EQUAL OPPORTUNITIES POLICY

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This document sets out the Equal Opportunities Policy at Jayex Technology Ltd.

Statement of policy and purpose of policy

1. Jayex Technology Ltd (the Employer) is committed to equal opportunities for all staff and applicants.

2. It is our policy that all employment decisions are based on merit and the legitimate business needs of the organisation. The Employer does not discriminate on the basis of race, colour or nationality, ethnic or
national origins, sex, gender reassignment, sexual orientation, marital or civil partner status, pregnancy or
maternity, disability, religion or belief, age or any other ground on which it is or becomes unlawful to
discriminate under the laws of the United Kingdom (referred to as Protected Characteristics).

3. Our intention is to enable all our staff to work in an environment which allows them to fulfil their
potential without fear of discrimination, harassment or victimisation. The Employer's commitment to
equal opportunities extends to all aspects of the working relationship including:

• recruitment and selection procedures;
• terms of employment, including pay, conditions and benefits;
• training, appraisals, career development and promotion;
• work practices, conduct issues, allocation of tasks, discipline and grievances;
• work-related social events; and
• termination of employment and matters after termination, including references.

4. This policy is intended to help the Employer achieve its diversity and anti-discrimination aims by
clarifying the responsibilities and duties of all staff in respect of equal opportunities and discrimination. The Employer will promote effective communication and consultation between the Employer and staff concerning equal opportunities by means it considers appropriate.

5. The principles of non-discrimination and equal opportunities also apply to the way in which staff treat
visitors, clients, customers, suppliers and former staff members.

6. This is a statement of policy only and does not form part of your contract of employment. This policy
may be amended at any time by the Employer, in its absolute discretion.

Who is responsible for equal opportunities?

7. Achieving an equal opportunities workplace is a collective task shared between the Employer and all its
staff. This policy and the rules contained in it therefore apply to all staff of the Employer irrespective of
seniority, tenure and working hours, including all employees, directors and officers, consultants and
contractors, casual or agency staff, trainees, homeworkers and fixed-term staff and any volunteers or
interns (referred to as Staff).

8. The board of directors of the Employer has overall responsibility for this policy and for equal
opportunities and discrimination law compliance in the workplace and the CFO has been appointed as the
person with day-to-day operational responsibility for these matters.

9. All Staff have personal responsibility to ensure compliance with this policy, to treat colleagues with
dignity at all times and not to discriminate against or harass other members of Staff, visitors, clients,
customers, suppliers and former staff members. In addition, Staff who take part in management,
recruitment, selection, promotion, training and other aspects of career development (referred to
as Managers) have special responsibility for leading by example and ensuring compliance.

10. Managers must take all necessary steps to:

• promote the objective of equal opportunities and the values set out in this policy;
• ensure that their own behaviour and those of the Staff they manage complies in full with this
  policy;
• ensure that any complaints of discrimination, victimisation or harassment (including against
  themselves) are dealt with appropriately and are not suppressed or disregarded.

What is discrimination?

11. Discrimination occurs in different ways, some more obvious than others. Discrimination on the
grounds of any of the Protected Characteristics is prohibited by law, even if unintentional, unless a
particular exception applies.

Direct discrimination
12. Direct Discrimination is less favourable treatment because of one of the Protected Characteristics.
Examples would include refusing a woman a job as a chauffeur because you believe that women are not
good drivers or restricting recruitment to persons under 40 because you want to have a young and
dynamic workforce.

13. Direct discrimination can arise in some cases even though the person complaining does not actually
possess the Protected Characteristic but is perceived to have it or associates with other people who do. For example, when a person is less favourably treated because they are (wrongly) believed to be homosexual or because they have a spouse who is Muslim.

Indirect discrimination

14. Indirect discrimination arises when an employer applies an apparently neutral provision, criterion or
practice which in fact puts individuals with a particular Protected Characteristic at a disadvantage,
statistically and this is unjustified. To show discrimination the individual complaining also has to be
personally disadvantaged. An example would be a requirement for job candidates to have ten years'
experience in a particular role, since this will be harder for young people to satisfy. This kind of
discrimination is unlawful unless it is a proportionate means of achieving a legitimate aim.

Victimisation & Bullying

15. Victimisation is treating someone less favourably than others because they have, in good faith, complained (whether formally or otherwise) that someone has been bullying or harassing them or someone else, or supported someone to make a complaint or given evidence in relation to a complaint. An example would be isolating someone or giving them an unfavourable work allocation because they have made a complaint.

