Handbook Template 20172

ASO /Company logo here ABC COMPANY DRAFT COMPANY POLICIES & EMPLOYEE HANDBOOK PRESENTED BY ABC CompanyABC Company Handbook Created A/O 01/01/2017 Company Policies and Employee Handbook

TABLE OF CONTENTSWELCOME............................................................................................................................................... 4NOTICE-AT WILL STATEMENT........................................................................................................ 5ABC COMPANY POLICIES .................................................................................................................. 6 INTRODUCTORY PERIOD............................................................................................................... 6 WORK HOURS .................................................................................................................................... 6 EMPLOYEE CATEGORY/STATUS ................................................................................................. 6 BREAKS/MEAL PERIOD................................................................................................................... 7 LACTATION BREAKS ....................................................................................................................... 7 TIMEKEEPING ................................................................................................................................... 7 COMPENSATION ............................................................................................................................... 8 PAYDAY ............................................................................................................................................. 8 PAY CALCULATION & SALARY DEDUCTIONS ........................................................................ 8 OVERTIME PAY............................................................................................................................... 9 EMPLOYEE CLASSIFICATIONS .................................................................................................. 9 WORK RELATED TRAVEL EXPENSES ..................................................................................... 10 JOB POSTING................................................................................................................................. 11 PERFORMANCE EVALUATIONS ............................................................................................... 11 EMPLOYEE RELATIONS ............................................................................................................. 11 WORKPLACE CONDUCT ............................................................................................................... 12 PERSONAL APPEARANCE AND CLEANLINESS .................................................................... 12 SMOKING/TOBACCO PRODUCTS.............................................................................................. 12 HOUSEKEEPING AT WORKSITES............................................................................................. 12 VISITORS IN THE WORKPLACE-alternates within................................................................... 12 LOST AND FOUND........................................................................................................................ 13 COMPANY MAIL............................................................................................................................ 13 TELEPHONES ................................................................................................................................ 13 USE OF COMPANY EQUIPMENT............................................................................................... 14 RECYCLING.................................................................................................................................... 14 COMMUNICATION SYSTEMS ...................................................................................................... 14 INTERNET USE & SOCIAL MEDIA............................................................................................ 16 CELL/MOBILE PHONES .............................................................................................................. 17 PERSONAL CELL PHONES ......................................................................................................... 17 MANAGER RESPONSIBILITIES................................................................................................. 17 CAMERA PHONES ........................................................................................................................ 17 PERSONAL USE OF COMPANY PROVIDED CELL PHONES................................................ 18 PHONE SAFETY ............................................................................................................................ 18 CONFIDENTIAL INFORMATION ................................................................................................. 18 CONFIDENTIAL INFORMATION PROCEDURE ..................................................................... 19 INTELLECTUAL CAPITAL/PROPERTY POLICY ..................................................................... 21 EMPLOYEE RECORDS ADMINISTRATION .............................................................................. 21 EMPLOYMENT APPLICATIONS................................................................................................. 21 I-9 FORMS AND RECORDS ......................................................................................................... 21 E-VERIFY........................................................................................................................................ 22 1

CHILD LABOR REQUIREMENTS............................................................................................... 22 GENETIC INFORMATION RECORDKEEPING........................................................................ 22 EMPLOYEE ACCESS TO PERSONNEL FILES......................................................................... 23 EMPLOYMENT VERIFICATIONS .............................................................................................. 23 SEPARATION OF EMPLOYMENT................................................................................................ 24 BUSINESS ETHICS ........................................................................................................................... 24 DISCIPLINARY ACTION ................................................................................................................ 25 EXAMPLES OF MISCONDUCT................................................................................................... 25EQUAL EMPLOYMENT OPPORTUNITY ....................................................................................... 26 PROHIBITED HARASSMENT/DISCRIMINATION ................................................................... 26 SEXUAL HARASSMENT............................................................................................................... 27 HARASSMENT/DISCRIMINATION-REPORTING &COMPLAINT PROCEDURE ........................... 28 DISABILITY ACCOMMODATION................................................................................................ 29 PREGNANCY ACCOMMODATION (FOR MARYLAND ONLY) ............................................. 30 RELIGION ACCOMMODATION................................................................................................... 30 CONFLICT OF INTEREST .............................................................................................................. 30 EMPLOYMENT OF FAMILY MEMBERS .................................................................................. 31 OUTSIDE EMPLOYMENT STATEMENT................................................................................... 31 PROHIBITION OF FRATERNIZATION ....................................................................................... 32 SOLICITATIONS/LITERATURE DISTRIBUTION .................................................................... 32 PERMITTED SOLICITATION BY EMPLOYEES....................................................................... 33 USE OF THE COMPANY EQUIPMENT FOR SOLICITATION/.............................................. 33 LITERATURE DISTRIBUTION BY EMPLOYEES .................................................................... 33 OFF-DUTY EMPLOYEE SOLICITATION/LITERATURE DISTRIBUTION .......................... 33 EXCEPTIONS TO RESTRICTIONS ON SOLICITATION/ ........................................................ 33 LITERATURE DISTRIBUTION.................................................................................................... 33 PROHIBITED DISCRIMINATION AND HARASSMENT ......................................................... 33 SOLICITATION/LITERATURE DISTRIBUTION-ALTERNATE.................................................. 34 COMPANY POSTINGS .................................................................................................................. 34CONFLICT RESOLUTION.................................................................................................................. 35 DISPUTE RESOLUTION PROCEDURE........................................................................................ 35SAFETY AND HEALTH ....................................................................................................................... 37 DRUGS AND ALCOHOL POLICY.................................................................................................. 37 WORKPLACE VIOLENCE PREVENTION POLICY .................................................................. 39 COPING WITH THREATENING OR VIOLENT INDIVIDUALS.............................................. 40 WORKERS’ COMPENSATION ...................................................................................................... 40 INJURY CARE/TREATMENT....................................................................................................... 41 LOST WAGES ................................................................................................................................. 41ABSENCES AND TIME OFF ............................................................................................................... 42 ATTENDANCE AND PUNCTUALITY ........................................................................................... 42 INCLEMENT WEATHER ................................................................................................................ 43 FUNERAL/BEREAVEMENT LEAVE ............................................................................................ 43 2

JURY DUTY........................................................................................................................................ 43 DISCRIMINATION ........................................................................................................................ 44 COMPENSATION........................................................................................................................... 44 RIGHT TO VOTE .............................................................................................................................. 44 MILITARY LEAVE (USERRA) ....................................................................................................... 44 FAMILY AND MEDICAL LEAVE ACT POLICY......................................................................... 46 STATE/LOCAL ADDITIONAL LEAVE REQUIREMENTS ....................................................... 50 HOLIDAYS OBSERVED .................................................................................................................. 50 PAID TIME OFF (PTO) ..................................................................................................................... 51EMPLOYEE BENEFITS....................................................................................................................... 53 RETIREMENT BENEFIT PLAN ..................................................................................................... 53 SECTION 125...................................................................................................................................... 53 COBRA ................................................................................................................................................ 53 SOCIAL SECURITY.......................................................................................................................... 54 EDUCATIONAL ASSISTANCE....................................................................................................... 54 EDUCATIONAL LEAVE................................................................................................................ 54 3

WELCOMEWe welcome you to ABC Company (hereinafter referred to as ‘ABC Company’ or ‘the Company’).This handbook has been prepared to welcome you to the Company and help you understand our policies,procedures, and benefits. The policies set forth in this handbook are intended as guidelines only and aresubject to change at the sole discretion of ABC Company.As an employee of ABC Company, you are required to review and familiarize yourself with thishandbook. We trust you will find your handbook both helpful and informative. It is your responsibilityto remain up to date with any handbook changes and review future editions as they become effective.Should you desire further information about subjects covered in this handbook or a copy of the currenthandbook, please contact ABC Company management. If you need assistance in reviewing thisinformation please contact your onsite HR manager for accommodation options or questions.Circumstances may require that the policies and practices described in this handbook change from timeto time. The Company will attempt to provide employees with notification of such changes when theyoccur. All previously issued handbooks and any inconsistent policy are hereby replaced. To the extentthat the Company has any collective bargaining agreement, certain statements in this handbook maydiffer from provisions of the collective bargaining agreement. Where there is a conflict, the terms of thecollective bargaining agreement will apply to any union employees who are subject to the collectivebargaining agreement. No language in this handbook is meant to, nor should it be interpreted to, in anyway limit rights under any applicable federal, state or local laws, including rights under the NationalLabor Relations Act.Throughout this Employee Handbook, you will find references to a company called ABC. ABC is an“administrative services organization” (ASO) that specializes in Human Resources management. Youwill receive your paycheck, benefits, and Human Resources services from ABC. [Company] maintainsresponsibility and control of the daily operation of the core business. ABC assumes responsibility forcertain Human Resources functions such as benefits and payroll administration, as well as medical andworkers’ compensation insurance programs. 4

NOTICE-AT WILL STATEMENTEmployment with the Company is voluntary and is subject to termination by the employee or theemployer at will, with or without cause and with or without notice, at any time. Nothing in thesepolicies, handbook or forms shall be interpreted to be in conflict with or to eliminate or modify inany way the employment-at-will status of employees. This policy of employment-at-will may not bemodified by any officer or employee of the Company, and shall not be modified in any publicationor document. The only exception to this policy is a written employment agreement approved at thediscretion of the President of the Company.Except for the at-will employment policy, the Company reserves the right to interpret theprovisions of this handbook as may be appropriate under the particular facts and circumstancesand to revise, modify, rescind, delete or add to the provisions of this handbook in its sole andabsolute discretion with or without notice.While we generally follow the policies and procedures herein, the policies and handbook shouldnot be construed to convey any actual, inferred or implied guarantee of any fixed terms,conditions, or duration of your employment with the Company. The employee handbook is notmeant to create, nor should it be construed as creating, a contract of employment. All employmentis at will and, as such, may be terminated by the Company or the employee at any time and withor without cause.Please understand that no supervisor, manager, or other representative of the Company or ABC,other than the President of the Company has the authority to enter into any agreement with youfor employment for any specified period of time or to make any promises or commitmentscontrary to the foregoing. Further, no employment agreement is enforceable unless it is in writingand signed by both the respective employee and the President of the Company. 5

ABC COMPANY POLICIESINTRODUCTORY PERIODThe first 90 days of your employment with ABC Company is considered an introductory period. Thisperiod of time should be used for you to decide whether ABC Company is a place that you wish tocontinue working in. At the same time, your work performance will be assessed to determine whetheryou may work well in the position that you were hired to fill. Upon advancement to a new position, thereis, again, an introductory period of the first ninety (90) days to determine whether the new position isright for you. Remember that employment with the Company is voluntary and is subject to terminationby the employee or the employer at will, with or without cause and with or without notice, at any time,including during the introductory period or after its completion.WORK HOURSCompany management and supervisors set the regular work hours for all employees. Your manager willnotify you of your scheduled work & break times. Federal law does not set hours of work. Some Stateslaws set hours of work or regulate work hours or break times for minors. Please contact your manager ifyou have any questions.ADD ANY APPLICABLE STATE REQUIREMENTS FOR HOURS OF WORK HEREEMPLOYEE CATEGORY/STATUSADD ANY CLIENT SPECIFIC DEFINITIONS OF FULL TIME/PART TIME here or modify below asapplicableDuring employment with the Company, employees may be categorized in any of the followingcategories, based on the terms of their employment and/or job position, work schedule and length ofemployment. These categories are intended to clarify employment status and benefit eligibility and donot guarantee employment for any specified period of time. Employment may be ended at any time byeither the employee or the Company.Each employee will belong to one employment category:  REGULAR FULL-TIME employees are those who are regularly scheduled to work the Company’s full-time schedule of ## hours or more per week. Generally, they are eligible for the Company full time employee benefit packages, subject to the terms, conditions, and limitations of each benefit program.  REGULAR PART-TIME employees are those who are scheduled to work regularly at a part time schedule of less than ## hours per week. Part-time employees will receive all legally-mandated benefits for part-time employees but are usually not eligible for additional Company-sponsored benefits.  TEMPORARY/SEASONAL employees are those who are hired as interim replacements, to temporarily supplement the work force, or to assist in the completion of a specific project. Employment assignments in this category are of a limited duration and may be either full or part time or as needed. Employment beyond any initially stated period does not in any way imply a change in employment status. Temporary employees retain that status unless and until notified of 6

a change. While temporary employees receive all legally mandated benefits (such as workers' compensation insurance and Social Security), they are ineligible for most of the Company’s regulated benefit programs.For Company internally regulated benefits (e.g. paid time off related policies), Company policy willgovern employee eligibility. For legally governed benefits, the applicable law or benefit programsummary plan description will govern employee eligibility based on hours/length of employment,regardless of their assigned category above.BREAKS/MEAL PERIODIn general, federal law does not set minimum requirements for the amount or length of breaks or mealperiods, though a few states may regulate hours/breaks for minors and/or other employees. Unless thereis an applicable legal requirement, the Company decides breaks and/or meal periods for employees basedon the operating needs of the Company’s business. As such, there may be times where breaks are notpossible, must be rescheduled, or cancelled by management unless applicable laws require otherwise.Breaks may not be used to extend meal periods, shifted or not used as scheduled in order to alter workschedules (e.g. arrive late/leave early) and do not accumulate if unused.Generally, the Company break(s) are # minutes, and # meal break(s) are ###. However this may vary bydepartment or position. Please contact your manager for your specific break/meal period times or if youhave any questions or concerns.ADD ANY STATE SPECIFIC BREAK REQUIREMENTS IF APPLICABLELACTATION BREAKSThe Company complies with all applicable federal and state laws and regulations concerning breast-feeding and nursing mothers and provides assistance for nursing mothers who want to express and storebreast milk at workplaces during business hours.Accordingly, employees who are nursing mothers can take reasonable break periods during the workdayeach time they need to express breast milk for their children beginning from the date of the nursingchild's birth for up to one year.The Company may designate/set aside a private/secure non-bathroom area to be used for lactation breakswhen doing so does not constitute an undue hardship. Please see your supervisor or onsite HR managerregarding break scheduling and designation of lactation area.TIMEKEEPINGAll employees may be required to record the time actually worked by the Company’s designated timerecord keeping method. Generally, employees should record each of the following times to accuratelyrecord the hours worked: 1) Time in for scheduled shift 2) Time out for scheduled meal 3) Time in from scheduled meal 4) Time out at the end of the scheduled shift. 7

