ANTI-DISCRIMINATION POLICY

Last updated on [5/6/2024]
Please read this Anti-Discrimination Policy (“Policy”) carefully. The Users, subscribers, and viewers (“Users”) accept the terms of this Policy by accessing and/or utilizing the services of POTOLO (the “Company”). The Users acknowledge that they agree to this Policy and accept the rights and obligations created by it. This Policy is drafted to outline the anti-discrimination of the Company. This Policy is designed to comply with applicable laws and standards.

INTRODUCTION

1.1 Purpose of the Policy: The purpose of this Policy is to establish the principles and guidelines for POTOLO's operations, ensuring a fair, respectful, and inclusive environment for all individuals engaging with the POTOLO platform. This Policy is designed to prevent and address discrimination and harassment based on protected characteristics, including but not limited to race, gender, religion, age, disability, sexual orientation, and any other characteristic protected by applicable law.

1.2 Scope and Applicability: This Policy applies to all aspects of POTOLO's operations, including the use of the POTOLO mobile application ("App"), interactions with POTOLO's kitchen partners, service providers, employees, and Users. It encompasses all services offered through the POTOLO platform, including but not limited to food ordering, task or project hiring, health consultations, gym memberships, fleet management solutions, dry cleaning services, and bus ticket sales. Additionally, this Policy extends to all POTOLO-sponsored events, activities, and communications.

1.3 Commitment to Diversity and Inclusion: POTOLO is committed to fostering a diverse and inclusive community within its platform and beyond. We believe that diversity strengthens our organization and enriches our User experience. We are dedicated to creating an environment where all individuals are treated with dignity, respect, and fairness, regardless of their background or identity. Through this Policy, POTOLO reaffirms its commitment to promoting diversity, equity, and inclusion in all aspects of its operations and interactions.

2. POLICY STATEMENTS

2.1 Prohibition of Discrimination: POTOLO unequivocally prohibits all forms of discrimination in any aspect of its operations, including but not limited to the provision of services through its mobile application, interactions with kitchen partners, service providers, employees, and Users. Discrimination based on race, gender, religion, age, disability, sexual orientation, or any other characteristic protected by applicable law is strictly prohibited. This prohibition extends to all individuals associated with POTOLO, including employees, contractors, partners, and Users.

2.2 Protected Characteristics: POTOLO recognizes and respects the diversity of its User base and workforce. The Company acknowledges that individuals may possess various characteristics that are protected by law and are inherent to their identity. These characteristics include, but are not limited to, race, ethnicity, color, national origin, ancestry, gender, gender identity, gender expression, sexual orientation, age, religion, disability, marital status, veteran status, genetic information, or any other characteristic protected by applicable law.

2.3 Equal Opportunity: POTOLO is committed to providing equal opportunities to all individuals, irrespective of their protected characteristics. The Company ensures that all Users and workers have access to its services, facilities, and employment opportunities on an equal basis, without discrimination or harassment. POTOLO promotes a merit-based system where decisions regarding hiring, promotion, compensation, and service provision are made based on qualifications, skills, and performance, rather than on protected characteristics.

2.4 Fair Treatment: POTOLO is dedicated to fostering a culture of fairness, respect, and dignity in all interactions within its platform and workplace. The Company expects all employees, partners, and Users to treat each other with professionalism, courtesy, and consideration, regardless of their background or identity. POTOLO prohibits any form of harassment, bullying, or mistreatment based on protected characteristics. Additionally, POTOLO commits to promptly addressing and remedying any incidents of discrimination or unfair treatment that may occur, in accordance with applicable laws and Company policies.

3. APPLICATION OF POLICY

3.1 Users of POTOLO Services: This Anti-Discrimination Policy applies to all individuals who utilize POTOLO's services through the App. Users of POTOLO services are expected to adhere to the principles outlined in this Policy and refrain from engaging in any discriminatory behavior or actions. POTOLO strives to provide a welcoming and inclusive environment for all Users, irrespective of their background, identity, or characteristics protected by law. Discriminatory conduct by Users, including but not limited to discriminatory remarks, requests, or actions directed at other Users or service providers, will not be tolerated and may result in disciplinary action, up to and including suspension or termination of access to POTOLO services.

