Employee Handbool(

SECTION I ..................................................................................................................................... 5 WELCOME TO NRG .............................................................................................................................. 5 A. INTRODUCTION TO YOUR HANDBOOK. ........................................................................................ 5 B. HISTORY ...................................................................................................................................................... 5 C. OUR MISSION ............................................................................................................................................ 5 D. OUR GOAL .................................................................................................................................................. 6 E. QUEST FOR QUALITY ............................................................................................................................. 6 F. NRG SAFETY POLICY STATEMENT .................................................................................................. 6 G. OUR FUTURE ............................................................................................................................................. 6 1. BUILDING ON TO DAY'S VALUES ....................................................................................................... 6 2. VISION .......................................................................................................................................................... 7 SECTION 11 .................................................................................................................................... 8 EMPLOYMENT & COMPENSATION POLICIES............................................................................. 8 A. EQUAL EMPLOYMENT OPPORTUNITY .......................................................................................... 8 B. OPEN DOOR POLICY ............................................................................................................................... 8 C. REPORTING ................................................................................................................................................ 8 D. NO THEFT ALLOWED ............................................................................................................................ 8 E. CONDITIONS FOR INITIAL EMPLOYMENT ................................................................................... 9 F. INITIAL EMPLOYMENT /TRAINING PERIOD ............................................................................... 9 G. ANNIVERSARY/JOB DATE ................................................................................................................... 9 H. JOB POSTING AND APPLICATION ..................................................................................................... 9 I. HIRING, PROMOTIONS, DEMOTIONS, TRANSFERS, AND REHIRES .................................. 10 J. PERFORMANCE EVALUATION .......................................................................................................... 11 K. COMPLAINT RESOLUTION PROCEDURE .................................................................................... 12 L. CLASSIFICATIONS OF EMPLOYMENT ........................................................................................... 12 M. CONVERSION BETWEEN FULL-TIME EMPLOYMENT .......................................................... 14 AND PART-TIME EMPLOYMENT .......................................................................................................... 14 N. LIGHTDUTY ............................................................................................................................................ 14 0. COMPENSATION AND PAY CYCLE ................................................................................................. 14 P. BONUSES .................................................................................................................................................... 15 Q. VOLUNTEER FIREFIGHTER PAY ......................................... Error! Bookmark not defined. R. INCLEMENT WEATHER OR POWER OUTAGE OR COMPUTER OUTAGE POLICY ....... 15 S. TIME CLOCK POLICY ............................................................................................................................. 15 SECTION 111 ............................................................................................................................... 17 INSURANCE AND RELATED BENEFITS ....................................................................................... 17 A. INTRODUCTION ...................................................................................................................................... 17 B. EMPLOYEE HEALTH CARE PLAN .................................................................................................... 17 C. 401(k) PLAN ........................................................................................................................................... 18 D. LIFE INSURANCE PROGRAM ............................................................................................................ 18 E. WORKERS' COMPENSATION POLICY............................................................................................ 18

F. UNEMPLOYMENT INSURANCE ........................................................................................................ 19 G. EMPLOYEE ASSISTANCE SERVICES .............................................................................................. 19 H. FLEX SPENDING PROGRAM .............................................................................................................. 20 I. GYM/FITNESS MEMBERSHIP ............................................................................................................ 20

SECTION IV................................................................................................................................ 21
A. PAID TIME OFF (PTO) .......................................................................................................................... 21

PTO CARRY OVER ........................................................................................................................................ 23 B. HOLIDAYS ................................................................................................................................................. 23 C. MATERNITY POLICY ............................................................................................................................ 23 D. SHORT TERM DISABILITY (STD) ................................................................................................... 24 E. LONG-TERM DISABILITY PLAN ....................................................................................................... 26 F. JURY DUTY ................................................................................................................................................ 26 G. FUNERAL LEAVE (Bereavement Leave) ...................................................................................... 27 H. UNPAID LEAVE OF ABSENCE ........................................................................................................... 27 I. FAMILY MEDICAL LEAVE BENEFIT ................................................................................................ 27 J. MILITARY LEAVE .................................................................................................................................... 29 K. VOTING POLICY ..................................................................................................................................... 29

SECTION V ................................................................................................................................. 30 EMPLOYEE CONDUCT ...................................................................................................................... 30

DISCIPLINARY ACTION ............................................................................................................................. 30 C. SO LICITATION PO LICY ........................................................................................................................ 33 D. ATTENDANCE POLICY ........................................................................................................................ 33 E. REPRODUCTION AND USE OF COMPUTER SOFTWARE ....................................................... 35 F. DRESS POLICY ......................................................................................................................................... 36 G. DATING POLICY ...................................................................................................................................... 37 H. TOBACCO USE POLICY ........................................................................................................................ 38 I. TELEPHONE USE .................................................................................................................................... 38 ). CELL PHONE POLICY .............................................................................................................................. 38 K. E-MAIL/INTERNET /VOICE MAIL POLICY .................................................................................. 39 L. DRUG AND ALCOHOL POLICY .......................................................................................................... 39 j. OTHER TESTING .................................................................................................................................... 42 M. REFERRAL TO EAS SUBSTANCE ABUSE ..................................................................................... 43 N. UNLAWFUL HARASSMENT PROHIBITED ................................................................................... 43 0. Workplace Violence Policy ................................................................................................................. 44 P. RESIGNATION AND TERMINATION .............................................................................................. 45 Q. EXIT PROCEDURES ............................................................................................................................... 45 R. ANTI-TRUST PO LI CY............................................................................................................................ 4 5 S. RECORDS RETENTION POLICY ........................................................................................................ 48 T. CORPORATE GIFT POLICY ................................................................................................................. 50 U. RIGHT TO INSPECT POLICY ............................................................................................................... 50 V. SOFTWARE POLICY .............................................................................................................................. 50 W. PATIENT AND EMPLOYEE PRIVACY POLICY ........................................................................... 51 X. PERSONNEL RECORDS POLICY ........................................................................................................ 51 Y. SOCIAL MEDIA POLICY ........................................................................................................................ 51 Z. WORKPLACE ETIQUETTE .................................................................................................................. 52 AA. POLICY ON BUSINESS OFFICE HOURS ...................................................................................... 53 BB. OFF-DUTY ACCESS .............................................................................................................................. 54 CC. SABOTAGE POLICY ............................................................................................................................. 54 DD. FALSIFICATION OF RECORDS AND MAKING FALSE STATEMENTS POLICY ........ 54

EE. LEGAL ACTION NOTIFICATION POLICY ................................................................................... 54 FF. OPEN DOOR POLICY .......................... ,............................................................................................... 54

SECTION VI ................................................................................................................................ 55
CODE OF CONDUCT ..........................................................................................................................55

PURPOSE ......................................................................................................................................................... 55 POLICY ............................................................................................................................................................. 55 IMPLEMENTATION OF THE CODE ....................................................................................................... 58 QUESTIONS REGARDING THE CODE .................................................................................................. 59 ACKNOWLEDGMENT ................................................................................................................................. 60
NRG ........................................................................................................................................................61 EMPLOYEE HANDBOOK RECEIPT ................................................................................................61

SECTION I
WELCOME TO NRG
A. INTRODUCTION TO YOUR HANDBOOK To answer some of the questions you may have concerning NRG and its policies, we have written this handbook. Please read it thoroughly, and retaio it for further use. The policies stated in this handbook are subject to change. From time to time, you may receive updated ioformation concemiog changes io policy. For the most recent version, you can go to the shared F drive at F:\NRG Employee Handbook and Revisions at any internal NRG computer or contact a member of our Human Resources Team. Should you have any questions, please ask your supervisor, manager, or a member of the Human Resources Team for assistance.
This handbook is not a contract of employment; nor is it a guarantee of employment. No supervisor, manager or representative of NRG, other than the Chief Executive Officer and the Chief Operating Officer, has the authority to enter into employment agreements, or make any promises or commitments contrary to the foregoing, and no such agreement authorized by the Chief Executive Officer or the Chief Operating Officer shall be binding on NRG unless written and signed by the Chief Executive Officer or Chief Operating Officer. Although we hope your employment relationship with us will be long-term, either you or NRG may terminate this relationship at any time, for any reason, without cause or notice. All employees of NRG are employees at will.

We wish you the best of success io your new position and hope that your employment relationship with NRG will be a rewarding experience. B. HISTORY NRG iocorporated in 1990 (origioally as Hioson Systems and then to National Reimbursement Group in 2005), is a privately held corporation headquartered in Macon, Georgia. Throughout our history, the company has processed more than 2 million EMS claims. NRG was founded by a paramedic and has provided billiog and dictation services to EMS agencies for over 20 years. EMS Operations is the foundation of our organization from which strong accounting practices, compliance and software flow. With a focus on billing and dictation services, NRG's comprehensive claims process and Medic Resource Center ensures a thorough and expedited process for EMS agencies. A passion for excellence is demonstrated through a high level of customer service, an efficient billiog process and innovative industry leading technology. NRG provides its agencies with personalized attention, decreased patient care reporting time, and increased reimbursement levels. While we've experienced dramatic changes and growth, our single greatest asset remains unchanged: the qualitv ofNRG emplovees. NRG is becomiog an industry leader because we have some of the finest, most dedicated, and most customer-responsive people io any business today. C. OUR MISSION NRG specializes in providing accurate ambulance codiog and billiog; efficient processes to control flow of claims, and collect all money owed to our clients. NRG provides added value and exceptional customer service to our nationwide customer base by adheriog to the highest standard of conduct and total compliance with all governmental regulations. NRG is committed to serviog our customers, patients, employees, and shareholders by fulfilling our missions, which are:

I. 2. 3. 4. 5. 6.

To establish our trusted business relationship as a recognized and valued service in the industry we serve. To positively contribute to our business partners' (customers) success by our efforts in their behalf. To lead in innovation, productivity, and quality in our industry service field. To provide a working environment which promotes respect for the individual, God, and our country. To grow our business aggressively and profitably at a rate enhancing shareholder value and generating profits to fund our growth. To provide a business environment that allows each employee to grow personally and professionally while pursuing opportunities and goals consistent with his or her abilities and ambition. D. OURGOAL

CUSTOMER AND PATIENT SERVICE EXCELLENCE

National Reimbursement Group Inc. has been, and continues to be, committed to conducting our activities in full compliance with all federal, state and local laws. Our reputation for quality service and excellent patient care and customer service has been achieved by the personal integrity, good judgment and common sense of our staff members. Staff members are expected to demonstrate appropriate ethical behavior when conducting activities with patients and their families, fellow staff members, the communities in which we serve, suppliers, vendors, consultants and those with whom we do business. We commit to provide each staff member the policies, procedures and guidelines to be aware of his/her responsibility in ensuring compliance with this goal.
E. QUEST FOR QUALITY

Our commitment to quality over quality is inherent in our program of service excellence to all our partners, and are as follows:
I. 2. 3.

4. 5.

We will fulfill promises to, and pro-actively communicate with customers and employees. We will conduct annual planning and decision-making in accordance with our quality goals. We will proactively eliminate waste and errors, and will challenge each process as an opportunity to improve quality. Our management will provide quality leadership and quality training, and will recognize individuals and teams committed to quality. We will foster an environment that encourages innovation and creativity.

Our mission is practiced in a variety of ways, including quarterly surveys of customer satisfaction and regular sessions of quality training for employees. F. NRG SAFETY POLICY STATEMENT At NRG, employee safety is not just a commitment or a value: safety is au expectation. This means everyone - from senior managers to employees at every level and location - shares the responsibility to create and maintain a safe work environment.

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G. OURFUTURE I. BUILDING ON TODAY'S VALUES We are proud of our history, but we are eager to meet the excitement of our future. The old-fashioned values and work ethic are an integral part of NRG. Those values are shared by the company as a whole, its owners and management team. NRG's successes are committed to those values,

and to the abiding belief that integrity and concern must be inseparable from day-to-day business transactions. Guided by years of experience, NRG will continue to benefit from the stability and caring influence of a family-owned business, as well as from state-of-the-art technology, the expertise of its team, and a costeffective operational philosophy.

We believe communication, integrity, and goodwill have been the cornerstone of our business and will continue to be the key to our success in whatever mode it takes, from the one-to-one contact we relied on in the "old days" (and still practice) to the cutting edge of Electronic Data Interchange (ED!) and database management of today. We continue to pursue new technologies, thus encouraging our client partners1 success. But we also maintain direct interest in our individual customers and other business partners and their individual challenges and successes.
Our goal is to move with our partners into the future, ahead of the competition, and to remain committed to the integrity and values upon which our family-owned business was founded. Our history has taught us well: by investing in the success of our business partners, we also make the surest investment in our company's success.

2. VISION At NRG, the opportunities are endless. NRG will continue to be driven by the values of integrity, growth,
profit, and customer satisfaction, with emphasis on innovation and employee welfare.

To attain our vision and to strengthen our commitment, we will continue to act according to the following
values:

Integrity: Promoting honesty and fulfilling obligations. Total Quality: Setting standards of performance with the goal of improvement and serving internal and external customers. People: Focusing on training, empowerment, opportunity, open communication and teamwork. Growth: Achieving revenue goals and increasing the net worth and asset value of the company; and diversifying our services, market and business opportunities. Innovation: Encouraging creative efforts to improve efficiency, challenging the status quo, and being innovative in our interactions with clients. Image: Maintaining our image of integrity, quality, and professionalism as reflected in all our interactions with employees, customers, suppliers, lenders, and the communities in which we serve.

SECTION II
EMPLOYMENT & COMPENSATION POLICIES
A. EQUAL EMPLOYMENT OPPORTUNITY

NRG believes all persons are entitled to equal employment opportunities. NRG will not discriminate
against its employees or applicants for employment because of sex, race, color, religion, national origin,

age, handicap, or veteran status or other basic classes protected by applicable federal or state law provided they are qualified for employment or for existing positions, and with reasonable accommodation can perform the essential functions of the job in question. Any employee (or applicant for employment) who believes he/she has been treated unfairly should promptly report the incident to his/her manager/supervisor (or the Chief Operating Officer (COO) if the manager/supervisor is involved in the matter being reported; or the Chief Executive Officer (CEO) if the COO is involved in the matter being reported), who will investigate the matter and take appropriate action. All complaints will be kept confidential to the maximum extent possible. NRG prohibits any form of retaliation against any employee for making a bona fide complaint under this policy or for assisting in a complaint investigation. However, if, after investigating a complaint of harassment or unlawful discrimination, NRG determines that the complaint is not bona fide or that the employee has provided false information regarding the complaint, disciplinary action may be taken against the complaining party, up to and including termination.
B. OPEN DOOR POLICY

We encourage you to bring your problems to your supervisor or any other member of management whom you believe can help you. We, in turn, promise to listen with respect and do our best to solve the workrelated problems. Management accepts the responsibility to provide fair working conditions, competitive pay, and benefits. We believe you, as an employee, have an individual right to speak for yourself. You do not need a union or an outsider to speak for you.

NRG is a non-union organization. We always have been, and it certainly is our desire to maintain this status. No Company is free from day-to-day problems, but we believe we have Human Resources policies and practices to help resolve problems more effectively than strikes or other work stoppages. Furthermore, unions cannot guarantee your job, nor can they assure you continuous employment. All of us working together to make our organization a viable customer-service-focused-organization is the only way we can provide a satisfactory employment situation.
If anyone ever asks you to sign a union card or participate in any union activity, we want you to know that you have a legal right to refuse such attempts and to discuss any questions you may have with someone in management to be sure you have all the facts on the subject.
C. REPORTING

Should a situation develop that you believe is detrimental to you or NRG, NRG and its management team strongly encourage you to discuss the situation with the Operational Manager as soon as possible. If the problem is unresolved or is sensitive circumstances prevent you from discussing your problems with your Operational Manager, you should ask to speak with the Chief Operating Officer.
D. NO THEFT ALLOWED

NRG encourages all employees to take an active role in preventing theft ofNRG property. You are trusted when you are employed and we expect honesty at all times from all employees. Therefore, NRG will not tolerate theft, and it is every employee's responsibility to report any knowledge of theft to his/her supervisor, member of management, or the Chief Operating Officer immediately.
E. CONDITIONS FOR INITIAL EMPLOYMENT All employees are required to:

1.

Complete tax withholding forms, employee benefits forms, employee agreements, releases, and supplemental information forms to the extent applicable and as necessary to complete NRG
records.

2.

3. 4.

Provide NRG witb substantial evidence of ability to work in tbe United States, license(s), credentials, diplomas, degrees, or certifications which are required for the position, or were expressed or implied by the employee in the application form or interviewing process. Take any other test and provide information from time to time reasonably required by NRG of employees. Complete the application process including but not limited to completion of 1-9 documentation, consent to background check and pre-employment drug screen.