If you leave the premises for any purpose other than Company business, you must record this on theCompany time records. These records MUST BE ACCURATE because this is the basis for preparingyour paycheck. If you make an error while recording your time worked, notify your managerimmediately. The calculation of pay is based on verifiable hours worked and timely reporting ofcorrections. If you have an off the clock break or meal period that is less than 30 minutes or because it isinterrupted by work, be sure to notify your manager as soon as possible so that your time record can becorrected accordingly. Unpaid breaks must be at least 30 minutes long, uninterrupted by work.Working an unauthorized schedule and/or unapproved overtime may lead to disciplinary action. Non-exempt employees may not work ‘off the clock’ and no one may instruct an employee to do so.Violations of this policy may result in disciplinary action.Employees may not sign or record time in or out on another employee’s behalf. Falsification of the timerecords, or recording or altering the time record of another employee is cause for immediate discharge.COMPENSATIONPAYDAYThe Company will not cash its employees' payroll checks. An employee’s paycheck will not be releasedto someone other than the employee without prior written signed authorization from that employee anddocumentation from the other person to verify their identity. If an employee requests reissue of a checkthat has been misplaced or destroyed after distribution to the employee, that employee may be requiredto cover the costs associated with check re-issuance. If your employment ends for any reason, your finalpaycheck will be issued on the next normally scheduled payday unless required otherwise by State law.Paychecks or direct deposits are issued on a #pay-period per year basis on the Company’s scheduled payperiods/check dates. The scheduled pay-period starts on DATE/TIME and ends on DATE/TIME withthe related pay date following on DATE/TIME. The Company designated workweek runs fromDATE/TIME to DATE/TIME. When the normally scheduled pay date falls on non-business day (e.g.weekend/holiday) the pay date will shift to the last business day prior to the normally scheduled paydate.PAY CALCULATION & SALARY DEDUCTIONSThe Company endeavors to follow all applicable provisions of the Fair Labor Standards Act (FLSA),including those governing salary deductions from employees exempt from overtime pay requirements.Your paycheck automatically includes a statement of your earnings for the pay period, and a summaryfor mandatory and voluntary deductions from your pay. Voluntary deductions include elective programswhich you sign up for and contribute money to, such as group health insurance, dental insurance, 401(k)savings plan. Mandatory deductions include federal income tax and FICA, and Social Security, as wellas federal, state and local income taxes, which vary by location. The Company is legally required tocomply with all valid garnishment/withholding orders in the processing of employee wages and willcomply with applicable laws protecting employees from adverse action based on garnishment of his/herwages. 8

The Company prohibits any pay deductions not proper under the applicable terms of the FLSA or failureto pay compensation according to terms specific to your employment/position. Non-exempt employeesmay not work ‘off the clock’ and no one may instruct an employee to do so. Violations of this policymay result in disciplinary action.If you believe that an improper deduction from your salary has been made, or that you were not paidcorrectly under the terms of your employment, you are required to immediately report the matter to yoursupervisor, manager, or the Human Resources Department of ABC by calling 1-800-776-0076. Onreceipt of the complaint, ABC Company will review the deduction for compliance with the FLSA, anddiscuss with you the results of that review. In the event an improper deduction or pay error is made, theCompany will reimburse you on the next scheduled check date.OVERTIME PAYOvertime is defined by law as hours worked in excess of 40 hours within a defined ‘workweek’. Theworkweek is a fixed and regularly recurring period of 168 hours/seven consecutive 24-hour periods, setby the Company and can be set to begin on any day and at any hour of the day. Different workweeks maybe established for different employees or groups of employees. Averaging of hours to determineovertime hours over two or more weeks is not permitted.Non-exempt employees may not alter their hours of work from one week to offset lower or highernumber of hours worked from another workweek in order to receive or avoid calculation of overtimehours/pay. ‘Comp Time’ or time off in lieu of overtime pay is generally prohibited by law unlessspecifically allowed under the FLSA statutory exceptions. If you have questions about what State orFederal law defines as ‘time worked’ for wage or overtime calculations, please contact your manager.If an employee accepts the opportunity to work overtime hours, the employee is expected to work thescheduled additional time as agreed and absences will be assessed under attendance policies just asabsences from normally scheduled work would be.EMPLOYEE CLASSIFICATIONSAll employees will be classified as exempt or non-exempt, salary or hourly as defined under the FairLabor Standards Act (FLSA). If you have a question about your classification, please contact yourmanager.Eligibility for Overtime by Classification:  Non-Exempt–Non-exempt hourly or salaried employees receive overtime pay at a rate of one and one-half times their regular effective hourly rate of pay for time worked in excess of 40 hours per workweek.  Exempt-Exempt employees are not eligible for overtime, and are generally expected to work hours as scheduled for their position unless designated as a position in which the employee may determine their own work schedule. Exempt employees are paid a set salary per workweek regardless of the number of hours worked except for deductions from pay allowed by law. As such, exempt employees are generally expected to work hours as required to successfully perform the duties of their position. 9

 Non-exempt Irregular-These are non-exempt employees who do not work a predetermined schedule, and whose duties necessitate unpredictable and irregular hours of work that cannot be predicted by employer or employee with any certainty. Under FLSA requirements for this classification, these employees, for all hours worked, whether very few or many, can be paid a set salary under agreement with the employer in order to minimize significant fluctuations in wages to the employee. These employees, in addition to their set salary for all hours worked including overtime hours, receive additional wages for overtime hours at one-half their effective hourly rate as defined by FLSA wage calculation requirements.WORK RELATED TRAVEL EXPENSESThe Company will reimburse employees for reasonable business travel expenses incurred while onassignments away from the normal work location. All business travel must be approved in advance bythe [Department /Position].Employees whose travel plans have been approved should make all travel arrangements through[Department /Position].When approved, the actual costs of travel, meals, lodging, and other expenses directly related toaccomplishing business travel objectives will be reimbursed by the Company. Employees are expectedto limit expenses to reasonable amounts.Expenses that generally will be reimbursed include the following:  Airfare or train fare for travel in coach or economy class or the lowest available fare.  Car rental fees, only for compact or mid-sized cars.  Fares for shuttle or airport bus service, where available; costs of public transportation for other ground travel.  Taxi fares, only when there is no less expensive alternative.  Mileage costs for use of personal cars, only when less expensive transportation is not available.  Cost of standard accommodations in low to mid-priced hotels, motels, or similar lodgings.  Cost of meals, no more lavish than would be eaten at the employee's own expense.  Tips not exceeding 15% of the total cost of a meal or 10% of a taxi fare.  Charges for telephone calls, fax, and similar services required for business purposes.  Charges for one personal telephone call each day.  Charges for laundry and valet services, only on trips of five or more days. (Personal entertainment and personal care items are not reimbursed.)Employees who are involved in an accident while traveling on business must promptly report theincident to their immediate supervisor. Vehicles owned, leased, or rented by the Company may not beused for personal use without prior approval.When travel is completed, employees should submit completed travel expense reports within [entertimeframe]. Receipts for all individual expenses should accompany reports.Employees should contact their supervisor for guidance and assistance on procedures related to travel 10

arrangements, expense reports, reimbursement for specific expenses, or any other business travel issues.Abuse of this business travel expenses policy, including falsifying expense reports to reflect costs notincurred by the employee, can be grounds for disciplinary action, up to and including termination ofemployment.JOB POSTINGThe Company provides employees an opportunity to indicate their interest in open positions and advancewithin the organization according to their skills and experience. In general, notices of all regular, full-time job openings are posted, although the Company reserves its discretionary right to not post aparticular opening.Job openings will be posted in/at location /format. To be eligible to apply for a posted job, employeesmust have performed competently for at least [length of time] in their current position. Employees whohave a written warning on file, or are on probation or suspension are not eligible to apply for posted jobs.Eligible employees can only apply for those posted jobs for which they possess the required skills,competencies, and qualifications.Job posting is a way to inform employees of openings and to identify qualified and interested applicantswho might not otherwise be known to the hiring manager. Other recruiting sources may also be used tofill open positions in the best interest of the organization.PERFORMANCE EVALUATIONSSupervisors and employees are strongly encouraged to discuss job performance and goals on aninformal, day-to-day basis. Generally, formal written performance evaluations will be conducted after ##days of service and then [every ##period of frequency] thereafter. Additional formal performanceevaluations are conducted to provide both supervisors and employees the opportunity to discuss jobtasks, identify and correct weaknesses, encourage and recognize strengths, and discuss positive,purposeful approaches for meeting goals.The Company, in an effort to recognize truly superior employee performance, may award merit-basedpay adjustments. The decision to award such an adjustment is dependent upon numerous factors,including the information documented by this formal performance evaluation process as well as currentbusiness operations/performance as a whole.EMPLOYEE RELATIONSThe Company believes that the work conditions, wages, and benefits it offers to its employees arecompetitive with those offered by other employers in this area and in this industry. If employees haveconcerns about work conditions or compensation, they are strongly encouraged to voice these concernsopenly and directly to their supervisors.Our experience has shown that when employees deal openly and directly with supervisors, the workenvironment can be excellent, communications can be clear, and attitudes can be positive. We believethat the Company amply demonstrates its commitment to employees by responding effectively toemployee concerns. 11

WORKPLACE CONDUCTPERSONAL APPEARANCE AND CLEANLINESSA well-groomed employee immediately makes a good impression for ABC Company and to fellowemployees. The opposite is also true. All employees are expected to maintain a neat and clean generalappearance, keep their hair well-groomed, wear clean clothing, and have good personal hygiene habitswith thought given to allergic substances which may cause problems for sensitive customers andemployees. Any facial hair should be kept neatly trimmed. Office employees should choose aconservative code of dress. Tight, worn out outfits should not be worn. Halter and crop tops or any other\"revealing\" clothing should not be worn. Shorts are not allowed in the office area except on specialoccasions created by management.Facial jewelry, such as eye brow rings, nose rings, lip rings, and tongue studs, are not professionallyappropriate and must not be worn during normal business hours. Multiple piercing (more than one ringin each ear) is not professionally appropriate and must not be worn during business hours. Earringsshould be no longer than two inches below the earlobe. Torso body piercing with visible jewelry orjewelry that can be seen through or under clothing must not be worn during business hours. Visibletattoos and similar body art must be covered during business hours.If you have questions about reasonable accommodations for dress or grooming directly related to aprotected class, please speak with your manager or HR personnel.SMOKING/TOBACCO PRODUCTSADD STATE SPECIFIC SMOKING LAW HEREHOUSEKEEPING AT WORKSITESAll employees are expected to keep work areas clean and free of hazards and to help with generalhousekeeping in all common work areas. This is to include when food is consumed at your workstation:when you have finished, place the remains in the trash.VISITORS IN THE WORKPLACE-alternates withinTo provide for the safety and security of employees and the facilities at the Company, only authorizedvisitors are allowed in the workplace. Restricting unauthorized visitors helps maintain safety standards,protects against theft, ensures security of equipment, protects confidential information, safeguardsemployee welfare, and avoids potential distractions and disturbances.Because of safety and security reasons, family and friends of employees are discouraged from visiting. Incases of emergency, employees will be called to meet any visitor outside their work area.All visitors should enter Company facilities at the main entrance. Authorized visitors will receivedirections or be escorted to their destination. Employees are responsible for the conduct and safety oftheir visitors. 12

If an unauthorized individual is observed on Company premises, employees should immediately notifytheir supervisor or, if necessary, direct the individual to the main entrance.[ALTERNATE FOR RETAIL LOCATION]To provide for the safety and security of employees and the facilities, only visitors authorized byManagement are allowed in the non-public areas of the workplace. Restricting unauthorized visitors, topublic areas only, helps to maintain safety standards, protect against theft, protect confidentialinformation and safeguard employee welfare.For safety and security reasons and to minimize disturbances, family and friends of employees arediscouraged from visiting Company [stores?] for social purposes. An employee who spends excessivetime interacting with personal visitors in the [store?] while on duty may be subject to disciplinary actionif these interactions seem to interfere with the employee’s productivity or attentiveness to our othercustomers.If you are being visited or approached by an unwelcome individual on our premises, Management mustbe notified immediately.LOST AND FOUNDAll lost and found articles should be turned over to your manager, where those articles may be claimedupon proper identification.COMPANY MAILPersonal use of Company-paid postage is prohibited. The mail system/equipment and use of theCompany mailing address for item receipt/delivery is for business purposes only.TELEPHONESThe nature of our business may require a high amount of telephone usage. As a result, we request thatpersonal calls on office or mobile phones, as well as text messaging, be limited to emergency or vitalmatters. If it should be necessary to make or receive a personal call, arrange to use your lunch period, orbefore and after work. Please explain this policy to your family. Messages will be taken for incomingcalls by the manager for an employee when necessary. Emergency phone calls will be given to youimmediately whenever possible.Courtesy and professionalism should be displayed in all telephone contacts. Your manager will arrangefor you to be given instructions regarding the use of our telephone system.The following points should be observed in using Company telephones:1. Telephones should always be promptly answered.2. See that messages are promptly forwarded.3. Keep all necessary personal calls brief.4. Report any telephone trouble to the manager. 13