3.2 Kitchen Partners and Service Providers: POTOLO's Anti-Discrimination Policy extends to all kitchen partners and service providers who collaborate with the Company to offer services through its platform. Kitchen partners and service providers are expected to comply with this Policy and ensure that their interactions with POTOLO Users and employees are free from discrimination or harassment based on protected characteristics. POTOLO reserves the right to terminate partnerships or contracts with kitchen partners or service providers found to have violated this Policy or engaged in discriminatory practices. Additionally, POTOLO may provide training and resources to kitchen partners and service providers to promote understanding and compliance with anti-discrimination principles.

3.3 Employees and Workers: POTOLO is committed to providing a discrimination-free workplace for all employees and workers, including full-time employees, contractors, and temporary workers. This Policy applies to all aspects of employment, including but not limited to recruitment, hiring, training, promotion, compensation, benefits, and termination. POTOLO prohibits discrimination and harassment of any kind, including but not limited to harassment based on race, gender, religion, age, disability, sexual orientation, or any other protected characteristic. Employees and workers who experience or witness discrimination or harassment are encouraged to report such incidents through the appropriate channels outlined in POTOLO's reporting and complaint procedures. POTOLO will promptly investigate all complaints of discrimination and take appropriate corrective action, up to and including disciplinary measures against perpetrators.

4. PROHIBITION OF DISCRIMINATORY PRACTICES

4.1 Harassment and Intimidation: POTOLO strictly prohibits harassment and intimidation of any individual based on their race, gender, religion, or any other protected characteristic. Harassment includes but is not limited to unwelcome verbal, physical, or visual conduct that creates a hostile or offensive environment. This encompasses offensive jokes, slurs, epithets, derogatory comments, gestures, physical assaults, threats, and other forms of intimidating behavior. POTOLO is committed to providing a safe and respectful environment for all individuals associated with the Company, and any instances of harassment or intimidation will be thoroughly investigated and addressed promptly. Perpetrators of harassment may face disciplinary action, up to and including termination of their relationship with POTOLO.

4.2 Differential Treatment: POTOLO prohibits any form of differential treatment or unequal opportunities based on protected characteristics such as race, gender, religion, or any other characteristic protected by law. This includes, but is not limited to, unequal pay, unequal access to opportunities for advancement, and disparate treatment in hiring, promotion, training, or assignment of tasks. POTOLO is committed to providing equal opportunities for all individuals, regardless of their background or identity. Any instances of discriminatory treatment will be thoroughly investigated, and appropriate corrective action will be taken to ensure fairness and equality in the workplace and in the provision of services through the POTOLO platform.

4.3 Retaliation: POTOLO strictly prohibits retaliation against individuals who report discrimination or harassment, participate in investigations regarding discriminatory practices, or oppose discriminatory conduct in good faith. Retaliation includes any adverse action taken against an individual as a result of their involvement in protected activities, such as demotion, suspension, termination, or other forms of retaliation. POTOLO encourages individuals to come forward with complaints or concerns regarding discrimination or harassment without fear of reprisal. Any acts of retaliation will be met with disciplinary action, and POTOLO will take all necessary steps to protect individuals from retaliation and ensure a safe environment for reporting and addressing discriminatory practices.

5. REPORTING AND COMPLAINT PROCEDURES

5.1 Reporting Mechanisms: POTOLO provides multiple avenues for reporting discrimination, harassment, or other violations of this Policy. Users, employees, service providers, and other individuals who believe they have experienced or witnessed discrimination are encouraged to report such incidents promptly. Reporting mechanisms may include contacting POTOLO's customer support team through the mobile application, emailing POTOLO's designated compliance officer, or submitting a formal complaint through POTOLO's website. Additionally, POTOLO may establish anonymous reporting channels to allow individuals to report concerns without fear of retaliation.

5.2 Confidentiality and Non-Retaliation: POTOLO is committed to maintaining the confidentiality of individuals who report discrimination or harassment and ensuring that they are protected from retaliation. All reports of discrimination will be handled with discretion, and information provided by individuals during the reporting process will be kept confidential to the extent possible, consistent with POTOLO's legal obligations and the need to conduct a thorough investigation. POTOLO prohibits retaliation against individuals who report discrimination in good faith or participate in investigations regarding discriminatory practices. Any acts of retaliation will be promptly addressed and may result in disciplinary action against the perpetrator.

