1.1 This Fraternization Policy establishes clear guidelines for personal and romantic relationships between employees to protect workplace professionalism, prevent conflicts of interest, minimise the risk of favouritism or harassment claims, and ensure that all employment decisions remain objective and merit-based. The Organization recognises that personal relationships may naturally develop among colleagues; however, certain relationships create inherent risks to the Organization's operations, culture, and legal exposure that must be proactively managed through disclosure and appropriate safeguards.

1.2 This policy applies to all employees, managers, supervisors, officers, directors, contractors, and temporary staff across all departments, locations, and levels of the Organization. It covers romantic, dating, sexual, and intimate relationships between any two individuals within the Organization's workforce, regardless of whether the individuals work in the same department or location. The policy applies to relationships that exist at the time of hire as well as relationships that develop during the course of employment. Social friendships and professional mentoring relationships are generally outside the scope of this policy unless they evolve into romantic or intimate relationships.

1.3 The HR department shall be responsible for administering this policy, receiving and processing relationship disclosures, conducting conflict of interest assessments, recommending and implementing management measures, and monitoring compliance. The HR department shall handle all disclosures with discretion and sensitivity, sharing information only with those who have a legitimate need to know for the purpose of implementing appropriate management measures. The HR department shall maintain a confidential register of disclosed relationships and shall report aggregate data, without identifying information, to the executive leadership team on a semi-annual basis.

2.1 Employees involved in a romantic or intimate relationship with another employee are required to disclose the relationship to the HR department promptly, and in any event within 10 business days, when any of the following conditions exist: one party has direct or indirect supervisory authority over the other; both parties work within the same department, team, or business unit; both parties are assigned to the same project or client engagement; the relationship could influence or could reasonably be perceived as influencing business decisions, including performance evaluations, compensation, promotion, or work assignments. Disclosure shall be made by both parties jointly, or individually if joint disclosure is not practicable, using the Organization's relationship disclosure form.

2.2 Relationships between a manager, supervisor, or any individual in a position of authority and a direct or indirect subordinate are subject to mandatory disclosure and management intervention, regardless of whether either party believes the relationship creates an actual conflict of interest. The inherent power imbalance in such relationships creates a presumptive conflict that must be addressed through structural measures such as reassignment of reporting lines, transfer of supervisory responsibility, or other modifications approved by the HR department. Failure to disclose a relationship that falls within this mandatory disclosure category shall be treated as a serious policy violation, subject to disciplinary action for both parties.

2.3 The Organization shall treat all relationship disclosures with strict confidentiality, and information shall be shared only with individuals who have a legitimate need to know for the purpose of assessing and managing the conflict. No employee shall face adverse employment consequences, including termination, demotion, transfer, or any reduction in responsibilities or opportunities, solely for making a good-faith disclosure under this policy. The HR department shall ensure that any management measures implemented following a disclosure are proportionate, non-punitive, and designed to protect the interests of both individuals and the Organization. Where an employee believes they have experienced adverse consequences as a result of a disclosure, they may file a complaint through the Organization's grievance process.

3.1 Romantic or intimate relationships are strictly prohibited between an employee and any individual over whom they exercise direct authority over hiring, termination, performance evaluation, compensation, promotion, or disciplinary decisions. Where such a relationship develops, the parties must disclose immediately, and the Organization shall reassign the supervisory or decision-making authority to an independent manager before the relationship may continue. Failure to disclose, or continuation of the supervisory relationship after disclosure without implementing the Organization's prescribed management measures, shall constitute grounds for disciplinary action up to and including termination for the individual in the position of authority.

3.2 Employees who are in a disclosed relationship covered by this policy shall be recused from participating in, influencing, or having access to information regarding any employment decision affecting the other party. Employment decisions include, but are not limited to, hiring, onboarding, performance evaluation, salary or bonus determination, promotion, transfer, disciplinary action, and termination. The HR department shall ensure that alternative decision-makers are assigned and that appropriate information barriers are in place to prevent the appearance of favouritism or bias. Both parties shall confirm in writing their understanding of and agreement to the recusal arrangements.