Employees who will be driving NRG vehicles must produce a valid driver's license, meet Department of Transportation (D.O.T.) requirements, if applicable, and make their driving record available.
F. INITIAL EMPLOYMENT/TRAINING PERIOD

NRG requires an initial employment/training period of 90 DAYS for every employee. This allows management to make a preliminary determination of job performance, and to determine whether or not the individual's employment, on a regular basis, has long term potential. On the discretion of NRG management, the 90 day initial employment-training period may be extended. Completion of the initial training period does not alter the at-will nature ofthe employment relationship.
G. ANNIVERSARY/JOB DATE

Years of Service Awards An employee's anniversary date of employment is the frrst day the employee began work at NRG on a fulltime (or part-time) basis. It is the effective date of hire as listed on the payroll information form. The anniversary date of employment remains fixed throughout the continuous employment of an individual with NRG. The anniversary date of employment is not adjusted except when a break in service occurs. Approved leaves of absence do not affect the anniversary date of hire. The starting date for Years of Service Awards recognition for a person who has terminated employment and was then rehired will be the date of rehire. Job-Date The job-date is the date an employee began working in their most current job assignment. Your job-date will be changed for transfers, promotions, or demotions. Service time in a particular job may affect work assignments, work schedules, vacation schedules and/or equipment assigrrrnent. This job date modification does not affect overall seniority status, which will be calculated from your initial date of hire.
H. JOB POSTING AND APPLICA TJON

NRG believes in promoting qualified employees from within and, at the sole discretion of management, occasionally post open positions to give employees the opportunity to apply for positions in which they are interested and for which they are qualified.

Positions that are location specific will be posted on bulletin boards at the location. Positions of managerial or professional level will be posted on bulletin boards and e-mailed to all NRG network users. Interested employees may access the posting document in [Electronic Public Folders]. Open positions will be posted for a minimum of (7) days. Employees interested in applying for a posted position should: 1.) 2.) 3.) Complete an "Internal Application Form". Available from the Human Resource Dept. at your location and in the Human Resources section/Users Reference of Public Folders. Contact the individual listed on the job posting and follow any specific instructions indicated. NotifY your current manager of your interest in the posted position. The purpose of this notification is for the employee to discuss with his/her manager their qualifications for the posted position.

The employee's existing manager will be contacted for their assessment and recommendations. Previous managers and employers may be contacted as part of the reference check. Your manager will be notified by the Chief Operating Officer if you are a finalist for the position. The Chief Operating Officer may schedule a personal interview with the applicant. Candidates who are not selected for the position will meet with their manager to discuss improvement areas and training opportunities that will contribute to the employee's career development.
The Chief Operating Officer and the selected candidate's manager will mutually agree on the transition steps and timetable for the transfer. Any questions regarding the job posting process may be directed to the Operations Manager.

I. HIRING, PROMOTIONS, DEMOTIONS, TRANSFERS, AND REHIRES

I. HIRING AND CONTINUED EMPLOYMENT

Position vacancies are filled by selecting the best-qualified applicant on the basis of merit, whether the applicant is an existing employee or from the outside NRG. NRG reserves the right to consider both internal and/or external candidates for all open positions. Employment applications and background checks are required on all external candidates for open positions. The Human Resource Department is responsible for ensuring employment references and background checks are properly checked on all external job candidates. NRG also reserves the right to perform reference and background checks on current employees. A consumer credit report may be obtained for employment purposes in accordance with the Fair Credit Reporting Act, and other background checks may be conducted, including driving and criminal records if appropriate. All applicants will be required to submit to a pre-employment drug screen as part of hiring process. Any falsifications, misleading information or misrepresentations by a job candidate will result in exclusion from further consideration. If discovered after the person has been hired, the employment relationship will be terminated. However, employment in any position must be based on individual qualifications, ability, efficiency, and conduct for that particular position. Therefore, from time to time, it will be necessary or desirable to hire from the outside. In compliance with the Immigration Reform and Control Act of 1986, NRG is committed to employing only individuals who are legally authorized to work in the United States. As a result, all new employees are required to present documentation proving identity and employment eligibility and complete the Employment Eligibility Verification Form I-9. 2. PROMOTIONS

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Employees who are in the NRG discipline process will not be eligible for a promotion. Promoted employees may be on a review period of varying duration, depending on the circumstances. If the employee does not perform successfully during this period, he/she may be returned to his/her former or a similar position, depending on the availability of the position. In such cases, the employee's rate of pay may be changed accordingly, and NRG will make a reasonable effort to find the employee a suitable position, but no such guarantee can be offered. 3. DEMOTIONS As an alternative to employment termination, at NRG' s option, an employee may be demoted to a position in a lower pay grade if, in NRG's opinion, he/she is unable for any reason to perform the job for which he/she was originally employed. In such cases, the employee's rate of pay may be changed accordingly. 4. TRANSFERS Employees may be transferred from one department to another, at the request of the employee, with mutual agreement between the current manager/supervisor and the new manager/supervisor. NRG may transfer an employee based on business needs at any time. Employees are not eligible for lateral transfer until they have completed one full year of employment in their current job. Employees are not eligible for transfer if they have received a written step of discipline or higher in the past twelve months.
Schedule and Pay Changes on Employee Internal Transfers

When an employee is hired into another position within the company, he/she will move within 30 calendar days of the date of hire, except when the current manager and Chief Operating Officer have negotiated an alternate move date. The current manager must communicate that alternate date to Human Resources. If an employee's pay will be positively affected by the move, that employee's pay will change on the first day in his/her new position or on the first day of the next pay period following thirty days, whichever comes first, regardless of whether the employee has moved. (Ifthe date of a new pay period falls on the 301h day, the pay change will take effect on that day.) In a case when the employee has not yet moved to the new position but the pay rate will change, the employee's current department will pay at the new rate until the actual move has taken place. The section of this policy concerning pay does not apply in situations where an employee is moving from a salary position to an hourly position, from one salary position to another salary position.. The Chief Operating Officer must submit the Payroll Change Form to accounting prior to the day on which the new rate of pay is to take effect. In the pay rate changes before the employee has moved, the hiring manager must submit a second Payroll Change Form showing the new department and position information when the employee moves.

J. PERFORMANCE EVALUATION

As a general rule, all full-time and part-time employees' job performances should be evaluated semiannually in January and July of each year employed. Among the factors evaluated during formal performance reviews are the employee's skill level, customer service, work habits, ability to work with other employees, and adaptability to job conditions. Each employee is encouraged to discuss his or her evaluation with the evaluating supervisor or manager. In these discussions, employees are encouraged to comment about their work performance and discuss working conditions and offer suggestions for improving business operations.

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K. COMPLAINT RESOLUTION PROCEDURE

Misunderstandings or conflicts can arise in any organization. To ensure effective working relations, it is important that such matters be resolved before serious problems develop. Most incidents resolve themselves naturally. However, should a situation persist that you believe is detrimental to you or NRG, you should follow the procedure described below for bringing your complaint to management's attention.

1.

Discussion of the problem with your immediate manager/supervisor is encouraged as a first step. If, however, you believe a discussion with your supervisor would be unproductive, please proceed directly to Step 2. If your problem is not resolved after discussion with your manger/supervisor, or if you feel discussion with your manager/supervisor is inappropriate, please request a meeting, in writing, with the Chief Operating Officer with a written summary attached to the request with your concerns. In an effort to resolve the problem, the Operations Manager will review tbe matter with you.

2.

Ideally, after review (which may include a review of tbe written summary of your statement, discussions with individuals concerned, and investigation), the Chief Operating Officer will advise you of his/her decision within 15 days. NRG does not tolerate any form of retaliation against an employee for availing himself/herself of this procedure. The procedure should not be construed, however, as preventing, limiting, or delaying NRG from taking disciplinary action against any individual, up to and including, termination, in circumstances where the company deems disciplinary action appropriate.
L. CLASSIFICATIONS OF EMPLOYMENT

Generally speaking, NRG classifies its employees as follows:

1. FULL-TIME EMPLOYEES

Employees regularly scheduled to work 32 hours or more a week are considered full-time employees. This defmition is not a guarantee of hours of work, either in any week or any other period of time. Managers/Supervisors may not schedule employees for full-time shifts of less than 40 hours without approval from Chief Operating Officer. Such employees may be "exempt" or "nonexempt" as defined below. Full-time employees qualify for the following benefits after meeting specified waiting periods: *Health Plan Insurance *Employee Assistance Program (EAP) *Life Insurance *401(k) Plan *Disability Program *Flex Spending Accounts *I>ental Insurance *Bonuses (sole discretion ofmgmt.) *Extra Life Insurance *Paid Time Off *Unemployment & Workers' Compensation Insurance 2. PART-TIMEEMPLOYEES Employees regularly scheduled to work less than 32 hours a week are considered part-time employees. Such employees may be "exempt" or "nonexempt" as defined below. Part-time employees qualify for the following benefits: 1. 2. The employer portion of Social Security contribution. Unemployment Insurance and Workers' Compensation Insurance on your behalf.

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3.

401(1<) and Profit Sharing Plan eligibility after one year of service if you work a minimum of 1000 hours per year, are age 21 or older, and employed on the last day of the year. 3. TERM CERTAIN EMPLOYEES

Employees engaged in work, full-time or part-time on NRG's payroll, with the understanding their employment will expire upon completion of a specific assigmnent or project are considered temporary employees. Such employees may be "exempt" or "nonexempt" as defmed below. (NOTE: Employees hired from a temporary employment agency for specific assigmnents are employees of the respective agency and not ofNRG.) Temporary employees currently quality for the following benefits: I. 2. 3. The employer portion of Social Security contribution. Unemployment Insurance and Workers' Compensation Insurance on your behalf. 401(k) after one year of service, if you have worked a minimum of 1000 hours, are age 21 or older, and employed on the last day of the year.

4. NONEXEMPTEMPLOYEES Nonexempt employees may be salaried or hourly employees who, when authorized to work overtime, will receive overtime pay in accordance with applicable wage and hour laws. You will be paid straight time (i.e., your regular hourly rate of pay) for all hours worked up to and including 40 hours in any given work week, and I Y, times your regular hourly rate of pay for all authorized hours worked beyond the 40th hour in any given work week. All employees are allowed up to a total of I 0 hours of overtime in a pay period without given permission, anything over I 0 hours the employee must be given express permission by Chief Operating Officer, Human Resource Manager, and/or supervisor. Overtime is paid for actual hours worked. Therefore, if you do not work due to using PTO, STD, LTD, Workers Camp., or for any other reason, that time is not computed when figuring overtime for the week. For example, an employee who is paid 8 hours of holiday pay and works the remainder of the week (32 hours) will not be paid overtime pay if she/he works an additional 8 hours that week. She/he will be paid their regular rate for the additional 8 hours. Once they "work" over 40 hours in the same week they are paid overtime. Your manager will make every attempt to provide you with reasonable notice when the need for overtime work arises. You will be expected to work overtime when it is scheduled for your job.

5. EXEMPT ("SALARIED") EMPLOYEES Exempt employees are salaried employees who are not legally required to be paid overtime for work beyond 40 hours in a workweek. You will be informed by the Chief Operating Officer of your initial employment classification and your status as an exempt or nonexempt employee at the time of your employment. If you change positions during your employment as a result of a promotion, transfer or otherwise, you will be informed by the Chief Operating Officer of any changes in your exemption status. If you disagree with your exempt or nonexempt classification, you should follow the Complaint Resolution Procedure above. Because exempt employees pay is primarily based on job performance and experience, as opposed to hours worked, exempt employees are not strictly subject to NRG policies on attendance and late/early leave except where attendance deficiencies affect job performance

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M. CONVERSION BETWEEN FULL-TIME EMPLOYMENT AND PART-TIME EMPLOYMENT

Whenever an employee converts from full-time to part-time employment, the employee will no longer qualify for full-time benefits. By way of example and not limitation, part-time employees are not eligible for PTO. Also, depending on the exact eligibility requirements of the company's group insurance policy and profit sharing plan, conversion to part-time employment may cause loss of other benefits. Additionally, conversion to part-time employment may involve a reduction in hourly compensation. After conversion to part-time employment, return to full-time will be subject to NRG's then employment needs. In such event, the employee may have tore-qualify with the eligibility requirements of all employee benefit programs.
N. LIGHT DUTY

Light Duty is a temporary work assignment provided for an employee with restricted physical activities. The purpose for light duty work assignments is to help an employee, who has been ill or injured, transition back into their regular job. Light duty is for employees with personal as well as work-related injuries or illnesses. Light duty assignments are subject to business needs and appropriate medical advice. As directed by a physician, employees will be given modified work duties within their regular work area until they can return to full duty, for as long as physical limitations are considered temporary in nature, or it becomes apparent that such recovery will take longer than 6 months. As a general rule, light duty assigmnents will terminate after 6 months. Light duty assignments may require a variation in shift, a change in days normally worked, and/or a change in work location. Light duty assigmnents are subject to layoff for lack of work as in the case of all other work assignments. During the first 30 days on light duty assignment in their regular work area, there is no change in the employee's rate of pay. After 30 days of light duty assigmnents in their regular work area, the employee's rate of pay will be changed to 80% of the normal base rate. Should an employee be unable to perform duties within their regular work area they may be assigned to work in another department. National Reimbursement Group Inc. may, but is not required, to request the employee have additional medical intervention, at company expense, to assist with establishing appropriate guidelines for work assignments. An employee who has been medically released to do light duty is expected to work in a light duty capacity.
0. COMPENSATION AND PAY CYCLE

The NRG compensation program is designed to attract and retain quality employees. performance-based rewards.

To attain this

objective, the compensation program reflects two primary considerations: market competitiveness and

Compensation levels are reviewed on an annual basis to assure non-discrimination with regard to sex, race, religion, ethnic background, age or disability.
Base pay is calculated by the hour (hourly), by the year (salaried) or by performance* (only applies to parttime and full-time ADIM workers). Additional compensation can be earned for working extended hours or performing special duties. Regular pay may be interrupted by personal situations. Employees who are on leave, except for military leave, are not eligible for pay raises until returning to full-time, and active status. Employees who are on light duty capacity are not eligible for pay raises until they return to full-time, active status.

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Employees are paid on semi-monthly payroll schedule, which refers to paydays that occur 24 times per year, such as paydays that occur on the 15th day and the last day of every month. Required payroll deductions (such as Federal, State and local taxes, FICA (Social Security), garnishments, bankruptcy wage deductions, etc), and all employee authorized voluntary deductions (such as health insurance premiums, supplemental life insurance, disability, 40l(k) deferrals, etc.) will be automatically deducted. For their security and convenience, the company encourages every employee to participate in the electronic direct deposit and the electronic pay stub options. Employees should review each pay stub and report any error to the Accounting/Payroll Department for inunediate correction. *Part-time and full-time ADIM workers pay structure is performance based (effective July 10, 2012). The values associated with each type of work item is decided upon by Executive Management and published via email notification to the affected employees. Also, employees will be notified via email notification of changes and updates relating to the pay for performance values as they occur. *Call Rite employees' pay structure is performance based (effective January 10, 2013). Call Rite employees will be paid minimum wage for each hour worked & will earn $1 for each PCR entered during their shift.

P.BONUSES

Bonuses are purely discretionary and may be increased, decreased, or discontinued at any time, without notice, in whole or in part, as to some or all employees.

Q. INCLEMENT WEATHER OR POWER OUTAGE OR COMPUTER OUTAGE POLICY

The decision to close the facility or declare an extreme weather event, power outage or computer outage

will be made by the Chief Executive Officer or the Chief Operating Officer if the CEO is unavailable. Employees will be notified over the telephone of any closings. Extreme weather events are typically defmed by weather-related school closings local to the facility. In these instances, the employee will be missing out on the opportunity to work. The company is very aware of the hardships that this would create for employees. Consequently, the company will offer the following options for an employee to make up the hours that they were missing due to the inclement weather, so they can be paid 40 hours in a week. The options are as follows:
I.

If there is work available that week, the supervisor of the employee will work with the employee to schedule them for additional hours. The supervisor will be the sole judge of whether there is work available. The employee can use their personal or vacation time to make up their hours so that they achieve 40 hours that week.

2.

It is important for employees to understand that they will not be paid for shifts that they miss due to the inclement weather.

R. TIME CLOCK POLICY

All hourly employees are required to use the time clock system when reporting their hours worked. They are required to punch in on the time clock prior to starting their work. They are also required to punch out whenever they are finished at the end of their scheduled work time.

15

Hourly employees must clock out for lunch each day. They must take a minimum of 30 minutes for lunch. This includes employees who eat their lunch at their workstation. All exceptions to these rules must be authorized by your supervisor/manager. Hourly employees are also required to punch out on the time clock during their normal working hours if they leave the facility for non-work related reasons. They are not required to punch out if they are leaving the NRG property for work related activities. NRG employees are forbidden to have their co-employees use the time clock on their behalf except with express and authorized permission from manager/supervisor or Chief Operating Officer.

16

SECTION III
INSURANCE AND RELATED BENEFITS
A. INTRODUCTION

NRG has established a variety of employee benefit programs designed to assist you and your eligible dependents in meeting the financial burdens resulting from illness, disability, death, and to help you plan for retirement, deal with job-related or personal problems, and enhance your job-related skills. This section of the handbook is meant to highlight certain information regarding our benefit programs. Our group health, disability and life insurance and retirement savings program are described more fully in Summary Plan Description booklets (SPD's), and the benefit plan documents, which are available for your review at our Human Resources Department during regular business hours on reasonable notice. NRG reserves the right to amend or discontinue any of these programs or to require or increase employee contribution toward any benefits at its discretion, with or without notice. Contact the Human Resources Department for eurollment forms and any questions you may have concerning your benefit package.
B. EMPLOYEE HEALTHCARE PLAN (Medical /DentaVVision)

I. MEDICAL PLAN

Employees are eligible to participate in NRG's group health benefits program at the first of the month following 30 days of full-time employment. A more complete explanation of the coverage available to you and your family under the Health care Plan is contained in a Healthcare Plan Booklet provided by the Human Resources Department. 2. DENTALPLAN Refer to the Benefits Eurollment and Healthcare Plan Booklet for details regarding coverage and cost. 3. VISION SA VlNGS EYECARE PROGRAM The Vision Savings Eyecare Program through MetLife provides discounts at participating providers, subject to some co-pay. Limitations apply and the employee will be responsible for charges that exceed the limitations. Contact your Human Resources representative for more details and for a directory of participating providers.

