POLICY OVERVIEW

1. STATEMENT AND SCOPE

2. DEFINITIONS
2.1 Bullying and Harassment
2.2 Discrimination
2.3 Violence
2.4 Sexual Harassment

3. ORGANIZATIONAL RESPONSIBILITY
3.1 Anyone in a leadership role is expected to
3.2 All Employees are expected to
3.3 People Team is expected to

4. COMPLAINT PROCEDURES
4.1 How to Report
4.2 When to Report
4.3 Reporting Contact
4.4 Informal Resolution Option
4.5 What to Include in a Report

5. INVESTIGATION PROCEDURES
5.1 How and when Investigations will be Conducted
5.2 What will be Included
5.3 Roles and Responsibilities
5.4 Follow-up
5.5 Record-keeping Requirements

6. ANNUAL REVIEW

Instructions

1. Read the guidelines and procedures.

2. Don't bully, don't harass, and don't tolerate this type of behaviour.

1. STATEMENT AND SCOPE

Hootsuite Inc., including its subsidiaries around the world, (together, “Hootsuite”) is committed to providing an environment of mutual respect, free of harassment and discrimination for our employees, customers, contractors and suppliers and is supportive of the dignity, self-esteem and productivity of every employee. We will take immediate action to investigate and resolve any issues that may arise. These Guidelines apply to all employees, including permanent, temporary, casual, contract, and student workers.

2. DEFINITIONS

2.1 Bullying and Harassment

1. includes any inappropriate conduct or comment by a person towards a worker that the person knew, or reasonably ought to have known, would cause that worker to be humiliated or intimidated, but

2. excludes any reasonable action taken by an employer or supervisor relating to the management and direction of workers or the place of employment.

Harassment is a form of discrimination and may take the form of verbal or physical abuse, threats, derogatory remarks, inappropriate jokes, taunts or innuendo which demean or embarrass, whether it be one event or a series of events or a course of conduct.

2.2 Discrimination

Discrimination involves treating any person or a group of persons in an unfair way based on a prohibited ground, including race, religious beliefs, colour, place of origin, gender identity, gender expression, mental or physical disability, ancestry, marital status, family status, a criminal conviction, age, sexual orientation or any other characteristic prohibited by local laws and regulations.

2.3 Violence

Violence is the exercise of physical force by a person against an employee that causes or could cause physical injury to the employee. It also includes verbal confrontation and statements of behavior that could be interpreted as threatening. Examples of violence include: threats, coercing, abuse, physical injury, threatening notes/emails, sexual violence/harassment, destruction of company property, bullying, and harassment.

2.4 Sexual Harassment

Sexual harassment is any sexual comments, gestures or physical contact that is known or ought reasonably to be known to be unwelcome, objectionable or offensive, either on a one-time basis or on a continuous basis. Sexual harassment can occur between any two or more people, and may involve people: of different genders; of the same gender; or who do not identify as male or female. Examples of sexual harassment include: questions or remarks about sex life; offers of job-related benefits in return for sexual favours; displaying or disseminating pornographic, sexist, or demeaning materials; repeated, unwanted requests for dates; and obscene gestures or leering.

3. ORGANIZATIONAL RESPONSIBILITY

3.1 Anyone in a leadership role is expected to

1. Lead by example and treat employees and co-workers with dignity and respect, and immediately identify and intervene in any inappropriate workplace behaviour.

2. Ensure complete confidentiality if they are included in any investigation or have knowledge of any incident; cooperate in any investigation where they may be identified as a complainant (the person making a report), respondent (the person alleged to have breached these Guidelines), or witness. Ensure compliance with our guidelines and relevant human rights legislation.

3. Immediately inform a member of Hootsuite’s People Team of any complaints.

3.2 All Employees are expected to

1. Treat co-workers with dignity and respect and either stop or report to their supervisor any incidents they think may constitute harassment. Should an incident involve one’s own supervisor, the employee should contact their Manager's superior or a member of the People Team.

2. Cooperating fully and in good faith in any investigation where they may be identified as a complainant, respondent, or witness.

3. Not engage in, and to prevent, workplace discrimination and harassment from happening and to help stop it when it occurs.

4. Report unresolved incidents of inappropriate workplace behaviour to their Manager or People Team.

3.3 People Team is expected to

1. Administer and communicate the intent and Guidelines of this document to all existing and new employees.

2. Promptly investigate complaints made.

3. Recommend appropriate disciplinary action to be taken where discrimination or harassment is determined to have occurred.

4. Make every effort to keep complaints as confidential as possible.

5. Maintain, on a confidential basis, all files and documents of complaints of harassment and subsequent action.

4. COMPLAINT PROCEDURES

This Policy outlines both informal and formal options available to any employee of Hootsuite who believes they have been bullied or harassed in violation of this policy. Regardless of whether a complaint is made or not, Hootsuite reserves the right to unilaterally investigate any behaviour it considers a violation of this, or any other, policy. Hootsuite also reserves the right to:

1. treat a complaint as a formal complaint or an informal complaint, and/or to proceed with a complaint, regardless of the wishes of the complainant; and/or
2. appoint an external or internal investigator(s) as the situation merits.