3.3 Where a disclosed relationship creates a conflict of interest that cannot be adequately managed through recusal or modified reporting lines alone, the Organization reserves the right to transfer or reassign one or both parties to different departments, teams, projects, or geographic locations. Such reassignment shall be conducted with due regard for minimising disruption to both parties' careers, compensation, and professional development opportunities, and shall not be used as a punitive measure. The HR department shall consult with both parties before implementing a reassignment and shall consider their preferences to the extent practicable. If neither party consents to voluntary reassignment and the conflict cannot otherwise be resolved, the Organization shall determine the reassignment based on operational need and seniority.

4.1 Where a relationship is disclosed and permitted to continue under this policy, the Organization may require both parties to sign a consensual relationship agreement. This agreement confirms that the relationship is voluntary, consensual, and free from coercion or intimidation; that both parties are aware of and agree to comply with this policy and any management measures imposed; that both parties understand the Organization's anti-harassment policy and their right to report any unwelcome conduct; and that both parties agree to notify the HR department promptly if the relationship ends. The consensual relationship agreement is not a waiver of either party's rights under employment law and is intended solely to document the voluntary nature of the relationship and the parties' acknowledgement of their obligations under this policy.

4.2 If a disclosed relationship ends, both parties are expected to maintain professional, courteous, and respectful conduct in all workplace interactions. Neither party shall engage in retaliatory, harassing, or disruptive behavior toward the other as a result of the relationship ending. Either party may notify the HR department if post-relationship workplace interactions become uncomfortable, hostile, or disruptive, and the HR department shall take appropriate measures, which may include mediation, temporary schedule adjustments, or reassignment, to restore a professional working environment. The Organization shall not disclose the former relationship to other employees or managers beyond those already aware through the original disclosure process.

4.3 The Organization respects employees' right to privacy in their personal lives and shall not proactively inquire into, investigate, or monitor employees' private relationships outside the workplace. The Organization's interest under this policy is limited to relationships that create an actual or potential conflict of interest within the workplace or that give rise to conduct that affects the working environment. Inquiries shall be initiated only where a credible report of a potential policy violation is received, where observable workplace conduct suggests a conflict of interest, or where a complaint of harassment or favouritism has been filed. All inquiries shall be conducted with discretion and in compliance with applicable privacy laws.

5.1 Violations of this policy, including failure to disclose a relationship that meets the disclosure criteria, providing false or misleading information in a disclosure, engaging in conduct that violates the management measures or recusal arrangements imposed under this policy, or retaliating against an individual who has made a disclosure or filed a complaint, shall result in disciplinary action proportionate to the severity of the violation. Disciplinary measures may include formal written warning, mandatory retraining, reassignment, suspension, or termination of employment. Individuals in positions of authority shall be held to a higher standard given their greater ability to influence employment outcomes. All disciplinary actions shall be documented and reviewed by the HR department for consistency.

5.2 This policy shall be reviewed comprehensively at least once every 12 months by the HR department in consultation with Legal Counsel and the executive leadership team. Reviews shall assess the policy's effectiveness based on the number and nature of disclosures received, management measures implemented, complaints filed, and feedback from employees and managers. The review shall also consider changes in applicable employment law, regulatory guidance, and evolving best practices in workplace relationship management. Amendments shall be approved by the Head of Human Resources and the Chief Executive Officer, and communicated to all employees at least 14 calendar days before the effective date.

5.3 All employees shall receive training on this policy as part of the onboarding process and on an annual basis thereafter. Training shall cover the types of relationships subject to disclosure, the disclosure process and timeline, the Organization's approach to managing conflicts arising from workplace relationships, the protections available to employees who make good-faith disclosures, and the consequences of non-compliance. Managers and supervisors shall receive additional targeted training on their heightened disclosure obligations, the prohibition on relationships with direct and indirect subordinates without appropriate management measures, and their responsibility to escalate concerns to the HR department. The HR department shall track training completion rates and report compliance metrics quarterly.