5.3 Investigation Process: Upon receiving a report of discrimination or harassment, POTOLO will conduct a prompt and impartial investigation to determine the validity of the complaint and take appropriate action. The investigation process may involve interviewing the individuals involved, gathering relevant evidence, and consulting with legal advisors or external experts as necessary. POTOLO is committed to conducting investigations in a fair and thorough manner, respecting the rights of all parties involved. Upon completing the investigation, POTOLO will communicate the findings to the parties involved and take appropriate corrective action, which may include disciplinary measures against the perpetrator and implementing measures to prevent recurrence of discriminatory behavior. Throughout the investigation process, POTOLO will strive to maintain transparency and provide updates to the individuals involved to the extent feasible without compromising the integrity of the investigation.

Anti-Discrimination Policy of POTOLO
6. Consequences of Violations

6.1 Disciplinary Action: POTOLO takes violations of its Anti-Discrimination Policy seriously and will impose disciplinary action against individuals found to have engaged in discriminatory behavior. Disciplinary action may include verbal or written warnings, suspension from accessing POTOLO's services or facilities, demotion, or termination of employment or partnership. The severity of disciplinary action will depend on the nature and severity of the violation, as well as any mitigating or aggravating factors. POTOLO reserves the right to exercise discretion in determining the appropriate disciplinary measures based on the circumstances of each case.

6.2 Remedial Measures: In addition to disciplinary action, POTOLO may implement remedial measures to address the consequences of discrimination and promote a culture of respect and inclusion. Remedial measures may include providing training or education on diversity and inclusion, implementing policies or procedures to prevent future incidents of discrimination, offering support services to individuals affected by discrimination, and taking steps to repair any harm caused by discriminatory behavior. POTOLO is committed to taking proactive measures to prevent and address discrimination within its organization and community.

6.3 Termination of Partnership, Employment, or Engagement: In cases where violations of the Anti-Discrimination Policy are deemed severe or recurring, POTOLO reserves the right to terminate partnerships, employment, or engagement relationships with individuals or entities found to have engaged in discriminatory conduct. Termination may occur immediately or following a disciplinary process, depending on the circumstances and severity of the violation. POTOLO will communicate termination decisions to the affected parties in a timely and respectful manner, ensuring that all relevant legal and contractual obligations are met. Termination of partnership, employment, or engagement is considered a serious consequence of violating POTOLO's Anti-Discrimination Policy and reflects the Company's commitment to maintaining a safe and inclusive environment for all Users and workers.

7. Compliance and Training

7.1 Training Programs: POTOLO is committed to promoting understanding and compliance with its Anti-Discrimination Policy through comprehensive training programs. These training programs are designed to educate employees, service providers, and other relevant stakeholders about the principles and requirements outlined in the Policy. Training sessions may cover topics such as recognizing and preventing discrimination, understanding the impact of unconscious bias, promoting diversity and inclusion, and responding effectively to complaints of discrimination. POTOLO will provide regular and ongoing training to ensure that all individuals associated with the Company are equipped with the knowledge and skills necessary to uphold the Company's commitment to a discrimination-free environment.

7.2 Compliance Monitoring: POTOLO implements robust compliance monitoring mechanisms to ensure adherence to its Anti-Discrimination Policy and applicable legal requirements. Compliance monitoring may involve conducting periodic audits, reviews, or assessments to evaluate the effectiveness of the Policy implementation and identify any areas for improvement. POTOLO may utilize various methods for compliance monitoring, including data analysis, feedback mechanisms, and direct observation of interactions within the POTOLO platform. In addition to internal monitoring, POTOLO may engage external experts or consultants to provide independent assessments of compliance and offer recommendations for enhancing the effectiveness of the Anti-Discrimination Policy. POTOLO is committed to maintaining a proactive approach to compliance monitoring to safeguard against discrimination and promote a culture of respect and inclusion within its organization and community.

8. Communication and Awareness

8.1 Distribution of Policy: POTOLO is committed to ensuring that its Anti-Discrimination Policy is widely communicated and readily accessible to all individuals associated with the Company. The Policy will be distributed to employees, service providers, Users, and other relevant stakeholders through various channels, including but not limited to the POTOLO mobile application, the Company's website, employee handbooks, orientation materials, and internal communication platforms. POTOLO will also provide translations of the Policy into multiple languages to accommodate the diverse linguistic needs of its User base and workforce. Additionally, POTOLO will periodically review and update the Policy as necessary to reflect changes in laws, regulations, or Company practices, and ensure that all individuals are informed of any updates or revisions to the Policy.

