Equal Employment Opportunity Policy Statement

McCarthy Holdings, Inc. and its subsidiaries¹ (the “Company”) are committed to equal employment opportunity and will not discriminate against any employee or applicant for employment because of that person’s race, color, gender, age, sexual orientation, gender identity, gender expression, religious beliefs, marital status, genetic information, national origin, disability, protected veteran status, or any other basis protected by federal, state, or local law and will treat all such employees or applicants equally as required by law. This policy applies to all areas of employment, including recruitment, testing, screening, hiring, selection for training, transfer, promotions, recalls, rates of pay, apprenticeship, demotion, layoff, discipline, termination, compensation, benefits, and all other privileges, terms, and conditions of employment.

Moreover, to the extent required under the relevant federal law pertaining to federal contractors, the Company will take affirmative action in an effort to ensure that applicants are employed, and that employees are treated in all aspects during employment, without regard to their race, color, gender, age, sexual orientation, gender identity, religious beliefs, marital status, genetic information, national origin, disability, or protected veteran status.

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.

This equal employment opportunity policy has the support of the Company’s Chief Executive Officer, who has assigned responsibility for its implementation to Allen Gershenson, the Vice President for the Office of Ethics and Compliance. The Company has designed an audit and reporting system to monitor its compliance.

The Company also maintains affirmative action programs to implement our equal employment opportunity policy for individuals with disabilities and protected veterans. Employees or applicants who wish to review the full narrative portion of the Company’s affirmative action program for individuals with disabilities or protected veterans may schedule an appointment to do so by contacting the Office of Ethics and Compliance during regular business hours.

¹Subsidiaries of McCarthy Holdings, Inc. include McCarthy Building Companies, Inc., Castle Contracting and MC Industrial, Inc.