CHRONOTOPE

Policy

Anti-Harassment and Respectful Workplace Policy

Chronotope Labs, Inc.

1. Purpose and scope

Everyone who works with Chronotope Labs, Inc. ("Chronotope") is entitled to a workplace free of harassment, abuse and intimidation. This policy prohibits workplace harassment and sexual harassment in any form, sets out how to report it and how we respond, and applies to directors, officers, employees, contractors, interns and advisors. It covers conduct toward colleagues, candidates, suppliers, and the personnel of our clients and partners, wherever work happens: our office, remote work, client and industrial sites, business travel, company events, and written or electronic communication including chat, email, video calls and social media.

2. What counts as harassment

Workplace harassment (acoso laboral) is any repeated or serious conduct, by a person at any level, that humiliates, intimidates, isolates or degrades another person or interferes with their work. It includes bullying, verbal abuse, threats, public ridicule, deliberate exclusion, sabotage of someone's work and the abuse of authority.

Sexual harassment is any unwelcome conduct of a sexual nature, whether verbal, non-verbal, physical or electronic. It includes both conduct that makes submission a condition of employment or advancement, explicitly or implicitly, and conduct that creates an intimidating, hostile or offensive environment. Mexican law distinguishes hostigamiento sexual (by a person in a position of power) from acoso sexual (between people at any level); both are prohibited here.

Discriminatory harassment is harassment directed at a person because of any characteristic protected under our Equal Opportunity, Diversity and Inclusion Policy.

Retaliation is any adverse action against a person because they reported harassment, supported someone who did, or took part in an investigation.

Conduct is judged by its effect on the person who experiences it, not only by the intent of the person who engages in it. A single serious incident is enough.

3. Prohibited conduct

The following are prohibited. The list gives examples and is not exhaustive.

4. Responsibilities

Everyone is responsible for treating others with respect, for not engaging in the conduct described above, and for not ignoring it when they see it. Anyone who witnesses harassment is encouraged to intervene if safe to do so and to report it.

Anyone who manages others, and the Chief Executive Officer in particular, is additionally responsible for modeling respectful behavior, acting on any report or sign of harassment immediately even if no formal complaint is made, keeping the matter confidential, and ensuring no one suffers retaliation. A manager who knows of harassment and does nothing violates this policy.

When our personnel work at a client site, the client's own harassment rules apply alongside this policy, and a report can be made under either.

5. Reporting and investigation

Anyone who experiences or witnesses harassment can report it, in English or Spanish, through any channel in the Speak-Up and Remediation Procedure: to the Chief Executive Officer, or, if the report concerns the Chief Executive Officer or the person prefers, to the company's outside counsel, which receives reports independently of management. Reports can be made anonymously. There is no time limit for reporting.

Every report is acknowledged within two business days. Where the facts are disputed or the conduct is serious, an impartial investigation is opened, led by someone with no involvement in the events; where the report concerns the Chief Executive Officer, outside counsel appoints the investigator. The person who reported and the person accused are both heard, witnesses are interviewed, and relevant records are reviewed. Investigations are concluded within 30 days unless the complexity of the case requires more time, in which case both parties are told why. Both are informed of the outcome.

While an investigation is open we take interim measures to protect the person who reported, such as changing reporting lines or separating the people involved, never to their disadvantage. Information is shared only with those who need it to handle the matter.

6. Consequences and non-retaliation

Harassment is misconduct. Depending on its seriousness, the consequences are a written warning, mandatory training, removal of management responsibilities, dismissal for cause, or termination of a contractor, advisor or supplier relationship. Where the conduct may be a crime, we support the affected person in reporting it to the authorities and cooperate with any investigation.

Retaliation against anyone who reports in good faith, supports a report or takes part in an investigation is prohibited and is treated as seriously as the harassment itself. A report that turns out to be unfounded has no consequences for the person who made it in good faith; a knowingly false report is misconduct.

7. Review

The Chief Executive Officer owns this policy and reviews it at least once a year, taking into account any reports received and changes in the law of the jurisdictions where we operate. Everyone who works for Chronotope acknowledges this policy on joining and completes harassment-prevention training as part of the annual policy refresher.

Approved by Santiago Ampudia Castelazo, Chief Executive Officer, Chronotope Labs, Inc.