THE COMPANY’S COMMITMENT TO EQUAL EMPLOYMENT

OPPORTUNITY: OUR POLICY FROM OUR CEO

The Company, including its leadership, is committed to cultivating an inclusive environment
where all our human differences are valued, respected, supported, and amplified. As such,
SiriusXM supports equal access to employment opportunities. We are dedicated to equal
opportunities in all people practices, including recruitment, selection, advancement, training,
compensation, benefits, transfer, layoff, and termination.
Our policies and practices are implemented without discriminating against individuals based upon sex,
gender, race (including hairstyle), color, religion/religious creed, national origin, ancestry, physical or
mental disability, genetic information, age, marital status, pregnancy (including childbirth, lactation or
related medical conditions), sexual orientation, gender identity, gender expression, sex stereotype,
transgender, immigration status, military and protected veteran status, medical condition, or any basis
prohibited under federal, state or local law. We take steps to provide our employees, applicants, and
others with whom we do business with an environment that is free of any form of harassment, including
harassment based on any of these characteristics, or bullying, and to take appropriate actions to remedy
for violations of our policy against harassment.
In addition, it is the Company’s policy that all employment actions, including recruitment, hiring,
selection for training, promotion, transfer, demotion, layoff, recall, termination, rates of pay or other
forms of compensation, will be administered without regard to physical or mental disability, or protected
veteran status, and that employment decisions are to be based on valid job requirements. The Company
will also provide qualified applicants and employees with disabilities, including but not limited to
disabled veterans, with needed reasonable accommodations, as required by law. The Company has also
developed a system that tracks and measures the effectiveness of the Company’s affirmative action
activities regarding individuals with disabilities and protected veterans, and show where additional action
is needed to meet the Company’s objectives.
To support the Company’s commitment to equal employment opportunities, we have designated the
Company’s Diversity, Equity and Inclusion team to focus on developing and implementing the
Company’s affirmative action programs and to report periodically to me and other members of our
management team on our equal employment opportunity efforts.
The Company will not tolerate statements or actions that create a discriminatory or harassing work
environment. Nor will we tolerate any coercion, intimidation, interference or other retaliation by any
employee or contractor against any member of our workforce for making a complaint in compliance with
the Company’s policies or for assisting in any investigation of unlawful discrimination or harassment.
The Company also specifically prohibits retaliation or punishment against employees and applicants for
filing a complaint alleging violation of Company policy, opposing any discriminatory act or practice,
assisting or participating in any manner in a review, investigation, or hearing regarding the Company’s
employment practices, or otherwise seeking to obtain their legal rights under any federal, state, or local
EEO law, including those requiring equal employment opportunity for individuals with disabilities or
protected veterans. Prohibited retaliation includes, but is not limited to harassment, intimidation, threats,
coercion or other adverse actions that might dissuade someone from asserting their rights.If any employee
believes that our policies prohibiting discrimination, harassment or retaliation have been violated, the
employee is expected to bring the matter to the attention of a manager and/or the People + Culture team,
or report it through employeerelations@siriusxm.com. The Company will promptly investigate, and take
appropriate action in response to, such complaints. Employees who violate our policies prohibiting
discrimination, harassment or retaliation will be subject to appropriate disciplinary action, up to and
including termination.
I’m excited about the future of the Company, and our commitment to building an enduring enterprise,
where everyone can celebrate their diverse backgrounds and experiences, like the way we want our
listeners to feel when they experience our product. We can only achieve this if everyone actively
demonstrates these values and carries out our commitment to provide equal opportunity to all.
Jennifer Witz, CEO
ANTI-HARASSMENT, DISCRIMINATION AND RETALIATION POLICY
Purpose
The Company is committed to maintaining a workplace free from harassment, including sexual
harassment. The Company will not tolerate any form of harassment, discrimination, and retaliation. All
employees have a legal right to a discrimination-free work environment.
Eligibility/Coverage
This policy applies to all Covered Individuals as well as applicants, contractors and consultants, suppliers,
vendors and any others who provide services to the Company. Unlawful harassment, including sexual
harassment, is not limited to the physical workplace itself. Unlawful harassment is prohibited while
employees are traveling for business and at Company sponsored events (such as offsites and conferences).
Calls, texts, emails, and social media usage by employees (including on personal devices) can constitute
unlawful workplace harassment, even if they occur away from the workplace premises or outside work
hours.
