I. PURPOSE

At Meta, we believe it is essential to provide Meta Personnel with a respectful and safe working environment. As a result, we do not tolerate harassment or any mistreatment of Meta Personnel in the workplace or work-related situations. The purpose of this Policy is to deter conduct that is unwanted, unreasonable, and demeaning.

II. DEFINITIONS

• Meta is explained here, including: All of Meta, including all subsidiaries and affiliates worldwide (e.g., Facebook Ireland, Instagram, WhatsApp, etc.).
• Meta Personnel is defined here as members of the Board of Directors, officers, and employees of Meta, as well as contingent workers (including vendor workers, contractors, consultants).

III. SCOPE & APPLICABILITY

The expectations of this Policy apply to everyone who works for Meta and any of its subsidiaries. Everyone — including individual contributors, managers, and contingent workers — is responsible for following and upholding this Policy. Additionally, we do not tolerate harassment of Meta Personnel, nor do we tolerate harassment of non-Meta Personnel.

This Policy applies to conduct at work and at work-related social events, office parties, off-sites, client entertainment events, including online or through other methods of communication used by Meta Personnel. Meta Personnel are expected to be particularly careful about what they say and do in these circumstances.

In the event of any inconsistency between this Policy and local laws (including any definition of harassment), local laws will apply unless this Policy provides greater protection.

IV. INTRODUCTION

At Meta, we believe it is essential to provide all Meta Personnel with a respectful and safe working environment. As a result, we do not tolerate harassment or any mistreatment of Meta Personnel in the workplace or work-related situations, including unlawful harassment, on the basis of the following protected categories:

• race, color, ethnic or national origin;
• age;
• religion or religious creed (or belief, where applicable);
• sex, including pregnancy, childbirth, breastfeeding, reproductive health decisions, or related medical conditions;
• sexual orientation;
• gender, gender identity, gender expression, transgender status, or sexual stereotypes;
• nationality, immigration status, citizenship, or ancestry;
• marital status;
• protected military or veteran status;
• physical or mental disability, medical condition, genetic information or characteristics (or those of a family member);
• political views or activity;
• status as a victim of domestic violence, sexual assault or stalking; or
• any other basis prohibited under federal, state, or local law.

Harassment under this Harassment Policy (Policy) may include conduct that creates a disrespectful, intimidating, hostile, degrading, humiliating, or offensive environment for an individual. Engaging in such conduct is a violation of this Policy.

Because the intent of this Policy is to deter conduct that is unwanted, unreasonable, and demeaning, Meta may consider an individual's conduct to be in violation of this Policy even if it falls short of unlawful harassment under applicable law. When determining whether conduct violates this Policy, we consider whether a reasonable person could conclude that the conduct created an intimidating, hostile, degrading, or demeaning environment.

All Meta managers globally are required to attend our mandatory sexual harassment training, which includes a comprehensive review of this Policy and applicable law.

V. EXAMPLES OF HARASSMENT

Harassment can range from extreme forms such as violence, threats, or physical touching to less obvious actions like ridiculing, teasing, or repeatedly bothering colleagues or subordinates or refusing to talk to them.

For example, harassment may include the following types of conduct:

• derogatory or insensitive jokes, pranks, or comments;
• slurs or epithets;
• unwelcome sexual advances or invitations;
• non-verbal behavior such as staring, leering, or gestures;
• ridiculing or demeaning comments;
• innuendos or veiled threats;
• intentionally excluding someone from normal workplace conversations and making them feel unwelcome;
• displaying or sharing (1) offensive images such as posters, videos, photos, cartoons, screensavers, emails, or drawings that are derogatory or sexual, or (2) symbols of hate directed at race, religion or other protected categories;
• offensive comments about appearance, or other personal or physical characteristics, such as sexually charged comments or comments on someone's physical disability;
• unnecessary or unwanted bodily contact such as groping or massaging, blocking normal movement, or physically interfering with the work of another individual; or
• threats or demands that a person submit to sexual requests as a condition of continued employment or to avoid some other loss, and offers of employment-related benefits in return for sexual favors.

This list of examples is not exhaustive, and there may be other behaviors that constitute unacceptable harassment under this Policy.

"I was joking" or "I didn't mean it that way" are not defenses to allegations of harassment. Nor is being under the influence of alcohol or other substances.

Sexual Harassment

Sexual harassment is harassment specifically based on sex, and/or unwanted conduct of a sexual nature and may include:

• Hostile Work Environment: Conduct that has the purpose or effect of unreasonably interfering with an individual's work performance or creating an intimidating, hostile, or offensive working environment; and
• Quid Pro Quo Harassment: Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when submission to such conduct is made either explicitly or implicitly a term or condition of an individual's employment, or when submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting that individual.

