Workplace Violence Prevention Policy

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Purpose

Neuroscale is committed to providing a safe workplace free from violence, threats of violence, harassment, intimidation, and other disruptive behavior. This policy establishes the program required by California’s Workplace Violence Prevention in General Industry standard (Cal. Lab. Code §6401.9, SB 553) and applies the same protections to all Neuroscale staff regardless of work location. This policy works alongside the Code of Conduct, the Incident Response Plan, and the Human Resources Security Policy.

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Scope

This policy applies to all Neuroscale employees, contractors, interns, and temporary staff at every location — Neuroscale offices, customer sites, conferences, off-sites, and remote-work environments where work is performed on behalf of Neuroscale. It covers:

• Workplace violence directed at Neuroscale staff by anyone, including co-workers, customers, vendors, family members, or strangers.
• Workplace violence committed by Neuroscale staff against anyone in the course of work.
• Threats, intimidation, or harassment that may foreseeably escalate to violence.

For California-based staff, this policy is the Workplace Violence Prevention Plan (WVPP) required by Cal. Lab. Code §6401.9. For staff in jurisdictions with state-specific WVPP-equivalent obligations, this policy is also implemented as the local plan, including:

• New York. The Retail Worker Safety Act (N.Y. Labor Law §27-e, effective June 2, 2025) imposes retail-specific WVPP and panic-button obligations; Neuroscale does not currently operate retail establishments, but the General Counsel reviews on any retail expansion. The general N.Y. Public Employee Safety and Health (PESH) WVPP (N.Y. Labor Law §27-b) applies to public employers and does not apply to Neuroscale.
• New Jersey. N.J. has no general private-sector WVPP statute as of the effective date of this policy; the New Jersey Healthcare Workplace Violence Prevention Act (N.J.S.A. 26:2H-12.6e) is healthcare-specific and does not apply.
• Washington. Wash. Rev. Code §49.19 imposes WVPP obligations on health-care settings only; not applicable to Neuroscale.
• Texas, Connecticut, Maryland, and other states. Sectoral WVPP obligations may apply (e.g., healthcare); not applicable to Neuroscale’s current scope.

For staff in any other state, the CA-equivalent standard above is applied as company policy regardless of whether a state-specific statute exists. The General Counsel reviews this list annually and on any material expansion of Neuroscale’s worksite footprint or customer-sector mix.

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Definitions

Neuroscale follows the typology used by Cal/OSHA and the U.S. Department of Labor:

• Type 1 — Criminal intent. Violence by someone with no legitimate relationship to Neuroscale (e.g., robbery, trespass).
• Type 2 — Customer/client. Violence by someone who has a legitimate relationship with Neuroscale and becomes violent while being served (e.g., a customer, partner contact, or visitor).
• Type 3 — Worker-on-worker. Violence by a current or former Neuroscale employee or contractor against another.
• Type 4 — Personal relationship. Violence by someone who does not have a relationship with Neuroscale but has a personal relationship with an employee (e.g., a current or former intimate partner).

Workplace violence includes any act or threat of physical violence, harassment, intimidation, stalking, or other disruptive behavior occurring in the workplace, including verbal threats, threatening written communications (email, Slack, social media), brandishing weapons, physical assault, and any conduct serious enough to cause an employee to fear for their safety.

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Prohibited conduct

The following are strictly prohibited at all Neuroscale-controlled locations and during all work activities:

• Physical assault, battery, or attempted assault.
• Threats of violence — direct, indirect, conditional, or implied — whether spoken, written, or transmitted electronically.
• Intimidation, stalking, or harassment that creates a reasonable fear of harm.
• Possession, use, or display of any weapon (firearms, explosives, knives intended as weapons, or any other object used to threaten or cause harm) on Neuroscale premises or at Neuroscale events. See the weapons provisions of the Code of Conduct.
• Damage or threatened damage to Neuroscale property or the property of staff, customers, or visitors with the intent to intimidate.
• Bringing a domestic-violence dispute, restraining-order subject, or other personal-safety issue into the workplace without notifying HR so protective measures can be put in place.

