Equal Employment Opportunity Policy

COMPANY STATEMENT

It is the policy of Independence Construction, LLC ("Independence") and its subsidiary Donley's Independence, LLC (collectively referred to herein as "Company" or "IC") to employ and advance in employment all qualified individuals. Independence will not discriminate against any employee or applicant for employment for a position for which the employee or applicant is qualified. Independence agrees to take affirmative action to employ, advance in employment and otherwise treat individuals equally in regards to: hiring, promotion, demotion, transfer, recruitment, advertising, layoff or termination, rates of pay and/or other forms of compensation, and/or selection for training, including apprenticeship.

To ensure that Independence furthers the principles of Equal Employment Opportunity, Lynn Jackson, has been designated as the individual responsible for operation of Independence's Equal Employment Opportunity/ Affirmative Action Officer ("EEO/AA Officer").

EQUAL EMPLOYMENT OPPORTUNITY POLICY STATEMENT

Independence has a longstanding policy of hiring and promoting individuals who best meet the requirements of available positions. It is our policy to provide Equal Employment Opportunity in compliance with applicable federal, state and local fair employment laws, regulations and rules, as any of them are amended from time to time, including but not limited to the Civil Rights Act of 1964, the Age Discrimination in. Employment Act of 1967, the Rehabilitation Act of 1973 and the Americans with Disabilities Act, the Genetic Information Nondiscrimination Act, and the Vietnam Era Veterans Readjustment Assistance Act of 1974.

In keeping with this policy, applicants for employment are recruited, hired, selected for training, transferred, upgraded, granted privileges of employment, laid off, demoted or discharged without regard to their race, color, religion, sex, sexual orientation, gender identity, pregnancy status, national origin, age, handicap or disability, genetic information, military status, veteran status, or any other protected classification or category.

In addition, it is the Company's policy to prohibit harassment or unwelcome conduct by an employee to another employee or a third party on the basis of any protected characteristic including but not limited to age, race, color, national origin, religion, disability or handicap, pregnancy status, gender identity, sexual orientation, sex, military status, veteran status, and/or genetic information. This includes any actions (verbal or non-verbal) which constitute harassment, as defined by the EEOC, including but not limited to including but not limited to use of slurs, epithets, threats, derogatory comments and unwelcome jokes, misgendering, outing, offensive gestures, sexual advances, requests for sexual favors and other verbal or physical conduct such as uninvited touching or sexually related comments, none of which will be tolerated either in person or virtually (video, text, chat systems such as Tearns, etc.). Violations of this policy may result in discipline up to and including termination.

The Company's objective is to achieve and to take affirmative action to ensure the absence of discrimination in filling management as well as non-management job classifications; employees/ applicants will not be discriminated against because of race, color, religion, national origin, pregnancy status, sex, sexual orientation, gender identify, age, hard1COp or disability, genetic information, military status or veteran status, or any other protected classification. This objective also calls for a work environment free of discrimination, including both physical and virtual work environments. It is the Company's policy that local, state and federal laws and regulations implementing equal employment opportunity objectives shall be fully complied with, not only by meeting the letter of the law and contractual, requirements, but by carrying out the full spirit as well.

This policy statement will be circulated to all Company officials and Company employees. Persons who believe they have been discriminated against or treated unfairly or have questions regarding this policy should contact the EEO/M Officer or the Human Resources Department.

Independence's Affirmative Action program can be viewed by appointment at its offices during normal office hours. Contact the EEO/M Officer to set up an appointment.