Sexual harassment can happen regardless of the individuals' gender, gender identity, or gender expression and can, for example, occur between same-sex individuals as well as between opposite-sex individuals, and does not require that the harassing conduct be motivated by sexual desire.

VI. BULLYING

Meta does not tolerate bullying. Bullying may include abusive conduct, or other intimidating, aggressive, offensive, malicious or insulting behavior. Bullying includes an abuse of power which is intended to undermine, exclude, humiliate, or demean an individual covered by this Policy, whether or not it is based on a protected category. If an individual is found to be bullying their colleagues, we will take appropriate action to stop the behavior.

If you would like to report behavior that you believe is bullying, you may use the same reporting procedures outlined below.

VII. REPORTING PROCEDURES

Managers at Meta are required to promptly (ideally, within 24 hours) report any violation or suspected violation of this Policy. Managers who receive a complaint of, or learn of, information that suggests this Policy may have been violated are required to promptly (ideally within 24 hours) forward that complaint to HR/ER/Employment Law, and will be subject to discipline for failing to timely report. As soon as reasonably possible, the Company will investigate any allegations and take appropriate remedial action.

Any employee who believes they have been harassed, discriminated, bullied or retaliated against or has witnessed or heard about a potential violation of this Policy, should report the conduct so that Meta can take steps to remedy any violations of the Policy.

If you suspect harassment, discrimination, bullying, or retaliation (see our Policy Prohibiting Retaliation below) has occurred, you are encouraged (and managers are required) to promptly provide a written or oral complaint to any of the following:

• Any Human Resources Business Partner (HRBP) or Employee Relations Business Partner (ERBP);
• Employment Law; or
• SpeakUp, Meta’s concern reporting system.

When possible, a complaint should include details of the incident or incidents, names of individuals involved, and names of any witnesses. You also have the option of using Meta's Discrimination, Harassment, Bullying, & Retaliation Complaint Form, which may be Submitted to your HRBP, ERBP or Employment Law.

For any New York or California based employees, please see the appendix for further guidance on reporting procedures.

Any contingent worker should report any concerns to their employer.

We will keep all complaints confidential to the extent possible while still fulfilling our obligation to investigate and end any harassing conduct.

VIII. INVESTIGATIONS PROCESS

Meta has a legal obligation to promptly investigate and respond to all complaints regarding potential violations of this Policy. Upon learning of conduct requiring further review, company investigators will complete thorough investigations in a timely and impartial manner.

All persons to whom a complaint is made or who learn of a complaint as part of a Meta investigation must do everything reasonably possible to keep the complaint confidential in order to preserve the integrity of the investigation while it is ongoing, to ensure fairness to all involved, and to protect the privacy of Meta Personnel who have brought complaints or are accused of misconduct.

Meta Personnel must cooperate, be respectful, and provide truthful information in an investigation.

Nothing in this Policy is to be construed as a guarantee of absolute confidentiality or intended to curtail employee rights under the law to discuss work-related matters. Disclosure of information learned through the complaint process and the investigation will be limited to disclosures that are necessary for Meta to fulfill its legal obligations to investigate and take prompt action to end harassment.

IX. POLICY PROHIBITING RETALIATION

We recognize that employees may find it difficult to raise complaints about harassment, discrimination and/or other violations of this Policy, so we have a policy meant to encourage employees to come forward with their concerns without fear of retaliation.

It is against Meta policy (and may be unlawful) for any employee to retaliate against another for their participation in the complaint process or opposition to harassment or discrimination.

Retaliation is when someone penalizes another person for any of the following:

• Reporting what they believe in good faith to be harassment, discrimination and/or a violation of this Policy;
• Expressing an intent to report what they believe in good faith to be harassment, discrimination and/or a violation of this Policy;
• Assisting another employee in an effort to report harassment, discrimination and/or a violation of this Policy;
• Participating in any investigation under this Policy; or
• Opposing conduct that they believe in good faith to be harassment, discrimination and/or a violation of this Policy.

Retaliating against Meta Personnel who made a complaint or otherwise participates in the investigation process or opposes harassment or discrimination is grounds for discipline, up to and including termination.

If you have questions about this Policy, please contact your HRBP, ERBP, or Employment Law.

X. STANDARD LANGUAGE

1. ENFORCEMENT

A violation of this Policy or law may result in disciplinary action up to and including termination of employment for Meta employees or removal from Meta’s account for contingent workers, subject to applicable law. For Meta managers, please be aware of your responsibilities under the Code of Conduct to report compliance concerns and alleged or known policy or legal violations to your Employee Relations Business Partner, Human Resources Business Partner, or Legal.

