EQUAL EMPLOYMENT

Equal Employment Opportunity and Affirmative Action Policy

Fincantieri Marine Systems of North America Inc. (hereinafter referred to as “FMSNA”) provides equal employment opportunities (EEO) without regard to race, color, religion, sex, national origin, age, disability, marital status, veteran status, sexual orientation, genetic information or any other protected characteristics under applicable law. This policy relates to all phases of employment, including, but not limited to recruiting, employment, placement, promotion, transfer, demotion, reduction of workforce and termination, rates of pay or other forms of compensation, selection for training, the use of all facilities, and participation in all company-sponsored employee activities. Provisions in applicable laws providing for bona fide occupational qualifications, business necessity or age limitations will be adhered to by the company where appropriate.

As part of FMSNA’s equal employment opportunity policy, FMSNA will also take affirmative action as called for by applicable laws and Executive Orders to ensure that minority group individuals, females, disabled veterans, recently separated veterans, and other protected veterans, Armed Forces service medal veterans, and qualified disabled persons are introduced into our work force and considered for promotional opportunities. 

Employees and applicants shall not be subjected to harassment, intimidation or any type of retaliation 
because they have (1) filed a complaint; (2) assisted or participated in an investigation, compliance review, hearing or any other activity related to the administration of any federal, state, or local law requiring equal opportunity; (3) opposed any act or practice made unlawful by any federal, state, or local law requiring equal opportunity; or (4) exercised any legal right protected by federal, state, or local law requiring equal opportunity.

The above-mentioned policies shall be periodically reviewed by each supervisor and shall be 
appropriately administered. It is the responsibility of each supervisor of the company to ensure affirmative implementations of these policies to avoid any discrimination in employment. All employees are expected to recognize these policies and cooperate with their implementation. Violation of these policies is a disciplinary offense.

The Affirmative Action Officer has been assigned to direct the establishment and monitor the implementation of personnel procedures to guide our affirmative action program throughout FMSNA. A notice explaining the company’s policy will remain posted.