DIVERSITY POLICY

We value and respect the strengths and differences among our employees, clients, and communities because they reflect our future success. Our clients, suppliers, and strategic partners are increasingly diverse and multicultural. We must be positioned to understand, interface, relate to and meet their needs. Our challenge is to seek out and use our diversity in ways that bring new and richer perspectives to our firm and the clients we support. Our commitment is consistent with our recognition that it is the outstanding people within the firm who have always been the source of our strength. Our colleagues are the firm’s greatest assets. We have long embraced the principles of equal employment opportunity. We further recognize that promoting diversity is an integral component of our continuing quest for excellence as individual attorneys and as a firm. As part of the effort to advance our commitment to diversity throughout the firm, the following initiatives, among others, are being pursued:

• Improve the level of diversity within the firm’s leadership positions, committees, and practice development efforts.

• Develop an attorney and senior administrative manager evaluation process to set clear expectations and accountability around diversity and inclusion.

• Annually review and recognize the contributions made by attorneys and managers to advance the firm’s commitment to diversity and inclusion.

• Emphasize the firm’s long-standing policy that encourages reporting of any discrimination or harassment based on sex, race, national origin or other protected status.

• Participate in opportunities outside the firm to explore diversity and inclusion initiatives underway with clients, bar associations and minority organizations that share this common objective.

• Strengthen our diversity through recruiting and retaining minority and women attorneys and staff personnel from all backgrounds.

• Work in partnership with law schools for placement of two (2) viable female and/or minority candidates for our summer internship program.

• Develop mentoring and sponsorship programs for our employees.

• Recognize diversity as a business imperative in increasing our business opportunities and partnerships with key external markets, communities, and suppliers.

• Create a work environment that engages, enables and empowers people to do their best work.

• Focus specifically on recruitment, retention and development of diverse talent at all levels in the organization.

• Lead in our community by valuing diversity.

All employees of Kelley Kronenberg have a responsibility to treat others with dignity and respect at all times. All employees are expected to exhibit conduct that reflects inclusion during work, at work functions in or out of the office, and at all firm sponsored and participative events. All employees are also required to attend and complete annual diversity awareness training which will be provided by the firm to enhance their knowledge to fulfill this responsibility.

All employees found to have exhibited any inappropriate conduct or behavior against others may be subject to disciplinary actions including but not limited to termination.

Employees who believe they have been subjected to any kind of discrimination that conflicts with the company’s diversity policy and initiatives should seek assistance from an HR representative. All complaints will be kept confidential to the extent possible, but confidentiality cannot be guaranteed. HR will review, analyze, and promptly address any complaint of discrimination brought to its attention.

A Committee on Diversity will work closely with the Shareholders and the Executive Team to carry out these and other initiatives to help strengthen diversity throughout the firm. Of course, each and every one of us must accept responsibility for and do our part to fulfill our organization’s commitment to diversity. Kelley Kronenberg accepts responsibility to be a leader in assuring that a diverse workforce is recognized as an important cornerstone for success in our industry. For Kelley Kronenberg to be an excellent utility and regional leader, we believe this commitment must be honored.

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