USE OF COMPANY EQUIPMENTAll workplace supplies/tools are the property of the company and should not be used for personalpurposes. If you need any supplies or tools to perform your job more effectively or comfortably, pleasedo not hesitate to make a request to your manager/supervisor.Equipment and vehicles essential in accomplishing job duties are expensive and may be difficult toreplace. When using Company property, employees are expected to exercise care, perform requiredmaintenance, and follow all operating instructions, safety standards, and guidelines.Please notify your supervisor if any equipment, machines, tools or vehicles appear to be damaged,defective, or in need of repair. Prompt reporting of damages, defects, and the need for repairs couldprevent deterioration of equipment and possible injury to employees or others.The improper, careless, negligent, destructive, or unsafe use or operation of equipment or vehicles, aswell as excessive or avoidable traffic and parking violations, can result in disciplinary action, up to andincluding termination of employment.Company vehicles are for the sole purpose of conducting the business of the Company and are not to beused for personal transportation purposes. In addition, no passengers are to be transported in companyvehicles unless they are employees of the Company.RECYCLINGThe Company supports environmental awareness by encouraging recycling and waste management in itsbusiness practices and operating procedures. This support includes a commitment to the purchase, use,and disposal of products and materials in a manner that will best utilize natural resources and minimizeany negative impact on the earth's environment. Employees are encouraged to make a commitment torecycle and be a part of this solution. For details on recycling, see your supervisor.The Company encourages reducing and, when possible, eliminating the use of disposable products.Source reduction decreases the consumption of valuable resources through such workplace practices as:  communication through computer networks with e-mail  posting memos for all employees  two-sided photocopying  minimum packaging  reusing paper clips, folders, binders, and packaging materialCOMMUNICATION SYSTEMSThe Company recognizes that use of technology has many benefits for the Company and its employees.The Internet, e-mail, mobile phones, personal digital assistants, and other digital/electronic media makecommunication more efficient and effective. Therefore, employees are expected to use these Companyand personal media appropriately, keeping in mind that improper usage can place the Company andothers at risk. 14

All electronic communication systems and all electronic communications and information transmittedby, received from, or stored in these systems are the property of the Company and subject to monitoring.All pass codes are the property of the Company. The Company retains the right to monitor all of itselectronic communication systems at its discretion including listening to and/or printing up and readingall e-mail messages, memos, photos, any other data stored in these systems, as well as non-personalphone calls. Employees should have no expectation of privacy on Company premises or in usage ofCompany property. Employees using Company systems for work purposes or to access personalemail/websites or send/receive personal text messages should have no expectation of privacy.Verbal statements of managers will not supersede this notice of no privacy and employees shouldkeep this in mind before using Company systems to handle personal electronic communications.Be aware that the Company may prohibit any personal use of communication systems. Please be sure torefer to related policies within this handbook for applicable guidelines.The following guidelines have been established for using the electronic communication systems in anappropriate, ethical and professional manner. The Company Internet and e-mail access may not be used for transmitting, retrieving or storing of any communications of a defamatory, discriminatory or harassing nature or materials that are obscene or X-rated. No messages with derogatory or inflammatory remarks about an individual's race, color, sex, national origin, religion, age, pregnancy, weight/perceived or actual physical or mental impairment, military service connection, genetic information, sexual orientation, family or care-giving responsibilities or any other legally protected class shall be transmitted. Illegal harassment/discrimination of any kind is prohibited. Disparaging, abusive, profane, or offensive language, materials that would adversely or negatively reflect upon the Company or be contrary to the Company’s best interests, and any illegal activities -- including piracy, hacking, extortion, blackmail, copyright infringement, and unauthorized access to any computers on the Internet, e-mail or other electronic/digital media -- are forbidden. Copyrighted materials belonging to entities other than the Company may not be transmitted by employees on the Company's network. All employees obtaining access to other companies' or individual's materials must respect all copyrights and may not copy, retrieve, modify or forward copyrighted materials, except with permission or as a single copy to reference only. If you find something on the Internet that may be interesting to others, do not copy it to a network drive. Instead, give the URL (uniform resource locator or \"address\") to the person who may be interested in the information and have that person reach the website directly from that link. Do not use the system in a way that disrupts its use by others. This includes excessive dial-in usage, sending or receiving many large files and \"spamming\" (sending e-mail messages to thousands of users.) Employees are not permitted to use a code, access a file, download information or software or retrieve any stored communication unless authorized to do so or unless they have received prior clearance from an authorized Company representative. No employee may use a pass code that has not been issued to that employee or that is unknown to the Company. Each employee is responsible for the content of all text, audio or images that he/she places or sends over the Company's Internet and e-mail or phone system. No e-mail or other communications may be sent which hides the identity of the sender or represents the sender as someone else. Also, be aware that the Company’s name is attached to all messages so use discretion in formulating messages. 15

 E-mail, or any other electronic/digital communications, copying, storage or use, is not guaranteed to be private or confidential. All electronic communications are the Company’s property. Therefore, the Company reserves the right to examine, monitor and regulate e-mail messages, directories and files, as well as Internet usage. Also, the Internet is not secure so do not assume that others cannot read -- or possibly alter -- your messages. Internal and external e-mail messages are considered business records and may be subject to discovery in the event of litigation. Be aware of this possibility when sending e-mail within and outside the Company. Unauthorized employee “blogging” from the Company premises or when utilizing Company hardware, software, or systems is prohibited. Employee blogging from home or other non-Company hardware and/or systems containing confidential or proprietary information is also prohibited. PDAs and electronic files taken off site must be password-protected or encrypted.All Company-supplied technology, including computer systems and Company-related work records,belong to the Company and not the employee. The Company routinely monitors usage patterns for its e-mail and Internet communications. Since all the computer systems and software, as well as the e-mailand Internet connection, are Company-owned, all Company policies are in effect at all times. Anyemployee who abuses the privilege of the Company facilitated access to e-mail or the Internet or violatesthe above policy, may be denied access to the Internet and, if appropriate, be subject to disciplinaryaction up to and including termination.INTERNET USE & SOCIAL MEDIAUse of social media by employees will become a problem if it interferes with the employee’s work, isused to harass co-workers or customers, creates a hostile work environment, or harms the goodwill andreputation of the Company among its customers or the community at large. Note: As used in this policy, “social media” refers to blogs, forums, and social networking sites,such as Twitter, Facebook, LinkedIn, YouTube, and MySpace, among others. The Company does not permit the use or access of any social networking sites other than those used specifically for the marketing of the Company’s business. Employees may not use Company equipment or facilities for non-work-related activities or access to/posting on social media without express permission. Social media activities should not interfere with your duties at work. The Company monitors its facilities to ensure compliance with this restriction. Any workplace access/use of social media without the express knowledge and approval of your superior will result in disciplinary action, up to and including immediate dismissal. Employees may not use Company time, systems/property to access or participate in any social media without the express knowledge and approval of their superior. In the event that the employee is granted permission to access/use social media in the workplace, all confidential information of the Company will be kept secure and not included in any postings/comments, neither will the employee post/comment any sensitive information of the Company, its employees or any of its customers. Unless given written consent, you may not use the Company’s logo or trademarks on your posts. Do not link to the Company’s website or post Company material on a social media site without written permission obtained from upper management. Employees may not make statements in effort to or resulting in disparagement of the Company, any of its employees, officers, products, customers, or any other information as relates to the Company that could be construed to be damaging to the Company. 16

 If your posts on social media mention the Company, its products or services, employees, customers, and/or competitors, make clear that the views posted are yours alone and do not represent the views of the Company. Do not mention Company employees, clients, customers, or partners without their express consent. Do not pick fights. If you see a misrepresentation about the Company, contact your manager regarding any possible response. Remember, you are responsible for what you write or present on social media. You may be susceptible to legal action by other employees, competitors, customers, and any individual that views your social media posts as defamatory, pornographic, proprietary, harassing, libelous, or creating a hostile work environment. Comply with copyright laws, and cite or reference sources accurately. All postings on social media must comply with the Company’s confidentiality and disclosure of proprietary information policies. If you are unsure about the confidential nature of information you are considering posting, consult with your manager/supervisor. All Company policies that reasonably regulate off-duty conduct apply to social media activity including, but not limited to, policies related to illegal harassment, code of conduct, non- competition, protecting confidential and/or proprietary information.Violation of this policy may lead to discipline up to and including immediate termination ofemployment.CELL/MOBILE PHONESFor the purposes of all references to ‘cell/mobile’ phones, this term includes all portable communicationor similar devices, including but not limited to blackberry, pda, cell, mobile, two-way radios, ipods, mp3players, hands-free devices, ipad, etc.PERSONAL CELL PHONESWhile at work employees are expected to exercise the same discretion in using personal cellular phonesas is expected for the use of Company phones. Personal calls during the work hours, regardless of thephones used, can interfere with employee productivity and be distracting to others. Employees are notauthorized to use personal cell phones for work purposes in place of Company provided beepers andradios unless granted express permission due to the needs of their position. The Company will not beliable for the loss of personal cellular phones brought into the workplace.MANAGER RESPONSIBILITIESAs with any policy, management staff is expected to serve as role models for proper compliance with theprovisions above and are encouraged to regularly remind employees of their responsibilities incomplying with this policyCAMERA PHONESThe Company prohibits employee use of cameras in the workplace, including camera phones, as apreventative step necessary to secure employee privacy, trade secrets and other business information. 17

PERSONAL USE OF COMPANY PROVIDED CELL PHONESWhere job or business needs demand immediate access to an employee the Company may issue abusiness-owned cell phone to an employee for work-related communications. To protect the employeefrom incurring an income tax liability for the personal use of this equipment, such phones are to be usedfor business reasons only. Please refer to current IRS guidelines for specific criteria.Employees in possession of Company equipment such as cellular phones are expected to protect theequipment from loss, damage or theft. Upon resignation or termination of employment, or at any timeupon request, the employee may be asked to produce the phone for return or inspection. Employeesunable to present the phone in good working condition within the time period requested (for example, 24hours) may be expected to bear the cost of a replacement or deductions from final wages when allowedby law.Employees who separate from employment with outstanding debts for equipment loss or unauthorizedcharges will be considered to have left employment on unsatisfactory terms and may be subject to legalaction for recovery of the loss.PHONE SAFETYThe primary responsibility while driving is to operate a motor vehicle safely. The task of driving requiresfull attention and focus. Cell phone use can distract drivers from this task, risking harm to themselvesand others, and may be specifically prohibited by State or Federal law. Employees whose jobresponsibilities include regular or occasional driving and who are issued or authorized to use a cellphone for business purposes use are prohibited from phone use while driving. Safety must come beforeall other concerns. Text messaging and /or emailing while operating a motor vehicle is especiallydangerous and distracting to the driver and is strictly forbidden by the Company.Regardless of the circumstances, including slow or stopped traffic, employees should, when safe to doso, pull off to the side of the road and safely stop the vehicle before placing or accepting a call.Employees whose job responsibilities do not specifically include driving as an essential function, butwho are issued a cell phone for business use, are also expected to abide by the provisions above. Underno circumstances are employees allowed to place themselves or others at risk to fulfill business needs.Employees who are charged with traffic violations resulting from the use of their phone while drivingwill be solely responsible for all liabilities that result from such actions.Violations of this policy will be subject to the highest forms of discipline, including termination.CONFIDENTIAL INFORMATIONIn the course of your work, you may have access to confidential information regarding the Company, itsclients/customers, or other employees. Such information is only to be disclosed and/or communicated inthe normal performance of your duties, and only on a need to know basis. If you should have anyquestions regarding the dissemination of Company information, consult your manager. Unauthorizeddisclosure of confidential information to any person, employee, independent contractor, company, client,customer, vendor etc. may result in disciplinary action up to and including termination. 18

Although it is not possible to specify every example of what constitutes confidential information, it is theresponsibility of each employee to insure that unauthorized release of confidential information does notoccur. Such information may be in print or electronic formats. If any employee believes this hasoccurred, they must report the occurrence or suspicion immediately. Failure to do may result indisciplinary action up to and including termination. Employees are also expected to comply withapplicable Company document/electronic information procedures for retention and disposal. If you havequestions about current procedure, please contact a member of management.Even if you leave the Company’s employment, subsequent disclosure of confidential or proprietaryinformation can result in the Company pursuing legal remedies to protect its interest. You may be askedto sign a non-disclosure/confidentiality agreement, however not signing such an agreement does notrelease you from the provisions of this policy.As part of the protection of confidential information of employees, customers and the Company,employees are expressly prohibited from recording phone or other oral communications in theworkplace, and/or copying Company documents records outside of normal processes as part of theirwork duties, and/or removing such recordings or copies from Company property without specificauthorization of management personnel. This policy also applies to use of personal or Company issuedcell phones or other electronic portable devices that have the capability to record audio, video or takephotographs. Violation of this policy will result in disciplinary action up to and including termination.Examples of confidential information can include but are not limited to:Client lists/information/ Pricing Medical information Pass Codespreferences Financial InformationMarketing strategies/sales Business Plans New materials/ Agreements/ contractsinformation products research Technological prototypesInternal processes Product/material costs Labor relations or data strategies Scientific prototypesSoftware/ systems Research & Pending projects andinformation/ codes/ Development data/ proposalsprograms processes, strategiesEmployee records Proprietary production Formulas/ Scientific techniques/ processes formulae/ dataCONFIDENTIAL INFORMATION PROCEDUREThe Company’s confidential information is a valuable asset. Employees and others acting on theCompany’s behalf are responsible for protecting the Company’s confidential information fromunauthorized disclosure. Just as we expect others to respect our Company’s confidential information, theCompany respects the confidential information of other parties.It is the Company’s policy to use only legal and ethical means to collect and utilize business and marketinformation in order to better understand our markets, customers and competitors. The Company will notcollect another party’s confidential information without that party’s permission. 19