Policy
All employees should be able to enjoy a work environment free from all forms of unlawful
discrimination, including unlawful harassment. The Company prohibits sexual harassment and
harassment based on: sex (including pregnancy, childbirth, breastfeeding, or related medical conditions),
race, color, age, national origin, religion, creed, ancestry, physical or mental disability (actual or
perceived, including AIDS and HIV status), medical condition or use of any legally protected leave,
marital or domestic partner status, familial status, sexual orientation, genetic information (predisposition
or carrier status), gender, gender identity or expression, status as a transgender or gender non-conforming
individual, citizenship, immigration status, military or protected veteran status, legal political activity or
affiliation, arrest record, status as a victim of domestic violence, sexual assault or stalking, or any other
characteristic protected by applicable federal, state, or local law. It is the Company’s policy that all such
harassment will not be tolerated.
All employees are required to attend mandatory sexual harassment training, including a component on
abusive conduct, as well as harassment based on gender identity, gender expression, and sexual
orientation, in accordance with applicable law.
Preventing harassment is everyone’s responsibility. All employees are charged with implementing and
complying with this policy by keeping the workplace and work functions free from unlawful harassment.
All supervisors and managers who receive a complaint or information about suspected unlawful
harassment, observe what may be harassing behavior, or for any reason suspect that harassment is
occurring, are required to report such suspected harassment to their People + Culture Business Partner or
employeerelations@siriusxm.com. Unlawful harassment, including sexual harassment, is a form of
employee misconduct and sanctions will be enforced against individuals engaged in any form of
harassment and also against supervisory or managerial personnel who knowingly allow such behavior to
occur.
Prohibition of harassing conduct applies to all employees of the Company and to consultants and
contractors, interns, applicants, suppliers, vendors and any others who provide services to the Company.
This policy covers conduct both in the workplace, as well as conduct at any off-site work-related event
(formal and non-formal) such as business meetings, seminars and Company functions.
We understand that due to the nature of the Company’s business, our workplace may expose employees
to topics and materials (such as adult content) which may be considered offensive to some individuals.
We expect that all individuals whose work involves such materials will be sensitive to their potentially
offensive nature and will act professionally and in accordance with this policy at all times. Although these
topics and materials are often a legitimate and essential aspect of our entertainment business, employees
must nevertheless notify management or the People + Culture team about any concerns in accordance
with this policy.
Sexual Harassment Defined
For purposes of this policy, sexual harassment is a form of sex discrimination and includes harassment on
the basis of sex, sexual orientation, gender, gender identity, gender expression, or the status of being
transgender or gender non-conforming. Sexual harassment includes harassment that is not sexual in nature
(for example, offensive remarks about an individual’s sex or gender), as well as unwelcome or unwanted
conduct of a sexual nature (verbal, physical, or visual) where:
● submission to such conduct is made either explicitly or implicitly a term or condition of employment;
● submission to, or rejection of, such conduct is used as the basis for decisions affecting an individual’s
employment; or
● such conduct unreasonably interferes with an individual’s work performance or has the purpose or
effect of creating an intimidating, hostile, or offensive working environment.
Examples of behavior that may constitute sexual harassment as described in the preceding paragraph
include, but are not limited to: unwelcome conduct such as requests for sexual favors accompanied by
implied or overt threats concerning the victim’s job performance evaluation, a promotion or other job
benefits or detriments (also called “quid pro quo” harassment); repeated sexual jokes; flirtations;
advances; propositions; verbal abuse of a sexual nature; graphic, verbal commentary about an individual’s
body, appearance, or sexual prowess; whistling, touching, pinching, leering, assault, coerced sexual acts
or suggestive, insulting, obscene comments or gestures or displays in the workplace of sexually
suggestive objects or pictures. No employee should be subjected to unsolicited and unwelcome sexual
overtures or conduct, in either verbal, physical, or visual form. Sexual harassment can occur between any
individuals, even if the individuals share the same sex or gender. An act may be sexual harassment
regardless of the sexual desire, gender, gender identity, gender expression, sexual orientation, or intent of
the alleged harasser.
Other Types Of Harassment
For purposes of this policy, impermissible harassment or discrimination also includes any verbal, visual,
or physical conduct that denigrates or shows hostility or aversion toward an individual based on a
lawfully protected characteristic, and that:
● creates an intimidating, hostile, or offensive work environment; or
● unreasonably alters or interferes with working conditions so as to make it more difficult to do the
individual’s job.
Abusive conduct and/or bullying on any protected basis is also prohibited. Some examples of such
impermissible harassment or discrimination are using epithets or slurs; mocking, ridiculing or mimicking
another’s culture, accent, appearance or customs; threatening, intimidating, or engaging in hostile or
offensive acts that focus on any characteristic protected by law, including jokes or pranks; the display on
walls, bulletin boards or elsewhere on Company premises, or circulation in the workplace, of written or
graphic material that denigrates or shows hostility or aversion toward a person or group because of any
characteristic protected by law. The above list of examples is not intended to be exhaustive.
