Rare’s safeguarding and sustainability policies.

Inclusion, equality, diversity, anti-bullying and sustainability.

COMPANY PLEDGE

As a Company we pledge to:

• Actively seek to increase the number of people we work with who are from groups/communities that are under-represented in the television industry, or in particular job roles in the industry.

• Review all our formal and informal employment/hiring practices and procedures to ensure they are fair and help us to identify the best talent.

• Identify and take opportunities to increase the diversity of casting decisions

• Ensure reasonable adjustments are made to enable disabled people to work in or with our company, both on and off screen.

• Actively seek to increase the diversity of our talent networks.

• Create an environment in which individual differences and the contributions of all our staff and freelancers are recognised and valued.

• Ensure every employee and freelancer can work in an environment that promotes dignity and respect for all. We will not tolerate any form of intimidation, bullying or harassment.

• Ensure training, development and progression opportunities are available to all staff.

• We believe that being a company with a fully diverse workforce is key to our future success. With that in mind we are committed to working to fully reflect the diversity of the United Kingdom and Ireland in what we do.

• We will monitor the success of this policy regularly and our review our progress at least once a year. We have developed an action plan to help us implement this policy. The person who is responsible for ensuring this action plan is implemented is our CEO, Alexander Gardiner.

• This policy is fully supported by the senior management of the company. Breaches of the policy may be regarded as misconduct and could lead to disciplinary proceedings.

SAFEGUARDING & STANDARDS OF CONDUCT

The following applies to all Rare TV policies contained herein, as follows:

• DIVERSITY, EQUALITY AND INCLUSION POLICY

• ANTI-BULLYING POLICY

• ANTI-HARRASSMENT (INCLUDING SEXUAL HARRASSMENT) POLICY

• ANTI-VIOLENCE POLICY

Training

The Company may implement what training it considers necessary in relation to behavioural standards and where appropriate will hold meetings to address standards, expectations and any issues.

The frequency, dates and form of this training and meetings will be determined by management of the Company, and will be communicated to staff, as necessary and new starters in the Company Welcome Pack. Managers and Supervisors may be asked to undertake ad ditional training, and it is theresponsibility of workers to complete all necessary mandatory training within the timeline outlined by the Company.

Everyone who works at the Company is required to complete the following mandatory training modules before they start, or on their first working day:

1. 2. 3. 4. Tackling Harassment and Bullying at Work – e-learning module, approx. 30 mins
Tackling Unconscious Bias – e-learning module, approx. 30 mins
Introduction to Mental Health Awareness – e-learning module, approx. 20 mins
Introduction to sustainability for the screen industries – e-learning module approx. 35 mins.

All Executive Producers, Series Producers/Showrunners, Line Producers and Production Managers are also required to complete the following additional training, in line with most broadcaster requirements.

1. Bullying & Harassment Training – online interactive webinar, approx. 1.5 hours, held every

2. few weeks so individuals need to book on as spaces becomes available.

Equality & Inclusion Essentials – online interactive webinar, approx. 1.5 hours, held every few weeks so individuals need to book on as spaces becomes available.

Communication

The company will monitor and review its Policies and approaches on a regular basis and take on board feedback from workers to ensure safeguarding and reporting procedures remain effective. It may unilaterally introduce, vary, remove or replace any of the Polic ies herein at any time.

Open lines of communication are encouraged between team members, and in reporting up to or seeking support from Managers and Supervisors. The senior team at the Company operate an open-door policy. The Company values the feedback of everyone it works with in continuing to evolve the culture of the Company.

The Company strives to maintain a creative, inclusive, and respectful working environment for staff and freelancers alike, and to help maintain these standards, it asks all leavers to complete an Exit Form questionnaire to provide an honest account of thei r time at Rare TV. Alternatively, leavers can request a phone call with a member of the senior team. This feedback assists the Company in identifying any gaps in training and communication among the team and ensures it can implement any necessary changes going forward.

The forms are confidential, and as such, are NOT shared with anyone outside of Production Executive, Claire Riddell (who sends the forms) the CEO (Alexander Gardiner) and Head of Production (Ben Sutton). The Company will contact any workers who raise conce rns in their responses, or if the Company identifies anything in their reply it feels needs to be addressed further, to discuss how the Company intends to do this before any action is taken.