4. COBRA Under a federal law commonly referred to as COBRA, NRG offers employees and their dependents participating in the company sponsored health care, vision, and dental plans, the opportunity to pay for continued health benefit coverage for a certain time after conversion to part-time employment or termination of employment for reasons other than gross misconduct.

Under a federal law commonly referred to as COBRA, NRG offers employees and their covered dependents participating in the company sponsored health care, vision and dental plans, the opportunity to continue benefit coverage for a period of time after loss of coverage due to reduction of hours, termination (for reasons other than gross misconduct) or loss of dependent status. Refer to the healthcare Program Booklet for more detail.

17

5. ANNUAL HEALTH CARE PLAN ELECTION PERIOD Each fall during our annual Benefit Open Enrollment period, employees have an opportunity to review their healthcare plan coverage aud, if they wish, make chauges for the following year. All chauges will be effective on August 1 aud remaiu in effect throughout the calendar year. Because NRG's Plau is qualified under IRS rules allowiug for employee premiums to be paid with pre-tax dollars, employees cao only make changes iu their coverage duriug the plao year if they have a qualicyiug family status change or an employment status change (such as marriage, birth of a child, divorce, employment of spouse, etc.). All employees eligible for Health Care benefits must complete their onliue enrolhnent anoually. Online enrollment confmnation is required from all eligible participauts, including those who elect not to enroll in aoy of the coverage's offered by the Company.
C. 401(k) PLAN

NRG provides employees with a qualified 401(k) plan that enables participauts to contribute a portion of their current compensation, on a tax-deferred basis, into a personal retirement savings account. Employees are eligible to participate in the 40l(k) plan when meeting the followiug eligibility requirements. I. 21 years of age, aud 2. Have completed !(one) full year of employment, and 3. Worked over 1000 hours in the previous year. NRG will match 100% of an employee's annual contribution into the 40l(k) program up to 5% of the employee's compensation. Contact your Human Resources representative for more details.

D. LIFE INSURANCE PROGRAM

I. BASIC LIFE INSURANCE COVERAGE

The NRG life insurance plan provides full-time employees with company paid basic life insurance of $50,000. Coverage begins on the I~ day of the month following the first 30-calendar days of your full-time employment. 2. SUPPLEMENTARY LIFE INSURANCE COVERAGE You may buy additional term life insurance coverage for you, your spouse and dependents through the NRG piau at group rates. Contact your Humao Resources representative for more details.
E. WORKERS' COMPENSATION POLICY

NRG strives to provide a safe work environment. Our Safety/Workers' Compensation program includes training, safety policies, safety inspections, prompt reporting and investigation safety service aud performance. NRG provides Workers' Compensation benefits as specified by applicable state laws. All active employees, full-time and part-time, are covered by the Worker's Compensation Act from the first day of work. All work-related accidents involviug personal iujury or property damage must be reported to the manager/supervisor or Chief Operating Officer prior to the end of the shift and/or withiu 24 hours of personal injury or property damage. Employees not reporting personal iujury or property damage in a timely manner will be subject to discipline. The mauger/supervisor must initiate an investigation at the time

18

it is reported. The completed documentation and follow up must be completed as soon as possible after the incident. Should the employee be medically unable to return to regular work or light duty, he/she may receive disability benefits in accordance with applicable state law. If the employee is unable to return to work they must notifY the Chief Operating Officer as per our attendance policy. If a visit to a medical provider is required, the employee must return a completed copy of the medical provider form to their supervisor within 24 hours following each and every visit to the medical provider. Thereafter, the employee must contact his/her supervisor with an update of his/her condition on at least a weekly basis. A medical provider form must also be completed by the medical provider and given to their supervisor, within 24 hours, following lost time away from work because of a work-related accident. On the day of the accident, the injured employee will be paid the remainder of theY, day worked. For example, employees injured during the first half of the day will receive pay for the rest of the first half day worked; employees injured during the last half of the day will receive pay for the rest oftheir work day. The Chief Operating Officer and Human Resources Team are responsible for compliance with Workers' Compensation laws and OSHA. He/She is responsible for managing each claim for maximum recovery and
return to work as expediently as possible. Your questions about Workers' Compensation can be answered

by talking directly to the Chief Operating Officer. NRG will resist fraudulent and/or inflated claims. Fraudulent claims are grounds for disciplinary action up to and including termination of employment and legal process. All Workers' Compensation injuries or illnesses that do not require immediate emergency room examination must be reported to the immediate supervisor before the end of the workday or before
physician examination and complete a "First Report of Injury or Occupational Disease" form as soon as

possible. The supervisor will require completion of a "First Report of Injury of Occupational Disease" form
before physician examination. If the injury or illness requires immediate emergency room examination, an

employee should still make every effort to inform someone of their whereabouts, but may proceed immediately to an emergency room and may report the injury upon release from the emergency room. Should an injury occur during the working hours of a non-emergency nature, the employee should report the injury to their supervisor who will schedule an examination to be performed by a physician of the employee's choice from the panel of physicians. Failure to follow the above procedures may result in delay or Joss of medical benefits or fmancial compensation and termination of employment.

F. UNEMPLOYMENT INSURANCE

Unemployment insurance is provided for you by NRG through payments of both State and Federal Unemployment Insurance Taxes. The taxes are paid by NRG and the program is administered by the appropriate state department. Payments are made if you are involuntarily laid off without cause and are unable to find work. If you have questions as to whether you are entitled to benefits, contact the state governmental agency in the state of your residence responsible for unemployment compensation.

G. EMPLOYEE ASSISTANCE SERVICES

NRG provides a confidential, professional counseling to full-time employees and their dependent family members (some restriction apply) for assistance with personal problems such as stress, relationship issues, family issues, parenting issues, divorce, physical illness, anxiety, depression, grief, and substance abuse. This service is provided to you and your family at no charge. The EAP service is provided by an outside licensed provider and is completely confidential. You or your family members may contact the EAP directly by calling the above number. An EAP staff member will assist you or your family member. Any information that is given to the EAP service is confidential and will not be shared with the NRG, except as required by law. The Human Resource Department is responsible for management of the program and will be available for advice, guidance, and assistance on any part of the program you wish. All communication

19

between you and your Human Resource representative will remain in the strictest confidence, except as

required by law or business needs.

H. FLEX SPENDING PROGRAM

NRG provides full-time employees with the opportunity to take advantage of pre-tax savings offered under IRS Code 125 for covered expenses. You are eligible to participate in the Flex Spending Program beginning the I" of the month following 30 days of full-time employment. The 30 days will be pro-rated to reflect the remainder of the year until enrollment. Refer to the online benefits program and/or Human Resources for details.
I. GYM/FITNESS MEMBERSHIP

NRG will reimburse full time employees for monthly gym membership fees not to exceed $50 per month per employee. This is contingent upon employee submitting proof of attending the gym at least eight times per month. This benefit is extended only to the employee not family members of employees. The employee must pay any registration fees or additional fees. The Wellness Center offers a 20% discount to NRG employees but employees may choose another gym & still receive reimbursement.

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SECTION IV
A. PAID TIME OFF (PTO}

Paid Time Off (PTO) is paid time off provided to you for vacation, holidays, bereavement and short duration sick leave. The benefits included in this section are for full-time employees only. Your eligibility for all ofthe following benefits ends on the date your active full-time service ends for any reason. Eligibility:
(l)

For all NRG employees beginning their full-time employment on or after January l, 2010, no such employee shall be entitled to accrue vacation pay, in whole or in part, until their designated employment start date. (Example: An employee who resigns or is fired after 5 months of full-time employment will not receive any vacation pay with his/her fmal paycheck). The employee will begin to accrue vacation time on day I of their employment that can be used after the one-year anniversary. After the first armiversary of such employee's full-time employment, an earn-inarrears vacation pay policy will apply in accordance with the eligibility table in subsection (b) below. The following eligibility table will apply (effective 8/1/11 ):
Time Period

(2)

Hours Accrued Per Pay Period

Hour Accrued per year

Translated into Weeks

1st

year

2nd, 3rd, 4th year

5th, 6th, 7th 8th year 9th year and continuing

3.34 5.00 6.67 8.34

80.16 120.00 160.08 200.16

2 weeks 3 weeks 4 weeks 5 weeks

(4)

Notice: After the first full year of employment, paid time off may be taken as it is accrued. Two weeks notice is requested for more than two days. A request to take a day or two may be approved or disapproved by the immediate supervisor depending on current circumstances. Requests for vacations to be taken during the first week of the month will not be granted. An employee may not take a holiday off 2 years in a row, unless no other employees have requested that day or days. All vacations are subject to approval by the Chief Operating Officer. Employees who need to take PTO for an illness must call their innnediate supervisor at least thirty minutes before their normal reporting time. In the event that the immediate supervisor is not in the office, the employee must leave a message on their innnediate supervisor's office phone. This procedure must be repeated every day that the employee will be out. The employee is responsible for obtaining the operations manager and their direct supervisor's cell phone numbers in case of
emergency.

If an employee reports sick, he/she must stay at his residence or be seeking medical care. An employee who requests more than two consecutive days for PTO may be asked for a doctor's excuse. All PTO must be approved by the Operations Manager. If an employee is going on short-term disability, PTO accrued may be used to bridge the time from first day missed until disability pay begins.

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ANY PTO USED BY A SALARIED EMPLOYEE MUST BE REPORTED BY ENTERING ON TIME SHEET WITIDN 5 BUSINESS DAYS OF THE EMPLOYEE'S RETURN TO WORK. Employees may request payment for any or all accrued Paid Time Off. The PTO time will be paid at regular time with no premium. The Chief Operating Officer must receive the request for this payment in writing 30 days prior to the payment. Payment will be included in normal payroll cycles. The employee must be fully entitled to the hours before payment will be made. An employee may elect to cash out PTO hours as follows: a. There must be a PTO balance greater than 80 to participate and a minimum of 80 hours after PTO buypack. Requests that reduce the balance below 80 hours will not be considered. No less than 8 hours and no more than 80 hours may be cashed ont two times per calendar year. All PTO buyback opportnnites will be paid at 90% of the dollar for financial compliance reasons.

b. c.

(5)

If a NRG paid holiday falls during your vacation, you will use the holiday time off for that given day. Employees will not earn vacation time when they are on long-term disability. Vacation hours are earned and paid based upon the regularly scheduled hours per week that the employee is working.

(6) (7)

(8) Upon voluntary resignation or retirement, an employee may request extending their effective date of termination by applying unused vacation tiroe. This request must be: in writing as part of the employee's signed Resignation Notice, be presented in a timely manner, be approved by signature ofthe employee's manager, and by signature of the Chief Operating Officer The Resignation Notice must specify both the last day actually worked and the desired termination date. This extension of employment status is subject to the Payroll Department's verification of unused vacation time currently available to the employee. Employees who have a current step of discipline on their record are not eligible to extend date of termination by use of vacation time. This extension of employment is also subject to the employee's continuing satisfactory work performance and may be retracted upon Manager discretion if work performance becomes unsatisfactory or the employee enters a stage of discipline. (9) Employees are disqualified from payment of accrued vacation upon separation of employment if they are terminated, with or without cause. Furthermore, employees are disqualified from payment of accrued vacation upon separation if they fail to give 2 weeks notice of resignation.

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PTO CARRY OVER

Hourly (non-exempt) employees who earn 120 or more hours in a vacation year and who have used at least 80 hours of vacation may elect to carry over a maximum of 40 hours to the next vacation year. Employees who earn less than 120 hours per calendar year are not eligible to carry over vacation. Salaried (exempt) employees are not eligible to carry over vacation.
B. HOLIDAYS

The following holidays are observed by NRG. Full-time employees will be paid regular pay for the following holidays:

NewYear'sDay Martin Luther King Day Memorial Day U.S. Independence Day- July 4th Labor Day Thanksgiving Day & Day After Christmas Day A 2 Day after or before Christmas- sole discretion the Chief Operating Officer Employee's birthday

The Employee Birthday Day is essentially an extra paid holiday that NRG grants to its employees. Employees may use their birthday day on their actual birthday or any day following preferably within a 30 day time period. The employee shall not lose their day simply because his or her schedule does not allow him or her to use the day within that time frame. The employee shall notate on the time sheet when he/she request to use their birthday day and always get approval by his/her manager/supervisor as with any other holiday. If the employee's birthday falls within the 90 day probationary period, the employee will not be permitted to use the birthday holiday. Employees who are scheduled to work more than eight hours on a holiday will be paid eight hours pay and will be allowed to make up the difference, subject to the business needs of NRG. Employees on disciplinary suspension will not be eligible for holiday pay during their suspension. From time to time, an employee may be asked to work on one of these holidays. If a nonexempt, full-time employee works on a paid holiday, he/she will receive their regular pay for the hours worked that day in addition to the holiday pay. An employee who is scheduled to work on the observed holiday date will be able (with manager's approval) to take their holiday off in advance of the scheduled holiday, or up to four weeks after the holiday. The employee will be paid during the payroll period in which he/she takes off, if the time off is taken in advance of the payroll and payroll is notified. If the time off is taken after the observed holiday, the employee will be paid during the payroll in which the holiday occurs. If a part-time hourly employee works on a holiday, he/she will receive regular pay, but no holiday pay.

C. MATERNITY POLICY

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Pregnancy disability (formerly covered as Maternity Policy) is covered through our Short Term Disability benefit. Refer to Human Resources for additional questions and/or concerns.

D. SHORT TERM DISABILITY (STD)

Full time employees are eligible for short-term disability (STD) at the beginning of the first day of the month following the first 30-calendar days of full time employment. Employees must enroll in the program, pay the premium, and comply with all program requirements, in order to have coverage. To be eligible for this benefit, you must be unable to perform any of your normal job duties. Please refer to Human Resource Department for additional information.
Disability Benefits Disability benefits will be paid if an employee becomes disabled while covered under this policy. A disabled employee must satisfY the benefit-waiting period and be under the appropriate care of a physician. Satisfactory proof of disability must be provided, at the employee's expense, before benefits will be paid. A disabled employee must provide continued proof of disability for benefits to continue. A release to return to work, signed by your physician, is required before you can return to work. We may require you to be examined by a doctor or other medical practitioner or vocational expert of our choice at NRG's expense. We may also require you to be interviewed by an authorized NRG representative. Benefit Waiting Period The benefit waiting period is the period of time an employee must be continuously disabled before disability payments may be payable. In order to fulfill the benefit waiting period for short-term disability benefits, you must be disabled and absent from work for 40 consecutive working hours due to a non-work related illness or injury. Disability Benefit Calculation If an employee is covered for disability benefits, the benefits are payable at 60% of regular pay (excluding bonuses, overtime, etc.), up to a maximum weekly benefit of $2000 less other income benefits as explained below. Disability benefits are calculated on the number of days in a normally scheduled workweek for the employee immediately prior to disability. Benefit payments will be prorated if payable for any period less than a week and/or if you are released to a partial workday schedule. Total benefit is based on receiving full I 00%, after-tax, contributory benefit; the disability benefit is non-taxable. If a holiday occurs during a week that you are receiving disability benefits, you will not be entitled to the holiday pay. See the Payroll Manager for the explanation of wage assignments and loans. Termination of Disability Benefits Disability benefits will end on the earliest of the following dates: The date an employee earns more than 80% of his or her indexed covered earnings. If an employee is not working, they would be allowed to PTO instead of STD. Upon depletion of paid time off, they could return to STD, providing their medical certification is approved. The date NRG detennines that you are no longer disabled. The end of the maximum benefit period. The date the employee dies. The date the employee refuses to participate in rehabilitation efforts as required by NRG. The date the employee is no longer receiving appropriate care. The date you fail to submit proof of continuing disability. The date you are able to work in your regular occupation on a part-time basis, or modified job duties, but you choose not to. Other Income Benefits While an employee is disabled, he or she may be eligible for benefits from other income sources. If so, the disability benefits payable may be reduced by the amount of other income benefits. If determination of

24

eligibility for other income benefits is made after the employee has received short-term disability payment, reimbursement of short-term disability payments may be requested. Other income benefits include: I. Any amounts which the employee or any dependents, if applicable, receive (or are assumed to receive)
under: a. b.

The Railroad Retirement Act. Any local, state, provincial, or federal government disability or retirement plan or law. Any PTO or salary continuation plan of the employer.
Any work provision in "No Fault" auto insurance.

c.
d.

I.

2. 3.