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Reporting

Neuroscale staff are required to report any act, threat, or warning sign of workplace violence as soon as they become aware of it. Reports may be made through any of the following channels — staff may choose the channel they are most comfortable with:

• Imminent danger or violence in progress. Call 911, then notify security@neuroscale.ai and your manager.
• Non-emergency reports. Email people@neuroscale.ai or speak to your manager, your manager’s manager, the CHRO, or the General Counsel.
• Anonymous reports. Submit through the Anonymous Reporting channel — third-party hotline (web and phone, 24/7, multilingual, follow-up via case ID).
• Ethics line. Email ethics@neuroscale.ai.

There is no requirement to confront or evaluate the threat yourself. If you are unsure whether something rises to the level of workplace violence, report it anyway and let the Threat Assessment Team triage. Reports are treated confidentially to the maximum extent consistent with conducting a thorough investigation and protecting safety.

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Threat Assessment Team

The Threat Assessment Team (TAT) is the cross-functional group that evaluates and responds to workplace-violence reports. Standing membership: The TAT convenes within one business day of a report, or immediately for any report involving an imminent threat. The TAT:

1. Interviews the reporter and witnesses.
2. Assesses the credibility, immediacy, and severity of the threat using a structured threat-assessment framework (e.g., WAVR-21 or equivalent).
3. Determines and implements protective measures: workspace changes, schedule changes, escort to/from parking, no-contact directives, suspension, termination, building-access changes, law-enforcement coordination, or restraining-order support.
4. Communicates outcomes to affected staff to the extent appropriate, while protecting the privacy of those involved.
5. Documents the matter in the violent-incident log (see Recordkeeping).

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Employee involvement (Cal. Lab. Code §6401.9(c)(1)(B))

Neuroscale obtains the active involvement of staff and, where applicable, their authorized representatives in the development and implementation of this Workplace Violence Prevention Plan, including:

• An annual all-hands review of the plan in which staff may surface hazards, ask questions, and propose changes.
• A standing channel (people@neuroscale.ai) and the anonymous reporting channel for plan-related feedback at any time.
• Staff input solicited as part of the annual hazard assessment described below, including a brief survey distributed through Vanta.
• Targeted consultation with staff in higher-exposure roles (front-desk, customer events, lone-worker schedules) when the plan is updated.

Feedback received through these channels is logged by the CHRO and reflected in the next plan revision; material safety concerns are escalated to the TAT immediately.

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Communication with staff (Cal. Lab. Code §6401.9(c)(2))

Neuroscale communicates with staff about workplace-violence matters through:

• Initial and annual training (see Training below).
• Posting of this plan on the internal documentation site, with notice to all staff on each material revision.
• Slack #announcements and email distribution for incident-related notices to the extent compatible with reporter confidentiality and ongoing investigations.
• Direct CHRO outreach to affected staff following any reported incident or near-miss.

The plan is provided in writing to any staff member or representative within 15 calendar days of a written request, consistent with Cal. Lab. Code §6401.9(f).

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Post-incident response and investigation

Following any reported incident — whether or not injury occurred — the TAT:

1. Ensures medical care and immediate safety needs are met.
2. Offers trauma counseling and Employee Assistance support to affected staff at no cost; counseling may be obtained without disclosing the substance of the matter to Neuroscale.
3. Conducts a structured investigation per the Threat Assessment Team section above, including documentary review and witness interviews.
4. Identifies root causes and updates engineering/administrative/PPE controls accordingly.
5. Reports findings (anonymized as needed) into the next employee-involvement review so that lessons are folded into the plan.
6. Where the incident involves a recordable injury, ensures OSHA 300 / 300A / 301 logging through the CHRO.

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Hazard identification & corrective measures

The CHRO, in coordination with the CISO and office/facilities leads, conducts a workplace-violence hazard assessment at least annually and whenever a new office is opened, work activities materially change, or a violent incident occurs. The assessment considers:

• Lone-worker situations (e.g., off-hours office access).
• Public-facing roles (front-desk, customer events, recruiting events).
• Field work at customer sites.
• Domestic-violence situations involving staff.
• Threats received via Neuroscale digital channels.

Identified hazards are corrected through engineering controls (locks, lighting, access control, panic buttons), administrative controls (buddy systems, schedule changes, training), and personal-protective measures as appropriate.