Harassment

16. Harassment is:

• unwanted conduct which is related to a Protected Characteristic and which has the purpose or
  effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating
  or offensive environment for them: or
• unwanted conduct which is of a sexual nature and which has the purpose or effect of violating a
  person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive
  environment for them (Sexual Harassment); or
• less favourable treatment because of the rejection of or the submission to Sexual Harassment.
• Conduct may be harassment whether or not the person behaving in that way intended to offend. Something intended as a joke, may offend another person. Everyone has the right to decide what behaviour is acceptable to them and to have their feelings respected by others. Behaviour which any reasonable person would realise would be likely to offend will be harassment without the recipient having to make it clear in advance that behaviour of that type is not acceptable to them. If it is not clear in advance that certain behaviour would be unwelcome to, or could offend a particular person then first-time conduct which unintentionally causes offence will not be harassment but it will become harassment if the conduct continues after the recipient has made it clear, by words or conduct, that such behaviour is unacceptable to them.

17. Harassment can arise in some cases even though the person complaining does not actually possess a
Protected Characteristic but is perceived to have it (for example, when a person is harassed because they
are (wrongly) believed to be homosexual) or associates with other people who possess a Protected
Characteristic (for example, because they have a spouse who is Muslim).

18. Harassment may include:

• use of insults or slurs based on a Protected Characteristic or of a sexual nature or other verbal
  abuse or derogatory, offensive or stereotyping jokes or remarks;
• physical or verbal abuse, threatening or intimidating behaviour because of a Protected
  Characteristic or behaviour of a sexual nature;
• unwelcome physical contact including touching, hugging, kissing, pinching or patting, brushing
  past, invading personal space, pushing, grabbing or other assaults;
• mocking, mimicking or belittling a person's disability, appearance, accent or other personal
  characteristics;
• unwelcome requests for sexual acts or favours; verbal sexual advances, vulgar, sexual, suggestive
  or explicit comments or behaviour;
• repeated requests, either explicitly or implicitly, for dates;
• repeated requests for social contact or after it has been made clear that requests are unwelcome;
• comments about body parts or sexual preference;
• displaying or distributing offensive or explicit pictures, items or materials relating to a Protected
  Characteristic or of a sexual nature;
• shunning or ostracising someone, for example, by deliberately excluding them from
  conversations or activities;
• 'outing' or threatening to 'out' someone's sexual orientation (i.e., to make it known);
• explicit or implicit suggestions that employment status or progression is related to toleration of,
  or acquiescence to sexual advances, or other behaviour amounting to harassment.

19. Other important points to note about harassment:

• a single incident can amount to harassment;
• behaviour that has continued for a long period without complaint can amount to harassment;
• it is not necessary for an individual to intend to harass someone for their behaviour to amount to
  harassment;
• it is not necessarily for an individual to communicate that behaviour is unwelcome before it
  amounts to harassment; and
• the onus is on each individual to be certain that their behaviour and conduct is appropriate and is
  not unwanted and in the case of doubt, you must refrain from such conduct.

Disability discrimination

20. This could be direct or indirect discrimination, and is any unjustified less favourable treatment
because of the effects of a disability, and failure to make reasonable adjustments to alleviate
disadvantages caused by a disability.

Disabled persons

21. Any Staff member who considers that they may have a disability is strongly encouraged to speak with
the CFO, particularly if they experience difficulties at work because of their disability so that any
reasonable adjustments to help overcome or minimise difficulties can be discussed. For these purposes,
disability includes any physical or mental impairment which substantially affects your ability to perform
day to day activities and has lasted (or is likely to last) more than 3 months. Disclosure of this information
will be treated in confidence, if you wish it to be, so far as is reasonably practicable and we will do our
best to handle matters sensitively and to ensure that you are treated with dignity and with respect for your privacy.

22. We will consult with you about whether adjustments are needed to avoid you being disadvantaged and
may ask you to see a doctor appointed by us, to advise on this. We will seek to accommodate your needs
within reason. If we consider a particular adjustment unreasonable we will explain why and try to find an
alternative solution.

23. Managers with responsibility for managing a member of Staff who they know or think to be disabled
should speak to the CFO to ensure that all relevant duties are complied with.

Making employment decisions fairly

24. As noted above, the Employer will recruit employees and make other employment decisions
concerning promotion, training, dismissal and related issues, on the basis of objective criteria.

25. Managers should only stipulate criteria or conditions for employment decisions (including job
selection, promotion and redundancy) which are based on a legitimate business need and which do not go
further than is needed to satisfy that need. If you are in any doubt about whether particular criteria or
conditions are indirectly discriminatory or justifiable, then please speak to the CFO.

Recruitment

26. Managers involved in recruitment must:

• specify only recruitment criteria that are relevant to the job, reflect genuine business needs and
  are proportionate. More than one person should be involved in shortlisting of applicants wherever
  practicable;
• ensure that vacancies are advertised to a diverse audience and try to avoid informal recruitment
  methods that exclude fair competition. In very rare cases, it may be legitimate and necessary to restrict recruitment to a particular role to certain groups, but it is essential that this is discussed
  with the CFO so that appropriate steps can be taken to ensure legality;
• review job advertisements carefully to ensure that stereotyping is avoided and that particular groups are not unjustifiably discouraged from applying;
• not ask applicants about health or disability before a job offer is made (other than in exceptional
  circumstances and after having been approved by the CFO). If necessary a job offer can be
  expressed to be conditional upon satisfactorily passing a medical check.
• not ask candidates about any Protected Characteristic if the question may demonstrate an
  intention to discriminate. For example, candidates should not be asked about current or future
  pregnancy, childcare or related matters; and
• not make assumptions about immigration status based on appearance, accent or apparent
  nationality;
• so far as reasonably practicable, keep a written record of their reasons for relevant decisions.