XI. RESOURCES

• Code of Conduct
• Whistleblower and Complaint Policy

XII. APPENDIX

A. US-Specific Guidance

1. For those based in the US, all new hires sign a mutual arbitration agreement with Meta, which requires claims to be adjudicated by an arbitrator instead of a court of law. Please note, however, that for any potential sexual harassment claims, employees have the option of either bringing an action in arbitration or a court of law - it is the employee’s choice.

2. The Federal Equal Employment Opportunity Commission (EEOC) and the California Department of Fair Employment and Housing (DFEH) investigate and prosecute complaints of prohibited harassment, discrimination, and retaliation in employment. If you think you have been harassed or discriminated against, or that you have been retaliated against for resisting, complaining or participating in an investigation, you may file a complaint with the appropriate agency. The nearest office can be found by visiting the agency websites at www.dfeh.ca.gov and www.eeoc.gov.

i. For California-based employees: To learn more about sexual harassment, see the California Department of Fair Employment and Housing's information sheet.

3. New York employees may also file a complaint with the New York State Division of Human Rights and/or the New York City Commission on Human Rights. New York Human Rights Law (HRL) allows employees to file a complaint with the New York State Division of Human Rights (DHR) alleging violation of Human Rights Law. Complaints with DHR may be filed any time within one year of the harassment. If an individual did not file at DHR, they can sue directly in state court under the HRL, within three years of the alleged discrimination. An individual may not file with DHR if they have already filed an HRL complaint in state court.

i. Raising an internal complaint does not extend your time to file with DHR or in court. The one year or three years is counted from date of the most recent incident of harassment. You do not need an attorney to file a complaint with DHR, and there is no cost to file with DHR.

ii. DHR will investigate your complaint and determine whether there is probable cause to believe that discrimination has occurred. Probable cause cases are forwarded to a public hearing before an administrative law judge. If discrimination is found after a hearing, DHR has the power to award relief, which varies but may include requiring your employer to take action to stop the harassment, or redress the damage caused, including paying monetary damages, attorney's fees and civil fines.

iii. DHR's main office contact information is: NYS Division of Human Rights, One Fordham Plaza, Fourth Floor, Bronx, New York 10458, (718) 741-8400 www.dhr.ny.gov. Contact DHR at (888) 392-3644 or visit dhr.ny.gov/complaint for more information about filing a complaint. The website has a complaint form that can be downloaded, filled out, notarized and mailed to DHR.

iv. The website also contains contact information for DHR's regional offices across New York State.

v. New York employees may also file complaints of sexual harassment with the New York City Commission on Human Rights. Contact their main office at Law Enforcement Bureau of the NYC Commission on Human Rights, 40 Rector Street, 10th Floor, New York, New York; call 311 or (212) 306-7450; or visit www1.nyc.gov/site/cchr/index.page.

Below we are sharing our internal FAQ for employees on Meta’s investigations process:

Who’s It For?

This outline applies to Meta’s US offices. Outside the US, the investigations process varies depending on local law. Contact the Employment Law Team if you have region-specific questions.

Why Do We Conduct Workplace Investigations?

When we learn about a potential violation of Meta policy or law, it’s our job and obligation to investigate, and when a violation of Meta policy or law is found, to stop the misconduct. Our goal is to create a safe and respectful environment where everyone can come and do their best work.

What Do We Investigate?

A few examples of the types of matters we investigate include complaints about harassment and discrimination, disclosure of confidential or proprietary information, improper conflicts of interest, and abuse of company resources.

Some of these topics are sensitive, and we want people to feel as comfortable as possible coming to us with concerns. To that end, we try to keep matters as confidential as possible.

How Do I Report a Potential Violation of Law or Policy?

If you see or hear of something that might be a violation of Meta policy or law, we encourage you to speak up. If you are a manager, you are required to report any potential violations to HR. Meta provides a variety of channels for people to report concerns:

1. Any Human Resources Business Partner (HRBP) or Employee Relations Partner (ERP)
2. Employment Law
3. Anonymous Whistleblower Hotline

Should I Be Concerned About Retaliation?

No. The law protects employees from retaliation for reporting or participating in an investigation, as does Meta policy. We have a zero-tolerance policy when it comes to unlawful retaliation. Specifically, Meta’s Harassment Policy encourages employees to come forward with their concerns and participate in the investigations process, all without fear of retaliation.

Who Conducts the Investigation?