Any disability benefits received for the Veterans Administration. Any Workers Compensation, occupational disease, unemployment compensation law or similar state or federal law, including all permanent as well as temporary disability benefits. This includes any damages, compromises, or settlement paid in place of such benefits, whether or not liability is admitted. g. Any Social Security disability or retirement benefits the employee or any third party received on the employee's behalf or for his or her dependents; or, if applicable, which his or her dependents receive because of the employee's entitlement to such benefits. Any proceeds payable under any franchise or group insurance or similar plan. If there is other insurance that applies to the same claim for disability, and contains the same or similar provision for reduction because of other insurance, a pro-rata share of the total claim will be paid by this plan. "Pro rata share" means the proportion ofthe total benefit that the amount payable under one policy, without other insurance, bears to the total benefits under all such policies. Any amounts paid on account of loss of earnings or earning capacity through settlement, judgment, and arbitration or otherwise paid. Any wage or salaries for work performed.
f.

e.

Dependents include any person who receives benefits under any applicable law on account of an employee's entitlement to benefits.
Reccurring Disability

When your return to work as an active employee is followed by a disability and such disability is:
1. Due to the same cause; or

2. 3.

Due to a related cause; and Within 15 consecutive calendar days of the return to work; the period of disability prior to your return to work and the recurrent disability will be considered one period of disability.

If you return to work as an active employee for 15 consecutive days or more, any recurrence of a disability will be treated as a new disability.
Maximum Benefit Period

The maximum period of payment is the lesser of 25 weeks, or until the long-term disability elimination period has been met. Premium payments are required for your coverage while you are receiving payments under this plan. Your coverage for short-term disability under the NRG policy ends on the date your active full-time service ends for any reason. Such reasons include but are not limited to: retirement, layoff, death, unpaid leave of absence, and the end of employment.
Exclusions:

Benefits are not payable for a disability that results, directly or indirectly, from the following: I. Occupational sickness or injury. 2. Suicide, attempted suicide, or whenever an employee injures himself or herself on purpose. 3. War or any act of war, whether or not declared. 4. Serving on full-time active duty in any armed forces.

25

5.

Terrorism or active participation in a riot.

6.
7.

Commission of a felony.
The revocation, restriction, or non-renewal of an employee's license, permit, or certification

8.

necessary to perform the duties of his or her occupation unless due solely to injury or sickness otherwise covered by the policy. Any cosmetic surgery or surgical procedure that is not medically necessary. Medically necessary means that the surgical procedure is prescribed by a physician in the treatment of the injury or illness and is appropriate treatment according to conventional medical practice for the injury or illness in the locality in which the surgery is performed. (Except that benefits are payable if the disability is caused by the employee donating an organ in a non-experimental organ transplant procedure.)

No benefit is payable for any period in which you are incarcerated in a penal or corrections institution.

Definitions Accident: A sudden unforeseeable event that causes bodily injury to an insured while coverage is in force under this policy. Employee: For eligibility purposes, an employee is a NRG employee, who has met the eligibility requirements and who is insured under the policy. Physician: A licensed doctor practicing within the scope of his or her license and rendering care and treatment to an employee that is appropriate for the condition and locality. Active Emplovment: Active employment means you must be: 1. Working at the employers usual place of business or on assignment for the purpose of furthering the employers business; and Performing the substantial and material duties of your regular occupation on a full-time 2. (40 hours per week) basis.

E. LONG-TERM DISABILITY PLAN Employees are eligible to participate in the Long-Term Disability Plan (LTD) on the I'' day of the month following the first 30-calendar days of your full-time employment. The LTD plan will provide you with up to 50% of your pay (not to exceed a certain maximum) if you become totally disabled. Benefits begin after 180 calendar days of total disability. Refer to Benefit Enrollment Form and LID Booklet for coverage details. Disability benefits may be paid up to the time you are no longer considered disabled under the NRG plan and/or are approved for social security.

F. JURYDUTY
NRG believes that all employees should fulfill their civic obligations. Therefore, you are urged to respond
when asked to serve on jury duty. 'When you are requested to serve as a juror, you will receive your regular

pay for up to 80 hours of jury duty, provided that you make the necessary arrangements with your supervisor. After 80 hours, if you are still serving on a jury, NRG compensation will end. You are expected to report for work on regularly schedule workdays when the jury is not in session, or if you are excused from jury duty iu time to permit you to work at least half of your scheduled workday. You may keep any expense reimbursement amount for Jury Duty service earned. You will be paid for auy absences up to I workiug day to appear iu court if you are subpoenaed as a witness to give testimony. Time off without pay or a personal day may be granted for court appearances when you are a party to the lawsuit or appearing without subpoena. In all cases, whenever you are asked to
serve on a jury or appear in court, you are expected to return to work as soon as possible.

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G. FUNERAL LEAVE (Bereavement Leave)

When there is a death in your innnediate family, full-time employees will be eligible to be paid for time off at their regular pay, up to a maximum of 3 working days, from the date of death up to and including the day after the funeral. Immediate family is defined as spouse, children, parents, brothers, sisters, immediate grandparents, grandchildren, stepmother or stepfather or stepchildren, mother-in-law or father-in-law, and foster parents or foster children. Any additional time taken may be charged against your vacation or personal time. In addition, full time employees may be allowed 4 hours of paid time off to attend the funeral of close relatives who are not innnediate family members. Attendance at a funeral of a close relative must be approved in advance by your supervisor in order for you to receive pay for it. Requests for bereavement leave for any other relative shall be reviewed on a case-by-case basis. Such leave may be used innnediately, upon notification to Chief Operating Officer, of the employee's loss or may be requested up to seven days after the death of the immediate family member.

lL UNPAID LEAVE OF ABSENCE

Unpaid leaves of absence may be granted for up to 30 days each on an individual basis at the sole discretion ofNRG, taking into consideration: the purpose of the leave, the employee's work record, and the needs ofNRG at the particular time, as follows: I. 2. 3. 4. 5. All paid time off must be used before an unpaid leave of absence can be taken. A personal unpaid leave of absence may be granted for reasons of a personal nature not specifically covered under other policies. The leave must be approved by the employee's supervisor and department manager. Personal, unpaid leaves of absence are without pay unless otherwise approved by the supervisor and department manager. NRG does not guarantee reinstatement to the former position or to a position with like status or pay. Upon return from the approved leave, every effort will be made to reinstate the employee in a comparable position. Employees on leave of absence may reapply to their supervisor and department manager for extensions in 30-day increments. Group life, health and disability insurance will continue for 30 days during an unpaid leave of absence, if premiums are paid. If you do not return to work within that 30-day period or you do not pay your premiums, coverage may be discontinued. COBRA may be an option at this time- please refer to that section of this Handbook. Service credit for other fringe benefits may be adversely affected if your leave of absence is more than 6 months long. FMLA leave runs concurrent with time off for an unpaid leave of absence.

6. 7.

8. 9.

I. FAMILY MEDICAL LEAVE BENEFIT

Under the Family and Medical Leave Act (FMLA) an eligible employee is entitled up to 12 weeks of unpaid leave in a 12-month period: However, where a husband and wife both work for NRG, the two employees are limited to a combined total of 12 weeks of family leave to cover the time off they need after the birth or placement of a child or to care for a seriously ill parent. Each employee is eligible to take any unused portion of the 12 weeks for his or her own serious health condition, the care of a seriously ill child or the care of the other spouse or approved relative.
I. For the employee's own serious health condition that makes the employee unable to perform the functions of his/her job;

A "serious health condition" is an illness, injury, or impainnent involving: A. An overnight stay in a hospital.; B. Continuing treatment by a health care provider in connection with:

27

a) Incapacity (including inability to attend work) for more than three consecutive calendar days; b) Any period of incapacity due to pregnancy or for prenatal care; c) Any period of incapacity due to a chronic serious health condition; d) Incapacity that may be permanent or long-term due to a condition for which treatment may not be effective; or 2. A period of absence to receive and recover from multiple treatments for restorative surgery or a condition that would likely result in incapacity for more than three consecutive calendar days in

the absence of medical intervention or treatment.

3. In conjunction with the birth or the placement of a child with the employee for adoption or

foster care; or
4. To care for the employee's child, spouse or parent with a serious health condition. Paid time off must be used during FMLA, if available. See use of PAL/BIB discussed in previous sections. Exempt employees can use partial days under FMLA and may be paid actual hours worked in a reduced schedule scenario. To be eligible for FMLA leave, you must have been employed by NRG for at least 12 months and have worked at least 1250 hours in the 12 months preceding the leave. The total time taken for FMLA leave cannot exceed 12 weeks within the rolling 12-month period backwards from the date the employee uses any leave under this policy. FMLA leave for birth or placement of a child for adoption or foster care must be concluded within 12 months after the birth or placement. Intermittent Leave Employees taking leave because of their own serious health condition or a covered relative's serious health condition can take their allotment of Family Medical leave intermittently or in accordance with a reduced work schedule, if this is medically necessary. Where employees have some control over the timing of their leave, they are expected to consult with their supervisors to try to arrange a mutually acceptable time. Employees taking leave to care for a newly born or newly placed child do not have a legal right to take

intermittent leave and can do so only with their supervisor's consent.

You must give at least 30 days advance written notice of the need for FMLA leave when the need for that leave is foreseeable or, if the need is not foreseeable, you must give notification as soon as practical and generally no later than two business days after need becomes known to you. Notice must be given to the Human Resources Department who will determine your eligibility and designate the FMLA leave upon receipt of medical certification of a serious health condition or other legal documentation. You must notifY your Department Director and/or supervisor as well. You will be provided with information on your specific rights and responsibilities regarding the leave. For example, if eligible, you will be able to use PTO for other designated leave, and you will be entitled to continue your group medical coverage during FMLA leave provided you make timely premium payments like active employees. Employees returning from a leave of absence (other than FMLA leave) should notify their Chief Operating Officer at least one week in advance. Employees returning to work after a prolonged illness, Leave of Absence, personal injury or surgery that may have changed their physical ability to perform the essential functions of their pre-leave of absence position may be required to submit to a Health Screen and review by a medical doctor. Persons not returning promptly at the end of any granted leave are subject to separation from employment unless express permission for extension of the leave is received from the Chief Operating Officer. Upon return to work within the 12 weeks FMLA protected time, you will be reinstated to your same or an equivalent job. If you plan to return to work before the expiration of the leave, you should give your

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Human Resources at least two business days advance notice of your intent to return early. If your leave is
for your own serious health condition, you must present a doctor's statement confrrming you are fit to

return to work in order to be reinstated. lfyou fail to report to work following the expiration of your FMLA leave, you may be terminated. Please note that an extended amount ofFMLA coverage may be available to those recovering from injuries or illnesses associated with military duty or those caring for individuals that become injured or ill while serving in the military. Under the National Defense Authorization Act, eligible FMLA employees are entitled to up to 12 weeks of leave because of "any qualifYing exigency" arising out of the fact that the spouse, son, daughter, or parent of the employee is on active duty, or has been notified of an impending call to active duty status, in support of a contingency operation. By the terms of the statute, this provision requires the Secretary of Labor to issue regulations defining "any qualifYing exigency." NRG will review each leave request for a "qualifYing exigency" based on the definition provided by the Secretary of Labor. An extension of a leave of absence may be granted after the FMLA designation has been exhausted if the employee is still under a doctor's care. Please note this extension is outside the FMLA entitlement and is not protected by any provision of FMLA. An updated doctor's certification is required to validate this extension. If the employee is released from the physician's care prior to the end of the extension date, the employee may place transfers for open positions up until the approved leave time expires. At no time during the extended LOA period is NRG responsible for placing the employee in a position and/or retaining benefits. An employee who is away from the job for a total of one (1) year (including use of PTO) will be administratively resigned with notice and terminated from the payroll system.

J. MILITARY LEAVE

All military leaves will be granted in accordance with the Uniformed Services Employment and Reemployment Rights Act of 1994 (USERRA) and other applicable Jaws. As appropriate, a copy of military orders will be required to validate military leave. Refer to Human Resource representative for further information.
K. VOTING POLICY

NRG encourages all employees to exercise their right to vote in governmental elections. Employees should vote prior to or after they have ended their workday at NRG. However, in situations where they are not able to go to the polls prior to or after work, an employee can take time off from work to vote. This needs to be requested from your manager and employees will not be paid for the time away from work in order to vote.

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SECTIONV
EMPLOYEE CONDUCT
DISCIPLINARY ACTION

NRG believes in progressive discipline and requires all supervisors to utilize progressive discipline whenever appropriate. However, not all situations lend themselves to progressive discipline, based on the serious nature of the performance deficiency or inappropriate conduct. Consequently, NRG cannot and does not guarantee that progressive discipline will be used iu all cases and reserves the right to discipliue and discharge any employee at any time without advance notice

NRG's progressive discipline action consists of three types

A. Documented Verbal Conference/Warning

In a private conversation, the Supervisor explains to the employee what he/she is doiug wrong and what is necessary to correct it. The Supervisor must make and sigu along with the employee a written record of this conversation including the date, name of the employee, and subject matter. The signature of the employee is required as acknowledgement of haviug seen the document and does not necessarily mean the employee agrees. For any of the progressive discipliuary steps, if the employee refuses to sign the memorandum for record it does not change the documentation and the progressive disciplinary process. In this case, it is recommended that the supervisor have a witness confrrmiug the employee's presence in the meeting. The documented verbal conference is kept in the personnel file of the employee.
B. Written Warning

A Written Warning is a formal warning for serious misconduct, or failure to improve conduct after a verbal warning. A written warning must be dated and signed by the employee and the employee's Supervisor or other management authority. As before, the employee must sign as acknowledgement of seeiug the form. A written warning must be made a part of the employee's personnel file.
Prior to discussing a written warniug with an employee, the Supervisor will explain that the purpose of the warniug is to reach a thorough understandiug with the employee and to give him/her a chance to improve. The employee will be told that a written record of the rule violation will be placed in his/her personnel records and he/she will be given an opportunity to read and sign the warning. The Supervisor may also advise the employee of the availability of the Employee Assistance Counselor, if applicable. The employee may submit a written response to the warning. Note: A Written Warniug is 12 months probation unless otherwise noted. C. Discharge Discharge is an iuvoluntary tenniuation of employment. It is a serious responsibility and should be exercised with caution. In unusual and documented circumstances, the employee may be suspended in lieu of discharge (with the concurrence of the responsible Chief Executive Office or Chief Operating Officer). Unpaid discipliuary suspension of one or more full days imposed in good faith for violations of workplace conduct rules, such as rules prohibiting sexual harassment or workplace violence will be imposed for all non- exempt and exempt employees. However, this action is not required prior to discharge and may not necessarily preclude discharge at a later date. Also, it may be necessary to suspend an employee pending investigation of serious allegations agaiust him/her.

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D. Procedures for Selecting Appropriate Discipline Rules of conduct have been divided into Group One (which are very serious and call for severe discipline) and Group Two (which are less serious in nature and call for progressive discipline). The purpose of this division in types of discipline is to provide for discipline appropriate to a rule violation. Further, adherence to this procedure will insure uniformity of treatment to all employees in disciplinary situations. Please consult your Operations Manager for advice. Disciplinary action will be taken as follows:
I. Group One

Violations of these rules are serious in nature and will, except in unusual circumstances, result in immediate discharge. Under no circumstances will an employee with a Group One violation receive less than a written warning with a probationary period of 12 months unless otherwise noted. An employee involuntarily discharged is not eligible for rehire without the express permission of the Chief Operating Officer. Examples of Group One violations are: a. b. c. Stealing while on duty or on system premises. Theft. Willful damage or destruction ofNRG property. Reporting to work intoxicated or noticeably under the influence of alcohol or drugs, possession or use of alcoholic beverages, intoxicants of any kind, or illegal drugs on system premises; refusal to submit to drug/alcohol testing when reasonably requested. Fighting, threatening or attempting bodily injury to any person on NRG property. Falsification ofNRG records, system records, forgery, alteration of documents, or providing false employment-related information. Refusal to perform assigned duties or to obey instructions - Insubordination. Use of abusive, profane, offensive, or threatening language and/or gestures. toward any person. Coercing or harassing fellow employees while on duty or any person while on NRG premises. Possession of firearms, dangerous weapons, explosives, etc. on system premises. Information System Access or Password abuse. Sleeping while on duty. Gambling while on dnty. Obtaining or conveying, without proper authority, confidential information about NRG operations, clients, patients or employees. Unauthorized leaving of system premises during working time. Gross negligence or intentional conduct resulting in injury to, or death of, another. person, or damage to NRG property. Failure to perform satisfactorily during the initial observation period o{ employment. Failure to report to work for two (2) consecutive days without notifYing your. Manager, Supervisor and/or Chief Operating Officer of the circumstances. Immoral or indecent conduct on NRG property. Sexual harassment or conduct not in accordance with common standards of. decency and propriety. (e.g. sexual harassment of an aggravated nature). Accepting bribes or kickbacks or engaging in any scheme to profit oneself to the. detriment of the NRG, or conducting activities, which result in a conflict o{ interest. Violation of safe practices dangerous to life of self or others. Regulatory compliance violations of an aggravated nature. i.e. HIPAA, EMTALA etc.

d. e. f.
g.

h. i. j. k. I. m. n. o. p. q. r. s. t. u. v.