Reporting

The Company recognises the need for open communication and suitable reporting channels in the workplace. Complaints of bullying, harassment and workplace violence will be taken seriously and will be handled in accordance with the Company’s Grievance Handli ng Policy.

Formal complaints should be directed to the CEO Alexander Gardiner or Head of Production Ben Sutton. However, if you prefer to speak in confidence to another member of staff Susanna Zeff and Karen Kennedy are our designated whistle -blowing champions and can offer independent support and advice.

If you make a complaint of workplace bullying, harassment or violence it will be taken seriously and will be dealt with sympathetically and in a confidential manner (except where the Company deems itis necessary to disclose information to properly deal with the complaint). You will not be victimised or treated unfairly for making a complaint.

If the claim is found to be substantiated, the Company will act in accordance with its Disciplinary & Termination Policy.

Please note that any worker found to have fabricated a complaint may be subject to disciplinary action under the Disciplinary & Termination Policy, up to and including termination of employment.

Support Resources

Employee Assistance Programme (EAP)

An EAP is a confidential employee benefit designed to help you deal with personal and professional problems that could be affecting a worker’s home life or work life, health, and general wellbeing.

Rare TV has an employee assistance programme (EAP) in place, which all staff and freelancers employed by Rare TV and Rare TV Ireland are welcome to use – services include:

· formal counselling (face-to-face or telephone sessions)

· online video counselling

· online CBT

· critical incident support

The EAP provider is British Association for Counselling and Psychotherapy (BACP) accredited, and a member of the Stonewall Diversity Program. Services are available in 240+ languages, and conversations are confidential (except where the individual or someone else is identified to be at risk). Please contact Claire Riddell, Production Executive (GMT) or the relevant Line Producer / Production Manager for details of how to access EAP services.

Some workers may also qualify to benefit from network support resources depending on the production they’re working on - please contact the relevant Line Producer / Production Manager for details.

Film & TV Charity

The charity operates a free and confidential 24/7 Support Line 0800 054 0000 for everyone working behind the scenes in film, TV, and cinem a. Workers can also email support@filmtvcharity.org.uk, or speak to someone through their Live Chat (mention “accessing the service via the Film and TV Support Line”) to arrange a call back from a counsellor (if no advisors are available (due to high traffic), please wait and try again later). Further details are available here: https://filmtvcharity.org.uk/your-support/24-hour-support-line/.

The charity’s Bullying and Support pages can be accessed here https://filmtvcharity.org.uk/your-support/bullying/.

Mental health and well-being support for freelancers can be found here https://filmtvcharity.org.uk/your-support/mental-wellbeing/freelancer-hub/Mental Health First Aider

Claire Riddell (GMT) is the company Mental Health First Aider, and workers can reach out to her in confidence.

Some of the SPs and PMs on productions are also Mental Health First Aiders, workers should check call sheets / risk assessment for details.

Whistleblower Support

Should any workers experience or witness bullying, or harassment, they can reach out to their Line Manager, or if they do not feel comfortable doing this, they can reach out to the Company Whistleblowers in confidence:

Susannah Zeff

Karen Kennedy (Dublin based)

For independent whistle-blowing advice the charity Protect can be reached here https://protect-advice.org.uk/

Expectations of Managers and Supervisors

Managers and supervisors have an important role to play in implementing the Company Code of Conduct, by fostering a culture that does not tolerate or encourage harassment, bullying or workplace violence and should ensure that they do not engage in any conduct of this nature themselves. They must clearly communicate the Company Policies contained herein to workers, and ensure they understand them, as well as the consequences of non-compliance.

Managers and Supervisors must do the same on individual productions and include examples of the specific risks and mitigating controls in place to safeguard team members, on their series risk assessment.

When managers and supervisors observe harassment, bullying or workplace violence occurring, they must take steps to prevent this conduct from continuing and warn the person or people involved of the consequences if the behaviour continues (including disciplinary measures up to and including

termination of employment). All grievances raised by workers must be handled in accordance with the Company’s Grievance Handling Policy.

