Non-discrimination and Equal Opportunity Policy

Entity: Arctic Panorama LodgeEffective Date: 02.05.2026Policy Owner: Human Resources/Management

1. Policy Statement

Arctic Panorama Lodge is committed to fostering a work environment and guest experience rooted in respect, dignity, and equal opportunity. We strictly prohibit discrimination in any form - whether against employees, contractors, guests, or business partners - based on any characteristic protected by applicable law. This commitment extends from our lodge to our booking offices and guided excursions.

2. Scope

This policy applies to all aspects of employment and business operations, including recruitment, hiring, training, compensation, promotion, transfers, social programs, discipline, termination, and the provisioning of hospitality services. It covers:

• Employees (permanent, seasonal, and temporary guides, hosts, kitchen staff, etc.)

• Applicants and Interns

• Guests, Visitors, and Contractors (third-party activity providers, transport operators)

3. Protected Grounds

Arctic Panorama Lodge prohibits discrimination or harassment based on:

• Race, colour, ethnic or national origin

• Gender, gender identity, or gender expression

• Sexual orientation

• Religion, belief, or life philosophy

• Age

• Disability (physical, mental, sensory, or chronic illness)

• Marital or family status (including pregnancy, parental leave)

• Political affiliation or trade union membership

• Any other status protected by Norwegian national law, or applicable international legal instruments

4. Definition of Prohibited Conduct

Discrimination: Any distinction, exclusion, or preference that has the purpose or effect of nullifying or impairing equal treatment. This includes job advertisement wording, interview questions, unequal pay, denial of cabin access, or differential service based on a guest’s protected characteristic.

Harassment: Unwanted conduct related to a protected ground, which creates an intimidating, hostile, degrading, humiliating, or offensive environment. Examples range from offensive remarks about a colleague’s indigenous Sami heritage to ridiculing a guest’s national dietary customs.

Sexual Harassment: Any form of unwanted verbal, non-verbal, or physical conduct of a sexual nature. This may include unwelcome advances, requests for sexual favours, displaying sexually suggestive imagery in staff common areas, or sexually charged remarks during ice-fishing or Northern Lights excursions.

Victimisation: Retaliating against an individual because they have made a complaint, testified, assisted, or participated in an investigation regarding discrimination or harassment.

5. Reasonable Accommodation

Arctic Panorama Lodge will make reasonable and feasible accommodations to enable qualified individuals to perform their essential job functions or to access our facilities and excursions. Accommodations may include, for example: modifying a snowmobile duty roster for a pregnant guide, providing communication aids in the lodge restaurant for a hearing-impaired guest, or arranging shifts to accommodate religious observance. Employees and guests are encouraged to inform management of their needs as early as possible so we can find safe and practical solutions within our operational context.

6. Complaint and Reporting Procedure

If you feel you have experienced or witnessed discrimination or harassment:

1. Informal Reporting: You may tell the person firmly that their behaviour is unwelcome. If you are uncomfortable doing so directly, consult your direct manager, the Lodge Manager, or the HR officer. Even an informal conversation will be treated seriously and confidentially.

2. Formal Complaint: A written statement should be submitted to the HR Officer or Lodge General Manager. It should detail the incident(s), dates, individuals involved, and any witnesses.

3. Third-Party Guests/Contractors: Any guest or contractor who experiences discriminatory treatment by our staff is urged to immediately speak to the General Manager or HR Manager directly at svein@arcticpanorama.com so corrective action can be taken.

All reports will be acknowledged within 48 hours.

7. Investigation Process

• All formal complaints will be investigated promptly, impartially, and as confidentially as possible.

• The Investigator (appointed by HR/General Manager) may interview the complainant, the respondent, and relevant witnesses.

• Both parties may have a representative or support person present.

• A written decision summarizing the findings will usually be issued within 21 working days.

• If a violation is found, appropriate corrective action will be taken. Where a complaint is found to be maliciously false, disciplinary measures will be considered.

8. Enforcement and Disciplinary Action

Any employee who violates this policy will be subject to disciplinary action, up to and including immediate termination of employment and, where applicable, reporting to civil authorities. Contracted guides or third-party operators found in violation will have their contracts immediately reviewed and may be terminated.

9. No Retaliation

Retaliation against an individual for filing a complaint in good faith or cooperating in an investigation is a serious violation of this policy and will not be tolerated. Any retaliation—such as unfair rostering, social exclusion, or termination—will itself lead to disciplinary sanctions.

10. Policy Dissemination and Training

A copy of this policy will be:

• Included in the Employee Handbook and seasonal starter packs.

• Displayed in staff common areas and the HR/administration office.

• Summarised for guests in the Lodge welcome booklet.

Mandatory refresher training on diversity, respectful behaviour, and active bystander intervention will be provided for all staff before the start of each main season.

Signed: Svein Jakobsen - General Manager Date: 02.05.2026