27. The Employer is legally required to verify that all employees have the right to work in the UK. Prior
to starting employment, all employees must produce original documents to the Employer's satisfaction,
irrespective of nationality. Information about the documents required is available from the CFO.

28. The Employer monitors applicants:

• Sex
• Ethnic group
• Disability
• Age

as part of our recruitment process. We do this to assess the effectiveness of our measures to promote equal opportunities and to help us identify and take appropriate steps to avoid discrimination, underrepresentation and potential disadvantage and improve diversity. Provision of this information is
voluntary and the information is kept in an anonymised format solely for the purposes stated here. The
information will not be used as part of any decision-making process relating to the recruitment or
employment of the person providing the information. Our recruitment policies must be reviewed at
regular intervals to ensure people are being treated fairly and according to ability and merit.

Staff training, career development and promotion

29. Training needs may be identified during the normal appraisal process. Appropriate training to
facilitate progression will be accessible to all staff.

30. All promotion decisions will be made on the basis of merit and according to proportionate criteria
determined by legitimate business need.

31. Staff diversity at different levels of the organisation will be kept under review to ensure equality of
opportunity. Where unjustified barriers to progression are identified, these will be removed.
Conditions of service

32. Access to benefits and facilities and terms of employment will be kept under review to ensure that
they are appropriately structured and that no unlawful barriers to qualification or access exist.

Discipline and termination of employment

33. Any redundancy selection criteria and procedures that are used, or other decisions taken to terminate
employment, will be fair and not directly or indirectly discriminatory.

34. Disciplinary procedures and penalties will be applied without discrimination, whether they result in
disciplinary warnings, dismissal or other disciplinary action.

Discipline and termination of employment

35. Part-time and fixed-term staff will be treated the same as full-time or permanent staff of the same
position and enjoy no less favourable terms and conditions (pro-rata, where appropriate), unless different
treatment is justified.

What to do if you encounter discrimination

36. If you believe that you have been the victim of discrimination, you should follow the Employer's
Grievance Procedure.

37. Every member of Staff has a responsibility to combat discrimination if they encounter it. Staff who
observe or are aware of acts that they believe amount to discrimination directed at others are encouraged to report these to the CFO.

38. Any grievance or report raised about discrimination will be kept confidential so far as this is
practicable. We may ask you if you wish your complaint(s) to be put to the alleged discriminator if
disciplinary action appears to be appropriate. It may sometimes be necessary to disclose the complaint or
take action even if this is not in line with your wishes, but we will seek to protect you from victimisation
and, if you wish, we will seek to protect your identity. You should be aware that disciplinary action may
be impossible without your co-operation or if you refuse to allow relevant information to be disclosed.

39. Staff who raise a complaint about or report discrimination in good faith will be protected from
retaliation or victimisation. As long as you act in good faith, the fact that you have raised a complaint or
report will not affect your position within the Employer, even if the complaint is not upheld. Making a
false allegation deliberately and in bad faith is a misconduct offence and will be dealt with in accordance
with our disciplinary policy. Any member of Staff who attempts acts of retaliation or victimisation may
be subject to disciplinary action up to and including summary dismissal for gross misconduct.

40. If you make a complaint, it may be necessary to ask you to stay at home on paid leave while
investigations are being conducted and the matter is being dealt with through the appropriate procedure.
This may particularly be necessary in cases of alleged harassment.

41. You may choose to bring a companion to the meeting who is either a work colleague or a trade union official. The choice of companion is a matter for you, but we may refuse to accept a companion whose presence would undermine the disciplinary process. Companions will be given appropriate paid time off to
accompany you at a disciplinary hearing or appeal hearing, if they agree to attend as your companion.

Non-compliance with equal opportunities rules

42. Any breach of equal opportunities rules or failure to comply with this policy will be taken very
seriously and is likely to result in disciplinary action against the offender, up to and including immediate
dismissal.

43. Staff should also note that:

• in some cases, they may be personally liable for their acts of discrimination and that legal action
  may be taken against them directly by the victim of any discrimination; and
• it may be a criminal offence to intentionally harass another employee.

Review of this policy

44. The board of directors of the Employer will keep this policy under review.

45. The Employer encourages Staff to comment on this policy and suggest ways in which it might be
improved or ask any questions if they are unsure about any part of this policy or how it is applied by
contacting the CFO.