Expectations of Workers

The Company expects workers not to engage in harassment, bullying or workplace violence, or aid, abet or encourage others to engage in harassment, bullying or workplace violence .

Workers must behave in a responsible and professional manner and treat others in the workplace with courtesy and respect.

The Company expects workers to listen and respond appropriately to the views and concerns of others, and to be fair and honest in their dealings with others in the workplace.

The Company requires workers to disclose family relationships and mutually consensual inter-worker relationships to their Line Manager, as follows:

• Inter-worker relationships – when a worker is in a relationship with a supervisor, when both workers are in the same department or working on the same production, or if they are in a relationship with a client, supplier, or customer.

• Family relationships – immediately (e.g. a worker’s parent is their line manager)

Family and inter-worker relationships have the potential to encourage favouritism and may present a conflict of interest in the workplace, likewise, their breakdown may create tension in the team,disrupt a production or lead to reports of sexual harassment. It’s important the Company is made aware of these relationships as soon as possible, as it may decide to put plans in place to mitigate these risks early on.

All workers are required to comply with the Company’s Equal Opportunity and Anti-Discrimination Policy which provides further guidance in this area.

Expectations of Clients, Suppliers, Customers and Co-Producers

Rare TV expects its clients, suppliers, customers and co-producers to maintain similar zero-tolerance policies towards harassment, bullying and workplace violence, as its own, and ensure that they do not engage in any conduct of this nature themselves.

Interactions between workers and clients, suppliers , customers and co-producers must be conducted in a courteous, respectful and professional manner. Should a worker have concerns regarding interactions with any clients, suppliers , customers and co- producers they must report it to the CEO, Alexander Gardiner or Head of Production, Ben Sutton. All complaints will be taken seriously and reported in confidence to the appropriate .

DIVERISTY, EQUALITY AND INCLUSION POLICY

Rare Television recognises that diversity and inclusion help to support creativity and innovation: they are an essential ingredient in a successful television company. We believe having a diverse workforce is something to be celebrated, enriches all who ar e part of it and are committed to achieving it.

We are committed to eliminating unlawful discrimination and promoting equality, diversity and inclusion in our own policies, practises and procedures and in influencing others we work and deal with, while doing business, to do the same.

We aim to treat everyone equally and with the same attention, courtesy and respect regardless of their age, disability, gender, marital status, race, racial group, colour, ethnic or national origin, nationality, religion, belief, social economic background or sexual orientation.

This Policy applies to employed and freelance staff and to people working both on and off screen. All will be treated fairly and with respect.

Senior leaders have a defining influence on the working culture and set the tone for expectations. They need to embed and live the values and behaviour that underpin dignity, respect and inclusion.

Discrimination

Discrimination means treating someone 'less favourably' than someone else, because of the following ‘protected characteristics’ (protected by law) even if the less favourable treatment is not intended:

• age

• disability

• gender reassignment

• marriage and civil partnership

• pregnancy and maternity

• race

• religion or belief

• sex

• sexual orientationLess favourable treatment can be anything that puts someone with a protected characteristic at a disadvantage, compared to someone who does not have that characteristic. There's no legal definition of 'putting someone at a disadvantage' but it may include:

• excluding someone from opportunities or benefits

• making it harder for someone to do their job

• causing someone emotional distress

• causing someone financial loss

Less favourable treatment may sometimes be justified (and is not unlawful discrimination) in certain situations in the workplace, such as:

• positive action – to help a disadvantaged or underrepresented group

• objective justification – when an employer can prove a legitimate need for less favourable treatment

• a disability exception – to specifically recruit a disabled person without the risk of disability discrimination

• occupational requirement – recruiting someone with a certain protected characteristic to do a particular job

We oppose all forms of unlawful and unfair discrimination, and this policy provides a framework of equality and fairness for everyone we work with. The following examples of discrimination do not comply with the Company’s policy:

• Direct discrimination - less favourable treatment directly because of a protected characteristic

• Indirect discrimination - when everyone's treated the same but people with a protected characteristic are put at a disadvantage (unless the practice is objectively justified by a legitimate aim and the means of achieving that aim are appropriate and necessary).

