1.1 This policy establishes the Organization's formal commitment to building a diverse, equitable, and inclusive workforce by embedding equity-focused practices into every stage of the recruitment and hiring process, from workforce planning and job design through sourcing, assessment, selection, and onboarding. The Organization recognises that workforce diversity — encompassing differences in race, ethnicity, gender, age, disability, sexual orientation, gender identity, religion, national origin, veteran status, socioeconomic background, neurodiversity, and cognitive style — is a strategic asset that drives innovation, strengthens decision-making, enhances employee engagement, and improves business performance. This policy applies to all recruitment activities across every employment category, department, and geographic location within the Organization and its subsidiaries.

1.2 The Organization shall establish measurable diversity representation targets as part of its annual workforce planning and talent acquisition strategy. Targets shall be informed by relevant labor market availability data, industry benchmarks, census demographics for the Organization's operating locations, and the Organization's current workforce composition. Targets shall be set at the organizational, divisional, and departmental levels and shall encompass representation across race, ethnicity, gender, disability status, and veteran status at a minimum. The Head of Diversity and Inclusion shall track progress against these targets on a quarterly basis and shall report findings to the executive leadership team. Targets are aspirational goals designed to drive focused effort and accountability; they are not quotas and shall not result in the selection of any candidate who does not meet the minimum qualifications for a position.

1.3 This policy supplements and operates in conjunction with the Organization's standard recruitment policy, equal employment opportunity policy, and anti-discrimination policy. All hiring decisions shall remain merit-based, with candidates evaluated against the same competency framework, scoring rubric, and minimum qualifications regardless of background. This policy does not authorise or require preferential treatment or the lowering of qualification standards for any candidate. Rather, it mandates the adoption of proactive, evidence-based practices to ensure that the Organization's recruitment processes are designed to reach, attract, and fairly evaluate the broadest possible range of qualified candidates, thereby reducing systemic barriers that may disadvantage underrepresented groups. Where a conflict arises between this policy and applicable law, the legal requirement shall prevail.

2.1 All job descriptions shall be reviewed by the HR department and, where available, the Diversity and Inclusion team before publication to ensure they use gender-neutral, inclusive language free from culturally specific jargon, gendered pronouns, and terminology that may inadvertently deter qualified candidates from underrepresented groups. Job requirements shall be limited to qualifications, skills, and experience that are genuinely essential for the performance of the role; unnecessary degree requirements, years-of-experience thresholds that exceed actual role needs, and other inflated criteria that may disproportionately exclude diverse candidates shall be removed. The Organization shall utilize bias-detection tools to scan job postings for exclusionary language before publication. All postings shall be formatted for accessibility, including compatibility with screen readers, and shall include the Organization's diversity and inclusion commitment statement.

2.2 The Organization shall implement a proactive, multi-channel sourcing strategy designed to reach qualified candidates from underrepresented groups. The Talent Acquisition team shall actively source candidates from diversity-focused job boards and platforms, professional associations representing women, people of color, LGBTQ+ individuals, individuals with disabilities, and veterans, Historically Black Colleges and Universities (HBCUs), Hispanic-Serving Institutions (HSIs), tribal colleges, community colleges, and technical training programs serving underrepresented populations, workforce development organizations and vocational rehabilitation agencies, and diversity-focused career fairs and conferences. For each requisition, the Talent Acquisition team shall document the diversity sourcing channels utilized. The Organization shall allocate a minimum of 20 percent of its annual sourcing budget to diversity-focused channels and partnerships, with the allocation reviewed annually based on program effectiveness.

