Equal Employment Opportunity

Purpose

Brannon Specialties, Inc. has a strong commitment to equal opportunity in the workforce and believes in treating people with dignity and providing equal employment and advancement opportunities for all. The Company values the unique contributions that each employee brings to his/her role within the Company and considers the variety of perspectives and backgrounds that exist within the Company a competitive advantage in the marketplace. The Company is committed to treating all employees fairly, without regard to any characteristics that have no bearing on job performance.

Scope

This policy applies to all employees and applicants of Brannon Specialties, Inc. In addition, this policy applies to all terms and conditions of employment, including, but not limited to, hiring, placement, promotion, termination, layoff, recall, transfer, leaves of absence, compensation, and training.

Policy

Brannon Specialties, Inc. is an Equal Employment Opportunity (EEO) employer and does not discriminate in any employer/employee relations based on race, color, religion, sex, sexual orientation, national origin, age, marital status, disability, veteran’s status or any other basis protected by applicable discrimination laws.

Objectives

Brannon Specialties, Inc. conducts business based on the following objectives:

• Recruit, hire, train, and promote persons in all job titles without regard to race, color, religion, sex, sexual orientation, national origin, age, marital status, disability, veteran’s status or any other basis protected by applicable discrimination laws.

• Make employment-related decisions in a manner that furthers the principles of EEO.

• Ensure all personnel actions, such as compensation, benefits, transfers, layoffs, returns from layoff, company-sponsored training, education, tuition assistance, social and recreation programs, are administered without regard to race, color, religion, sex, sexual orientation, national origin, age, marital status, disability, veteran’s status or any other basis protected by applicable discrimination laws.

Legal Requirements

Brannon Specialties, Inc. will comply with the following legal requirements as they pertain to EEO:

• Legally required notices will be openly displayed to ensure employee and applicant awareness of EEO policies.

• Company personnel actions at all facilities will conform to this policy and to federal, state and local statutes regarding fair employment practices.

Responsibilities

Brannon Specialties, Inc :

• Establish EEO policies.

• Monitor, enforce and support EEO to ensure compliance with the Company’s EEO policy, and federal, state and local requirements.

• Conduct periodic audits and report to management on EEO performance.

• Review all personnel actions on a regular basis to ensure equal opportunity exists for all employees.

• Maintain a non-hostile, harassment-free work environment.

• Investigate, discuss and take immediate and appropriate action on all employee discrimination complaints, and resolve these complaints to a satisfactory conclusion.

Reservation of Rights

Brannon Specialties, Inc.  reserves the right to interpret, modify, terminate or revise this policy, in whole or in part, without notice. No provision in this policy is to be construed as an employment contract nor does it alter an employee’s at-will status. Similarly, statements within this policy regarding behavior that may result in termination do not limit, in any way, the rights of the Company to terminate employees to only those behaviors described. The employee remains free to resign his or her employment at any time for any or no reason without notice. Similarly, the Company reserves the right to terminate any employee for any reason or for no reason without notice.