• Victimisation - negative treatment because of being involved with a discrimination or harassment complaint

• Harassment - unwanted or offensive behaviour related to a protected characteristic (see also ANTI-HARRASSMENT POLICY section).

Recruitment and Development

We want our workforce to be truly representative of all sections of society. We want our company to be one in which every employee and freelancer feels respected, supported and able to give their best.

Selection for employment, whether as a member of staff or on a freelance basis, will be based on aptitude and ability. Access to opportunities for promotion, training or any other benefit will also be based on aptitude and ability. All employees will be encouraged to develop their full potential, and the talents and resources of the workforce will be fully utilised to maximise the creativity and success of the company.

Please see SAFEGUARDING section above for details on Training, Communication, Reporting, Support Resources, Expectations of Managers and Supervisors, Expectations of Workers and Expectations of Clients, Suppliers, Customers and Co -Producers.

ANTI-BULLYING POLICY

Rare TV seeks to provide a work environment that is safe and enjoyable for all.

Workplace bullying has a detrimental effect on the Company and its people. It can create an unsafe working environment, result in a loss of trained and talented workers, cause the breakdown of teams and individual relationships, increase absenteeism and reduce efficiency and productivity. People who are bullied can become distressed, anxious, withdrawn and can lose self -esteem and self-confidence. Workplace bullying is also in some circumstances against the law. For these reasons, bullying will not be tolerated by the Company.

The Company recognises that workplace bullying may involve comments and behaviours that offend some people and not others. The Company accepts that individuals may react differently to certain comments and behaviour. That is why a minimum standard of behav iour is required of workers. Thisstandard aims to be respectful of all workers.

The Company recognises that workplace bullying can take place though several different methods of communication including face to face, email, text messaging and social media platforms. As such, this Policy applies to all methods of communication through which workplace bullying can take place

This Policy applies to behaviours that occur:

• In connection with work, even if it occurs outside normal working hours;

• During work activities, for example, when dealing with clients;

• At work related events and functions, for example, at Christmas parties; and

• On social media platforms where workers interact.

This Policy applies to all workers including employees, contractors and volunteers. In so far as this policy imposes any obligations on the Company ( i.e. those additional to those set out under legislation), those obligations are not contractual and do not give rise to any contractual rights.

To the extent that this policy describes benefits and entitlements for employees ( i.e. those additionalto those set out under legislation), they are discretionary in nature and are also not intended to be contractual. The terms and conditions of employment that are intended to be contractual are set out in an employee’s written employment contract.

All staff including contractors are included in this Policy and any incidents will be fully investigated and could lead to dismissal.

All staff have a responsibility to ensure they respect and adhere to these new regulations.

What is Workplace Bullying?

Workplace bullying occurs when an individual, or a group of individuals, repeatedly behaves unreasonably towards a worker, or a group of workers, and the behaviour creates a risk to health and safety. It includes both physical and psychological abuse.

Bullying behaviours can take many different forms, from the obvious (direct) to the more subtle (indirect). The following are some examples of direct bullying:

• Abusive, insulting or offensive language or comments; Violent, aggressive or intimidating conduct;

• Belittling or humiliating comments; Victimisation; and

• Practical jokes or initiation.

The following are some examples of indirect bullying:

• Unjustified criticism or complaints;

• Deliberately excluding someone from work-related activities; Withholding information that is vital for effective work performance; Setting unreasonable timelines or constantly changing deadlines;

• Setting tasks that are unreasonably below or beyond a person’s skill level;

• Denying access to information, supervision, consultation or resources to the detriment of the worker; Spreading misinformation or malicious rumours; and Changing work arrangements such as rosters and leave to deliberately inconvenience a particular worker or workers.The above examples are not an exhaustive list of bullying behaviours. They are indicative of the type of behaviours that may constitute bullying and are therefore unacceptable to the Company. If you are unsure whether behaviour not provided on this list co nstitutes bullying, you should contact your direct supervisor in the first instance.