Once a concern has been raised, our Investigations Team, an independent and impartial function within the People Team, conducts a prompt and thorough investigation to determine facts. Each investigation is tailored to the specific issues being investigated and is also documented and tracked to ensure reasonable progress and timely closure of the investigation. Findings are then shared with a very small group of people, generally folks in HR and Legal, on a need-to-know basis. The Investigations Team is not the decision maker, but simply a fact finder tasked with reaching reasonable conclusions.

How are employees involved in investigations?

If you’re asked to participate in an investigation, here’s what you can expect:

1. Prior to the meeting: A member of the Investigations Team will reach out to you by email to schedule a meeting. You do not need to prepare for the meeting unless specifically requested to do so. Given the sensitive nature of an investigation, you will be asked to keep this information as confidential as possible. Our Investigations Team generally does not provide context for the meeting at this stage of the process. If you experience stress as a result of being invited to this meeting and need someone to talk to, reach out to your HR Business Partner or ER Partner.
2. During the meeting: There will likely be two people from the Investigations Team in the room during the meeting. One will be there to take notes. You’ll be asked a variety of questions about a particular topic. It’s important that you be open and honest in your responses. The Investigations Team is committed to being respectful, impartial, and professional during the meeting.
3. Following the meeting: To protect confidentiality and to ensure fairness to everyone involved, we may not be able to answer specific questions about an investigation, but the Investigations Team will reach out to you to inform you that the matter has been addressed and closed. Contact the lead investigator or your HR Business Partner or ER Partner if you have follow up questions or need help.

Do I Have to Participate in an Investigation if Asked?

Yes. Our people have an obligation to participate in an investigation.

Do I Have to Report a Meta Policy Violation?

We ask everyone who works for Meta to report a potential violation of policy or law, but if you are a manager, you are required to report anything that comes to your attention. If you have questions about what that might look like, refer to our Corporate Policies, which includes our Code of Conduct and Harassment Policy. You can also ask your HR Business Partner or ER Partner.

Will My Manager Find Out if I’m Meeting With the Investigations Team?

Not necessarily. Information regarding the investigation is shared on a need-to-know basis. There are many instances where a manager doesn’t need to know that you are participating in an investigation.

Will This Meeting Be Recorded?

No, but notes may be taken.

Who Can I Talk to About This Investigation?

Contact the lead investigator who reached out to you initially or your HR Business Partner or ER Partner. To protect the confidentiality of the investigation, you should not speak to anyone else, including your manager, about this investigation. As a result we may not be able to answer specific questions about an investigation but are happy to talk to you about the process.

What Are the Outcomes of an Investigation?

Outcomes range from no action to education, coaching or counseling, warnings, and other disciplinary actions up to and including termination. Outcomes are usually determined by business leaders with input from HR and Legal.

Why Do You Ask That I Keep the Investigation Confidential?

In order to preserve the integrity of the investigation while it is ongoing, to ensure fairness to all involved, and to protect the privacy of employees who have brought complaints or are accused of misconduct. Additionally, keeping things confidential helps minimize retaliation against participants and minimizes disruption in the workplace. Our request for confidentiality is not meant or intended to curtail your rights under the law to discuss work-related matters.

Below are tips and guidelines from Meta’s Employment Law Team on how to run successful anti-harassment training:

Training managers and supervisors on the prevention of harassment, discrimination, and retaliation is key to making sure supervisors understand your company’s policies, the law, and what’s expected and required of them to root out bad behavior. For all but the smallest employers in California, training supervisors is required by law.

The required training is intended to accomplish the following goals:

• assist employers in changing or modifying workplace behaviors that create or contribute to sexual harassment;
• provide participants with information related to the negative effects of bullying; and
• develop, foster, and encourage a set of values in supervisory employees that will assist them in preventing, effectively responding to incidents of sexual harassment, and implementing mechanisms to promptly address and correct wrongful behavior.

And the training is required to address the following topics:

• information regarding the federal and state statutory provisions concerning the prohibition against and the prevention and correction of sexual harassment;
• the remedies available to victims of sexual harassment in employment;
• information about the prevention of bullying in the workplace;
• harassment based on gender identity, gender expression, and sexual orientation; and
• practical guidance and examples aimed at instructing supervisors in the prevention of harassment, discrimination, and retaliation.

Below is an outline of what’s required to be included in the training and who can lead the training. For additional detail and before you launch your training, it’s recommended that you review the legal requirements (here) and the resources provided by the California Department of Fair Employment and Housing (here). This overview is not intended to constitute legal advice and should not replace your review of the legal requirements.