2.3 The Organization shall implement a diverse slate requirement mandating that the shortlist of candidates advanced to the interview stage for every open position includes a minimum of 30 percent candidates from underrepresented groups, as self-identified through the Organization's voluntary demographic data collection process. Where the diverse slate requirement is not met after exhausting standard sourcing timelines, the Hiring Manager shall consult with the Head of Diversity and Inclusion and the Talent Acquisition team to implement additional targeted sourcing efforts for a minimum of 10 additional business days before proceeding. If, after extended sourcing, the diverse slate target remains unmet, the Hiring Manager may proceed with documented approval from the Head of Diversity and Inclusion, accompanied by a written explanation of the sourcing efforts undertaken and the market conditions that limited the candidate pool. The diverse slate requirement shall be tracked as a key performance indicator for all Talent Acquisition team members.

2.4 The Organization shall conduct an annual review of its application process to identify and remove barriers that may disproportionately deter or disadvantage candidates from underrepresented groups. Barriers to be assessed and addressed include excessively long application forms that exceed 15 minutes to complete, requirements for social media profile links or personal website URLs that are not essential for the role, mandatory video introductions or other requirements that may create bias based on appearance, accent, or disability, application systems that are not accessible to individuals using assistive technologies, and requirements for salary history disclosure in jurisdictions where such enquiries are prohibited or where the Organization has elected to ban the practice. The Talent Acquisition team shall conduct user experience testing of the application process at least annually, including testing with individuals who use assistive technologies, and shall implement improvements within 60 days of identifying accessibility or usability issues.

3.1 All interview panels shall be composed to promote diverse perspectives and reduce the risk of affinity bias in candidate evaluation. Each panel shall include a minimum of two interviewers and shall, wherever practicable, include at least one member from a group that is underrepresented in the Organization or the specific department, and at least one member who has completed the Organization's advanced bias-free interviewing certification program. Panel composition shall be reviewed by the HR department before interview scheduling, and panels that do not meet diversity requirements shall be reconstituted. Interview panel members shall independently score candidates using standardised competency-based scorecards before engaging in collective deliberation, to minimise anchoring bias and groupthink. The HR department shall track interview panel diversity metrics and report them quarterly alongside hiring outcome data.

3.2 The Organization shall implement structured interviews as the primary assessment method for all positions, using standardised, competency-based questions that are directly aligned with the requirements of the role and applied consistently to every candidate. Each question shall be accompanied by a detailed scoring rubric with behavioral anchors defining each rating level, ensuring that evaluations are based on evidence rather than subjective impressions. Unstructured or conversational interviews are prohibited as the sole method of candidate evaluation, as research consistently demonstrates they are less predictive of job performance and more susceptible to unconscious bias. Where technical assessments, work samples, or case studies are used, they shall be designed to be skill-relevant, standardised across candidates, and reviewed for potential adverse impact on protected groups. All assessment tools shall be audited annually by the HR department for validity, reliability, and fairness.

3.3 The Organization shall implement blind resume screening for the initial application review stage, removing or masking candidate names, photographs, age indicators, addresses, educational institution names, graduation dates, and other identifying information that is not directly relevant to assessing job qualifications. The applicant tracking system shall be configured to present screeners with anonymised candidate profiles that display only qualifications, skills, relevant experience, and competencies. Blind screening shall be maintained through the initial shortlisting stage; candidate identity shall be revealed only when candidates are advanced to the interview stage. The HR department shall compare the demographic composition of candidates advanced under blind screening with historical data to assess the impact of blind screening on candidate diversity. Where blind screening is not technically feasible for specific recruitment channels, the HR department shall implement alternative bias-mitigation measures such as dual-screener review and calibration sessions.

4.1 The Organization's structured onboarding program shall incorporate specific elements designed to support the inclusion and belonging of all new hires, with particular attention to employees from underrepresented groups. These elements shall include a diversity and inclusion orientation session covering the Organization's D&I values, policies, employee resource groups, and support resources, conducted within the first week of employment; an introduction to relevant employee resource groups with an invitation to attend upcoming events; the option to be paired with a buddy or mentor from a similar or allied background, in addition to the standard departmental onboarding buddy; and a check-in with the HR department at the 30-day mark specifically addressing the new hire's sense of inclusion and belonging. The Hiring Manager shall ensure that the new hire's team is briefed on inclusive onboarding practices and that the work environment is welcoming and respectful from day one.