What is Not Workplace Bullying?

Reasonable management action taken by managers or supervisors to direct and control the way work is carried out is not considered to be workplace bullying, if the action is taken in a reasonable and lawful way.

The following are some examples of reasonable management action:

• Realistic and achievable performance goals, standards and deadlines;

• Fair and appropriate rostering and allocation of working hours;

• Transferring a worker to another area or role for operational reasons; Deciding not to select a worker for a promotion where a fair and transparent process is followed;

• Informing a worker about unsatisfactory work performance in an honest, fair and constructive way;

• Informing a worker about unreasonable behaviour in an objective and confidential way; Implementing organisational changes or restructuring; and

Taking disciplinary action, including suspension or terminating employment where appropriate or justified in the circumstances.

ANTI-HARRASSMENT POLICY

Harassment

Harassment is considered to be any form of behaviour that is:

• Unwanted;

• Offends, humiliates or intimidates;

• or Creates a hostile environment.

Where such conduct occurs towards a person due to a particular characteristic of that person (such as when based on sex, sexual orientation, pregnancy, marital status, age, disability, ethnicity or race,) this may be unlawful under discrimination and equal opportunity law, even if it is limited to a

single incident.

Harassment covers unwanted conduct related to a protected characteristic which has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them.

Sexual Harassment

Following an update in legislation, the Equality Act has been updated to include specifically Anti-Harassment protection. All staff have a responsibility to ensure they respect and adhere to these new regulations.

Sexual harassment is defined as unwanted conduct of a sexual nature that has the purpose or effect of violating a person's dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment for them.

Sexual harassment may include, but is not limited to the following, and may be unlawful even where it is not repeated conduct:

• Unwelcome sexual comments, jokes, or innuendoes

• A supervisor firing an employee for not going out with them

• A supervisor consistently asking female employees to plan office parties

• Using sexually explicit language

Production specific examples of sexual harassment risks are outlined in the production risk assessments, alongside appropriate controls the Company has in place to mitigate against them.

The most extreme form of sexual harassment is sexual assault. This is a serious crime, and ourCompany will support employees who want to press charges against offenders.

The Company has a zero-tolerance policy towards sexual harassment, as follows:

• No one has the right to sexually harass our employees . Any person in our company who is found guilty of serious harassment will be terminated, whether they are VPs or assistants. Also, if representatives of our contractors or vendors sexually harass our employees, we will demand that the company they work for takes disciplinary action and/or refuse to work with this person in the futu re.

• Sexual harassment is never too minor to be dealt with . Any kind of harassment can wear down employees and create a hostile workplace. We will hear every claim and punish offenders appropriately.

• Sexual harassment is about how we make others feel . Many do not consider behaviours like flirting or sexual comments to be sexual harassment, thinking they are too innocent to be labelled that way. But, if something you do makes your colleagues uncomfortable, or makes them feel unsafe, you must stop.

• We assume every sexual harassment claim is legitimate unless proven otherwise. We listen to victims of sexual harassment and always conduct our investigations properly. Occasional false reports do not undermine this principle.

• We will not allow further victimization of harassed employees. We will fully support employees who were sexually harassed and will not take any adverse action against them. For example, we will not move them to positions with worse pay or benefits or allow others to retaliate against them.

• Those who support or overlook sexual harassment are as much at fault as offenders. Managers and HR especially are obliged to prevent sexual harassment and act when they have suspicions or receive reports. Letting this behaviour go on or encouraging it will bring about disciplinary action. Anyone who witnesses an incident of sexual harassment or has other kinds of proof should report it to their Line Manager, or if they feel more comfortable, our CEO, Alexander Gardiner or Head of Production, Ben Sutton.

ANTI-VIOLENCE POLICY

The Company will not tolerate any form of workplace violence. Workplace violence is considered to be any incident where a person is physically attacked or threatened in the workplace, whether this is directed to a co- worker, subcontractor, client, customer or visitor.

It includes (but is not limited to):

• Any type of direct physical contact such as punching, pushing, tripping, spitting or blocking of someone’s way;

• Any form of unwanted physical contact.