2. GroupTwo

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Violations of these rules, which are less serious in nature, will result in at least an oral warning and, depending upon the circumstances, a written warning, or discharge. Excessive tardiness (See Attendance Policy) Please note any termination for Time and Attendance infractions may result in the denial of your unemployment benefits. b. Excessive absenteeism (See Attendance Policy) Please note any Time and Attendance infractions may result in the denial of your unemployment benefits. c. Performing careless or improper work. d. Poor customer service. e. Failing to do an acceptable quantity and quality of work f. Being out of assigned area without permission. g. Loafing or neglecting work. h. Failing to follow health, safety or fire rules and regulations. i. Failing to obey instructions. j. Unauthorized operation ofNRG equipment. k. Harassment of any employee due to that employee's race, religion, national. origin, sex, age or handicap/disability. 1. Unauthorized posting of material or defacing material on system bulletin boards. m. Excessive time on breaks or taking unauthorized breaks. n. Committing an act contrary to the standards of conduct after being notified tha' the conduct was unacceptable by your Supervisor or by posted NRG notice. o. Violation of no solicitation-distribution rule. p. Unnecessary waste of materials or supplies. q. Refusal to work overtime or special hours when required to do so. r. Failing to exercise reasonable care, consideration or courtesy in dealing with. patients or visitors. s. Failing to adhere to dress code policy. t. Creating or contributing to unsanitary conditions or to conditions creating bad housekeeping. u. Damaging, abusing or neglecting system equipment or supplies. v. Engaging in horseplay or disorderly conduct on NRG property. w. Engaging in conduct which would tend to reflect adversely on NRG and/or. any member of the NRG staff at any time or at any place. x. Failing to immediately report any injuries sustained on NRG property or in. connection with your work. y. Marking bulletin boards or notices contained on bulletin boards; removing bulletin. board notices or material without permission. (Nothing is to be posted on bulletin. boards without management approval.) z. Failing to comply with applicable system ethics and code of conduct. aa. Failure to notifY your Department head or supervisor in advance when you will be. absent from
work.

a.

E. Progressive Discipline Guideline Schedule Additional violations occurring within a twelve (12) month period will be managed as listed below.
Violation Different Rule Same Rule

First Second

Verbal Warning Verbal or Written Warning Written Warning

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Third Fourth

Written Warning or Discharge* Discharge

Discharge

* Two written warnings within twelve (12) months will automatically result in discharge. A Written Warning is 12 months probation unless otherwise noted. An involuntary discharge will result in an entry of "Ineligible for Rehire" in the employee's personnel record.

C. SOLICITATION POLICY To maintain a working environment free of undue litter and outside interference, the following rules regarding solicitation and distribution ofliterature on NRG's premises have been established.
I. SOLICITATION BY EMPLOYEES

Employees may not solicit other employees on behalf of any cause or outside organization during the working time of either the employee soliciting or the employee being solicited. Employees may solicit coemployees during non-working time, such as lunchtime and break time. 2. DISTRIBUTION AND POSTING OF LITERATURE BY EMPLOYEES

Employees may not pass out or post literature of any kind at any time in working areas. except work-related
literature. During non-working time, employees may pass out non-work related literature in non-working

areas, such as the employee break area, provided a litter problem does not result. In addition, use of any NRG electronic communication systems (e-mail, voice mail, fax, copiers, etc) by any employee to propose
any type of commercial or personal transaction is prohibited.

3. NON-EMPLOYEE SOLICITATION Non-employees may not solicit employees or pass out or post literature of any kind at any time on NRG's premises, except literature regarding NRG's business. 4. EXCEPTIONS TO THE SOLICITATION POLICY Exceptions to the solicitation policy are the Corporate Sponsored Programs. 5. BULLETIN BOARDS NRG maintains bulletin boards at all locations to post government and NRG information and announcements. Employees may not post items or remove information from any bulletin board without the express permission of the Chief Operating Officer. Tampering with bulletin boards, including posting personal messages, is strictly prohibited. Violations will be considered grounds for disciplinary action, up to and including termination. All employees are urged to checks bulletin boards daily. D. ATTENDANCE POLICY A key element of our success is teamwork. Each of us at NRG relies upon the performance and support of those around us to achieve NRG's goals. Therefore, regular and punctual attendance is expected of all employees. UNSCHEDULED ABSENCES Unscheduled Absences are those that do not have specific prior approval. You are required to notifY your supervisor by telephone as soon as possible whenever an unexpected circumstance causes you to be absent

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from your scheduled work times. If it is uot possible to speak directly to your supervisor, you must contact HR Coordinator, Chief Operating Officer or Operations Manager. For those absences extending beyond one day, you should stay in daily contact with your supervisor. Whenever you miss work due to illness, injury, or disability, or in any situation in which NRG has concern that your medical or mental condition is affecting your attendance at work, your job performance or your ability to work safely, your supervisor may require a note from your doctor prior to your return to work. The required statement from a medical physician licensed in the state includes: verification of the beginning and ending date of the illness, injury, or disability, any limitations on your ability to perform work, the expected duration of those limitations, and any suggestions on how NRG can accommodate those limitations. The supervisor may refer the employee to the NRG Case Manager for follow-up and verification of absence. Disciplinary steps will be initiated should you fail to provide your supervisor with information or documentation that your supervisor believes to he reasonable and appropriate under the circumstances. FAILURE TO NOTIFY When an employee is absent for two (2) or more consecutive days without providing notification to his/her supervisor, the presumption of management will be that the employee no longer wishes to be employed and has abandoned his/her job, and the termination process will be initiated. Extenuating causes for failure to notify will be considered in the application of the appropriate discipline or termination. ARRIVING LATE OR LEAVING EARLY Reporting to work on time is critical to meeting customer service goals. Employees who have a predetermined need to arrive late or leave early need to request permission from their supervisor by giving sufficient advance notice so that all business needs can be accommodated.
Employees whose work is considered as "exempt" from overtime laws and regulations are granted flexibility in their work schedules to accommodate non-routine workloads and responsibilities.

EXCESSIVE ABSENCES

Regular attendance is critical in servicing our customers. Unscheduled absences inhibit our effectiveness and productivity.
Unscheduled absences occurring during a given calendar year that exceed an employee's available paid time off for that year will be considered "excessive absences" regardless of whether the employee provides a doctor's note or not. For those employees who have exhausted their paid time oft; further unscheduled absences during the calendar year will be subject to Progressive Discipline Steps. An unscheduled absence from a scheduled shift and/or consecutively scheduled shifts will be considered one incident. While PTO eligibility is re-calculated at the start of each calendar year (with a provision for carryover as stated in the PTO policy section), Progressive Discipline Steps are rolled forward and are not reset on a calendar year basis. An employee must complete one full year (a rolling 12-month period) without any discipline activity before the employee is considered to be out of the discipline process.

Progressive disciplinary steps are employed to address an excessive absence pattern or inappropriate conduct arising from discretionary employee behavior that needs to be corrected.
Employees' rights under the Family Medical Leave Act will be protected and will govern should they conflict with the application of these guidelines.

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ATTENDANCE DISCIPLINARY ACTION The disciplinary procedure for an absence, tardy and leave early will be based on the number of instances, not the number of days out. The procedure explained below uses a point system. Each occurrence is assigned a value, and the Operations Manager will monitor the total points incurred. Disciplinary actions will be administered according to the points scale listed below.

Occurrence Absence

Tardy Leave early No show/No call

Action

2 points (excluding vacation & holidays) I point 1 point 3 points

Verbal warning Written warning Termination

7 points 11 points 15 points

*Each employee will accumulate points at the beginning of every quarter (points will start over at the beginning of each quarter) *Point accumulation may be altered at the discretion of the Operations Manager upon an individual basis. *An instance of absence may be one day or any number of successive days out, FOR EXAMPLE: an employee who is out three consecutive days with the flu would only accrue 2 points *Combination of absence and tardy/early quits may also result in disciplinary action up to and including termination *If an employee is absent for three consecutive days without calling the Operations Manager or their immediate supervisor, he/she is considered to have voluntarily abandoned his/her job. This is considered a voluntary termination.

E. REPRODUCTION AND USE OF COMPUTER SOFTWARE

All employees must refrain from illegal copying and illegal use of any computer software. Under the U.S. Copyright Law, it is illegal to reproduce computer software without license or permission of the software publisher. Violation of this law can subject both you and NRG to civil damages and possible criminal penalties including fines and imprisonment. NRG does not condone the illegal copying or illegal use of computer software. NRG, through license
agreements, licenses the use of its computer software from a variety of outside companies. The money paid

for a purchased software product includes a license fee for the use of only the copies purchased unless otherwise specified. Neither NRG, nor any of its employees have the right to reproduce any licensed or purchased software or related docmnentation unless specifically authorized to do so by the software developer or publisher through a license agreement. Software copying in violation of the license agreement or receiving or using illegally copied software product is a crime. Such criminal activity could have serious legal ramifications and could expose both you and NRG to severe liabilities. You should assume that the copying of purchased software is prohibited and not copy such software unless specific written authorization is obtained from the software developer or publisher. You should use licensed software only in accordance with the terms of the license agreement. If you have any questions about a software license agreement, you should contact your supervisor for clarification.

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The computer hardware owned and operated by NRG is to be used for business purposes only. In accordance with this policy, employees are prohibited from loading, operating, compiling, or using any computer software not owned by NRG on NRG computer hardware. This prohibition includes but is not limited to, the use or loading of personal finance software, personal productivity tools, utilities, Shareware, or games of any kind.

F. DRESS POLICY
Updated 8.21.2012

NRG believes that presenting a professional image is both good for the business and good for employees. All employees are expected to dress appropriately for their job responsibilities and maintain a neat, wellgroomed appearance. Employees should exercise sound judgment with regard to personal appearance, dress and grooming to enable them to be most effective in the performance of their duties and to present a professional image to our employees, customers, patients and guests who visit our workplace. For these reasons, the Company has formulated a set of dress standards and expectations, which are stated below. Failure to adhere to such policy may include verbaVwritten warnings or termination. A. Monday through Thursday (Business Casual Attire). Males: Examples include dress slacks, khaki slacks (no blue jeans or shorts). Open collared dress shirts, turtlenecks, mock turtlenecks, collared golf shirts (no shirts without collars or without sleeves). Leather shoes (no sandals or flip-flops). Females: Dress slacks, Capri pants, dresses/skirts (no higher than 4 inches above the knee). No denim fabrics. Tops with covered shoulders (minimum width of3 inches). No bare midriffs. Dressy, crew-neck tops are ok, but casual cotton T-shirts are not. Turtlenecks and mock turtlenecks are ole. Leather shoes, dress sandals, dressy flip-flops (no beach type flip-flops). B. Casual Fridays and Designated Casual Dress Days. Males: Same standards as "Business Casual" with additional flexibility of blue jeans, and canvas shoes or tennis shoes. (No exercise shorts, cut-offs, workout clothes, warm-ups, sandals or Tshirts). All shirts must have collars. Females: Same standards as "Business Casual" with the additional flexibility of blue jeans, denim skirts/dresses, canvas shoes or tennis shoes (No exercise clothes, warm-ups, cut-offs, casual cotton T-shirts or beach-type flip-flops). For All Employees the following items are expressly not permitted: -Ripped, soiled or stained clothing. -Clothing that contains offensive language or graphics. -Mini-skirts (more than 4 inches from the middle of knee is unacceptable) -Extremely high slit skirts. -Exposed midriff, tank tops, halter-tops, spaghetti straps. -Pants that are excessively baggy or hanging below the waist. -Excessively tight or revealing clothing. -Visible undergarments.

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Hair, Jewelry, Perfume, Nails, Piercings, etc. (Employees working in Office Settings). A. Facial Hair. Beards, mustaches, goatees and sideburns are acceptable but must remain neatly trimmed. Extreme styles will not be permitted. B. Hair. Hair should be of a conservative manner and will be kept neatly trimmed and combed at all times. No decorative bows, ribbons, flowers, or feathery headgear will be worn. Length of hair for men should not touch the shoulders and ponytails are not permitted. Extreme styles not permitted for males or females. C. Head Coverings. Types of head covering which are non-essential to the employee's position and work are not permitted. D. Jewelry. Males may not wear earrings. Cologne or perfume should be worn in moderation. E. Body Piercings. No jewelry associated with visible body piercing (except earrings for women) may be worn. F. Tattoos (All Employees). Any and all tattoos must be covered during working hours in order to minimize possible disruption in our working environment. Departmental Managers may make exceptions to the Dress Code to accommodate Company sponsored events, such as celebrations, sports outings, picnics, etc. that will be part of the normal work day. Dress for these occasions may be typical for the activity planned. Exceptions may be made by Chief Operating Officer to accommodate an Employee's religious practice, medical condition and/or ethnic custom. G. DATING POLICY NRG is responsible for providing a positive work environment for all its employees. This environment can be affected very negatively by dating relationships between managers and employees. In order to avoid any appearance of favoritism and other potential workplace indiscretions, the Company has implemented a policy that prohibits any manager from being the direct supervisor of an individual he or she is dating, married to or has a significant relationship with (defmed as long-term committed relationship with shared assets and integrated life). Nepotism Policy: Nepotism is defined for purposes of this policy to be the making of employment decisions by a manager on the manager's spouse, significant other (defmed as long term committed relationship with shared assets and integrated life), or children. Managers are prohibited from participating in the hiring of his or her spouse, significant other, or child into any position at NRG. If a significant other, spouse, or child applies for a position within the department, the manager will have to excuse himself or herself completely from the hiring process. In addition, no manager is allowed under any circumstances to be the direct supervisor for their spouse, significant other, or their child. If a relative relationship or dating relationship is established after employment between employees who in a reporting situation described above, it is the responsibility and obligation of the manager/supervisor involved in the relationship to disclose the existence of the relationship to the Chief Operating Officer. The employees involved will be given an opportunity to decide who is to be transferred to another available position, if available, or who will resign from employment if the relationship continues and no other available positions exist. If that decision is not made within 30 calendar days, management will decide who is to be transferred or, if necessary, terminated from employment to avoid further violation of policy. In other cases where a conflict or the potential for conflict arises because of the relationship between employees, even if there is no line of authority or reporting involved, the employees may be separated by

37

reassignment or terminated from employment. Employees in a close personal relationship should refrain from public workplace displays of affection or excessive personal conversation.

H. TOBACCO USE POLICY For your heath and safety, NRG is a smoke-free/tobacco-free company and does not allow the use of tobacco products on NRG premises except when you are on break, lunch, or before or after your scheduled work period. If you wish to smoke or use smokeless tobacco products, you must do so outside of the buildings in the designated areas. Inappropriate disposal of tobacco products on the floor, in water fountains, etc. is prohibited and will not be tolerated. I. TELEPHONE USE The telephone is a very important part of our business in serving the customers ofNRG and it is critical for our customers to be able to reach us at any time during the day. Therefore, you are requested not to use the company telephones for personal calls except when necessary. Any such personal calls must he kept to a minimum and as brief as possible. Because courteous communications with our customers is such an important part of our service to them, always remember when using the telephone to be polite and helpful. Your proper use of the telephone will allow other incoming calls to be answered promptly, and will assist us in providing efficient service to our customers.

J. CELL PHONE POLICY

This policy about cellular phone usage applies to any device that makes or receives phone calls, leaves messages, sends text messages, surfs the Internet, or downloads and allows for the reading of and responding to email whether the device is company-supplied or personally owned. Company Owned and Supplied Devices or Vehicles An employee who uses a NRG supplied device or a NRG supplied vehicle is prohibited from using a cell phone, hands on or hands off, or similar device while driving, whether the business conducted is personal

or company-related. Thjs prohibition includes receiving or placing calls, text messaging, surfmg the
Internet, receiving or responding to email, checking for phone messages, or any other pm-pose related to your employment; the business; our customers; our vendors; volunteer activities, meetings, or civic responsibilities performed for or attended in the name of the company; or any other company or personally related activities not named here while driving. Use of company owned vehicles or devices for personal business is discouraged. Cell Phones or Similar Devices at Work NRG is aware that employees utilize their personal or company-supplied cellular phones for business purposes. At the same time, cell phones are a disttaction in the workplace and should be kept on silent or vibrate and its' use limited. To ensure the effectiveness of meetings, employees are asked to leave cell phones at their desk. Or, on the unusual occasion of an emergency or anticipated emergency that requires immediate attention, the cell phone may be carried to the meeting on vibrate mode. Employees who violate this policy will be subject to disciplinary actions, up to and including employment termination.