Complaint Procedures
Employees who believe they have been the subject of discrimination or harassment, or who witness such
behavior toward others, should promptly report such discrimination or harassment to People + Culture or
employeerelations@siriusxm.com, as soon as possible. Employees also can use the Company’s complaint
form, which is located on Center Stage (https://centerstage.siriusxmpandora.com/ ) within the People +
Culture Center. If a complaint is brought to the attention of any supervisor or manager, the supervisor or
manager must promptly inform the People + Culture team. Upon receipt of the complaint, the People +
Culture team will conduct a prompt review of the allegations and take any preliminary actions (such as
instructing the respondent to refrain from communications with the complainant) that it deems necessary.
Though the process may vary from case to case, the Company will impartially investigate all complaints
of harassment in a fair, timely and thorough manner with the goal of remedying any violation of this
policy. The steps of an appropriate investigation cannot be fixed in advance, but will vary depending on
the nature of the allegations. Typically, the People + Culture team will interview the complainant, the
respondent, and any other relevant witnesses identified through the investigation process. Additionally,
the People + Culture team will identify, review, and preserve any relevant documents, including e-mails.
The People + Culture team will document the investigation in writing. All such investigations will be
conducted discreetly and confidentially, to the extent reasonably possible. Employees are expected to
fully cooperate with the People + Culture team during the course of any investigations. Upon completion
of the investigation, the Company will resolve the complaint and take appropriate remedial measures if
misconduct is found during the investigation. Appropriate corrective action, up to and including
termination of employment, will be taken against any employee who violates this policy. Other service
providers who violate this policy risk having their contractual relationship with the Company severed.
The Company will notify the individual who reported and the individual(s) about whom the complaint
was made of the outcome of the investigation.
Legal Protections and External Remedies
Harassment is not only prohibited by the Company, but is also prohibited by state, federal, and where
applicable, local law. Aside from the Company’s internal process, employees may also choose to pursue
legal remedies with the following governmental entities, as applicable.
If harassment involves unwanted physical touching, coerced physical confinement or coerced sex acts, the
conduct may constitute a crime. Employees subjected to this form of harassment can file a report with the
local Police Department.
United States Equal Employment Opportunity Commission (“EEOC”)
The EEOC enforces federal anti-discrimination laws, including Title VII of the 1964 federal Civil Rights
Act (codified as 42 U.S.C. § 2000e et seq.). An individual can file a complaint with the EEOC anytime
within 300 days from the harassment. There is no cost to file a complaint with the EEOC. The EEOC will
investigate the complaint, and determine whether there is reasonable cause to believe that discrimination
has occurred, at which point the EEOC will issue a Right to Sue letter permitting the individual to file a
complaint in federal court. The EEOC does not hold hearings or award relief, but may take other action
including pursuing cases in federal court on behalf of complaining parties. Federal courts may award
remedies if discrimination is found to have occurred. If an employee believes that they have been
discriminated against at work, they can file a “Charge of Discrimination.” The EEOC has district, area,
and field offices where complaints can be filed. Contact the EEOC by calling 1-800-669-4000 (1-800-
669-6820 (TTY)), visiting their website at www.eeoc.govor via email at info@eeoc.gov
Additional Enforcement Information for New York Personnel
New York State Division of Human Rights New York City Commission on Human Rights
The agencies listed above are tasked with enforcing anti-discrimination and anti-harassment laws
including the New York Human Rights Law (codified as N.Y. Executive Law, art. 15, § 290 et seq.), Title
VII of the Civil Rights Act (codified as 42 U.S.C. § 2000e et seq.), the Age Discrimination in
Employment Act of 1967 (29 U.S.C. § 623 et seq.), the Americans with Disabilities Act of 1990 (42
U.S.C. § 12101 et seq.), and the New York City Human Rights Laws (codified as Administrative Code of
City of N.Y. § 8–107 et seq.). Successful complainants may be entitled to remedies including monetary
damages, attorney’s fees and civil fines.