Confidential information may include administrative, sales, marketing, manufacturing or technicalinformation. Specific examples may include financial data; trade secrets; sales figures; information aboutemployees, customers or suppliers; wage and salary data; capital investment plans; earnings projections;testing data; plans to improve products; documents containing product formulas or drawings; records ofinvention; technical reports; proprietary manufacturing methods and processes; pricing and profitinformation; and information about future products, marketing, advertising programs or managementchanges.It is important to:  Know which information is the Company confidential information and what security precautions must be taken to protect it.  Use appropriate security precautions for confidential information. This applies to electronic information and voice mail, as well as to documents. Share confidential information inside the Company only with those who have a business need to know the information.  Have a signed confidential disclosure agreement or subpoena before disclosing confidential information to a party outside the Company.Unless you have another party’s permission to use the party’s information, make sure you can answer“no” to each of these questions before using information:  Is the information actually confidential information?  Was the information obtained illegally or unethically?  Would using the information violate any other business conduct principle?Contact the Company’s legal counsel:  If you need help determining whether certain information is confidential.  Before hiring or using a consultant or agent to obtain information for the Company.  If you learn that an improper disclosure or improper use of confidential information may have occurred.What to avoid  Don’t talk about sensitive Company information with friends and family, or when you can be overheard in public places, such as elevators, airplanes or restaurants.  Disclosing the Company confidential information to anyone outside the Company who does not have a confidential disclosure agreement protecting that information, or to anyone inside the Company who does not have a need to know the information.  Divulging information about a new product or service before any necessary patent applications have been filed.  Receiving confidential information from an employee about his or her former employer.  Accepting proprietary information from an outsider, under circumstances where a confidential relationship exists or may be implied, without first consulting the Company’s legal counsel.  Interviewing or hiring employees and consultants of competitors if it appears you may be attempting to obtain confidential information they are not authorized to disclose.  Using third party confidential information that has been obtained illegally or unethically. 20

INTELLECTUAL CAPITAL/PROPERTY POLICYEmployees should recognize that Intellectual Capital (IC) is central to our Company’s success andcompetitive advantage. The Intellectual Capital of our Company is its possession of the knowledge,applied experience, organizational technology, customer relationships and professional skills thatprovides it with a competitive edge in the market. It is this intellectual material – knowledge,information, intellectual property, and experience – that the Company uses to create the Company’swealth, or value. Intellectual Capital includes factors such as technology, leadership, ongoing employeetraining, brand names and trademarks, and even speed of response to client service calls.While employed by the Company, the employee is expected to protect and keep confidential thisintellectual property. If the employee leaves employment with the Company, all intellectual propertywill remain with the Company. Any removal from the Company of the intellectual property will beconsidered theft.While the Company is not restricting the former employee from the use of any knowledge, programmingskills, training or other developed skills while employed with the Company, intellectual property mustremain the property of and not used in competition with the Company.EMPLOYEE RECORDS ADMINISTRATIONTo keep records current, you will be responsible for notifying the Company of all changes in your statusfrom the information that you originally submitted on your employment application. Always be certainthat the Company has your correct legal name for wage/tax reporting purposes. Generally this is yourname as listed with the Social Security Administration (e.g. on your SS card) or alternatively, under yourassigned individual taxpayer ID number. Other information needed may include your current telephonenumber, mailing/residential address, and the name and telephone number of whom to notify in case of anemergency.Any change in your family status, including the birth or adoption of children, marriage, or divorce, canaffect your benefit coverage and tax status. Should a change in status occur, as soon as possible, contactthe Company’s worksite Benefits Manager, and/or ABC Benefits Department by calling 1-800-776-0076and obtain a receipt of change in family status. Failure to provide notice of these changes within fourteen(14) days of the event may result in a delay of coverage, lack of coverage, or a loss in coverage for aspouse or children.EMPLOYMENT APPLICATIONSThe Company relies upon the accuracy of information contained in the employment application, as wellas the accuracy of other data presented throughout the hiring process and employment. Anymisrepresentations, falsifications, or material omissions in any of this information or data may result inthe Company's exclusion of the individual from further consideration for employment or, if the personhas been hired, termination of employment.I-9 FORMS AND RECORDSThe Immigration Reform and Control Act (IRCA) requires all U.S. employers to be responsible forverifying the employment eligibility and identity of all employees hired to work in the United States 21

after November 6, 1986. To comply, the Company is required to complete Employment EligibilityVerification forms (Form I-9) for all employees, including U.S. citizens.The I-9 form compliance procedure stipulates that employees complete the employee section of the I-9form no later than the first day of work, and provide for review no later than the 3rd business day fromhire, original verifiable documents from those listed as acceptable on the I-9 form to verify identity andeligibility to work in the United States. If employment will be less than 3 days, these documents must bepresented on start date of employment. If you have questions about what documentation is required,please ask your manager or call ABC at 1-800-776-0076. Should I-9 procedures require re-verification,the Company will follow the USCIS produced I-9 handbook procedures regarding the allowable timeemployees have to provide required documents.Per I-9 compliance requirements, employees who cannot provide verifiable documentation by therequired deadlines will be terminated from employment. Employees found to have knowingly providedfalse documents, or falsified their I-9 forms or other employee records may be subject to disciplinaryaction up to and including termination.E-VERIFY(INCLUDE IF APPLIES TO CLIENT OR STATE)The Company is currently participating in E-verify. As part of E-verify, the Company will provide theSocial Security Administration (SSA) and, if necessary, the Department of Homeland Security (DHS),with information from each new employee’s form I-9 to confirm work authorization. If the Governmentcannot confirm that an employee is authorized to work, the Company is required to provide you withwritten instructions and an opportunity to contact SSA and/or DHS before taking adverse action againstyou, including terminating your employment. E-verify may not be used to pre-screen applicants or re-verify current employees. Employees are free to provide any documents listed on the I-9 formrequirements, however, due to participation in E-verify, if a B document is provided, it must be adocument that has a photograph and a SS number must also be provided on the I-9 form. Please refer tothe posted E-verify notices in the workplace for additional information and contact your manager if youhave any questions.CHILD LABOR REQUIREMENTSThe Company will comply with all applicable laws regarding the employment of minors. Applicablelaws may regulate hours of work or which occupations minors may be able to hold with the Company.As part of the Company’s compliance with applicable child labor regulations, minors hired for positionsmay be required to provide documentation including but not limited to a work permit. Documentationrequirements may vary by State. Please contact a manager if you have questions or concerns aboutapplicable requirements.GENETIC INFORMATION RECORDKEEPINGThe Company will not request genetic information unless legally required by other laws, or formonitoring of effects of substances in the workplace and/or the requiring of the information is allowedunder the Genetic Information Non-Discrimination Act (GINA). Any genetic information in Companyrecords will be kept confidential and not be disclosed unless that disclosure is allowed or required underlaw. Such circumstances may include disclosure to the employee upon request; to a health researcher; as 22

directed by a court order; to a government official investigating compliance with the GINA; or inconnection with federal and state family and medical leave act provisions.GINA NOTICEIn compliance with GINA, employees are hereby advised that they should not provide any geneticinformation when responding to a request for medical information as part of a leave request/certification,disability accommodation request, or medical examination.`Genetic information,' as defined by GINA, includes an individual's family medical history, the results ofan individual's or family member's genetic tests, the fact that an individual or an individual's familymember sought or received genetic services, and genetic information of a fetus carried by an individualor an individual's family member or an embryo lawfully held by an individual or family memberreceiving assistive reproductive services.EMPLOYEE ACCESS TO PERSONNEL FILESEmployee files are maintained by the Company and ABC, and are considered confidential and theproperty of the Company and ABC.Managers and supervisors other than Human Resources may only have access to personnel fileinformation on a need-to-know basis. Representatives of government or law enforcement agencies, inthe course of their business, may be allowed access to file information. This decision will be made at thediscretion of the Company in response to the request, a legal subpoena, or court order or applicable laws.Other than exceptions described above, former or non-employees will generally not have access topersonnel files unless required by law.ADD OR REPLACE BELOW WITH ANY CONTRARY STATE SPECIFIC REQUIREMENTSIt is the policy of ABC Company that personnel files may not be removed but may be viewed underobservation by Human Resources. A current employee may not normally make copies but the Companymay provide copies upon request within a reasonable amount of time or as required by State law. Solong as the copying requests are reasonable, no copying fees will be charged.EMPLOYMENT VERIFICATIONSAny agency needing to verify the employment of any present or past employee should be directed tocontact ABC at 1-800-776-0076. It is the Company’s policy that without a signed release from theemployee in question, only dates of employment may be provided to a requesting agency unless requiredotherwise by law.If additional and/or confidential information is requested by any outside agency in regards to youremployment, both a release signed by the employee for ABC to release certain information as well as therequesting agency’s own forms for completion specifying the information requested are necessary. Ifappropriate, notice of separation letters or employment references may be requested from ABCCompany directly. 23

SEPARATION OF EMPLOYMENTIf you should resign, you are expected to give at least two weeks advance notice along with a writtenstatement of resignation. Resignation notice period expectation does not alter the at-will status ofemployment.Prior to your last day of work, regardless of reason for separation, you should schedule a meeting withyour manager to take care of details concerning final pay, benefit conversion, office key, credit cards andany other Company-owned material or equipment. The payment of any remaining available unused paidleave time will be at the Company's discretion or as stated in applicable policy.All forms, procedure manuals, material, equipment, software systems, etc. used by the Company areconsidered the private property of ABC Company and are intended for the sole use of its employees. Assuch, these type items shall not be removed from Company premises and shall be returned to theCompany on the termination of your employment. Failure to return such Company property may lead tocivil and/or criminal action and/or police involvement.Determination of eligibility for unemployment insurance benefits will be determined solely by the Stateunemployment office based on State criteria for eligibility, usually including earnings and reason forseparation of employment.ADD/REPLACE WITH ANY APPLICABLE STATE REQUIREMENTS BELOW REGARDINGTIMING OF FINAL CHECK IF DIFFERENTShould employment be ended for any reason, the final paycheck will be issued on the next normallyscheduled payday or as required by law.BUSINESS ETHICSThe successful business operation and reputation of the Company is built upon the principles of fairdealing and ethical conduct of our employees. Our reputation for integrity and excellence requirescareful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulousregard for the highest standards of conduct and personal integrity.The continued success of the Company is dependent upon our customers' trust and we are dedicated topreserving that trust. Employees owe a duty to the Company and its customers, to act in a way that willmerit the continued trust and confidence of the public.ABC Company will comply with all applicable laws and regulations and expects its directors, officers,and employees to conduct business in accordance with the letter, spirit, and intent of all relevant lawsand to refrain from any illegal, dishonest, or unethical conduct.In general, the use of good judgment, based on high ethical principles, will guide you with respect tolines of acceptable conduct. If a situation arises where it is difficult to determine the proper course ofaction the matter should be discussed openly with your immediate supervisor, and if necessary, with asenior member of management for advice and consultation.Compliance with this policy of business ethics and conduct is the responsibility of every Company 24

employee. Disregarding or failing to comply with this standard of business ethics and conduct could leadto disciplinary action, up to and including possible termination of employment.DISCIPLINARY ACTIONThe great majority of our employees live up to the Company's expectations, respecting the rights offellow employees, and abiding by the employment policies of the Company. However, when anemployee's performance is unsatisfactory or when an employee violates the rules of the Company,appropriate disciplinary action will be taken.Whenever an employee's conduct warrants disciplinary action, that action may include using verbal orwritten warnings, unpaid suspensions or termination of employment. Disciplinary action is not restrictedto proceed in a sequence from lesser to more severe warnings but may vary depending on the seriousnessof the offense committed, employee’s past conduct with the Company, and the circumstances of theviolation. Employees should be aware that engaging in prohibited conduct may result in reduction or lossof eligibility for unemployment benefits as determined by the State unemployment office.The Company’s failure or perceived failure to adhere to the types of Disciplinary Action statedabove does not limit its right to discharge an employee at-will. Likewise the types of disciplinaryaction stated in the disciplinary policy are not exclusive. Employees may be discharged with orwithout cause, and with or without previous notice, counseling, reprimands, or suspensions.EXAMPLES OF MISCONDUCTThe following are examples of conduct that will not be tolerated and that may resultin immediate termination of employment.1. Demonstrating any type of behavior on the job that disparages the good name and reputation of our Company, including but not limited to, rude behavior, verbal confrontations, disrespect, and disorderly or immoral conduct.2. Any violation of the Company’s Equal Employment, Discrimination and Harassment policies.3. Any violation of the Company’s Attendance and Leave Policies. (refer to policy for specifics)4. Any violation of the Company’s Drug & Alcohol policy.5. Any acts of dishonesty or theft, including but not limited to, falsifying personnel records, time worked or Company records; pilferage of cash, products or any other property of the Company, a customer, vendor, or another employee; unauthorized use or removal from worksite of Company, vendor, supplier, provider, or government funds and/or merchandise/property; doing personal tasks while on Company paid time.6. Intentionally defacing or damaging property or products of the Company, vendors, suppliers, providers, government, other employees or customers.7. Insubordination-Refusal to comply with reasonable instruction of persons designated to direct employee work/operations. This includes reasonable instructions from managers/supervisors other than an employee’s direct manager or a refusal without attempting to resolve any uncertainty regarding the instructions received.8. Fighting on Company premises/worksites or threatening, intimidating, coercing, striking or using abusive language to another employee, or customer.9. Trespassing in any unauthorized area without manager’s approval. 25

