Anti-Human Trafficking Policy

Purpose

Outlook Group, LLC (the “Company”) is committed to preventing, detecting, and eliminating any form of human trafficking, forced labor, child labor, or exploitation in our operations, supply chains, and business relationships. The Company respects and upholds the human rights and dignity of all people, and we comply with all applicable laws and regulations in the United States and the states where we operate. The U.S. Government’s policy prohibiting trafficking in persons is available at 48 CFR § 52.222-50.

Human trafficking is a crime that involves the use of force, fraud, or coercion to obtain labor or commercial sex acts from a person. Forced labor is any work or service performed involuntarily under the threat of physical or psychological harm, abuse of power, or deception. Child labor is any work that deprives children of their childhood, education, health, or development, or that violates the minimum age requirements of the relevant jurisdiction. Exploitation is any act or omission that takes unfair advantage of a person’s vulnerability, need, or trust for profit or benefit.

Scope

This policy applies to all Outlook Group, LLC employees.

Policy

The Company has a zero-tolerance policy for any form of human trafficking, forced labor, child labor, or exploitation in our operations, supply chains, and business relationships. We expect our employees, contractors, suppliers, and partners to share our commitment and adhere to our standards and procedures. We also encourage our customers, stakeholders, and the public to report any concerns or suspicions of human trafficking, forced labor, child labor, or exploitation involving our company or our affiliates.

Due to the nature of our business, the Company only hires employees who are 18 years of age or older. Employment at the Company is “at will” which means that any employment relationship may be terminated by the employer or employee at any time and for any or no reason.

It is the Company’s policy that to provide equal employment opportunities without regard to age, race, creed, color, disability, marital status, gender, sexual orientation, national origin, ancestry, arrest or conviction record, membership in the armed forces or any other basis protected by law. This policy applies to all aspects of the employment process, including recruiting, hiring, transfer, promotion, training, compensation, benefits, layoff, recall, leaves of absence and termination.

We have a confidential and anonymous reporting mechanism for our employees to raise any concerns or suspicions of human trafficking, forced labor, child labor, or exploitation involving our company or our affiliates. We prohibit discrimination, harassment, or retaliation against victims and reporters. We investigate and respond to all reports promptly and thoroughly, and we take appropriate disciplinary action as necessary.

We cooperate with the relevant authorities to prevent, detect, and eliminate human trafficking, forced labor, child labor, and exploitation, and to support victims and survivors. We comply with all the reporting and disclosure requirements of the applicable laws and regulations.

Every employee of the Company is responsible for reading, understanding and complying with this policy. Company managers are responsible for ensuring that employees who report to them, directly or indirectly, comply with this policy. If you have any questions or concerns relating to this policy, consult the human resources department.

Employees are required to report any conduct that they believe to be a violation of this policy to the Company’s human resources department.

Employees who fail to report actual or suspected misconduct may be deemed in violation of this policy.

Any violation of this policy may be grounds for disciplinary action, up to and including termination. The Company and its subsidiaries have the exclusive right to interpret this policy regarding their respective employees.

Violation of the U.S. Government’s policy against human trafficking may also result in criminal prosecution of responsible individuals.

We are committed to continuously reviewing and improving our policy and procedures to ensure their effectiveness and alignment with the evolving standards and expectations of our stakeholders and the society. We welcome any feedback or suggestions on how we can enhance our performance and impact in this area.

See Policy