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K. E-MAIL/INTERNET/VOICE MAIL POLICY

Electronic Connnunication Equipment: E-Mail/Internet/Voice Mail Policy/Fax, and etc. NRG employees have access to various types of electronic communication technology consisting of e-mail, facsimile machines, voice mail, and the Internet. The purpose of having electronic communication technology available to our employees is for the benefit of enhanced efficiencies in connnunication and information for our internal and external customers. We highly encourage our employees to learn and use the NRG electronic connnunication technology. We understand that, from time to time, the NRG electronic connnunication technology may be used for personal reasons. And, like with the use of company phones, personal use must be held to a minimum and not interfere with productivity or the ability to get your job done as expected. Employees should have no expectation of personal privacy when they use company-owned electronic communication technology. NRG employees should always be mindful of the fact that documents or communications created on or communicated via NRG-owned systems are considered business records and the property of National Reimbursement Group Inc. As such, they may be subject to review by third parties through litigation or under other circumstances. Also, employees should be aware that some electronic communications, such as e-mails and computer files, may be retained on back-up tapes well after the employee deleted them from his/her computer. National Reimbursement Group Inc. reserves the right to review or monitor any employee communication sent or received on NRG owned electronic communication technology. NRG reserves the right to block an employee's use of the Internet during working hours. This could include total non-use of Internet or just access of certain sites. Passwords assigned to NRG employees for the use of any electronic communications systems are used to prevent unauthorized access by other employees and are to be held in confidence. Such passwords should not be construed, however, as creating an expectation of privacy for the employee who uses them. We expect all employees to use electronic communication technology in a professional manner. Abuse of electronic connnunication technology is not acceptable and will be subject to discipline, up to and including termination. Unacceptable uses include but are not limited to; sending jokes, profanity, chain letters; spreading rumors, misinformation, and complaints; communication that is offensive, threatening, or could be construed in any way as harassment; pornography and or "sex" sites; solicitations for information, services, or money as per our "No Solicitation" policy; sayings of any kind (except those promoting NRG services) that are part of an employee's automatic signature; violations of the rights of any person or company protected by copyright, trade secret, patent or other intellectual property, or similar Jaws or regulations, including, but not limited to, the installation or distribution of "pirated" or other software products that are not appropriately licensed for use by NRG; and, excessive personal use. Questions regarding appropriate use of NRG communication and information tools should be directed to yoirr supervisor, manager, or Chief Operating Officer. Unprofessional uses of the NRG electronic communication technology should be reported to your supervisor or manager immediately.
L. DRUG AND ALCOHOL POLICY

1. Introduction NRG is connnitted to providing its employees with a safe and drug-free workplace and promoting programs, which encourage high standards of employee health. In addition, NRG expects that employees in the performance of their duties will not unnecessarily endanger other employees, customers, and the general public. For these reasons, all employees are expected to be unimpaired by drng and alcohol while at work. Under no circumstances are employees to drive company vehicles while under the iniluence of alcohol or drugs. Employees driving company vehicles while under the influence of drugs or alcohol will be subject to immediate termination.

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Although NRG does not desire to intrude into the personal lives of its employees alcohol abuse and illegal drug use can negatively impact the workplace and NRG's ability to maintain a safe and productive work environment. Although employees make their own lifestyle choices, NRG will not accept the risks or performance problems which substance abuse can create. 2. Illegal Drugs No employee, agent, contractor, or visitor shall use or have in his or her possession illegal drugs during working hours or on NRG's property at any time, or sell, buy, or offer to sell or buy illegal drugs on NRG property, and no such substance shall be stored in employee vehicles on NRG' s premises. Additionally, no employee, or contractor shall report to work while under the influence of illegal drugs (i.e. any detectable level). Illegal drugs are any substance that the Federal Drug Enforcement Agency has defmed as a controlled substance. 3. Alcoholic Beverages
No employee, agent, contractor, or visitor shall possess, consume, or distribute alcoholic beverages on

NRG's property. No employee, agent, or contractor may report to work, at the start of a shift or after a meal or break period, with a .04 or higher breath alcohol level. 4. Employee Assistance Services If you have a drug or alcohol problem, you are encouraged to request assistance from the Employee Assistance Services. Participation in the Employee Assistance Services is confidential. Voluntary participation in a drug or alcohol rehabilitation program by itself will not subject you to disciplinary action by NRG. However, if you are found to have violated NRG policy, you will receive assistance only at NRG' s discretion. For more information, see the EAS Referral section. 5. Drug and Alcohol Testing
a. Pre-Employment Drug Screening

All applicants 16 years and older considered for employment will be asked to sign a consent/release form authorizing a drug screen test and the submission of its results to NRG. Applicants who refuse to sign the consent/release form will not be hired. Test results must be reported as negative in order for the applicant to be considered for employment. b. Random Drug and/or Alcohol Testing All employees in the safety sensitive positions will be subject to random drug testing during their employment at NRG. Failure to Submit To Drug Testing If the covered employee engages in conduct, which does not lead to a collection as soon as practicable after notification (which cannot exceed 24 hours), such conduct will be considered a refusal to test. Any employee refusing to submit to a random test, or attempting to adulterate a test, will be removed from his/her safety sensitive position and be subject to discipline up to and including termination.
c. Reasonab1e Suspicion

On reasonable suspicion of unlawful drug use, alcohol abuse, or deficient job performance possibly caused by drug or alcohol use, you may be required to submit to a drug or alcohol-screening test. Reasonable suspicion may be based on one or more factors including but not limited to; (I) observations at work such as observation of an employee engaged in drug related activity or exhibiting the physical symptoms of being under the influence of a drug or alcohol; (2) a pattern of abnormal or irrational behavior; (3) any sudden change in work performance including unexplained or excessive absenteeism, tardiness or workplace negligence; (4) an arrest or conviction of a drug related offense; (5) a report of illegal drug or excessive alcohol use; relative to work performance, provided by a reliable and credible source; or (6) any evidence that an individual has tampered with a drug or alcohol test during employment with the Company.

40

In instances of reasonable suspicion testing, a management representative will take the employee to the testing site and secure arrangements for the employee's travel home after the test. Employees awaiting reasonable suspicion test results during subsequent scheduled workdays will be reassigned to nonsafety sensitive work if available and appropriate. If non-safety sensitive work is not available, the employee will be suspended. If the test result is negative the suspension will be with pay. d. Post-Accident Drug Testing Company employees who are involved in a work related accident that results in either (a) personal injury requiring the inunediate services of a medical doctor or (b) property damage in excess of $2,500 will be required to submit to a substance screening for illegal drugs and blood/alcohol at the time of medical treatment, or if not injured, inunediately following tbe accident's occurrence. A positive drug test or a .04 or higher blood/alcohol level, or refusal to submit to such screening will be cause for discharge. In instances of post accident testing, the testing will be completed either on-site or at the health care provider's location. Employees awaiting post accident test results will not be allowed to work until results are provided.
e. Therapeutic Drug and Prescription Medication Use You must notify Operations Manager or Chief Operating Officer, before reporting to work, if you are using therapeutic drug and/or prescription medication that may alter your behavior, physical or mental ability to perform your job duties or may adversely affect, in any manner, your ability to perform your job duties.

f.

Workplace Searches NRG reserves the right to carry out reasonable searches for unlawful drugs, weapons, stolen property, and alcohol of you and your personal effects including items stored in NRG property (e.g., desks, credenzas, lockers, vehicles, etc.), and your personal vehicle when on NRG property without prior
notice.

g.

Compliance Failure to comply with any of the provisions of this section may result in discipline up to and including termination.

h.

Discipline An employee testing positive for illegal drugs or alcohol as the result of a random, reasonable suspicion, or post-accident drug screen will be subject to a step of discipline up to and including termination.

i.

Prohibitions National Reimbursement Group policy prohibits the following:

(1) Use, possession, manufacture, distribution, dispensation or sale of illegal drugs or drug paraphernalia on NRG premises, ofNRG business, in NRG vehicles, or during working hours.

(2) Distribution, dispensation, sale or improper use ( defmed as any violation of the prescribed dosage) of a legally prescribed controlled substance on NRG premises or NRG business, in NRG supplied vehicles, or during working hours. (3) Use, possession, manufacture, distribution, dispensation or sale of alcohol on NRG premises of NRG business, in NRG supplied vehicles, or during working hours. (4) Storing in a locker, desk, automobile, or other repository on NRG premises any illegal drug, drug paraphernalia, any illegally obtained controlled substance, or any alcohol.

41

(5) Being under the influence of an unauthorized controlled substance, illegal drug or alcohol on NRG premises or NRG business, in NRG supplied vehicles, or during working hours. "Being under the influence" of alcohol is defmed as a blood alcohol content of .05. "Being under the influence" of an illegal drug defmed as testing positive at a specified nglml level. "Being under the influence" of a legally prescribed but controlled substance is defmed as testing positive at a specified nglmllevel above the prescribed dosage amount. (6) Use of alcohol offNRG premises that adversely affects the employee's work performance, his
own or other's safety at work, or NRG's regard or reputation in the community.

(7) Possession, use, manufacture, distribution, dispensation or sale of illegal drugs offNRG premises. (8) Switching or adulterating any urine sample submitted for testing. (9) Refusing consent to testing or to submit a urine or blood sample for testing when requested by management. (lO)Refusing to submit to an inspection when requested by management. (ll)Failing to adhere to the requirements of any drug or alcohol treatment or counseling program in which the employee is enrolled. (12) Conviction, guilty plea, or other disposition of guilt under any criminal drug statute for a violation occurring in the workplace. (13)Arrest or conviction under any criminal drug statute under circmnstances which adversely affects NRG's regard or reputation in the community. (14)Failure to notify the immediate supervisor of any arrest or conviction under any criminal drug statute within five days of the arrest or conviction. (15)Failure to report to the immediate supervisor the use of a prescribed drug which may alter the employee's behavior or physical or mental ability. (16) Failure to keep prescribed medicine in the original container. (!?)Refusing to sigu a statement agreeing to abide by NRG's Alcohol and Drug Abuse Policy.
j. OTHER TESTING

NRG requires that every newly hired employee be free of alcohol or drug abuse. Each offer of employment shall be conditioned upon the passing of a blood and/or urine test for alcohol and drugs. NRG will not hire any applicant who fails to pass the pre-employment drug test. Whenever NRG suspects that an employee's work performance or on-the-job behavior may have been affected in any way by alcohol or drugs, or that an employee has otherwise violated this policy, NRG may require the employee to submit a urine and/or blood sample for alcohol and drug testing. An employee who tests positive for alcohol or drugs as a result of such a test will be in violation of this policy. NRG will afford applicants and employees subject to testing the opportunity, prior to testing, to list all prescription and non-prescription drugs that have been used in the last thirty days, and to explain the circumstances surrounding the use of such drugs. If the drugs listed are prescription medications, valid prescriptions for those drugs must also be submitted to the testing facility within 5 days following the test.

42

Applicants and employees subject to testing must sign, prior to testing, an approved form consenting to the testing and consenting to the release of the test results. All reports will be sent to the Operations Manager ofNRG. Whenever NRG suspects that an employee's work performance or on-the-job behavior may have been affected in any way by alcohol or drugs, NRG management may search the employee, the employee's desk, the employee's locker, or other NRG property under the control of the employee, as well as the employee's personal affects or automobile on NRG property.

M. REFERRAL TO EAS SUBSTANCE ABUSE

If you self-refer yourself to the Employee Assistance Program (EAS), and are required to take time off work to participate in a program because of alcohol or substance abuse, you may be eligible to use your time-off benefits. Full-time employees so electing to use their tirue-off benefits must use them in the following order: PTO and short term disability. Prior to your return to work, you will be required to provide a release to return to work from the EAS. If you are required to enter the EAS because of a positive drug screen or performance problem related to alcohol or substance abuse and are required to take tirue off work to participate, you will not be eligible to use your time off benefits. In addition, you will not otherwise be compensated for taking the tirue off; and you may be relieved from work duties without pay until you successfully complete the treatment program. During the treatment period, you are eligible to continue all other benefits not in the above described. You must pay the appropriate premium(s) to continue benefit coverage. When you successfully complete the (EAS), you may be reinstated to your job. In such an event, your reinstatement may be conditioned on your relevant, multiple dmg tests without prior notice at any time during the next 36 months. Any positive test or failure to comply with the recommended EAS program during this time may result in your immediate termination of employment. Testing is at discretion of EAS orNRG.
N. UNLAWFUL HARASSMENT PROHIBITED

POLICY OBJECTIVE The Company intends to maintain a work environment in which every employee is treated with respect and which is free from all forms of unlawful harassment, including conduct that creates an illegal, hostile work enviromnent. The Company intends to provide a workplace enviromnent that is free from harassment based on race, color, religion, sex, national origin, age, veteran status, or disability. APPLICABILITY This policy applies to all employees, applicants, contractors and business visitors. POLICY
I. Offensive Conduct Prohibited

a. Sexual Harassment: Sexual harassment will not be tolerated at the Company. Sexual advances, requests for sexual favors, or other verbal or physical actions of a sexual nature that have the purpose or effect of creating an illegal, hostile work environment will not be permitted. b. Other Harassment: Harassment based on race, color, religion, national origin, age, veteran status, disability or any other unlawful harassment is also prohibited. Discriruinatory intimidation or conduct that has the purpose or effect of creating an illegal, hostile work environment will not be tolerated at the Company. c. Supervisor/Manager Conduct: Supervisors and managers are responsible for maintaining a work environment free from unlawful harassment and must report anything they hear or observe that may constitute a violation of this policy. No supervisor or manager has the authority to condition any

43

tangible job benefit on an employee's acceptance of any unlawful harassment and threats of any such harassment must be reported immediately. If any employee believes that he or she has been deprived of a tangible job benefit (such as a significant change in employment status, like discharge or demotion), because the employee refused to cooperate with unlawful harassment, he or she should report this action immediately. d. Examples: Prohibited conduct under this policy encompasses a broad range of verbal and physical actions. Examples include, but are not limited to, engaging in sexual favoritism or retaliation based on the granting or refusal of sexual favors, making sexually offensive or suggestive jokes or remarks, subjecting another employee to unwelcome pressure for dates and making derogatory comments based on a person's race, national origin, sex, religion, color, disability, or veteran's status. 2. Reporting of Illegal Harassment Required a. Any person who believes that he or she has been subjected to words or conduct that violate this policy, or who learns of such offensive words or conduct even if not personally involved, should report such, preferably in writing, as soon as possible to one of the following: Chief Executive Officer (CEO) Chief Operating Officer (COO) Head of his or her Department His or her Immediate Supervisor If the individual believes that any of these people are responsible for the words or conduct that violates the policy then that person is not the appropriate person with whom to report the incident. Therefore in that situation, please select an alternate person from the list with whom to report the alleged violation. The complaint should include the material details of the incident or incidents, the names of the individuals involved and the names of any witnesses. The COO or an alternate designee will promptly investigate all complaints of violations of this policy. Corrective action will be taken as determined by the Company to be appropriate under the circumstances and subsequently communicated to those individuals with a need to know. All complaints of violations of this policy are considered confidential and all parties involved in the complaint or investigation are expected to take reasonable steps to protect the privacy of the individuals involved. Penalties Violation of this policy by an employee, whether directed at another employee, an applicant for employment, a contractor or a business visitor, is grounds for disciplinary action, up to and including immediate termination. No Retaliation No one who makes a complaint of unlawful harassment in good faith, or who provides information for a complaint investigation in good faith, will be retaliated against by loss of a tangible job benefit or otherwise, even if unlawful harassment is not proven. However, if you make a false or frivolous accusation of unlawful harassment or provide inaccurate or misleading information in connection with a complaint investigation, you may be subject to discipline, up to and including discharge.
0. Workplace Violence Policy

b. c.

d.

3.

4.

NRG is committed to working with its employees to maintain a work environment free from violence, threats of violence, harassment, intimidation, and other disruptive behavior. While this kind of conduct is not pervasive at our company, no company is immune. Violence, threats, harassment, intimidation, and other disruptive behavior in our workplace will not be tolerated; that is, all reports of incidents will be taken seriously and will be dealt with appropriately. Such behavior can include oral or written statements, gestures, or expressions that communicate direct or indirect threat of physical harm. Individuals who commit such acts may be removed from the premises and may be subject to disciplinary action up to and including termination, criminal penalties, or both.
We need employee cooperation to implement this policy effectively and maintain a safe working environment. Do not ignore violent, threatening, harassing, intimidating, or other disruptive behavior. If you observe or experience such behavior by anyone on company premises, whether he or she is an

44

employee or not, report it immediately to a supervisor or manager. Supervisors and managers who receive

such reports should seek advice from the Humau Resource Department regarding investigating the incident aud initiating appropriate action.
P. RESIGNATION AND TERMINATION

If you wish to leave your employment with NRG, you must provide notice of resignation to your innnediate supervisor prior to the effective date, stating the specific reason(s) for the resignation. Notice should be commensurate with your job responsibilities and under no circumstance should it be less than 2 weeks. Failure to give such notice will be noted on your termination record. If employee leaves contrary to this resignation policy, he/s he may not be eligible for any scheduled vacation time, and/or re-employment. Termination of employment is an inevitable part of personnel activity within any orgauization, and many
reason for termination are routine. Below are examples of the most common circumstances under which

employment is terminated: *Resignation- voluntary employment termination initiated by au employee *Discharge- involuntary employment termination initiated by the organization Since employment with NRG is based on mutual consent, both the employee and NRG have the right to terminate employment at will, with or without cause, at the time. Employee benefits will be affected by employment termination in the following marmer. All accrued, vested benefits that are due and payable at termination will be paid. Some benefits may be continued at the employee's expense if the employee so chooses. The employee will be notified in writing
of the benefits that may be continued and of the terms, conditions, and limitations of such continuance.

Q. EXIT PROCEDURE
If you resign, retire, or are discharged or laid off, you may be required to tum in any NRG owned property or working materials to your supervisor no later than your final work day. You will be asked to participate
in an exit interview with your supervisor and/or a member of Human Resources. In cases involving

termination, you will be escorted to your work area to gather your personal belongings and escorted off NRG's premises.
R. ANTI-TRUST POLICY

Antitrust laws are designed to preserve and foster fair and honest competition within the free enterprise system. To accomplish this goal, the language of these laws is deliberately broad, prohibiting such
activities as "unfair methods of competition" and agreements "in restraint oftrade. 11 Such language gives

enforcement agencies the right to examine many different business activities to judge their effect on
competition.