10. Refusal to submit to a lawful security check of an employee's personal property located on Company premises, and/or worksites.11. Intimidation or interference with the rights of any employee.The following are examples of other behavior that will not be tolerated and thatmay result in disciplinary action up to and including discharge as described above.1. Continual reluctance to comply with, or disrespectful/disruptive behavior in response to, reasonable instructions of persons designated to direct employee work/operations. Behavior committed in bad faith or with disruptive intent.2. Leaving worksite or assigned work area without permission or notice, loafing, sleeping, disturbing other's work, horseplay or wasting time during working hours.3. Violation of established safety practices. Failure to report an accident or on-the-job injury as required by Safety and Workers’ Compensation policy.4. Neglect of duties or refusal to follow standards and procedures established by the Company including where such behavior causes equipment or property damage, employee injury, or intentionally restricts production/completion of duties.5. Repeated violation of Company attendance policy or of clock in/out procedures.6. Unauthorized/improper use of the Company’s communication or computer systems or inappropriate/unauthorized release of confidential information.7. Engaging in communications or activities that may harm the Company’s reputation, disparage the Company or its products.8. Continued poor performance of duties and procedures.9. Behavior that shows a deliberate or willful disregard for reasonable standards of employee behavior or a disregard for the Company’s interests.10. Violation of other stated Company policies and expectations for behavior not specifically mentioned above that are listed elsewhere in this handbook or communicated during employee training or by supervisory personnel.ADD ANY CLIENT SPECIFIC/INDUSTRY PROHIBITIONS EQUAL EMPLOYMENT OPPORTUNITYIt is the policy of the Company to provide equal employment opportunity to all employees and applicantsfor employment without regard to race, color, sex, national origin, religion, age, pregnancy, perceived oractual physical or mental impairment, military service connection, genetic information, family or care-giving responsibilities or any other legally protected class. This policy applies to all aspects ofemployment, including, but not limited to, hiring, placement, promotion, termination, layoff, recall,transfer, leave of absence, compensation, benefits and training. The Company provides reasonableaccommodation to the known disabilities of applicants and employees when requested by the applicantor employee. We accommodate the religious beliefs and practices of our employees provided suchaccommodations do not cause undue hardship.PROHIBITED HARASSMENT/DISCRIMINATIONThe Company, in accordance with applicable federal and state laws, prohibits protected classdiscrimination/harassment in the workplace and is committed to prevent any employee from being 26

subjected to such behavior. It is a violation of Company policy, as well as of applicable laws, for anyemployee in any aspects of employment to harass/discriminate in word or action against a fellowemployee or applicant on the basis of the following:  Race-This includes physical characteristics (e.g. color/ethnicity), language, and/or actual or perceived country of origin/nationality;  Sex (See details and explanation in following policy);  Gender;  Religion;  Age-40 years or older;  Pregnancy-This includes childbirth, or related medical conditions as with other short term disabilities;  Disability-perceived or actual physical or mental impairment/disability;  Military service connection;  Genetic information of the employee or any of his/her family members; or  ADD ANY ADDITIONAL STATE/LOCALITY APPLICABLE PROTECTED CLASS PROTECTIONS HERE  Any other legally protected basis.This policy prohibits the use of epithets and stereotypes, slang words or names, or any otherlanguage or action against which by their nature or effect degrade or insult a person, or any groupof persons, on the basis of the above described groups.If any employee feels that he/she has witnessed or been subjected to any type of harassment ordiscrimination, that employee is to report the complaint or incident immediately to the Company. Pleaserefer to procedures set forth in the following section, “Harassment/Discrimination - ComplaintProcedure.”SEXUAL HARASSMENTThe Company does not tolerate illegal workplace sexual harassment/discrimination. Such conductviolates an individual's fundamental rights and personal dignity and undermines the Company’scommitment to the ensuring freedom from such behavior in all aspects of employment. The Companyconsiders sexual harassment/discrimination in all its forms to be a serious offense.Sexual harassment is unwanted sexual attention of a persistent or offensive nature from another person.This is defined under policy and applicable laws to include sexually oriented conduct that is sufficientlypervasive or severe to unreasonably interfere with an employee's job performance or create anintimidating, hostile, or offensive working environment, as well as sexual harassment by tangibleemployment action (a.k.a. quid pro quo) where an employee is pressured to comply with a sexuallyoriented request as a basis for employment decisions.Sexual harassment can be physical and/or psychological in nature. An accumulation of multiple minorincidents can constitute sexual harassment even if one of the incidents considered on its own would notbe harassing. Employees are prohibited from harassing other employees whether or not the incidents ofharassment occur on Company premises and whether or not the incidents occur during working hours. 27

Sexual harassment can involve males or females being harassed by members of either sex. ALLemployees are governed by the Company’s policy against sexual harassment regardless of whether asupervisor/subordinate relationship exists between the harasser and the harassed. Any person in theworkplace is prohibited from engaging in prohibited harassment including third parties (non-employees)present in the workplace, such as customers or suppliers who interact with employees.Our policy is not intended to discourage innocent activities, such as compliments on personal appearancethat may contribute to healthy working relationships, good morale, and Company unity. At the sametime, certain conduct and comments of a sexual nature that may not amount to unlawful sexualharassment are inappropriate in the workplace. We expect our employees to use good judgment at alltimes and avoid even the appearance of sexual impropriety in all of their relationships with otheremployees.Examples of sexual harassment can include the following behaviors: promising or denying, directly or indirectly, an employee a reward or employment opportunity or penalty, based on an employee’s response to a sexually oriented request; threatening, directly or indirectly, to retaliate against an employee, if the employee refuses to comply with a sexually oriented request; engaging in sexually suggestive physical contact, gestures or touching; displaying/communicating sexually themed jokes, taunts, drawings/writings, cartoons, posters; displaying/using sexual or other gender related epithets, slurs, slang terms or profanity; displaying, storing, or transmitting pornographic or sexually oriented materials using Company equipment or in the workplace; comments or references to parts of a person’s anatomy; engaging in indecent exposure, or displaying images of nude or scantily clad persons; or making sexual or romantic advances toward an employee and/or persisting despite the employee's rejection of the advances.PLEASE NOTE: This list is not intended as nor should it be considered to include all behaviors that maybe considered sexual harassment.HARASSMENT/DISCRIMINATION-Reporting &ComplaintProcedure1. If ANY person experiences any job-related harassment, has a related complaint, or believes they have been treated in an illegal harassing/discriminatory/retaliatory manner, that person is required to report the matter to a member of ABC Company management, or, if he/she prefers, the Human Resources Department of ABC by calling 1-800-776-0076. Persons wishing to report a complaint are encouraged (but not required) to do so via a written statement of events/concerns in order to facilitate a thorough investigation. All concerns reported in good faith will be taken seriously.2. Upon receipt of the complaint to management directly or via ABC, ABC Company or ABC will undertake an investigation to determine whether illegal harassment/discrimination/retaliation has occurred.3. Reasonable efforts will be made to keep the investigation of the complaint confidential to the fullest extent possible except as necessary to investigate the incident. As such, the employee reporting the 28

concern, and all those involved in providing information for the investigation are instructed to not discuss the investigation with other co-workers. Such discussions may hamper the investigation, cause further disruptions in the workplace and inadvertently tamper with evidence/testimony important to the investigation. Violation of confidentiality in bad faith may result in disciplinary action.4. Should ABC Company determine through the investigation that an individual is guilty of violating Company policies regarding harassment/discrimination/retaliation and/or applicable laws, penalty appropriate to the offense will be taken towards the harasser by ABC Company. Penalties potentially include training/counseling, monitoring, job change, monetary penalty, disciplinary action, up to and including discharge or equivalent penalty for non-employees.5. If through the investigation, ABC Company finds that a complaint is not bona fide, or was made in bad faith/malicious intent, or that an employee or witnesses have provided false information about the complaint, disciplinary action may be taken against those individuals accordingly.ABC Company expressly prohibits any form of retaliatory action against any employee for filing abona fide complaint under this policy or for assisting in or providing information related to acomplaint investigation. Managers in receipt of any complaint of possibleharassment/discrimination/retaliation are required to initiate an investigation of the incident as describedin the above procedure. Failure to do so may result in disciplinary action or personal liability towards themanager.DISABILITY ACCOMMODATIONThe Company is committed to complying with all applicable provisions of the Americans withDisabilities Act (\"ADA\"). It is the Company's policy not to illegally harass/discriminate against anyqualified employee or applicant with regard to any terms or conditions of employment because of suchindividual's disability or perceived disability so long as the employee can perform the essential functionsof the job. Consistent with this policy of nondiscrimination, the Company will provide reasonableaccommodations to a qualified individual with a disability, as defined by the ADA, who has made theCompany aware of his or her disability and requested accommodation, provided that suchaccommodation does not constitute an undue hardship on the Company.On receipt of an accommodation request, a member of ABC Company Human Resources Departmentand your manager will meet with you to discuss and identify the precise limitations resulting from thedisability and the potential accommodation that the Company might make to help overcome thoselimitations.ABC Company will determine the feasibility of the requested accommodation considering variousfactors, including, but not limited to, the nature and cost of the accommodation, the availability of taxcredits and deductions, outside funding, the Company's overall financial resources and organization, andthe accommodation's impact on the operation of the Company, including its impact on the ability ofother employees to perform their duties and on the Company's ability to conduct business.ABC Company will inform the employee of its decision on the accommodation request or on how tomake the accommodation. If the accommodation request is denied, employees will be advised of their 29

right to request the decision be reconsidered by submitting a written statement explaining the reasons forthe request. If the request on appeal is denied, that decision is final.The ADA does not require ABC Company to make the best possible accommodation, to reallocateessential job functions, or to provide personal use items (i.e., eyeglasses, hearing aids, wheelchairs etc.).An employee or job applicant who has questions regarding this policy or believes that he or she has beenharassed/discriminated against based on a disability should notify a member of management or cancontact ABC. All such inquiries or complaints will be treated as confidential to the extent practicable bylaw.PREGNANCY ACCOMMODATION (FOR MARYLAND ONLY)THIS APPLIES TO CLIENTS WITH 15+ EMPLOYEESUpon request, the Company will make reasonable accommodations for an employee’s temporarydisability caused by pregnancy or childbirth, as long as it does not impose an undue hardship on theCompany. A medical certification should accompany this request.RELIGION ACCOMMODATIONThe Company will attempt to accommodate employee religious observance or practices that conflictwith an employment requirement when such accommodation does not impose undue hardship on theCompany.CONFLICT OF INTERESTThe Company expects our employees to conduct business according to the highest ethical standards ofconduct. Employees are expected to devote their best efforts to the interests of the Company. Businessdealings that appear to create a conflict between the interests of the Company and an employee areunacceptable. A conflict of interest must be resolved in order for the employee to remain employed bythe Company.The Company recognizes the right of employees to engage in activities outside of their employmentwhich are of a private nature and unrelated to our business. However, the employee must disclose anypossible conflicts of interest so that the Company may assess potential conflicts of interest. A potentialor actual conflict of interest occurs whenever an employee is in a position to influence or appears to bein such a position to influence a decision that may result in a personal gain for the employee or animmediate family member (i.e., spouse or significant other, children, parents, siblings) as a result of theCompany's business dealings. These may include outside employment, financial interest in competingbusinesses, or the unauthorized disclosure of confidential information or products and procedures withoutside parties or competitors.Approval will not be given unless the Company determines that the relationship will not interfere withthe employee's duties or not damage the Company's business dealings. Although it is not possible tospecify every action that might create a conflict of interest, an employee must promptly disclose actual orpotential conflicts of interest, in writing, to his or her manager. The purpose of this policy is to protectemployees from any conflict of interest that might arise. If an employee has any question whether anaction or proposed course of conduct would create a conflict of interest, he or she should immediately 30

contact the Company President to obtain advice on the issue. A failure to disclose will result inappropriate discipline, up to and including immediate termination.EMPLOYMENT OF FAMILY MEMBERSThe employment of family members in the same area of the Company may cause potential conflicts ofinterest and issues of bias/favoritism. Family members of current employees may be considered for openpositions within the Company when qualified, but in cases where the family members would be withinthe same line of authority/supervision, a prohibited conflict of interest may result. Family members orindividuals involved in a dating relationship may not occupy positions with direct supervisor/subordinatereporting responsibility. Employees in a close personal relationship should refrain from publicworkplace displays of affection and excessive personal conversation. While there may be cases where anexception is granted for legitimate business reasons, if workplace disruptions or favoritism/negative biasoccur as a result of the relationship between two employees, disciplinary action may result and/or because for revocation of the exception.For the purposes of this policy, family members are any person who is related by blood or marriage, orwhose relationship with the employee is similar to that of persons who are related by blood or marriage.This policy will be applied in accordance with applicable law. Any employees with concerns about thispolicy should follow steps as described in the conflict resolution or harassment/discrimination policies,whichever applies.OUTSIDE EMPLOYMENT STATEMENTThe Company expects its employees to give full attention to their assigned duties and responsibilities tomeet acceptable standards of performance and productivity. It is the Company’s goal to accomplish allwork within regular established hours whenever possible and practicable. The Company does notattempt to regulate how employees spend their time away from the job. Employees are encouraged toobtain written approval from their manager before participating in outside employment activitieselsewhere. Approval will be granted unless the activity conflicts with the Company's business interest.In general, outside work activities are not allowed when they:  Prevent the employee from fully performing work for which he or she is employed at the Company, including overtime assignments;  Involve organizations that are doing or seek to do business with the Company, including actual or potential vendors or customers, not including civic organizations; or  Violate provisions of law or the Company's policies or rules.  Compete with the Company or result in a conflict of interest (refer to related policy above)From time to time, employees may be required to work beyond their normally scheduled hours as part oftheir job duties, therefore, employees are expected to perform additional work hours when required. Incases of conflict with any outside activity, the employee's obligations to the Company must be givenpriority, except in emergency personal situations. Employees are hired and continue in our Company’semploy with the understanding that the Company is their primary employer and that other employmentor commercial involvement that is in conflict with the business interests of the Company is strictlyprohibited. 31