4.2 The Organization shall track employee retention rates disaggregated by race, ethnicity, gender, disability status, veteran status, and other relevant demographic categories on a quarterly basis. Where retention rates for any demographic group differ from the organization-wide average by more than 5 percentage points, the Head of Diversity and Inclusion shall initiate a focused investigation within 30 calendar days to identify contributing factors and recommend corrective actions. All voluntary departures shall include a structured exit interview conducted by the HR department, incorporating questions specifically addressing the departing employee's experience with inclusion, belonging, equitable treatment, and any incidents of discrimination or bias. Exit interview data shall be aggregated, anonymised, and analysed semi-annually for patterns related to D&I, with findings reported to the executive leadership team. Identified trends shall inform updates to the Organization's retention strategy and diversity action plans.

4.3 The Organization shall conduct an annual inclusion survey, administered confidentially to all employees, measuring key dimensions of the inclusion experience including sense of belonging, psychological safety, perception of equitable treatment in career development and compensation, access to mentorship and sponsorship opportunities, confidence in the Organization's complaint and resolution processes, and perception of leadership commitment to diversity and inclusion. Survey results shall be disaggregated by demographic group, department, grade level, and tenure to identify areas where the experience of inclusion varies significantly across populations. Results shall be reported to the executive leadership team within 45 days of survey completion, and each department shall develop a targeted action plan within 60 days to address any areas scoring below the Organization's inclusion benchmark. Year-over-year trends shall be tracked and published in the Organization's annual diversity and inclusion report.

5.1 Diversity and inclusion hiring metrics shall be formally incorporated into the performance objectives and annual evaluation criteria of all Hiring Managers, Talent Acquisition team members, HR Business Partners, and members of the senior leadership team. Metrics shall include diverse slate compliance rates, diverse interview panel composition, representation of hires from underrepresented groups relative to market availability, retention rates of diverse hires at 12 and 24 months, and participation in and completion of inclusive hiring training programs. Achievement against D&I goals shall factor into annual performance ratings and, where applicable, variable compensation determinations. The Organization shall recognise and celebrate managers and teams that demonstrate outstanding commitment to diversity and inclusion through formal recognition programs, and shall address persistent underperformance against D&I objectives through coaching, additional training, and, where necessary, performance improvement plans.

5.2 The Head of Diversity and Inclusion shall prepare and present a quarterly diversity hiring report to the executive leadership team and, at least annually, to the Board of Directors or its designated committee. The report shall include current workforce demographic composition compared to targets and market availability, demographic analysis of the hiring funnel at each stage from application through offer acceptance, diverse slate and diverse panel compliance rates by department, analysis of any statistically significant disparities in selection rates by demographic group, retention and promotion rates for diverse hires compared to the overall population, summary of inclusive hiring training participation and completion, and a narrative assessment of progress, challenges, and recommended actions. The report shall be data-driven, actionable, and presented with sufficient granularity to enable the leadership team to make informed resource allocation and strategy decisions.

5.3 This policy shall be reviewed comprehensively at least once every 12 months by the Head of Diversity and Inclusion in consultation with Legal Counsel, the Head of Human Resources, external diversity and inclusion advisors, and leaders of the Organization's employee resource groups. The review shall assess the policy's effectiveness based on quantitative metrics and qualitative feedback, alignment with current legal requirements and evolving best practices in diversity and inclusion, relevance to the Organization's current workforce composition and strategic priorities, and feedback from employees, candidates, and community partners. Proposed amendments shall be reviewed by Legal Counsel, approved by the Chief Executive Officer, and communicated to all employees at least 14 calendar days before the effective date. The Organization shall publish a summary of material policy changes and the rationale for each change as part of its commitment to transparency in D&I governance.