Employees may not be discriminated or retaliated against on the basis of their or their dependents’
reproductive health decisions. Reproductive health decisions include, but is not limited to, employees’ or
their dependents’ use or access to a particular drug, device, or medical service. Under New York State
Labor Laws in Section 203-e, employers are prohibited from:
● Accessing an employee’s personal information regarding the employee’s or the employee’s dependent's
reproductive health decision making, without the employee’s prior informed affirmative written consent;
● Discriminating or taking any retaliatory personnel action against an employee with respect to
compensation, terms, conditions or privileges of employment because of or of the basis of the employee’s
or the employee’s dependent’s reproductive health decision making;
● Requiring an employee to sign a waiver or other document that purports to deny an employee the right
to make their own reproductive health care decisions; and
● Retaliating against an employee (including discharging, suspending, demoting, or otherwise penalizing
an employee) for exercising any rights under the statute.
Successful complainants may be entitled to remedies including monetary damages, attorney’s fees,
injunctive relief, an order of reinstatement, and/or civil fines.
Additional Enforcement Information for California Personnel
The California Department of Fair Employment and Housing (“DFEH”) protects individuals from
unlawful discrimination in employment and may have jurisdiction over your complaint(s) and may
investigate and prosecute complaints of unlawful harassment, discrimination and retaliation in
employment. If an employee believes that they have been unlawfully harassed, discriminated or retaliated
against, the employee may file a charge with the DFEH or other regulatory agencies in their home State.
The DFEH (or other similar administrative agencies in your state) serve as neutral fact finders and attempt
to help the parties voluntarily resolve disputes. If disputes cannot be resolved, the DFEH has the authority
to process complaints of harassment, retaliation and discrimination through the courts, seek injunctive
relief to stop the illegal activity, and seek monetary damages. For more information, contact the DFEH or
the applicable state antidiscrimination agency directly.
You can contact the DFEH at (800) 884-1684 or visit http://www.dfeh.ca.gov/.
Additional Enforcement Information for Illinois Personnel
To report discrimination, employees in Illinois may contact the Illinois Department of Human Rights to
file a charge at www.illinois.gov/dhr or IDHR.Intake@illinois.gov. Employees may also call the Illinois
Sexual Harassment and Discrimination Helpline at 1-877-236-7703 to talk to someone about the
employee’s concerns.
No Retaliation
The Company will not retaliate against any employee for using the complaint procedure outlined in this
policy in good faith. Retaliation is unlawful under federal, state, and (where applicable) local law.
Generally, employees who have engaged in “protected activity” are protected from retaliation. Protected
activity occurs when a person in good faith has: filed a complaint of sexual harassment or other
misconduct under this policy, either internally or with any anti-discrimination agency; testified or assisted
in a proceeding involving sexual harassment or other misconduct under this policy; is a witness in an
internal investigation; opposed sexual or other discriminatory harassment or retaliation by making a
verbal or informal complaint to management, or by simply informing a supervisor or manager of
harassment, discrimination, or retaliation; complained that another employee has been harassed,
discriminated, or retaliated against; or encouraged a fellow employee to report harassment,
discrimination, or retaliation.
Retaliation is a serious violation of this policy and should be reported immediately. The report and
investigation of allegations of retaliation will follow the procedures set forth in this policy. Managers will
be subject to discipline for engaging in any retaliation.
However, if after investigating any complaint of harassment or discrimination, the Company determines
that an employee has provided false information to the Company, appropriate disciplinary action, up to
and including termination of employment, may be taken against the person who provided the false
information.
Consequences of Prohibited Behavior
Any employee, whether an individual contributor or manager, who is found to have engaged in prohibited
discrimination or harassment, or retaliation, may be subject to appropriate disciplinary action, up to and
including termination of employment. Any employee who engages in prohibited discrimination or
harassment may be held personally liable for monetary damages under applicable law for such
discriminatory or harassing conduct. The Company does not consider conduct in violation of this policy
to be within the course and scope of employment or the direct consequence of the discharge of any
employee’s duties. Accordingly, to the extent permitted by law, the Company reserves the right not to
provide a defense or pay damages assessed against employees personally for conduct in violation of this
policy.
Open Door Policy for General Employment Concerns
Employees are encouraged to raise work-related concerns with their immediate manager as soon as
possible after any event that causes concern. Alternatively, employees may raise concerns with the People
+ Culture team or Employee Relations (employeerelations@siriusxm.com). If the employee wishes to
remain anonymous, a report can be made through the whistleblower hotline found on Center Stage
(https://centerstage.siriusxmpandora.com/ ).
The Company believes that employee concerns are best addressed through informal and open
communication. However, it may not always be possible to achieve the result an employee wants. The
Company will attempt to keep all such expressions of concern, its investigation, and the terms of the
resolution confidential. However, in the course of investigating and resolving concerns, some
dissemination of information to others may be necessary.