COMPANY POLICY ON SUSTAINABILITY

RARE TV are committed to reducing the environmental impact of making productions, wherever possible. In order to achieve this, we have the following in place across all our programmes.

RENEWABLE ENERGY SOURCES – Production will check with the locations if they use renewable energy sources and ask to see their green policy to show how they are reducing their carbon footprint.

GREEN POLICIES – Production will ask for and save Green Policies from all companies that we work with.

TRAVEL - Where possible, production will book hybrid/electric taxis and cars for talent and crew.

COURIERS – Production will enquire about booking push bikes where possible, and when cars are necessary production will aim to book hybrid/electric vehicles.

KIT HIRE COMPANIES – When hiring kit from hire companies, Production will ask for their green policy. Where possible Production will hire kit from the studios we are working in so there is no courier service needed, to reduce our carbon footprint.

RECHARGABLE KIT – Crew will be using rechargeable batteries wherever possible.

RECYCLE AS MUCH AS POSSIBLE – Production will encourage recycling, this includes composting food waste where bins are available and keeping the amount of waste put in non-recyclable rubbish bins to an absolute minimum.

REUSABLE BOTTLES AND CUPS - The crew will be encouraged to bring their own reusable water bottle and coffee cups. Where this isn’t possible production will provide biodegradable cups and bottles of water from suppliers like Water in a Box.

PAPERLESS POLICY - All docs such as call sheet & RAs will be sent out electronically, but if a paper copy is required, this should be done in booklet style to reduce the amount of paper used. Wherever possible, release forms to be sent via online platforms such as docusign rather than hard copy. Invoices should never need to be printed.

PRINTING – Only printing when absolutely essential and should be booklet style or at the very least double sided.

CUTLERY & PLATES - The crew should try and eat meals on locations at restaurants with real plates and cutlery wherever possible. When this is not possible, take away meals should be purchased from companies with sustainable practices such as Leon that have all compostable packaging and cutlery.

LOW ENERGY LIGHTS – Where possible we will use low energy lights and LED fixtures as much as possible, without compromising the visuals.

BIODEGRADABLE BAGS – When bags are required, e.g. putting sterilised mics into bag in preparation for contributor, these should be biodegradable/compostable.

BIODEGRADABLE PPE – Where possible we will purchase PPE that is biodegradable.

PPE WASTE: Mask hooks/strings should be cut before disposal.

WORKING FROM HOME- Team members working from home will be asked if they have a 100% renewable energy supplier and WFH will help reduce travel carbon emissions. Team members who do not have 100% renewable energy suppliers are encouraged to switch!

VIDEO CALLS – We are encouraging video calls where possible for meetings especially when people are working from home or on location.

RECYCLING – Using the correct recycling bins that are placed around the office.

STATIONERY – If required, ordering paper and notepads made of recycled paper from a sustainable source where possible.

POWER DOWN – When the team are working in the office, we are asking everyone to be responsible for turning off their appliances, lights and power sockets. Working from home, we ask everyone to close down their computers every night.

TRAVEL – Crew will be encouraged to walk, cycle or get public transport such as trains or buses wherever possible or car share when covid protocols are implemented. When booking cars, production will request hybrid vehicles.

ORDERING ONLINE AS LAST RESORT – We will be mindful of where we buy things and source locally where we can, with as minimal packaging as we can find.

ACCOMODATION- We will seek out eco-conscious hotels wherever possible within the location.

EDIT SUITES– Editors will be asked to turn off machines at night to reduce energy required to power the systems. Offline edits at Lower Marsh are on 100% zero carbon energy.

POST PRODUCTION HOUSE – Evolutions is an Albert Partner.

FOOD CHOICES – We encourage all team members to eat at least one vegetarian or vegan meal a week reducing the amount of meat consumed by our team members with “Meat Free Mondays!”

AT HOME – We also encourage anyone not on a sustainable green energy tariff at home, to switch and also make sustainable changes within the hope such as reducing plastic waste and buying locally sourced food and products.

ALWAYS UPDATING! Please contact Sally Gamgee or your PM if you have any more sustainable ideas that you would like for us to implement at Rare or your production!