PROHIBITION OF FRATERNIZATIONThe Company is committed to providing a workplace free of sexual harassment, to minimizing thedisruption of the workplace by personal relationships, to protecting the Company and its clients frompotential liability, and to maintaining their good reputation within the community. This policy is basedon these goals, as well as to prevent any conflict of interests, and to avoid any appearance or inference ofimpropriety or bias among employees or inappropriate disclosure of confidential information. Pleaserefer to the previous policy within regarding possible conflict of interest situations. Romantic or sexual relationships between a supervisory employee of the Company and a subordinate employee that create or imply a conflict of interest or bias for or against the subordinate employee or other employees are prohibited, regardless of when that relationship began. This policy may also apply in the case of similar relationships between an employee and a Company customer/vendor. Violations of this policy are grounds for discipline, including termination. Allegations of violation of this policy shall be brought to the attention of a member of management or the Human Resources Department of ABC by calling 1-800-776-0076. ABC Company will investigate alleged violations and make a determination in order to end the conflict of interest created by the relationship. Such changes may require transfer of employees to remove a conflict of interest or reporting relationship. Any employee who in good faith alleges violation of this policy or who provides information about an alleged violation will be free from any adverse action because of their participation and cooperation in the investigation.This policy is an addition to, and does not supplant, the Company’s policy on sexual harassment, whichremains in full force and effect.SOLICITATIONS/LITERATURE DISTRIBUTIONAlternate shortened policy on topic follows this one, select whichever preferredThis policy establishes rules governing solicitation and the distribution of literature on the Company’spremises.Solicitation includes asking employees:• for funds or contributions;• to purchase goods for charitable or commercial purposes;• to sign petitions;• to join or become members of a group;• to support political candidates; or• to support or commit to causes, groups, or interests.Distribution of literature is defined as handing out or giving employees written materials about causes,products, charities, unions, or political issues. Company premises include all buildings, roads, parkinglots, and land owned or leased by the Company or used as a worksite. Company premises do not includepublic property such as public streets and public sidewalks. Public spaces are areas not owned or leasedby the Company, including city or county public roads, highways, and sidewalks. Work areas are anyareas where actual work is performed for the Company and non-work areas include cafeterias, lobbies, 32

parking lots, break rooms, and restrooms but do not include any areas where customers or clients maycongregate or employees perform work for the Company.PERMITTED SOLICITATION BY EMPLOYEESThe Company does not interfere with, restrain, or coerce employees in exercising their rights underfederal or state labor laws. The Company allows employees to solicit co-workers about causes, interests,political issues, unions, or union organizing during meal and rest breaks and during any other period ofnonworking time, so long as employees do not disrupt or interfere with ongoing Company operations orharass other employees.The Company prohibits solicitations by employees in all work areas. Employees can distribute writteninformation or materials to co-workers in non-work areas during meal and rest breaks or whenever theemployees and their co-workers are not scheduled to be working. The Company prohibits employeesfrom distributing literature at all times in work areas.USE OF THE COMPANY EQUIPMENT FOR SOLICITATION/LITERATURE DISTRIBUTION BY EMPLOYEESThe Company prohibits employees from using Company equipment and supplies to copy or distributeliterature or to solicit support for non-work-related causes. The Company permits employees to use theCompany's equipment and supplies to copy or distribute materials for the Company-sponsored or -approved activities if employees receive their managers' permission (see Exceptions to Restrictions onSolicitation/Literature Distribution, below).OFF-DUTY EMPLOYEE SOLICITATION/LITERATURE DISTRIBUTIONEmployees who have clocked out may return to or remain in non-work areas for reasonable periods oftime if they wish to solicit co-workers or give co-workers printed materials on non-work-related causes,products, or activities. Off-duty employees cannot solicit in work areas.EXCEPTIONS TO RESTRICTIONS ON SOLICITATION/LITERATURE DISTRIBUTIONThe Company does not restrict employees' involvement in Company-sponsored activities. The Companyalso allows employees to solicit funds for the Company-sanctioned events and activities, such as sendingflowers to sick or bereaved co-workers or collecting funds for the Company-sponsored parties or picnics.As part of the duties of their position, employees may be requested to participate in Company sponsoredevents and memberships as representatives of the Company. If for any reason, you feel a permittedsolicitation under this exception is inappropriate, please contact an appropriate member of management.PROHIBITED DISCRIMINATION AND HARASSMENTThe Company prohibits any solicitation or distribution of literature that is discriminatory, hateful,harassing, illegal, defamatory, profane, or obscene. To ensure appropriateness of literature, the Companyrequires all written materials to be screened in advance by HR and stamped and dated.The Company expects employees to respect the desires of co-workers who do not wish to receivehandouts or talk to employees who solicit their support for causes, products, interests, or organizations. 33

The Company prohibits employees from pressuring co-workers to contribute to or get involved in anycauses or activities, even if the Company supports the causes or activities.This policy does not supersede prohibition of harassment and discrimination in the workplace.Employees should thoroughly consider whether causes or reasons they wish to solicit for ordistribute literature for as allowed under this policy might result in harassment or discriminationtowards other employees related to their membership in any protected class. Protected classescurrently include race, color, sex, national origin, religion, age, perceived or actual physical ormental impairment, pregnancy, military service connection, genetic information and any otherlegally protected class.Solicitation/Literature Distribution by Non-employeesThe Company prohibits non-employees from entering the Company's premises to solicit support,proselytize, distribute literature, or sell products or services. The Company has the right to contact locallaw-enforcement authorities to take action against non-employees who trespass on Company property.The Company requires employees to contact Security or the HR Department immediately to report non-employee violations of this policy. Non-employees can solicit or distribute literature in public spacesoutside the Company's premises.DisciplineEmployees who violate this policy are subject to progressive discipline, up to and including termination.Employees who have questions or complaints about the Company's solicitation/literature distributionpolicy or who wish to report violations of the policy are encouraged to speak to their managers.Employees whose manager is involved in a violation should contact the HR Department. Please note thatpermitted solicitation does not include or allow for an employee inciting other employees to leaveemployment or disrupting the workplace to that end. Employees are not prohibited in any way fromseeking other employment should they choose to do so. However, inciting other employees to also do sowith the intent of disrupting the workplace or affect the Company’s business through outsidecompetition may be considered a conflict of interest.SOLICITATION/LITERATURE DISTRIBUTION-alternateIn an effort to ensure a productive and harmonious work environment, persons not employed by theCompany may not solicit or distribute literature in the workplace at any time for any purpose.The Company recognizes that employees may have interests in events and organizations outside theworkplace. However, employees may not solicit or distribute literature concerning these activities duringworking time or in work areas. (Working time does not include lunch periods, work breaks, or any otherperiods in which employees are not on duty.) Employees can distribute written information or materialsto co-workers in non-work areas during meal and rest breaks or whenever the employees and their co-workers are not scheduled to be working. Any solicitation or distribution must also comply with anyCompany policies prohibiting harassment and discrimination.COMPANY POSTINGSLocated in work and break areas are postings of employment related information and Company internalnotices for employees. These postings display important information, and employees should consult 34

them frequently for:  Employee announcements  Internal memoranda  Organization announcements  Workers' compensation information  State disability insurance  Unemployment insurance information  Federal/State labor noticesIf employees have a message of interest to the workplace they wish to post in non-work areas, they maysubmit it for possible approval by contacting their supervisor or onsite HR management. CONFLICT RESOLUTIONMisunderstandings or conflicts can arise in any organization. To ensure effective working relations, it isimportant that such matters be resolved before serious problems develop. Any non-work related orpersonal dispute that occurs offsite is not to be brought to the worksite or addressed during workinghours.The Company recognizes that problems and complaints may arise in the workplace at times. It is theCompany’s intention to attempt to resolve these differences promptly within the organization by theprocedure below. It is the intent of this procedure to remind employees to address concerns appropriatelyby bringing the issue to the attention of management according to this procedure and to reduce thepossibility that the concern will cause any further problems or disruption in the workplace or for otheremployees.1. An employee with a concern about policies, procedures, practices, or any issue arising in the workplace should express the concern to the employee’s immediate manager.2. If an employee believes it would be inappropriate to express the concern to the manager directly, the employee may bypass the manager and seek assistance from another member of management3. Upon receipt of the concern to management, ABC Company will investigate the concern and endeavor to work out a reasonable solution to the problem. ABC Company will not tolerate any form of retaliation against any employee for good faith use of this complaint and conflict resolution process in good faith.DISPUTE RESOLUTION PROCEDUREWe recognize that there may be a circumstance where an employee is simply not satisfied with theCompany’s final resolution of his or her problem through the Conflict Resolution Procedure. Thefollowing sets forth a summary of the Company’s Dispute Resolution Procedure. The actual DisputeResolution Procedure will be governed by the arbitration agreement.To promote the just, speedy, and inexpensive resolution of any unresolved legal disputes between theCompany and an employee, most disputes of a legal nature (i.e., a dispute arising under federal, state, or 35

local law) will be submitted to final and binding arbitration. The same substantive law that a given stateor federal court sitting would apply will be used to resolve the dispute. This means that the arbitratorwill have the same authority as a court to award the employee or the Company money damages or otherrelief, and the parties will have the same legal rights that they would have had in court.The main difference between arbitration and a lawsuit is that the arbitrator (a neutral person selected bythe parties), instead of a court or jury, will decide the issue, and it will generally be the arbitrator’sresponsibility to set a schedule which provides that, after a party demands arbitration, the dispute will beresolved in six months or less time, unless the arbitrator determines that more time is necessary to ensurethat both parties get a fair hearing. By contrast, court actions can take several years. A party inarbitration is not required to have a lawyer, but can if the party wants one.The purpose of this policy is to resolve as many disputes as possible outside of the overburdened andexpensive court system. This arbitration procedure therefore applies to any legal dispute between theCompany and an employee, which could be brought in court (including claims regarding Companyproperty, wrongful discharge, employment discrimination, harassment, or any other dispute relating tothe employee’s employment or arising under any labor, employment, or civil rights law). The only typesof claims excepted from this arbitration procedure are as follows: (i) claims for workers' compensationbenefits and unemployment compensation benefits (ii) claims brought by Company or ABC forinjunctions or other types of equitable relief for unfair competition, the use or unauthorized disclosure oftrade secrets or confidential information, or the violation of non-competition agreements as to whichCompany or ABC may seek and obtain relief from the courts, and (iii) claims arising from a separateemployment contract to which ABC is not a party so long as ABC has no protectable interest at issueand no potential liability for such claims. While this policy does not preclude the filing of a charge withthe Equal Employment Opportunity Commission or other federal agencies, the dispute underlying suchcharges will be arbitrated; a party need not file a charge or complaint with any agency as a prerequisite toinitiating arbitration. Disputes involving any party whose liability or right of recovery derives from aclaim that is covered by this procedure (e.g., agent, subsidiary or parent corporation) are included.All disputes must be brought under this policy within the applicable limitations period for filing alawsuit or agency claim beginning with the event or occurrence giving rise to the dispute; if no claim istimely brought, that dispute is waived and barred forever, and no action or suit may be brought in anycourt or other forum. Arbitration will be enforced under the Federal Arbitration Act, which is the federallaw that favors the enforcement of arbitration agreements.The \"American Arbitration Association\" (hereinafter \"AAA\") is a public service, not-for-profitorganization offering a broad range of dispute resolution services through offices located in major citiesthroughout the United States. The AAA has developed a panel of mediators and arbitrators who areexperts on employment law and have experience deciding employment-related claims. Initiating anarbitration of a legal dispute that the employee and the Company have been unable to resolve may bedone, by filing a written request with the AAA for mediation pursuant to these rules. A form forinitiating mediation is available upon request from the AAA (American Arbitration Association, Attn:Regional Vice President, 2200 Century Parkway, Suite 300, Atlanta, GA 30345-3203) or ABC's DisputeResolution Administrator (HR Manager at 1-800-776-0076). 36

