Anti Harassment and Non-Discrimination Policy

It is our policy to maintain an environment that encourages mutual respect and promotes respectful and congenial relationships and that is free from all forms of harassment by anyone, including partners, employees, vendors, or contractors toward HOF Capital employees or contractors, investors and employees thereof, founders, portfolio company employees, general partners (“GPs”) and employees thereof (collectively, “Stakeholders”). Harassment, even when not unlawful or directed at a protected category, is expressly prohibited and will not be tolerated by HOF Capital. Accordingly, HOF Capital management is committed to vigorously addressing complaints of harassment, sexual harassment and discrimination at all levels within the company. This policy also applies with respect to interactions with employees of portfolio companies and portfolio funds (including venture partners), in meetings with entrepreneurs and fund managers outside of our portfolios (including, but not limited to meetings regarding prospective investments), and at any event where an employee is representing us.

We are committed to maintaining a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits discriminatory practices, including harassment. We expect that all relationships among persons in the workplace will be free of bias, prejudice and harassment. Therefore, it is the firm’s policy to ensure equal employment opportunity without discrimination or harassment on the basis of race; color; religion or creed; sex (with or without sexual conduct); age; disability; military or veteran status; national origin or ancestry; citizenship status; genetic information; marital and partnership status; sexual orientation; gender identity or expression; credit history; unemployment; status as a victim of domestic violence, stalking or sex offenses; height; weight; arrest or conviction record; affiliation with a spouse or domestic partner falling within the protected categories of this Policy; or any other characteristic protected by law. The Firm prohibits and will not tolerate any such discrimination or harassment.

Harassment defined

Harassment occurs when conduct interferes with an employee's work performance or creates an intimidating or offensive work environment, based upon an employee's race, color, religion, religious creed, national origin, ancestry, age, sex, gender, gender identity or expression, physical disability, mental disability, medical condition, genetic information, marital status, sexual orientation, family care or medical leave status, veteran or military status, or any other basis protected by federal or state laws. Harassing conduct can take many forms and may include, but is not limited to, the following: slurs, jokes, statements, gestures, assault, impeding or blocking another’s movement or otherwise physically interfering with normal work, pictures, drawings, or cartoons.

Sexual harassment in particular may include all of the above mentioned prohibited actions, as well as other unwelcome conduct, such as requests for sexual favors, conversations containing sexual comments, and unwelcome sexual advances, when:

1) submission to the conduct is made either an explicit or implicit condition of employment or business;

2) submission or rejection of the conduct is used as the basis for an employment or business decision; or

3) the harassment has the purpose or effect of unreasonably interfering with an employee's work performance or creates an intimidating, hostile or offensive work environment.

Harassment based on gender, pregnancy, childbirth or related medical conditions may also constitute sexual harassment. Sexually harassing conduct can be by a person of either the same or opposite sex, and need not be motivated by sexual desire.

Reporting harassing conduct

To report an issue or concern, please contact David Teten. Reports will be reviewed promptly and handled in confidence, as well as investigated and/or otherwise escalated and acted upon as appropriate.

Corrective action

If HOF Capital determines that harassment has occurred, effective remedial action will be taken in accordance with the circumstances involved. Any employee determined by HOF Capital to be responsible for discrimination or harassment in violation of this policy will be subject to appropriate disciplinary action, up to and including termination. Because a hostility-free work environment is so important, HOF Capital may take disciplinary action against an employee who exhibits poor judgment or engages in inappropriate behavior, even if it falls short of being severe or pervasive.