8.2 Awareness Campaigns: POTOLO will conduct proactive awareness campaigns to promote understanding and compliance with its Anti-Discrimination Policy. These campaigns may include educational initiatives, such as seminars, workshops, or online training modules, designed to raise awareness about discrimination, diversity, and inclusion. POTOLO may also leverage its communication channels, including social media platforms, newsletters, and email updates, to disseminate information and resources related to the Policy. Furthermore, POTOLO may collaborate with external organizations, advocacy groups, or experts in diversity and inclusion to develop and implement awareness campaigns that are tailored to the needs of its User base and workforce. Through these efforts, POTOLO seeks to foster a culture of respect, equality, and inclusivity within its organization and community, and empower individuals to recognize and address discriminatory behavior effectively.

9. Legal Compliance

9.1 Applicable Laws and Regulations: POTOLO is committed to full compliance with all applicable laws and regulations pertaining to anti-discrimination and equal opportunity in the jurisdictions where it operates. This includes, but is not limited to, federal, state, and local laws prohibiting discrimination on the basis of race, color, religion, gender, sexual orientation, gender identity, national origin, age, disability, or any other characteristic protected by law. POTOLO will regularly monitor changes in relevant legislation and ensure that its Anti-Discrimination Policy and practices remain up-to-date and aligned with legal requirements. In the event of any discrepancies between this Policy and applicable laws or regulations, POTOLO will adhere to the stricter standard to ensure maximum protection against discrimination for its Users and workers.

9.2 Cooperation with Authorities: POTOLO is committed to cooperating fully with relevant authorities in the investigation and resolution of any complaints or allegations of discrimination. This includes providing access to information, records, and personnel necessary for the investigation process, as well as responding promptly and transparently to requests for cooperation from law enforcement agencies, regulatory bodies, or other authorities. POTOLO will also take appropriate steps to address any findings or recommendations resulting from investigations by authorities and implement corrective measures as necessary to ensure compliance with legal requirements and prevent recurrence of discriminatory practices. By cooperating with authorities, POTOLO demonstrates its commitment to upholding the highest standards of legal compliance and accountability in matters related to anti-discrimination and equal opportunity.

10. 10DLC Compliance Option

10.1 Explanation of 10DLC: The 10DLC (10 Digit Long Code) Compliance Option is a feature integrated into POTOLO's communication systems to provide Users with the ability to opt-in or opt-out of receiving text messages and communications from the Company. This compliance option is in accordance with regulations governing commercial messaging, ensuring that POTOLO maintains transparency and respects the preferences of its Users regarding communication methods. The 10DLC Compliance Option allows POTOLO to send text messages and communications to Users who have explicitly consented to receiving such communications, while also providing Users with the option to withdraw their consent and opt-out of receiving further messages.

10.2 Opt-In/Opt-Out Procedures: POTOLO facilitates the Opt-In/Opt-Out procedures for Users to manage their preferences regarding text messages and communications effectively. Users who wish to receive text messages and communications from POTOLO may opt-in by providing explicit consent through the POTOLO mobile application or other designated channels. The opt-in process will involve clear disclosure of the types of messages and communications Users may expect to receive, as well as the frequency of such communications. Additionally, POTOLO will provide Users with the option to opt-out of receiving messages at any time by following simple instructions provided in the messages or by adjusting their communication preferences within the POTOLO mobile application settings. POTOLO is committed to honoring User preferences and ensuring compliance with applicable regulations governing commercial messaging through the implementation of robust Opt-In/Opt-Out procedures.

11. Policy Review and Revision

11.1 Regular Review Schedule: POTOLO establishes a regular review schedule to ensure that its Anti-Discrimination Policy remains relevant, effective, and compliant with evolving legal standards and industry best practices. The Policy will be subject to review at least annually, with additional reviews conducted as needed in response to significant changes in legislation, business operations, or stakeholder feedback. The review schedule will be documented and communicated to relevant stakeholders to ensure transparency and accountability in the Policy review process. POTOLO recognizes the importance of conducting regular reviews to identify any gaps or areas for improvement in the Policy and to make necessary updates to maintain alignment with the Company's commitment to fostering a safe and inclusive environment for all Users and workers. Upon approval within the Company, the updated Anti-Discrimination Policy will be communicated to all relevant stakeholders, including employees, service providers, and Users. POTOLO will utilize various communication channels, such as e-mail notifications, in-app announcements, and posting on the Company website, to ensure that stakeholders are informed of the changes and understand their implications POTOLO will implement the updated Policy promptly following communication to stakeholders. The Company will also monitor the implementation of the updates to ensure compliance and effectiveness in achieving the intended objectives. Any issues or concerns arising from the implementation of the updates will be promptly addressed through appropriate measures.