These rules and procedures are based on and generally follow the American Arbitration Association'sNational Rules for the Resolution of Employment Disputes. SAFETY AND HEALTHThe Company is committed to providing the highest level of safety and security for all employees andwill comply with all applicable federal, state and local safety and health regulations. All employees mustadhere to safe work practices and all applicable (OSHA) regulations. It is your responsibility to reportany safety hazard to your manager immediately. Tripping hazards, potential fire hazards, exposedjagged edges, wet floors -- anything an employee perceives as a hazard -- should be reportedimmediately. In the event of an employee injury/illness or close call, the manager should be notifiedimmediately. The Company will not tolerate or engage in adverse action towards an employee becausehe/she reports a safety concern in good faith.An employee injured on the job must report the accident to his or her manager immediately. UnderCompany or worker’s compensation insurance policy requirements the employee may be required tosubmit to a drug and/or alcohol test. If you go to a doctor or hospital without notifying your manager ofan on-the-job injury or seek medical attention due to an on the job injury without notification andauthorization, it may be at your own expense.Do not lift items that are too bulky or too heavy to be handled by one person. Bend your knees, keepyour back straight, and lift with your legs. Ask for assistance when the load is too heavy. Do notparticipate in horseplay, practical jokes, and tease or otherwise distract fellow workers and increase thelikelihood of injury.Any violation of any safety rules, or unsafe use, vandalism, misuse, unauthorized use of any property orequipment on Company premises or worksites which results in personal or property damage, may resultin disciplinary action up to and including discharge for the first offense pending investigation anddetermination by management.DRUGS AND ALCOHOL POLICYReplace with State specific Drug free policy or WC carrier provided policy if applicableFor your safety and protection, the Company is a Drug and Alcohol Free Workplace. We will complywith applicable Drug Free Workplace Guidelines and DOT guidelines. The Company reserves the rightto conduct pre-employment, random, post- accident, periodic and fitness for duty drug/alcohol testingwith or without notice.The proper use of medication prescribed by a physician is not prohibited; however, the Company doesprohibit the misuse of prescribed or over the counter medications or use of prescription drugs when notunder a valid prescription. For positions where safety concerns exist, the Company requires employeesusing medications at the direction of a physician to notify their manager prior to beginning any workwhere these medications may potentially create a safety hazard to the employee or others. In such cases,the employee should contact their supervisor or onsite HR personnel for a copy of their current jobdescription so their prescribing physician can properly assess any significant safety risks. Alternatively, 37

the Company may verify the effects of any substance with the Company’s Medical Review Officer(MRO) prior to the employee beginning or returning to work. The use, sale, transfer, or possession of alcohol, drugs, controlled substances, drug paraphernalia, or any combination thereof, on any Company premises or worksites (including Company vehicles and any private vehicles parked on Company premises or worksites) is grounds for discharge for the first offense. Entry upon Company premises/worksites or being at work with drug paraphernalia or under the influence of alcohol, drugs, or unauthorized controlled substances, or any combination thereof is grounds for discharge for the first offense. \"Under the influence\" is defined as having any detectable level, in excess of testing limit minimums, of alcohol, drugs, or controlled substances, or any combination thereof, in the blood, being unable to perform work in a safe and productive manner, being in a physical or mental condition which creates a risk to the safety and/or well-being of the individual, other employees, the public, or Company property. The Company may require reasonable suspicion testing under State Drug Free Workplace laws and guidelines. Any person with a non-definitive test result may be required to undergo immediate repeat testing. If the 2nd test results are non-definitive without legitimate cause, it will be considered a positive test result. An employee's refusal to submit to a lawful security check (e.g., a search or inspection of their personal property located on Company premises, worksites or facilities, including, but not limited to, Company parking lots), or refusal to submit to Drug or Alcohol testing or knowingly altering sample or attempting to falsify results of testing (e.g., urine sample, hair sample, saliva sample, blood sample, physical examination, sobriety examination) is grounds for a discharge for the first offense. The Company offers resource information on various means of employee assistance in our community including but not limited to drug and alcohol abuse programs. Employees are encouraged to use this resource (see your manager or the ABC Human Resources Department at 1- 800-776-0076 for details). In addition, the Company will distribute this information to employees in confidence and in keeping with Drug Free Workplace and/or DOT guidelines when applicable. An available location to find more information of substance abuse, and for assistance to combat drug and alcohol abuse is the Substance Abuse and Mental Health Services Administration (SAMSHA) On the web, go to: http://www.samhsa.gov/ You can also call SAMHSA's Toll-Free Referral Helpline at 1-800-662-HELP (1-800-662-4357). As a condition of employment, employees must abide by the terms of the Company policy and must notify the Company in writing of any convictions of a violation of a criminal drug statute no later than five calendar days after such conviction. Employees are required to promptly report all injury or damage related accidents involving Company property or personnel or during Company-related activities and may be required to submit to alcohol screening within two (2) hours and to drug screening within twenty-four (24) hours of a reportable accident. Delay in reporting of an accident will not remove this requirement. Employees who return to work following a suspension or rehabilitation may be required to undergo return to duty and periodic random follow up testing in addition to the general Company testing requirements. 38

WORKPLACE VIOLENCE PREVENTION POLICYThe Company is committed to preventing workplace violence and to maintaining a safe workenvironment. Given the increasing violence in society in general, the Company has adopted thefollowing guidelines to deal with intimidation, harassment, or other threats of (or actual) violence thatmay occur during business hours or on its premises.All employees, including managers and temporary employees, should be treated with courtesy andrespect at all times. Employees are expected to refrain from fighting, \"horseplay,\" or other conduct thatmay be dangerous to others. Violent or threatening behavior can include, but is not limited to, physicalacts, oral or written statements, harassing telephone calls, gestures and expressions or behaviors such asstalking, violent horseplay or “joking around.”The Company does not tolerate behavior, whether direct or through the use of Company facilities,property or resources that:  Is violent;  Threatens violence;  Harasses or intimidates others;  Interferes with an individual's legal rights of movement or expression; or,  Disrupts the workplace, our collegial environment or the Company's ability to provide service to the public.Firearms, weapons, and other dangerous or hazardous devices or substances are prohibited from thepremises of the Company without proper authorization or specific exceptions under local laws.Conduct that threatens, intimidates, or coerces another employee, a customer, or a member of the publicwill not be tolerated. This prohibition includes all acts of harassment, including harassment that is basedon an individual's sex, race, age, or any characteristic protected by federal, state, or local law.All threats of (or actual) violence, both direct and indirect, should be reported as soon as possible to yourimmediate manager or any other member of management. This includes threats by employees, as well asthreats by customers, vendors, solicitors, or other members of the public. When reporting a threat ofviolence, the employee should be as specific and detailed as possible.ABC Company will promptly and thoroughly investigate all reports of threats of (or actual) violence andof suspicious individuals or activities. The identity of the Company individual making a report will beprotected except as necessary to conduct the investigation. In order to maintain workplace safety and theintegrity of its investigation, the Company may suspend employees, either with or without pay asallowed by law, pending investigation. Anyone determined to be responsible for threats of (or actual)violence or other conduct that is in violation of these guidelines will be subject to prompt disciplinaryaction up to and including termination of employment.All suspicious individuals or activities should also be reported as soon as possible to a manager. Do notplace yourself in peril. If you see or hear a commotion or disturbance near your workstation, do not try tointercede or see what is happening. If you observe suspicious persons anywhere in the worksites, or inparking areas, please notify management or the police immediately as appropriate to the situation. 39

The Company encourages employees to bring their disputes or differences with other employees to theattention of a member of management before the situation escalates into potential violence. TheCompany is eager to assist in the resolution of employee disputes, and will not discipline employees forraising such concerns in good faith.COPING WITH THREATENING OR VIOLENT INDIVIDUALSEffective handling of threatening or violent individuals requires you to use good judgment and commonsense and rely on your own assessment of the particular situation. Nevertheless, you might be able toresolve or cope with many types of threatening or violent situations by following the guidelines below.When confronted with an angry or hostile individual: 1. Stay calm. 2. Listen attentively. 3. Maintain eye contact. 4. Be courteous and patient, but try to keep the situation under control by expressing a willingness to sit and calmly discuss the matter with the individual.When confronted with a person shouting, swearing, threatening violence, or engaging in bizarre ordangerous behavior: 1. Stay calm. 2. Be courteous and patient, but maintain your distance from the individual. 3. Signal a co-worker or manager that you need help. Do not call for help yourself if the individual is directly confronting you. 4. Have the co-worker or manager call the security guard or the local police.When confronted by someone with a gun, knife, or other weapon: 1. Stay calm. 2. Never try to grab the weapon. 3. Quietly signal a co-worker or manager that you need help. Do not call for help yourself if the individual is directly confronting you. 4. Have the co-worker or manager call the security guard or local police. 5. Be courteous and patient. Keep talking, but follow the instructions from the person who has the weapon. Stall for time, but do not risk harm to yourself or others. 6. Watch for a safe chance to escape to a safe area. Take direction from the police or Security personnel once they arrive on the scene.Threats, threatening conduct, or any other acts of aggression or violence in the workplace will not betolerated. Any employee determined to have committed such acts will be subject to disciplinary action,up to and including termination. Non-employees engaged in violent acts on the Company’s premises willbe reported to the proper authorities.WORKERS’ COMPENSATIONAs an employee of the Company, you are protected under the Workers’ Compensation (WC) State Lawsat no cost to you. This benefit covers accidental injuries, which are caused by, and arise out of the 40

course of your employment with ABC Company as defined by State law. This coverage is providedthrough the Company’s WC insurance carrier. Payments may be made for medical expenses, lost wages,disability, death, and burial expenses up to certain limits as provided by law. Determination ofpayments to an employee related to a work injury are made under the terms of the WC insurance policyby the claims office and based on applicable State law. The Company will not engage in or tolerateadverse action against an employee because he/she suffers a work injury, files for WC benefits, ortestifies at a WC hearing.In the event of an injury/illness, an accident report must be completed and returned within twenty-four(24) hours to the WC claims office. These forms are available from your manager or from ABC at 1-800-776-0076. The Company may require you to submit to post-accident Drug/Alcohol testing after theoccurrence of a work-related injury. Please note that the state law where you work dictates howtreatment is rendered to you as the injured employee. In some states, your employer has the right todirect which doctor you are treated by for up to 10 days post-accident. If you have any questions aboutthe selection of doctors, you can call the Workers Compensation Administrator at 1-800-776-0076.Time off work resulting from a workplace injury may fall under the criteria for FMLA leave under thatlaw. If applicable, the employee will be expected to comply with the terms of FMLA leave or otherCompany leave policies & procedures.Failure to abide by the instructions provided by the doctor of record for the workers’ compensation casecan result in decreased or ineligibility for workers’ compensation benefits. As is required by law, theCompany will forward cases of suspected fraud to the state for investigation and prosecution andencourages reporting of any suspected fraud. If the Workers’ Compensation Insurance carrier or claimsoffice determines the injury not to be a work related injury, the employee will not be entitled to anycompensation or other workers’ compensation insurance benefits other than specifically authorizedmedical treatment.If you have questions concerning this policy, please contact your manager or the WC claims office.INJURY CARE/TREATMENTShould you sustain a work-related injury or illness, you must immediately notify your immediatemanager. Except for an emergency/serious injury (e.g. requiring emergency treatment/transport byambulance to the ER), you must receive approval and direction from the Company to receive treatmentat a medical facility authorized by the WC claims office prior to getting treatment at that facility.Designated clinic information may be posted in your workplace also. Any treatment after the firstevaluation/medical care or further specialized treatment must be authorized in advance by the WCclaims office to ensure coverage. If you seek treatment without authorization and/or from anunauthorized facility, you may be personally responsible for the costs of unauthorized medical care, asthe WC claims office may not cover unauthorized treatment.LOST WAGESTo be paid compensation for lost wages for work missed as a result of work duty restrictions, the WCclaims office may require documentation from the authorized medical treatment provider listing anywork duty restrictions. Employees are personally responsible for ensuring this documentation is issued 41

by the medical provider and provided to the Company. State WC law may require a waiting periodwithout compensation from the Company before WC lost time payments will begin. When safetyconcerns exist, before being returned to work, the employee may be required to provide confirmationfrom the WC medical treatment provider of a release to full or light duty work restrictions that can bereasonably accommodated without undue hardship. ABSENCES AND TIME OFFATTENDANCE AND PUNCTUALITYAn employee’s attendance for work as scheduled is vital to our overall commitment to serving ourcustomers and operating efficiency. If employees are absent or late, it places a greater load on everyoneelse. In some cases, it could cause a loss of business that all of our jobs depend upon. As such,unexplained and unexcused absences and tardiness may not be tolerated. The Company expects allemployees to assume diligent responsibility for their attendance and promptness. Any time that an employee will be late or absent from work, it is the employee’s sole responsibility to personally notify his/her manager as soon as reasonably possible. ‘Reasonably possible’ is considered to be as soon as the need for absence is known, and no later than (TIME) before the start of the scheduled shift that will be missed, except in emergency situations. FAILURE TO PROPERLY REPORT OFF WORK MAY RESULT IN THE ABSENCE/TARDY BEING CONSIDERED AN UNEXCUSED ABSENCE. If an employee arrives at work late for the scheduled shift or wishes to leave before the end of the shift, the employee must check in with his/her manager before starting work or leaving. If an employee wishes to take time off for personal reasons, he/she must submit the request for that time to their manager at least one week in advance, or as soon as the need for the absence is known. Failure to properly comply with this requirement may result in the absence being considered unexcused. Unexpected absences or tardiness, such as those that result from sickness or other emergency, should be reported to the employee’s manager prior to the start of the shift on each day of absence/tardy or as soon as reasonably possible. Only if the employee has been granted an authorized leave for the time off for a specified period in advance, would other notification procedures under applicable Company leave policy apply. For any absence to be considered excused the employee may be required to provide documentation so that the Company can verify the need for the absence. For example, an absence/tardy for any medical treatment or illness would require documentation from the treating medical facility. A verifiable original of the Doctor’s excuse from work would be acceptable, whereas a photocopy or facsimile would not be acceptable. Any employee absent for personal illness may be required to submit a Doctor’s excuse explaining the absence and authorizing the employee to return to work. When significant safety concerns exist, this documentation may be required before the employee will be allowed to return to work. If an employee’s frequency of absences/tardiness is considered excessive by the Company, unless the reasons for the absences/tardiness are excused under a separate leave policy, the employee may be requested to resign because of the employee’s failure to fulfill the essential duties required by the position. 42

 Employees who miss work may be required to use any accrued paid time off (PTO) in order to cover wages for the time missed, as allowed by law and specified under Company policy. If an employee continues to have unexcused tardiness/absenteeism, the employee may be subject to disciplinary action up to and including termination If any employee is absent for three (3) consecutive scheduled workdays without notice to his/her manager, and without good cause for the absence or lack of notice, the employee will be considered to have resigned his/her position by abandoning their job.Any violations of the above policy and procedure may lead to disciplinary action up to andincluding termination of employment.INCLEMENT WEATHERAt certain times of the year inclement weather may create a situation where it is questionable as towhether or not the office will be open for business. In the event such a situation arises, it is theemployee’s personal responsibility to call and speak to your manager regarding this question.Employees are expected to make every possible safe effort to report to work, even under unfavorableweather conditions. During those rare instances when the office is to be closed because of inclementweather, the period for which no working activity takes place will go as unpaid hours for hourly non-exempt employees.FUNERAL/BEREAVEMENT LEAVEWe understand the need for an employee to be with his/her family when there is a death in theimmediate family. When it is necessary for a regular full-time employee to be absent from scheduledwork for this reason, that employee will receive eight (8) hours of regular pay and be excused for thattime period. An employee will not receive pay for any days when his/her department is not scheduled towork. The following are considered immediate family: Spouse, Children, Siblings, and Parents.Paid time off for this reason is not considered hours worked for the purposes of calculating overtime.Proof of death and relationships may be required.JURY DUTYThe Company encourages its’ employees to fulfill their civic responsibilities by serving as jurors whencalled upon to do so. The Company will excuse employees selected for jury duty from regularlyscheduled work for the time they are required to serve. This excused time from work is not necessarilyonly for your usual work schedule (in the case of employees who may work an evening shift but areselected for jury duty during morning hours), but is for the entire 24 hours of each day of service (12:00AM to 12:00 PM).Employees serving as jurors are required to return to work only after being finally discharged for all juryservice or if released from court prior to the end of the scheduled workday. For employees whose workschedule may begin during the afternoon, evening, or night you are not required to report to work unlessyou have been excused for the entire day from jury duty and/or were not required to report to court onthat day. 43

