Date Issued: April 1, 2002   Supersedes: New   Review Date: April 1, 2005

I. PURPOSE

The purpose of this policy is to provide a mechanism for addressing acts of violence which affect the workplace, as defined and described below. This policy applies to the perpetrators of violence only. Victims of violence affecting the workplace should refer to the Firm's "Guidelines for Managing Family and Domestic Violence Situations."

II. SUMMARY

Mintz Levin is committed to providing a workplace where acts or threats of violence are neither tolerated nor excused. Mintz Levin uses early intervention and awareness strategies, as well as disciplinary measures when necessary, to prevent or minimize the occurrence and effects of such violence.

III. SCOPE

This Policy applies to all employees and on-site vendors, consultants or independent contractors (including, without limitation, DMS and Garber Travel) of Mintz Levin (collectively, for purposes of this policy only, "Employee"), including Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.; ML Strategies, LLC; ML Capital, LLC; and Mintz Levin Financial Advisors, LLC (collectively, "Mintz Levin" or the "Firm").

IV. DEFINITION OF "ACTS OF VIOLENCE WHICH AFFECT THE WORKPLACE"

For purposes of this policy, "acts of violence which affect the workplace" includes both Workplace Violence and Domestic Violence Affecting the Workplace and Workplace Violence (hereinafter "Acts of Violence").

A. Workplace Violence "Workplace Violence" includes conduct of a violent nature which is perpetrated by an Employee and which takes place: (i) on Firm premises, (ii) at client sites, (iii) during the performance of Firm business, or (iv) while using Firm resources such as workplace telephones, FAX machines, mail, E-mail, the Internet, voice mail or other forms of electronic communication. Such conduct includes, but is not limited to, the following:

• Any act or threat of stalking, harassment or physical battery against any other person (regardless of gender)
• Any assault or threat of sexual, emotional or psychological violence against any other person (regardless of gender)
• Any pattern of coercive behavior which involves physical violence, sexual, emotional or psychological violence, intimidation inappropriate in a supervisory relationship, or verbal abuse which one person uses to control another or others
• Enlisting, coercing or asking others to do any of the above actions
• Aiding or abetting others in doing any of the above actions

"Domestic Violence Affecting the Workplace" includes violent acts (whether occurring within or outside of the workplace) occurring between family or household members, and which the Firm, in its sole discretion and judgment, determines affects Mintz Levin's workplace. Such conduct includes, but is not necessarily limited to, the following:

• Any act or threat of an act of physical aggression that causes physical harm to any other person (regardless of gender)
• Any statement or action that reasonably could be perceived as demonstrating an intent to cause physical or serious emotional harm to another (regardless of gender)
• Intimidation or verbal harassment
• Disorderly conduct
• Display or discussion of weapons
• Threats of suicide
• Homicide, assault and battery or rape
• Stalking
• Enlisting, coercing or asking others to do any of the above actions
• Aiding or abetting others in doing any of the above actions