COMPETITIVE PRACTICES/ANTITRUST LAWS The Company competes vigorously, but fairly. As we expand product lines, all employees mnst be aware of the applicable antitrust laws and the statutory restraints on competitive practices. These laws, which at the federal level include the Sherman, the Clayton, the Robinson-Patman and the Federal Trade Commission acts, all seek to advance and maintain the free enterprise system, which the Company endorses. Price fixing, restrictive agreements, boycotts, tieing arrangements, exclusive or reciprocal dealings, monopolization, price inducements and discriminatory allowances are ahnost always illegal. Employees should scrupulously avoid any conduct, which may be construed as a violation of the antitrust laws. Violation of the antitrust laws can subject both the Company and individual employees to criminal as well

45

as civil liability. For willful civil violations, triple damages can be assessed. Foreign sales and the conduct of our business in foreign countries also require compliance with their business competition laws. Below is a general guide to compliance with the federal antitrust laws. The Legal Department should always be consulted before engaging in any business practice that may involve antitrust implications. These laws are not always clear and court interpretation and regulatory enforcement frequently change. Relationships with Competitors Discussions with competitors. You may never, except where specifically authorized by the government or by an approved cooperative business agreement (e.g. joint venture; teaming agreement), discuss (directly or indirectly) with a competitor, any of the following information not already in the public domain:
Prices;
Costs;

Profits; Product or service offering; Terms and conditions of sale; Deliveries; Production facilities or capabilities; Production or sales volume;

Market Share; Decisions to quote or not to quote; Customer or supplier classification;

allocation or selection

Sales territories; Distribution methods or channels; or

Potential acquisitions

Meetings with Competitors; Professional Societies and Trade Associations. Meetings with competitors are troublesome because they too often give appearance of impropriety. However, in the ordinary conduct of business, contact with competitors can be expected to occur and, when properly controlled, is acceptable in carrying out lawful business activities.

To avoid any appearance of impropriety, you should avoid meeting with a competitor outside of a
controlled environment. A hotel room, a bar, on a golf course or other informal meeting places is not

considered controlled environments. Contact with competitors in an uncontrolled environment cannot always be avoided (e.g., when entering or
leaving the office of a customer). When chance meetings occur, limit conversations to the exchange of

mere pleasantries. Avoid business talk of prohibited subjects. Attending trade shows, trade association meetings or professional gatherings which employees of competitors also attend is both legal and acceptable to further legitimate business interests. Since such meetings may be treated with suspicion by some, including the U.S. Department of Justice, and may imply
that collusive activities occur, thus violating the antitrust laws, your membership in trade associations or

participation in their meetings should be carefully considered. In general, participation should be limited to nationally recognized trade associations that have professional staffs knowledgeable of the antitrust issues
facing such associations.

The content of and discussions at meetings in which competitors are in attendance should be carefully controlled by adhering to a prescribed meeting agenda and maintaining minutes recording the activity conducted at the meeting. You should never discuss Company business except as it may relate to the specific issues addressed on the meeting agenda. If a competitor brings up business topics of a prohibited nature, the dialogue should be cut short by a reminder to the competitor that it is strict Company policy not to discuss such topics. If the competitor persists with such activity, you and any other employees of the
Company also in attendance must leave the meeting immediate1y in such a manner as to draw the attention

of others in attendance to your departure. You should report any such incident to the Legal Department. Selling To Competitors Many companies have multiple product/service lines. In some lines the Company may be a competitor and in other lines a customer. Although it is permissible to do business with a competitor who is also a customer or supplier, such relationships have many legal pitfalls that must be reviewed carefully. Doing
business with a competitor is permissible so long as there is no action taken, conscious or otherwise, that

has the appearance of, or can be construed by another, as being collusive. You are permitted to communicate with or meet with competitors in controlled situations so long as the communications and

46

meetings are relevant and appropriate to a bona fide prospective or existing buyer-seller relationship. You should seek advance advice of the Legal Department with regard to these special situations. When the Company is both buying from and selling to the same customer/supplier, our management should take steps to avoid violations such as reciprocal dealings. One way to reduce this risk is to restrict communications between Company people who are buying from and those who are selling to the same customer/supplier.
Unfair Competition Against Competitors You must avoid actions taken against a competitor that are unethical or which constitute unfair competition. The following illustrates some common forms of unfair competition:

When selling to a customer, or dealing with a supplier, if they have a firm contractual commitment with a competitor, action by us to induce them to break their contract would be unfair competition and could be construed as unlawful interference with contractual relations; Stealing or misappropriating a competitor's confidential information (e.g., through industrial espionage, hiring away a competitor's personnel to disclose such information, obtaining such confidential information without consent of a competitor) is unfair competition (such conduct can also be grounds for civil or criminal actions against the Company and/or its employees); Malicious tampering with a competitor's product, collecting and destroying its product literature, harassing a competitor by fictitious inquiries, coercing or intimidating its suppliers or passing off its products, as the products of some other firm are unfair competition.
Deceptive Trade Practices Statements made by employees regarding the capabilities of the Company's products, either verbally or in advertising brochures and literature describing our products, product samples, demonstrations and exhibits, must be accurate and complete, with disclosure of relevant information that keeps such statements from being misleading. Always be guided by the fact that tbe Company is bound by the claims we make about our products. All statements must be true and within the bounds of good taste and must be backed by documentation of the claims of superiority to the products of competitors. Although factual comparisons of the Company's products with a competitor's products are perfectly permissible, it is unlawful and against Company policy to make false remarks about competitors, their products or services. Relationships With Suppliers Supplier relationships are valuable and must be protected. When dealing with suppliers, certain activities must be avoided for both ethical and legal reasons.

You should not have any relationship with a supplier, fmancial or otherwise, which has the appearance of, or may cause, a conflict of interest or other impropriety. When dealing with suppliers, it is important to obtain the best possible (but lawful) price, terms and conditions. For example, you may bargain diligently with respect to price, but you may not lie about receiving a more favorable price or terms from another supplier. You should not attempt to develop any business relationships through reciprocity. (Reciprocity is the use of our buying leverage to induce others to buy Company products.) It is legal to sell to a supplier so long as the supplier is not compelled to deal with us because of our buying leverage. To avoid the appearance of reciprocity, it is best that marketing and purchasing personnel not trade information as to who is buying from and who is selling to the Company. If you are approached by either a supplier or a customer concerning any form of reciprocal agreements, you should inform the Legal Department. Care must be taken about agreements obligating us not to buy from another. Such boycott activity may be unlawful.
Relationships With Customers The Company's customer relationships are valuable and all dealings with customers must be carried out fairly, ethically and legally. Activities such as the following are not only unfair and unethical, but illegal:

47

In dealing with a customer, you should avoid actions or discussions which might be construed as a form of resale restriction, such as resale price maintenance, which would liinit a customer1s freedom of choice in

setting its own policies or prices for the resale of Company products (we may, however, publish manufacturer s suggested retail prices "MSRP"); It is unlawful for you to tie the sale or lease of one Company product as a condition to the sale or lease of another Company product. Forbidden tieing arrangements also extend to service and warranty
1

arrangements;

To avoid the appearance of any reciprocity between the Company and a customer, whenever a customersupplier relationship may exist, do not negotiate with a customer by reference to the Company's past or expected future purchases from such customer/supplier; Although the law permits the Company to do business with anyone it chooses, the right to refuse to deal with a current or potential customer is not without limitations. The Company may refuse to deal with any customer when such decision has been made unilaterally and not in furtherance of any anti-competitive activity. Any refusal to deal with a customer after consultation with other customers may be an illegal boycott. Although the problems inherent with the refusal to deal with new customers are not severe, you should consult the Legal Department when terminating an existing relationship with a customer of any size; Terminating a distributor agreement is a serious matter that should only be considered for legal cause and only after consultation with the Legal Department; So long as there is no potential for a monopolistic position, you are permitted to sell exclusively to one
customer. Resale restrictions limiting territorial coverage or re-marketing activities of an exclusive

customer should be avoided. Avoid exclusive dealing arrangements which could suggest that the Company is prohibited or restraining a customer rrom buying or handling competitive products. You may not charge different prices to competing customers purchasing a product of like grade and quality
where the effect of such price discrimination may be to lessen substantially or injure competition. You may not grant a promotional allowance, service or facility to one customer upon terms not accorded to all

competing customers on substantially equal terms. The issues of price discrimination are complex and all questions with respect to the pricing of products must be reviewed with the Legal Department before implementation; You should not price below cost. This may be construed as predatory pricing, an antitrust violation;
You may not pay any brokerage fees or commissions to any customer or to any agent or intermediary

controlled by the customer. Brokerage fees or commissions may be paid only to an independent agent
providing a beneficial service for a customer;

Certain acts you commit under the antitrust laws are completely indefensible no matter how good a reason
may have existed when the violation was committed. These indefensible acts are known as "per se 11

violations; they include the following prohibited conduct:

Price Fixing - any agreement or understanding between competitors with respect to raising, lowering or

stabilizing prices. Any agreement or understanding between a supplier and its customers as to the price at which the customers may resell the goods purchased rrom the supplier also constitutes price fixing.
Limitation of Supply- any agreement or understanding between competitors to restrict the volume of goods they will produce or make available for sale. Allocation ofBusiness - any agreement or understanding that each competitor will confine its business to a different geographical area, to a different line of business or to different customers or classes of customers.
Boycott - any agreement or understanding between a supplier and a customer or between a customer and its

supplier that they will not sell to, or purchase rrom, particular outsiders.
Tieing - any arrangement whereby a seller compels the buyer of a product to buy a different one (the tied product) from the seller.

S. RECORDS RETENTION POLICY

48

The corporate records of National Reimbursement Group Inc. and its subsidiaries (hereafter the "Company'') are important assets. Corporate records include essentially all records you produce or use as
an employee, whether paper or electronic. A record may be as obvious as a memorandum, an e-mail, a

contract, or something not as obvious, such as a computerized desk calendar, an appointment book or an
expense record.

The law requires the Company to maintain certain types of corporate records, usually for a specified period of time. Failure to retain those records for those minimum periods could subject the Company to penalties and fines, or seriously disadvantage the Company in litigation. The Company expects all employees to fully comply with any published records retention or disposal policies and schedules, provided that all employees should note the following general exception to any stated disposal schedule: If you believe, or the Company informs you, that Company records are relevant to litigation, or potential litigation (i.e., a dispute that could result in litigation), then you must preserve those records until the Legal Department determines the records are no longer needed. That exception supersedes any previously or subsequently established disposal schedule for those records. If you believe that exception may apply, or have any question regarding the possible applicability of that exception, please contact the Legal Department. From time to time the Company establishes retention or disposal policies and schedules for specific categories of records in order to ensure legal compliance, and also to accomplish other objectives, such as preserving intellectual property and cost management. Company record schedules may require that certain records scheduled for disposal be reviewed by the NRG archivist in advance of their disposal. The archivist, in consultation with the legal department, may determine that the records are of permanent value and should be retained in the NRG archives. Several categories of documents that bear special
consideration are identified below. While minimum retention periods are suggested, the retention of the

documents identified below and of documents not included in the identified categories should be determined primarily by the application of the general guidelines affecting document retention identified above, as well as any other pertinent factors. (I) Tax Records. Tax records include, but may not be limited to, documents concerning payroll, expenses, proof of deductions, business costs, accounting procedures, and other documents concerning the Company's revenues. Tax records should be retained for seven years from the date of filing the applicable return. (2) Employment Records/Personnel Records. State and federal statutes require the Company to keep certain recruitment, employment and personnel information. The Company should also keep personnel files that reflect performance reviews and any complaints brought against the Company or individual employees under applicable state and federal statutes. Employment and personnel records should be retained for six years. (3) Applications. All applications and related material for a specific job are to be retained for two years after the position was filled. (4) Background checks. All background checks on applicants, new hires and/or current employees are to be retained for six years in a secured location only accessible by the Chief Operating Officer and Director of Payroll/Accounting. Background checks are to be kept separate from other Employment records/personnel records. (5) Board and Board Committee Materials. Board and shareholder meeting minutes should be retained in perpetuity in the Company's minute book. The Company should retain a scanned, electronic copy of all Board and Board Committee materials in the NRG archives. (6) Legal Files. Legal counsel should be consulted to determine the retention period of particular documents, but legal documents should be maintained for a period often years. (7) Marketing and Sales Documents. The Company should keep fmal copies of marketing and sales documents for the same period of time it keeps other corporate files, two years plus current year to date. An exception to the two-year policy may be the sales invoices, contracts, leases, licenses and

49

other legal documentation. These documents should be kept for three years beyond the life of the transaction docmnented. (8) Contracts. Final, execution copies of all contracts entered into by the Company should be retained. The Company should retain copies of the final contracts for five years beyond the life of the agreement. Only contracts determined to be of major legaVhistorical significance should be forwarded to the NRG archives for permanent retention. (9) Electronic Mail. E-mail is like any other type of record, which should comply with above listed time frames on the specific categories of documents. Employees have a tendency to retain e-mails long beyond their useful life. This creates unnecessary expense for the Company, as it requires larger than necessary file space to store these e-mails. The Company has a strong interest in regular permanent deletion of employee e-mails. The Company will delete all employee e-mails that are older than six (6) months from the date the employee received e-mail. This will only apply to e-mails in the inbox, delete box, or sent box. (lO)OSHA Records. Federal law requires that the Company retain all OSHA records for five years, plus the current year. Failure to comply with Document Retention Policy may result in discipline action against employee.
T. CORPORATE GIFT POLICY

Company employees are approached by vendors on a routine basis with gifts and entertainment. It is a normal way of doing business. Modest gifts and entertainment can be accepted if they are reasonable compliments to a business relationship. Employees should never exploit their position in the company to solicit vendors for personal gifts or favors in exchange for preferential treatment. Employees at all times also need to avoid the appearance of impropriety when receiving any gifts from vendors. The company has concerns that these types of gifts can influence employees to make improper decisions as it relates to company resources. In order to provide some guidelines to employees so that this doesn't have a negative affect on the company and also provide other guidance it has been determined that we need to establish a corporate gift giving policy. Employees are allowed to accept gifts and entertainment from vendors as long as the value of the gift or entertainment is under $150. Gifts or entertainment over $150 but less than $250 are required to be reported to Chief Operating Officer. All gifts or entertainment over $250 have to be approved by the Chief Operating Officer before being accepted. As always, use common sense in making decisions. If you have any doubt on whether or not to accept a gift from a vendor, then consult the Chief Operating Officer.

U. RIGHT TO INSPECT POLICY

NRG reserves the right to inspect the property and person of any individual or vehicle on NRG property. This right includes, but is not limited to, the inspection of parcels, packages, purses, lunch boxes, briefcases, lockers, work stations and desks. Whenever it deems appropriate, NRG may use trained dogs to detect illegal drugs and/or other material possessions within personal and/or NRG property or anywhere on NRG premises.

V. SOFTWAREPOLICY

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To prevent computer viruses from being transmitted through the company's computer system, unauthorized downloading of any software is strictly prohibited. Only software registered through NRG may be downloaded. Employees should contact the system administrator if they have any questions.

W. PATIENT AND EMPLOYEE PRIVACY POLICY

Information in our files concerning our patients is highly confidential. Information necessary to file medical claims with thlrd party payers may be released to the authorized representative of these companies. Phone calls to the Business Office regarding incidents of an EMS operations nature or patients that we may be currently carrying en-route should be referred to the EMS Agency Director. All requests from other parties requesting information MUST be in writing. The only exception to this rule is if the request comes from the Insurance Company and we already have the Insurance Company noted in Saber. You may then send information without a written request.

Requests received for information from our files from attorneys must contain a written authorization from the patient and payment for copies. Each employee will be made aware of all HIPAA laws. Each employee understands that breaking NRG's Privacy policy as defined in NRG's HIPAA training guide is a terminable offence. Each employee must sign a form stating they are aware, have been informed and will abide by the NRG privacy policy and the HIPAA laws.
Employee: We must take every precaution to protect our employee's privacy. Anyone wishing to receive a reference on an employee or previous employee should be directed to the Chief Operating Officer. References are given only after we receive a written request. We do not give out home phone numbers or addresses llllless otherwise required by law. Should any call be received in the Business Office conceruing an employee of NRG or National Reimbursement Group Service, the call should be directed to the Chief Operating Officer.

X. PERSONNEL RECORDS POLICY

It is vital that personnel records contain accurate and up-to-date information about every employee. Any change in marital status, number of children or other dependents in the immediate family must be reported to the HR Coordinator. This information affects the amount of an employee's payroll deduction for federal withholding tax, insurance premiums and benefits. Any change in address or telephone should also be reported.

An employee's personnel record is kept confidential, to the maximum extent protected by law. Outside parties or agencies are not provided with information in your personnel file unless specifically authorized by you in writing, or as required by law. Personnel records are the sole property ofNRG.

Y. SOCIAL MEDIA POLICY Purpose NRG recognizes that the internet provides unique opportunities to participate in interactive discussions and share information on particular topics using a wide variety of social media, such as Facebook, Twitter, blogs and wilds. However, employees' use of social media can pose risks to NRG's confidential and proprietary information and can jeopardize the company's compliance with business rules and laws.