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Training

All Neuroscale staff complete workplace-violence-prevention training:

• At hire — within 30 days of start date, before any unaccompanied customer-facing or office-only work.
• Annually thereafter — assigned and tracked through Vanta.
• When a new or previously unrecognized hazard is identified — targeted re-training for affected staff.

Training covers:

• This policy and how to report.
• Recognition of warning signs and de-escalation basics.
• Type 1–4 violence and the controls that apply to each.
• Resources available to staff (Employee Assistance, security escort, time-off provisions for victims of domestic violence, sexual assault, or stalking under Cal. Lab. Code §230 and §230.1).
• Specific controls for the staff member’s role and worksite (e.g., front-desk staff receive additional Type 2 training).

The TAT and any manager designated as a first-line responder receive enhanced training annually.

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Recordkeeping

Neuroscale maintains the following records, retained for at least five (5) years:

• Violent-incident log — every reported incident of workplace violence (whether or not injury occurred), including: date, time, and location; a description of the incident; the Type 1–4 classification; who was involved (without identifying victims who request anonymity, where law allows); consequences; and corrective actions taken. The log is maintained by the CHRO.
• Hazard assessments — annual and event-driven assessments and the corrective actions taken.
• Training records — completion dates and content, exported from Vanta.
• TAT case files — investigation notes, threat-assessment scoring, and outcomes, held by the CHRO under restricted access.

Records are stored in Microsoft SharePoint under access controls limited to HR, Legal, and the CISO. Records are made available to employees and their representatives within 15 calendar days of a written request, consistent with Cal. Lab. Code §6401.9(f) and applicable state law. Personally identifying information about reporters and victims is redacted before disclosure unless disclosure is legally required. See the Records Retention Schedule for the master retention table.

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No retaliation

Neuroscale strictly prohibits retaliation against any person who, in good faith, reports a threat or act of workplace violence, participates in an investigation, or requests protective measures. Retaliation is itself a violation of this policy and will result in disciplinary action up to and including termination. Suspected retaliation should be reported through any of the channels in Reporting.

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Coordination with other policies and processes

• The Code of Conduct defines unacceptable behavior more broadly. Workplace violence is a per-se violation of the Code.
• The Incident Response Plan governs digital incidents that overlap with threats (e.g., threatening emails delivered via Neuroscale systems, doxing, account compromise used to threaten staff). The CISO coordinates between the TAT and the IRT in those cases.
• The Human Resources Security Policy governs background screening and the disciplinary process used for substantiated violations.
• Domestic-violence accommodations follow Cal. Lab. Code §230 and §230.1 in California and the analogous statutes in other jurisdictions where Neuroscale staff work, including: New York (N.Y. Labor Law §196-b paid sick leave and N.Y. Penal Law §215.14 victim leave; N.Y.C. Admin. Code §8-107.1 reasonable-accommodation requirement), Illinois (Victims’ Economic Security and Safety Act, 820 ILCS 180), Washington (Wash. Rev. Code §49.76 Domestic Violence Leave Act), Connecticut (Conn. Gen. Stat. §31-51ss), Colorado (Colo. Rev. Stat. §24-34-402.7 unpaid leave), New Jersey (N.J.S.A. 34:11C-1 SAFE Act), Oregon (Or. Rev. Stat. §659A.270), Massachusetts (Mass. Gen. Laws ch. 149 §52E), Minnesota (Minn. Stat. §181.9413), and the federal Family and Medical Leave Act (29 U.S.C. §2601 et seq.) where its eligibility criteria are met. Where two regimes overlap, Neuroscale applies the more protective. The General Counsel and CHRO review this list annually and on any change to Neuroscale’s state footprint.

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Exceptions

There are no general exceptions to the prohibitions in this policy. Operational exceptions to procedural elements (e.g., training timing for a returning leave-of-absence employee) require written approval of the CHRO.

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Violations & enforcement

Violations of this policy result in disciplinary action up to and including immediate termination, removal from Neuroscale premises, revocation of system access, and referral to law enforcement. Contractors and vendors who violate this policy will be removed from Neuroscale engagements and their access terminated. Report violations through any channel in Reporting, or directly to the CHRO or General Counsel.

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