4.1 How to Report

All employees at Hootsuite can report incidents or complaints of workplace bullying and harassment verbally or in writing. When submitting a written complaint, please use the Respectful Workplace bullying and harassment complaint form found on the internal wiki. When reporting verbally, the reporting contact, along with the complainant, will fill out the complaint form.

4.2 When to Report

Incidents or complaints should be reported as soon as possible after experiencing or witnessing an incident. This allows the incident to be addressed promptly and, if applicable, investigated.

4.3 Reporting Contact

Report any incidents or complaints to a member of management and/or a member of the People Team. If your Manager, or the reporting contact is the person engaging in bullying and harassing behaviour, contact another member of management or a member of the People Team.

4.4 Informal Resolution Option

In many situations, simply informing the person that their behaviour is unwelcome will resolve the issue. Telling the person to stop may be difficult, but frequently it is the most effective means of eliminating the problem. If it is to difficult to speak to the person directly or if the behaviour persists, the matter should be discussed with your Manager, or another member of management or a member of the People Team with whom you are comfortable discussing the matter.

Your Manager (or the People Team) will assist in the resolution of the matter and for that purpose may:

• address the matter informally with the person, or accompany you in doing so;

• in consultation with the parties, attempt mediation to resolve the matter; or

• in particularly serious circumstances, request that Hootsuite initiate a formal investigation of the matter.

The Manager (or Reporting Contact) will keep you apprised of the steps being taken to address the matter, including any proposed resolution initiatives.

4.5 What to Include in a Report

When submitting a formal written complaint, provide as much information as possible in the report, such as:

• The names of people involved;

• The names of witnesses;

• The date and location of the events;

• What behaviour and/or words led to the complaint; and

• Any supporting documents, such as emails, handwritten notes, or photographs. Physical evidence, such as vandalized personal belongings, can also be submitted.

If you would like assistance in drafting the formal written complaint, please speak to your Manager (or People Partner).

No Hootsuite employee will face discipline or repercussion for reporting, in good faith, a breach or suspected breach of these Guidelines. “Good faith” includes situations where the complaint is based on a mistake, a misunderstanding, or where the complaint cannot be proven.

Nothing in these Guidelines precludes an employee from pursuing other avenues of redress, including making a complaint under local criminal or human rights laws.

5. INVESTIGATION PROCEDURES

5.1 How and when Investigations will be Conducted

Most investigations at Hootsuite will be conducted internally. In complex or sensitive situations, an external investigator might be hired.

Investigations will:

• Be undertaken promptly and diligently, and be as thorough as necessary, given the circumstances.

• Be fair and impartial, providing both the complainant and respondent equal treatment in evaluating the allegations. This includes providing the respondent with a full understanding of the allegations made against him/her.

• Be sensitive to the interests of all parties involved, and maintain confidentiality to the extent permitted by the investigation. Information relating to the complaint will be disclosed only to the extent necessary to carry out the procedures under these Guidelines, or where disclosure is required by law.

• Be focused on finding facts and evidence, including interviews of the complainant, respondent, and any witnesses.

• Incorporate, where appropriate, any need or request from the complainant or respondent for assistance during the investigation process.

5.2 What will be Included

Investigations will include interviews with the complainant, the respondent, and any witnesses. If the complainant and the respondent agree on what happened, then Hootsuite will not investigate any further, and will determine what corrective action to take, if necessary. The investigator will also review any evidence, such as emails, handwritten notes, photographs, or physical evidence like vandalized objects.

5.3 Roles and Responsibilities

Managers and Supervisors are responsible for ensuring workplace investigation procedures are followed.

Employees are expected to fully cooperate with investigators and provide any details of incidents they have experienced or witnessed.

The People Team will conduct investigations and provide a written report with conclusions.

5.4 Follow-up

A member of the People Team will advise the complainant and the respondent of the investigation findings.

Following an investigation, the People Team will review and revise workplace procedures to prevent any future bullying and harassment incidents in the workplace. Appropriate corrective actions will be taken within a reasonable time frame. Corrective action resulting from a violation of these Guidelines may include: a) an apology; b) educational training; c) counseling; d) reassignment; e) probation; f) a suspension, with or without pay; or g) dismissal, with or without notice.

In appropriate circumstances, workers may be referred to the employee assistance program or be encouraged to seek medical advice.

5.5 Record-keeping Requirements

Hootsuite expects that workers will keep written accounts of incidents to submit with any complaints. Hootsuite will keep a record of investigations, including investigation notes, evidence collected, and findings, as required by applicable laws.

6. ANNUAL REVIEW

This guidelines statement will be reviewed every year. All workers will be provided access to a copy.