Guidewire, Inc.

DISCRIMINATION & HARASSMENT POLICY,INCLUDING SEXUAL HARASSMENT

I.Introduction

Guidewire, Inc. is committed to a work environment free of any type of illegal discriminatory harassment, including sexual harassment. Discriminatory harassment consists of any unwelcome conduct, whether verbal or physical, that is based on a characteristic protected by law, such as race, color, sex, religion, creed, age, disability, national origin, sexual orientation, transgender status, genetic information, veteran and military status, any other status as defined by federal and state laws and regulations, or participation in discrimination complaint-related activities (retaliation). Guidewire, Inc. will not tolerate harassing conduct that affects employment conditions, that interferes unreasonably with an individual’s performance, or that creates an intimidating, hostile, or offensive work environment.

Harassment or discrimination of employees occurring in the workplace, in connection with work-related travel, and/or work-sponsored events will not be tolerated. Further, any retaliation against an individual who has complained about harassment or retaliation against individuals for cooperating with an investigation of a harassment complaint is similarly unlawful and will not be tolerated.

Because Guidewire, Inc. takes allegations of harassment and discrimination seriously, we will respond promptly to complaints. Where it is determined that inappropriate conduct has occurred, we will act promptly to eliminate the conduct and impose such corrective action up to and including immediate termination where appropriate.

Please note that while this policy sets forth our goals of promoting a workplace that is free of harassment and discrimination, the policy is not designed or intended to limit our authority to discipline or take remedial action for workplace conduct which we deem unacceptable, regardless of whether that conduct satisfies the definition of harassment or discrimination.

II.Definitions

“Harassment” means unwelcome conduct, whether verbal or physical, that is based on a characteristic protected by law. Harassment includes, but is not limited to:

  1. Display or circulation of written materials or pictures that are degrading to a person or group as previously described.
  2. Verbal abuse, slurs, derogatory comments, or insults about, directed at, or made in the presence of an individual or group as previously described.

“Sexual harassment: means unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when:

  1. Submission to or rejection of such conduct is made either explicitly or implicitly a term or condition of an individual’s employment; or
  2. Submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or
  3. Such advances, requests or conduct have the purpose or effect of unreasonably interfering with an individual’s work performance by creating intimidating, hostile, humiliating or sexually offensive work environment.

“Discrimination” means unfairly treating a person or group of people differently from other people or groups of people based on a characteristic protected by law. Discrimination includes, but is not limited to:

  1. Display or circulation of written materials or pictures that are degrading to a person or group as previously described.
  2. Verbal abuse, slurs, derogatory comments, or insults about, directed at, or made in the presence of an individual or group as previously described.

Under these definitions, direct or implied requests by a supervisor for sexual favors in exchange for actual promised job benefits such as favorable reviews, salary increases, promotions, increased benefits or continued employment constitutes sexual harassment.

The definition of sexual harassment is broad and in addition to the above examples, other sexually oriented conduct, whether intended or not intended, that is unwelcome and has the effect of creating a workplace environment that is hostile, offensive, intimidating or humiliating to male or female workers may also constitute sexual harassment.

While it is not possible to list all those additional circumstances that may constitute sexual harassment, the following are some examples of conduct which if unwelcome may constitute sexual harassment depending on the totality of the circumstances including the severity of the conduct and its pervasiveness:

* Unwelcome sexual advances, whether they involve physical touching or not;

* Sexual epithets (nicknames, descriptions), jokes, written or oral references to sexual conduct, gossip regarding one’s sex life, comments on an individual's body, or comments about an individual sexual activity, deficiencies, or prowess (ability, expertise, skill)

* Displaying sexually suggestive objects, pictures, or cartoons

* Unwelcome leering (staring up and down), whistling, brushing against the body, sexual gestures, suggestive or insulting comments;

* Inquiries into one's sexual experiences and discussion of one's sexual activities

All employees should take special note that, as stated above, any retaliation against an individual who has made a complaint or any retaliation against an individual who is cooperating with an investigation of harassment, sexual harassment, or discrimination complaint is similarly unlawful and will not be tolerated.

  1. Complaint Procedures

If any employee believes that he or she has been subjected to harassment or discrimination, the employee has the right to file a complaint with our organization. This may be done in writing or orally.

If you would like to file a complaint you may do so by contacting; Michelle Roy, Human Resources Director, 413-733-6100 ext. 120 at 551 East Columbus Ave., Springfield MA 01105 or you may contact Colleen Adamski, Vice President, Human Resources, 413-733-6100 ext. 111 at 551 East Columbus Ave., Springfield MA 01105. They are all also available to discuss any concerns you may have and to provide you information about our policy on sexual harassment and our complaint process.

IV.Complaint Investigation

When we receive a complaint we will promptly investigate the allegation in a fair and expeditious manner. The investigation will be conducted in such a way as to maintain confidentiality to the extent practicable under the circumstances. Our investigation will include a private interview with the person filing the complaint and with witnesses. We will also interview the person alleged to have committed the sexual harassment. When we have completed our investigation, we will, to the extent appropriate, inform the person filing the complaint and the person alleged to have committed the conduct of the results of the investigation.

If it is determined that inappropriate conduct has occurred, we will act promptly to eliminate the offending conduct, and where it is appropriate we will also impose disciplinary action.

V.Disciplinary Action

If it is determined that inappropriate conduct has been committed by one of our employees, we will take such action as appropriate under the circumstances. Such action may range from counseling to termination of employment, and may include such forms of disciplinary action as we deem appropriate under the circumstances.

VI.State and Federal Remedies

In addition to the above, if you believe that you have been subjected to harassment, sexual harassment, or discrimination, you may file a formal complaint with either or both government agencies set forth below. Using our complaint process does not prohibit you from filing a complaint with these agencies. Each agency has a designated time period for filing a claim. EEOC has 180 days and MCAD has 300 days.

The United States Equal Employment Opportunity Commission EEOC

1 Congress Street, 10th Floor

Boston, MA02114

617-565-3200

The Massachusetts Commission Against Discrimination MCAD

Boston Office: Springfield Office:

One Ashburton Place, Room 601436 Dwight St, Room 202

Boston, MA02108Springfield, MA01103

617-727-3990413-739-2145

Guidewire, Inc. encourages employees to communicate any and all concerns about harassment, sexual harassment and discrimination in accordance with this policy.

The complete Harassment, Sexual Harassment,and Discrimination Policy is distributed each year to every employee.

01/2014