defending unacceptable behavior; and - criticizing the recipient of unwanted behavior for having an inappropriate emotional state of mind in response to an unacceptable behavior.

Reporting

Creandum strongly encourages its stakeholders to adopt a zero-tolerance approach to the conduct described herein and to implement processes to report and take appropriate measures against such behavior.

Creandum also encourages reporting of violations against this policy. We specifically expect people in senior positions or positions of power to report violations they may encounter as they are less vulnerable to retaliation or pressure.

Reporting can be made by email to Creandum's General Counsel carolina@creandum.com or to Operating Partner daniel@creandum.com.

We take all complaints seriously and will investigate promptly. Every effort will be made to ensure the victim's privacy is maintained whilst protecting the rights of the accused. The information obtained in the investigation will be communicated on a "need to know" basis. For some complaints, third party assistance may be required.

Remedial Action

Creandum has zero-tolerance for violations of this policy and if it is determined that a violation of this policy has occurred, effective remedial action will be taken. Such actions may include the following:

• appropriate support to portfolio companies or other stakeholders to handle the violation;

• informal or formal warning;

• removal of responsibilities;

• suspension;

• termination of employment or contract;

• reporting to authorities; and

• follow-up monitoring to ensure that the inappropriate conduct or act has ceased.

For more information concerning Creandum's zero-tolerance policy, please contact carolina@creandum.com. This policy is reviewed on an annual basis.