Employees must notify their managers of impending jury duty as soon as they receive a notice to serve.A copy of this notice must be provided. Failure to provide proper documentation of notices, actual timeserved or other documents required by the employer to validate jury service may result in disciplinaryaction up to and including termination.ADD ANY ADDITIONAL STATE SPECIFIC PROVISIONS HERE OR IN BELOW SECTIONSDISCRIMINATIONThe Company will not tolerate discrimination towards or penalize employees because they are called tojury duty, or subpoenaed to appear at judicial proceedings, or miss work to appear as a victim or victim’srepresentative. This protection does not extend to employees who are absent due to attending criminalproceedings against their own self/as a defendant.COMPENSATIONFull-time employees are eligible to receive pay from the Company for time served on jury duty. In orderto receive normal compensation from the employer, proper documentation of time actually served mustbe provided. For hourly-paid full-time employees, pay will be based on the hours actually scheduled forthe days an employee is serving on jury service for which the employee would have otherwise worked ifnot for jury service. This time will not count as time actually worked for purposes of calculatingovertime. If the courts pay a fee to the employee for jury service the Company may offset any court paidfees received by an employee for a particular week against the compensation due for that particularweek. Monies paid by the court as expense reimbursement will not be deducted from wages paid by theCompany. For salaried & exempt full-time employees, the usual salary will apply.RIGHT TO VOTEThe Company encourages its employees to exercise their privileges and duties as citizens, including theirright to vote. Employees who do not have sufficient time outside their normal work schedules to voteshould make arrangements with their immediate managers as far in advance as possible, and no laterthan the day before the election.Generally voting time is not considered hours worked for purposes of computing overtime. Hourlyemployee time off to vote is generally not paid by the Company, unless specified otherwise by Companypolicy or under terms specified by State law.The Company will not tolerate any employee/manager attempting to coerce, intimidate, threatening todischarge, or changing the wages of another employee in order to influence his/her vote in any election.ADD ANY ADDITIONAL STATE APPLICABLE PROVISIONS HEREMILITARY LEAVE (USERRA)The Company will abide by all applicable USERRA guidelines regarding military leave. If possible,present a copy of the orders received to your manager as soon as you receive them. For leaves longerthan 30 days, a copy of orders may be required, but their lack may not delay return to work. AlthoughMilitary Training is not considered as vacation time, you may elect to receive vacation pay in lieu oftime off without pay. 44

INSURANCE CONTINUATIONYou have the right to continue your existing employer based health plan for up to 24 months while in theservice. If you do not elect to continue coverage while on leave, you have the right to be re-instated inthe employer’s health plan when re-employed (some conditions may apply in certain cases). 45

FAMILY AND MEDICAL LEAVE ACT POLICYINCLUDE IF APPLICABLE BASED ON CLIENT SIZEEmployees may be eligible for unpaid leave for eligible reasons during a 12-month period under thispolicy provided the following circumstances apply.  He/She has been employed for at least 12 months with Company. These 12 months do not need to be consecutive, but employment periods prior to a break in employment of more than 7 years would not be counted, unless other contracts apply or the break in service was due to military leave. Time spent on military leave is considered time worked for FMLA eligibility;  He/She has worked at least 1,250 hours during the 12-month period immediately preceding the commencement of the leave for the Company; and  He/She is employed at a worksite where 50 or more employees are employed by the Company within 75 miles of that worksite.Please see explanation below regarding the determination of ’12 month period’.ELIGIBLE REASONS AND LENGTH OF LEAVEFMLA leave may apply for any of the following reasons: 1. The birth of a child, or the placement of a child with you for adoption or foster care. Leave for this reason must be completed within the 12-month period beginning on the date of birth or placement. Leave after the birth of a child may not require doctor’s certification, but leave prior to birth due to complications (i.e. reason #2) would require doctor’s certification. 2. A serious health condition that makes you unable to perform the essential functions of your job or a serious health condition affecting your spouse/child/parent, for which you are needed to provide care. If you are requesting leave because of your own or a covered family member's serious health condition, it is your responsibility to make certain that the relevant health care provider supplies appropriate medical certification to certify the need for leave.  Leave to care for a family member cannot be also designated as leave under reason #3 or overlap. 3. To care for a recovering service member (member of Armed Forces) who has suffered an injury or illness while on active-duty that may render the person unable to perform the duties of the member’s office, grade, rank or rating, for which you are needed to provide care. Leave under this reason provides up to 26 workweeks of FMLA during a single 12-month period.  The Department of Labor has defined eligible employees under this reason as the nearest blood relatives who may be considered “next of kin of a covered service- member” and excluded the covered service-member’s spouse, parent, son, or daughter, as they are already entitled to leave for this purpose under reason #2. The covered service-members may specifically designate in writing another blood relative as his or her nearest blood relative for purposes of military caregiver leave under the FMLA. If no such designation is made, and there are multiple family members with the same level of relationship to the covered service-member, all such family members shall be considered the covered service-member’s next of kin and may take FMLA leave to provide care to the covered service-member, either consecutively or simultaneously if other requirements for leave eligibility are met.  Leave under this reason cannot be also designated as leave under reason #2 or overlap. 46

4. Leave due to the employee’s spouse, son, daughter or parent being on active duty or having been notified of an impending call or order to active duty in the Armed Forces. Leave may be used for any “qualifying exigency” arising out of the service member’s current tour of active duty or because the service member is notified of an impending call to duty in support of a contingency operation.  A qualifying exigency under leave for reason #5 is defined as (1) short-notice deployment, (2) military events and related activities, (3) childcare and school activities, (4) financial and legal arrangements, (5) counseling, (6) rest and recuperation, (7) post-deployment activities, and (8) additional activities to address other events which arise out of the covered military member’s active duty or call to active duty status, provided the Company and employee agree that such leave shall qualify as an exigency, and agree to both the timing and duration of such leave.  An employee’s obligation to provide notice of leave due to a qualifying exigency is triggered when the employee first seeks to take such leave, not necessarily when the employee first becomes aware of the call to duty. When the need for this leave is foreseeable, eligible employees must provide notice to the Company that is “reasonable and practicable.”12-MONTH PERIODThe Company will measure the twelve-month period as a rolling twelve-month period measured forwardfrom the date the employee’s first FMLA leave begins. An employee would be entitled to 12 weeks ofleave during the year beginning on the first date FMLA leave is taken. The next 12-month period wouldbegin the first time FMLA leave is taken after completion of any previous 12-month period. If ahusband and wife both work for the Company and each wishes to take leave for the birth of a child,adoption or placement of a child in foster care, or to care for a parent (but not a parent \"in-law\") with aserious health condition, the husband and wife may only take a combined total of 12 weeks of leave. If ahusband and wife both work for the Company and each wishes to take leave to care for a covered injuredor ill servicemember, the husband and wife may only take a combined total of 26 weeks of leave.SERIOUS HEALTH CONDITIONSerious health condition\" means an illness, injury, impairment, or physical or mental condition thatinvolves any of the following:  any period of incapacity or treatment connected with inpatient care (i.e., an overnight stay) in a hospital, hospice, or residential medical care facility  a period of incapacity requiring absence of more than three full consecutive calendar days from work, school, or other regular daily activities. The incapacity must require treatment by a healthcare provider under the following conditions: o the first treatment visit must take place within seven days of the first day of incapacity. o The incapacity requires treatments that are either a) two or more treatments by a health care provider within the first 30 days of incapacity, absent extenuating circumstances, or (b) one treatment by a healthcare provider which results in a regimen of continuing treatment under the supervision of the health care provider, o any determinations of whether additional treatment visits or regimens of continuing treatment are necessary shall be made by the health care provider, not the employee.  any period of incapacity due to pregnancy, or for prenatal care 47

 any period of incapacity (or treatment therefore) due to a chronic serious health condition (e.g., asthma, diabetes, epilepsy, etc.) requiring periodic visits for treatment by a health care provider of at least twice a year  a period of incapacity that is permanent or long-term due to a condition for which treatment may not be effective (e.g., Alzheimer's, stroke, terminal diseases, etc.)  any absences to receive multiple treatments (including any period of recovery therefrom) by, or on referral by, a health care provider for a condition that likely would result in incapacity of more than three consecutive days if left untreated (e.g., chemotherapy, physical therapy, dialysis, etc.)Conditions for which cosmetic treatments are administered (such as most treatments for acne or plasticsurgery) are not ``serious health conditions'' unless inpatient hospital care is required or unlesscomplications develop. Ordinarily, unless complications arise, the common cold, the flu, ear aches, upsetstomach, minor ulcers, headaches other than migraine, routine dental or orthodontia problems,periodontal disease, etc., are examples of conditions that generally do not meet the definition of a serioushealth condition and therefore may not qualify for FMLA leave.INTERMITTENT LEAVEIntermittent / Reduced Schedule leave may be taken when medically necessary to care for a seriously illfamily member, or because of the employee's serious health condition. Intermittent/reduced scheduleleave may be taken to care for a newborn or newly placed adopted or foster care child only with theCompany's approval.Employees needing intermittent/reduced schedule leave for foreseeable medical treatment must make a\"reasonable effort\" to schedule treatment so as not to disrupt unduly the Company's operations. In suchcases, the Company may transfer the employee temporarily to an alternative job with equivalent pay andbenefits that accommodate recurring periods of leave better than the employee's regular job. Re-certification from a healthcare provider may not be required for each individual instance of absenceunder intermittent leave, except as provided for under FMLA Guidelines. Employees need not providespecific private medical information for each absence under FMLA leave, but should indicate to theperson to whom they would normally indicate a need to miss work whether unexpected absences (notpreviously scheduled as planned FMLA time off) are needed for the FMLA leave reason or not. If notindicated, time missed will be assumed as FMLA until the employee indicates otherwise. Any absencesnot related to the FMLA approved reason will fall under other applicable Company attendance or timeoff policies. While FMLA covers approval of the time off based on the reason for leave, employees arestill required to comply with Company attendance policy and procedures covering communication andnotice of time off (e.g. contacting the Company as required on a day where employee will need to beoff). See attendance policy for specific requirements.If an employee takes intermittent or reduced schedule leave, the Company may require re-certification offitness for duty up to once every 30 days and safety concerns exist based on the reason for leave. TheCompany may not require 2nd opinions on fitness for duty certifications and may not delay return towork while awaiting the certification. However, an employee may authorize the Company leaverepresentative (described above) to contact the health care provider for clarification on the fitness forduty certification. 48

BENEFITS AND TIME OFF DURING LEAVEFMLA leave is unpaid leave. However, an employee may be required to use any available paid leavetime in combination with unpaid FMLA leave. The substitution of paid leave time for unpaid leave timedoes not delay or extend the 12-week FMLA leave period. If the employee will receive disabilitybenefits through other coverage while on leave, or workers compensation benefits while off work, theuse of paid time off is not required but is at the employee’s option.While on FMLA approved leave, you will continue to be responsible for the employee portion of anyinsurance coverage you carry through the Company. If you do not return to work following FMLA leavefor a reason other than: 1) the continuation, recurrence, or onset of a serious health condition whichwould entitle you to FMLA leave; of (2) other circumstances beyond your control, you may be requiredto reimburse the Company for their share of any health insurance premiums paid on your behalf duringyour FMLA leave.NOTICE AND CERTIFICATION OF LEAVEIf your need for family/medical leave is foreseeable, you must give the Company at least 30 days priorwritten notice. Failure to provide such notice may be grounds for delay of leave. Where the need forleave is not foreseeable, you are expected to notify the Company as soon as practicable, generally thesame day or by the next business day after learning of your need for leave. Employees must explainsufficiently the reason for leave so as to allow the Company to determine if potential eligibility forFMLA exists. Calling in sick alone is not sufficient. If an employee needs to take leave related to aprevious FMLA leave approved condition, the employee must specifically reference the qualifyingreason for leave or the need for FMLA leave.If you wish to request leave, please contact a supervisor or member of management as soon as you areaware of this need, so that eligibility can be verified, and the necessary documentation provided to you.You may also contact ABC if you have general questions about FMLA leave.LEAVE CERTIFICATIONRequired certification of any reason for leave must be given within 15 days after it is requested, or assoon as reasonably possible under the circumstances. If certification received is insufficient, theemployee will be notified specifically what is missing and given 7 additional days to provide the missinginformation. If the employee chooses, instead of providing additional information the employee canprovide written authorization for a Company representative (health care provider, human resourceprofessional, leave administrator or a management official, excluding the employee's direct supervisor)to contact the employee’s doctor directly for the information. Failure to provide requested medicalcertification or authorization in a timely manner may result in delay of leave approval until it is providedor the leave is declined.The Company is responsible for designating time off as FMLA whenever an eligible reason exists thatthe Company is aware of. Leave can be retroactive if the employee fails to provide indication of potentialeligibility. In all cases where leave would qualify for FMLA leave protection, employees and Companycan mutually agree that the leave be retroactively designated as FMLA leave. 49