Policy on Equal Employment Opportunity

04/2026

Creek Lane Capital, LLC, and its affiliates (collectively referred to herein as “the Company”) hereby reaffirm that its officers and employees are committed to, and shall diligently apply, all the terms and provisions of the Civil Rights Act of 1964 and other applicable state, local, or federal laws. The Company shall also abide by the requirements of 41 CFR Parts 60.300.5 (a) referring to Disabled Veterans and/or Protected Veterans and 41 CFR Parts 60-741.5 (a) referring to Individuals with Disabilities, as well as other relevant federal, state, and local laws and regulations. These regulations prohibit discrimination against qualified individuals on the basis of race, gender, gender identity, sexual orientation, disability or protected veteran status, and require affirmative action by covered prime contractors and subcontractors to employ and advance in employment qualified individuals with disabilities and/or protected veterans. It is this Company’s policy to assure that applicants and employees are treated without regard to their race, religion, sex, color, national origin, age or disability. Such action shall include: employment, promotion, demotion, or transfer; recruitment or recruitment advertising; layoff or termination; rates of pay or other forms of compensation; and selection for training, including apprenticeship, pre-apprenticeship, and/or on-the-job training.

Statement of Policy

In order to provide equal employment and advancement opportunities to all qualified persons without regard to race, color, religion, gender, gender identity, sexual orientation, age, national origin, disability, protected veteran status, or any other protected characteristic under federal, state, or local law, the Company shall do the following:

Recruit, hire, train, and promote persons in all job titles without regard to race, color, religion, gender, gender identity, sexual orientation, age, national origin, disability, protected veteran status, or any other protected characteristic under federal, state, or local law;
Base decisions on employment to further the principle of equal employment opportunity. Employment decisions of the Company will be based on merit, qualifications, and abilities. The Company does not discriminate in employment opportunities or practices on the basis of race, color, religion, sex, national origin, age, disability, or any other characteristic protected by law;
Ensure that promotion decisions are in accordance with the principles of equal employment opportunity by imposing only valid requirements for promotional opportunities.
Ensure that all personnel actions, including but not limited to termination, compensation, benefits, transfers, demotion, lay-offs, and return from lay-offs, will be undertaken without regard to race, color, religion, gender, gender identity, sexual orientation, age, national origin, disability, or protected veteran status, or any other protected characteristic under federal, state, or local law; and
Ensure that all services, company-sponsored training, and company-sponsored activities are made available to all employees regardless of handicap, race, color, religion, gender, gender identity, sexual orientation, age, national origin, disability, protected veteran status, or any other protected characteristic under federal, state, or local law.
The Company will not discharge or in any other manner discriminate against employees or applicants because they have inquired about, discussed, or disclosed their own pay or the pay of another employee or applicant. However, employees who have access to the compensation information of other employees or applicants as a part of their essential job functions cannot disclose the pay of other employees or applicants to individuals who do not otherwise have access to compensation information, unless the disclosure is (a) in response to a formal complaint or charge, (b) in furtherance of an investigation, proceeding, hearing, or action, including an investigation conducted by the employer, or (c) consistent with the contractor’s legal duty to furnish information. 41 CFR 60-1.35(c).
The Company will make reasonable accommodations for qualified individuals with known disabilities unless doing so would result in an undue hardship. This policy governs all aspects of employment, including selection, job assignment, compensation, discipline, termination, and access to benefits and training.

To implement this Policy, the Company will adhere to the following:

The Company has designated Blair Knopp as the Equal Employment Opportunity Officer (“EEO Officer”). Blair Knopp is located in the Chicago, Illinois office and can be reached at (312) 563-5400. The Regional Offices of the Company should designate Equal Employment Representatives for the Region or for a Specific Project. When any Representative is designated, that designation must be forwarded to the EEO Officer and published in all offices and projects covered by the representative. The Representative must report all contacts to the EEO Officer.
The EEO Officer is hereby given full authority to carry out the program and is given the responsibility and authority to: a. Implement the Equal Employment Opportunity program, including internal and external dissemination of the Company’s policies. b. Assist line management in collecting and analyzing employment data, identifying problem areas, setting goals and timetables, and developing programs to achieve goals. Such programs should include specific remedies if discriminatory practices are discovered in the employment system. c. Design, implement, and monitor internal audit and reporting systems to measure program effectiveness to determine where progress has been made and where further action is needed, if necessary, to ensure that such action is taken. d. Serve as a liaison between the Company, government regulatory agencies, and other community groups. e. Keep management informed of the latest developments in the area of Equal Employment Opportunity.
Project Management shall be responsible for carrying out the Company policies and this EEO Policy in their respective jobs. Any questions regarding the compliance with this Policy may be directed to the Corporate EEO Officer, Business Group Leader, the designated EEO Officer for your region, or the Human Resources Director. This Policy shall be published throughout the company, including in The Walsh Group Employee Handbook, on the Company’s public and internal websites, and will be reviewed at all new hire orientations so that every new employee of the Company shall be made aware of its provisions. Regular management-level training will be conducted to ensure publication of the policy to supervisory employees. The Policy shall be posted at all jobsites and in all offices where employee notices are posted.
All superintendents, foremen, office managers, and other supervisory personnel employed by the Company and having the authority to hire, discharge, promote, demote, lay off, or discipline employees, will read and be familiar with this EEO Policy.
The Company shall maintain such documentation as may be necessary to comply with this policy, including personnel files, EEO-1 reports, VETS-100 reports, and all other records required by applicable law.
The Company will post conspicuously such announcements with respect to nondiscrimination and equal employment opportunity as required by law, rules, and regulations of agencies concerned, including the United States Department of Labor, and require that all subcontractors shall do likewise.
The Company will make its hiring policy and Equal Opportunity Policy available to all subcontractors upon request and shall include as a condition of the subcontract that the subcontractor shall observe applicable state, local or federal laws regarding nondiscrimination.
The Company will undertake appropriate recruitment methods to effectively recruit qualified individuals with disabilities as required by 41CFR 60-741.5(a) and qualified protected veterans as required by 41 CFR 60-300.1(a). The Company will ask for written assurances from hiring sources that admission to their referral facilities is open on equal terms to all qualified persons, without discrimination based on race, color, religion, gender, gender identity, sexual orientation, age, national origin, disability, or protected veteran status.
The Company will cooperate with governmental agencies, federal, state and local, who have the responsibility to observe our actual compliance with various laws relating to recruitment and employment by furnishing such reports, records and other matters as requested, in order to foster the Equal Employment Opportunity (“EEO”) Policy for all persons, regardless of handicap, race, color, religion, gender, gender identity, sexual orientation, age, protected veteran status, or national origin.
In all Company advertisements for employees, such advertisements shall contain the phrase, “An Equal Opportunity Employer, Disabled/Veteran.”
Placement, promotion, and transfer activities at all levels will be monitored to ensure that full consideration, as required by this policy, has been given to disabled persons and protected veterans. From time to time, the Company will review job categories where disabled persons and protected veterans may appear to be underemployed and seek to determine the cause for such situations. When necessary, remedial efforts may include such actions as the following: a. More vigorous recruitment of qualified disabled persons and protected veterans. b. Special discussions with appropriate management, supervisory, or other personnel, regarding the Company’s policy and its desire to ensure the utilization of qualified disabled persons and protected veterans at all job levels. c. Re-evaluate the qualifications of the lower echelon of disabled persons and protected veterans to determine whether their skills and capabilities may be more fully utilized at higher job levels or would warrant their transfer to other types of jobs more readily leading to advancement. d. On-the-job training programs, as well as all other training and educational programs, to which the Company gives support or sponsorship, will be reviewed to ensure that disabled persons and protected veterans, as well as all other employees, are given equal opportunity to participate. e. Steps will be taken to give active encouragement to disabled persons and protected veterans to increase their skills and job potential through participation in available training and educational programs. f. The Company will ensure that qualified disabled persons and protected veterans are included in supervisory training classes sponsored or supported by the Company.
The Company will ensure that all services and Company-sponsored activities are made available to employees, regardless of disability, race, color, religion, gender, gender identity, sexual orientation, age, national origin, or protected veteran status.
There will be no segregated facilities sponsored by, nor the use of such accepted by, the Company for employee utilization. These include, but are not limited to, rest areas, parking lots, drinking fountains, and all other such common facilities. Toilets and necessary changing facilities will offer privacy to both male and female employees.
The Company will advise and make known in writing to all sources from which it obtains employees that it is an Equal Opportunity Employer and will provide this Equal Opportunity Policy if required or requested. The Company will work cooperatively with affected unions in reviewing construction action on apprenticeship programs, apprenticeship training and union referral practices.

Any employees with questions or concerns about any type of discrimination in the workplace are encouraged to bring these issues to the attention of their immediate supervisor, EEO Officer, or the Human Resources Manager. Employees can raise concerns and make reports without fear of reprisal. Anyone found to be engaging in any type of unlawful discrimination will be subject to disciplinary action, up to and including termination of employment.

In addition to submitting complaints internally, employees also have the option to file charges of discrimination with the Equal Employment Opportunity Commission or the equivalent state agency in the state where they work. Employees can contact HR to find out the contact information for the relevant state agency and/or check job site bulletins for this information.

On behalf of Creek Lane Capital, LLC, and its affiliates.

Signed: Gregory Ciambrone, Michael Gibbons, Danielle Gurgone — Creek Lane Capital, LLC