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To minimize these business and legal risks, to avoid loss of productivity and distraction from employees' job performance and to ensure that the company's IT resources and communications systems are used only for appropriate business purposes, NRG expects its employees to adhere to the followiug guidelines and rules regardiug use of social media. Compliance With Related Policies and Agreements Social media should never be used iu a way that violates any other NRG policies or employee obligations. If your post would violate any of NRG's policies in another forum, it will also violate them in an onliue forum. For example, employees are prohibited from usiug social media to: Harass other employees iu any way !hat affects the work environment. Circumvent policies prohibitiug unlawful discrimination agaiust current employees or applicants for employment. Managers are prohibited from visiting social media sites of an applicant until after a face-to-face interview with applicant. Employees who violate NRG policies will be subject to discipliue, up to and iucluding termination of employment. All discipliue resultiug from violation of this social media policy has to be approved by NRG's General Counsel.
We recognize that employees occasionally may desire to use social media for personal activities at the office or by means of the company's computers, networks and other IT resources and communications systems. We authorize such occasional use so long as it does not involve unprofessional or inappropriate

content and does not interfere with your employment responsibilities or productivity. While using social media at work, circulating chaiu letters or other spam is never permitted. Circulatiug or postiug commercial, personal, religious or political solicitations, or promotion of outside organizations unrelated to company business are also prohibited.
No Expectation of Privacy All contents of NRG's IT resources and communications systems are the property of the company. Therefore, employees should have no expectation of privacy whatsoever in any message, files, data, document, facsimile, telephone conversation, social media post, conversation or message, or any other kind of information or communications transmitted to, received or printed from, or stored or recorded on the company s electronic information and communications systems.
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You are expressly advised that iu order to prevent misuse, NRG reserves the right to monitor, iutercept and
review, without further notice, every employee's activities using the company's IT resources and

communications systems, iucludiug but not limited to social media postings and activities. This might
include monitoring, interception, accessing, recording, disclosing, reviewing, retrieving and printing of transactions, messages, communications, postings, log-ins, recordings and other uses of the systems as well

as keystroke capturiug and other network monitoriug technologies. Respect Your Co-Workers and OtherNRG Stakeholders
Do not post anything that your co-workers or NRG's customers, business partners, suppliers, or other NRG's affiliates would fmd offensive, including ethnic slurs, sexist comments, discriminatory comments,

iusults or obscenity. Make it clear iu your social media postiugs that you are speaking on your own behalf. You are personally responsible for what you communicate iu social media. Remember that what you publish might be available to be read by the masses (iucludiug the company itself, future employers and social acquainttmces) for a long time. Keep this iu mind before you post content.

Z. WORKPLACE ETIQUETTE

NRG strives to maiutain a positive work environment where employees treat each oilier with respect and courtesy. Sometimes issues arise when employees are unaware that their behavior iu the workplace may be disruptive or annoying to others. Many of these day to day issues can be addressed by politely talking with

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a co-worker to bring the perceived problem to his or her attention. In most cases, common sense will dictate an appropriate resolution.
NRG encourages all employees to keep an open mind and graciously accept constructive feedback or a request to change behavior that may be affecting another employee's ability to concentrate and be productive. The following workplace etiquette guidelines are not necessarily intended to be hard and fast work rules with disciplinary consequences. They are simply suggestions for appropriate workplace behavior to help everyone be more conscientious and considerate of co-workers and the work environment. Please contact the Operations Manager if you have comments, concerns or suggestions regarding these workplace etiquette guidelines. Return copy machine and printer setting to their default settings after changing them Replace paper in the copy machine and printer paper trays when they are empty Retrieve print jobs in a timely marmer and be sure to collect all your pages Keep the area around the copy machine and printers orderly and picked up Be careful not to take or discard other's print jobs or faxes when collecting your own Avoid public accusations or criticism of other employees. Address such issues privately with those involved or your supervisor. Try to minimize unscheduled interruptions of other employees while they are working Communicate by e-mail or phone whenever possible, instead of walking unexpectedly into someone's office or workspace Be conscious of how your voice travels, and try to lower the volwne of your voice when talking on the phone or to others in open areas Keep socializing to a minimum and try to conduct conversations in areas where the noise will not be distracting to others Minimize talking between workspaces or over cubicle walls. Instead, conduct conversations with others in their workspace Try not to block walkways while carrying on conversations Refrain from using inappropriate language (swearing) that others may overhear. Avoid discussions of your personal life/issues in public conversations that can be easily overheard Monitor the volume when listening to music, voice mail or a speakerphone that others can hear Clean up after yourself and do not leave behind waste or discarded papers

AA. POLICY ON BUSINESS OFFICE HOURS

Normal operating hours for NRG are 8:00 a.m. to 5:00 p.m. Monday through Friday, except for the Customer Service Call center which are 7.a.m. to 7 p.m.. If the employee is unable to work during these hours, or if it is necessary to work additional hours, the employee must notifY his/her immediate supervisor. Overtime: Should it be necessary for the employee to work overtime, the rate of pay will be time and a half. Time and a half is paid only for actual physical overtime worked over 40 hours per week. Employees, who accumulate more than 45 hours per week, should have approval of the Operations Manager. Lunch: Is generally observed between the hours of II :00 and 2:00. It is requested that lunches, either taken in or out of the office, be talcen during this time Employees should make every effort to take a lunch break away from their desk and, if possible, should not perform any work during their lunch break.

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Should the employee choose to go out for lunch, the employee will clock out/in and limit the lunch to one hour. If extra time is needed for errands, etc., the employee should obtain approval from his/her immediate supervisor BEFORE the lunch break. Breaks: Are to be taken at the scheduled times. Breaks are 15 minutes long and the employee is to make all personal phone calls or handle any personal business during this time. The employee is not to leave the premises during this time. Lock-Up: If you are the last person to leave the Business Office, the responsibility for securing the building for the night is yours. You must make sure you are 1he last person to leave. All doors must be locked and the alarm must be activated.
BB. OFF-DUTY ACCESS

For the safety and security of clients and personnel, except during a reasonable period of time before or after a scheduled shift, or unless visiting as a client, an employee is not to remain or return to the Company property for any purpose unless the employee is either on duty or scheduled for work. Exceptions will be allowed for the purpose of attending to Company business in administrative and supervisory offices, such as picking up paychecks or submitting insurance forms, etc. Due to safety and insurance considerations, an employee may not have visitors while working or while on Company property. Non-employees are not allowed in restricted areas unless under the supervision of an employee. Trespassing is prohibited. If someone drives you to work and picks you up, please have them wait for you outside in the staff parking area. These rules will be strictly enforced. Violations will be considered grounds for disciplinary action, up to and including discharge.
CC. SABOTAGE POLICY

Knowing and/or willful malicious sabotage of the company, its property, or its employees, either physically or verbally, will result in the following: A. First offense: Financial reimbursement, if applicable and suspension or termination. B. Second offense: Financial reimbursement, if applicable, and termination.
DD. FALSIFICATION OF RECORDS AND MAKING FALSE STATEMENTS POLICY

Any deliberate attempts to falsify any documents and/or deliberately making false statements may result in immediate termination of employment.
EE. LEGAL ACTION NOTIFICATION POLICY Any employee that is arrested, convicted of a crime, whether felony or misdemeanor, or has any license or certification revoked or rescinded, must report such to their Operations Manager or Chief Operating Officer within 5 (five) days of the action being taken. Failure to do so may result in immediate termination.

FF. OPEN DOOR POLICY Misunderstandings or conflicts can arise in any organization and should be resolved before serious problems develop. Most incidents will resolve themselves naturally. Should a situation develop that you believe is detrimental to you or to National Reimbursement Group, however, National Reimbursement Group encourages you to feel free to discuss it with the Operations Manager as soon as possible. If the problem is still not resolved or is awkward or sensitive circumstances prevent you from discussing your problems with your Operations Manager, you should ask to see the Chief Operating Officer.

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SECTION VI
CODE OF CONDUCT
PURPOSE

National Reimbursement Group Inc. (NRG) continually strives to provide accurate ambulance coding and billing, efficient processes to control flows of claims, and collect all money owed to our clients. We will do business only with agencies that conform to govermnent regulations and will incur excessive cost in our pursuit to handle all business transactions in absolute compliance with all govermnent and ethical regulations. This requires the highest standard of conduct from all of our staff members. This philosophy of total compliance is the foundation of all that we do, and consistent with that philosophy, National Reimbursement Group Inc. has approved and adopted this Code of Conduct.
POLICY

A.

STATEMENT OF COMMITMENT

National Reimbursement Group Inc. has been, and continues to be, committed to conducting our activities in full compliance with all federal, state and local laws. Our reputation for quality service and excellent patient care and customer service has been achieved by the personal integrity, good judgment and common sense of our staff members. Staff members are expected to demonstrate appropriate ethical behavior when conducting activities with patients and their families, fellow staff members, suppliers, vendors, consultants and those with whom we do business. We commit to provide each staff member the policies, procedures and guidelines to be aware of his/her responsibility in ensuring compliance with this Code of Conduct. B. PURPOSE OF THE COMPLIANCE PLAN

The Compliance Plan provides the approach to guide our conduct in all that we do. It is intended to provide overall guidance for us in providing EMS billing services in a legal, ethical, and appropriate manner; however, it does not supersede the more specific policies of National Reimbursement Group Inc .. The Compliance Plan is a supplement to the standards of conduct as presented in general staff member policies and procedures, such as in our personnel handbook, where applicable. Each staff member and all supervisory and administrative personnel should read and understand the Code, and subscribe to its standards and procedures. This Code of Conduct does not address every aspect of National Reimbursement Group Inc. activities and the applicable legal issues they may entail. Because of changes in National Reimbursement Group Inc. structure and operations or changes in regulatory requirements, the document is inherently subject to change. Each staff member, supervisor, and manager should participate in an initial training program explaining the Code. New staff members should receive compliance training during new staff member
orientation. Annually, each staff member may receive a minimum of one hour of compliance training.

Upon completion of each training session or orientation, staff members should be required to sign a statement of participation and attendance. Each staff member is expected to be familiar with the applicable laws and regulations that govern the matters set forth in the Code of Conduct as it pertains to his or her duties. That familiarity should be part of every staff member's job performance and a regular part of that staff member's review.

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C.

STANDARD OF COMPLIANCE WITH LAWS

I. National Reimbursement Group Inc. personnel, including, where applicable, managers, staff members, agents, consultants and other representatives, should conduct their activities in compliance with applicable laws, rules and regulations. If there is reasonable doubt as to the appropriateness of an activity, staff members should seek advice within the National Reimbursement Group Inc. chain of command. Staff members may also contact the National Reimbursement Group Inc. Compliance Officer at any time ifthey have questions about the appropriateness of any particular action or course of conduct. 2. Policies and procedures regarding certain laws and regulations important to the provision of health care services are a part of the Compliance Plan. a) Patient Rights

National Reimbursement Group Inc. is dedicated to protecting its patients' personal privacy and confidentiality of information consistent with National Reimbursement Group Inc.'s mission, applicable laws (including HIPAA, where applicable) and quality standards. b) Disclosure

National Reimbursement Group Inc. and its agents will deal honestly and fairly with patients, community members, vendors, competitors, mutual aid companies, payers and other outside contractors. Communication and disclosure information should be clear, accurate and sufficiently complete. Financial and operational reports should be prepared in accordance with applicable rules and regulations and prepared within National Reimbursement Group Inc.'s normal system of accountability. c) Patient Billing

National Reimbursement Group Inc. will deal honestly with all payors (e.g., self-pay, insurance companies, HMOs, Medicare, Medicaid, etc.). Claims submitted to Medicare and other govermnental and private payors should be complete and accurately reflect the services rendered. National Reimbursement Group Inc. should submit claims for services that are supported by the necessary documentation, while maintaining prompt and proper billing practices.
Billing issues should be resolved according to applicable laws, regulations, organizational policies and, where applicable, payor contracts. Questions regarding patient billing should be resolved expeditiously. If staff members are unsure of the proper response to a question or inquiry, the staff member should contact the Compliance Officer or other responsible person in the organizational chain of command.

d)

Integrity of Workforce

We recognize that the personal integrity, good judgment and common sense of our staff members is responsible for our reputation of quality service. To maintain that reputation, prior to entering into a relationship with National Reimbursement Group Inc., all staff members, contractors, vendors and others will be subject to a reasonable and prudent background investigation, including a reference check. Applicants (career and/or volunteer, as applicable) will be asked to disclose any criminal convictions, (as defined by 42 U.S.C. 1320a-7(i) and state law) or any action taken by the government to exclude the individual from participation in federal health care programs. Individuals who have been recently convicted of a criminal offense related to health care or who are listed as debarred, excluded or otherwise ineligible for participation in federal health care programs (as defmed in 42 U.S. C. 1320a-7b(f)) may not be considered for employment or a volunteer position with National Reimbursement Group Inc .. Additionally, applicants may be required to divulge their driving record, particularly if their work involves the operation of National Reimbursement Group Inc. vehicles.

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e)

Conflict ofinterest

Staff members are to conduct themselves in a manner that encourages and preserves the trust of those we serve. Staff members should not have financial relationships with parties with which National Reimbursement Group Inc. does business. Prompt disclosure of conflicts of interest should be made to National Reimbursement Group Inc. administration. Violations should be handled in accordance with applicable National Reimbursement Group Inc. disciplinary procedures.
f)

Confidentiality

No member of the organization should use confidential or proprietary information for his or her own personal gain or for the benefit of another person or entity, while associated with National Reimbursement Group Inc. or at any time thereafter. Information concerning a patient is confidential. National Reimbursement Group Inc. personnel should not obtain or divulge details of a patient's condition without a specific professional reason, except as required by law. Violations should be handled in accordance with National Reimbursement Group Inc. disciplinary policies, and/or our HIPAA compliance plan, where applicable. All new personnel, prior to performing any substantial duties with National Reimbursement Group Inc. that involve patient interaction or information, shall undergo the mandatory privacy training as required under the HIPAA Privacy Regulations (where National Reimbursement Group Inc. is a "covered entity" in accordance with HIPAA). g) Compliance with FederaL State and Local Laws and Regulations

National Reimbursement Group Inc. will take all actions necessary to ensure compliance with all applicable federal, state and/or local laws and regulations, as well as with the public policies they represent. h) Anti-Kickback Laws

National Reimbursement Group Inc. will take all actions necessary to ensure compliance with Federal and State anti-kickback Jaws regarding the acceptance or payment of any remuneration for the inducement of referrals of services or the generation of other business, and shall comply with all applicable regulations regarding self-referrals and kickbacks. Staff members should not give or receive kickbacks, rebates or anything of value to a vendor, patient, physician or other health care provider in exchange for a referral for services or the generation of other business.

i)

Business Arrangements With Physicians or other Referral Sources

National Reimbursement Group Inc. will take all actions necessary to ensure compliance with federal and state laws regarding self-referral and business arrangements. Business arrangements with any referral sources should be set forth in a written contract and should be in accordance with applicable federal and state laws. Payments by National Reimbursement Group Inc. to any referral source should be equal to the fair market value of the services rendered or items being purchased by National Reimbursement Group Inc. and should not be based on the volume of transports or the value of referrals generated by the referral source. j) Enviromnent

National Reimbursement Group Inc. strives to manage and operate in ways to ensure there is minimal risk to patients, staff members, visitors and the community environment within the confmes of National Reimbursement Group Inc .. Every staff member should comply with the safety, hazardous waste and other environmental care policies established by National Reimbursement Group Inc .. k) National Reimbursement Group Inc. Transactions

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National Reimbursement Group Inc. transactions should be completed at fair market value and should not result in a direct or indirect monetary benefit to a staff member. National Reimbursement Group Inc. assets should not be used for the benefit of private individuals or staff members. I) Anti-Competitive Practices

National Reimbursement Group Inc. will take all actions necessary to ensure compliance with federal, state and/or local laws and regulations that prohibit price-fixing and other anti-competitive practices. This includes compliance with all laws and regulations related to the procurement of EMS or ambulance service for a municipality or other government entity. m) Gifts to Government Representatives

Staff members should not provide gifts or pay for meals, refreshments travel or lodging expenses for government or public agency representatives, with the intent to influence an official action or decision in an illegal, unethical or uulawful manner. n) Government Investigation

National Reimbursement Group Inc. has established prescribed procedures and guidelines to ensure an appropriate response to government inquiries. Information disclosed without proper authorization jeopardizes the rights of our patients. We also do not want to hinder in any way a legitimate government investigation. If federal or state law enforcement officials request information from an National Reimbursement Group Inc. staff member, the staff member should direct the federal or state law official to contact the National Reimbursement Group Inc. Compliance Officer. The National Reimbursement Group Inc. Compliance Officer should then communicate with the staff member to ensure that the appropriate documents are provided.
Whenever there is any indication that a government investigation may be underway, under no circumstances will any records or documents that could have a bearing on that investigation be destroyed or altered in any way. Any question about disposition of documents or records should be directed to the Compliance Officer.

o)

Individual Judgment

Staff members are often faced with making critical decisions based on activities in the workplace. Remember to always respect others and use good judgment and common sense. If anything within this Code of Conduct goes against your own good judgment, you are encouraged to discuss it with the Compliance Officer or other member ofNational Reimbursement Group Inc. management.
IMPLEMENTATION OF THE CODE

A.

COMPLIANCE COMMITTEE/COMPLIANCE OFFICER

National Reimbursement Group Inc. may appoint a Compliance Committee. The Compliance Committee, where applicable, is responsible for working with the appropriate personnel to ensure that the Code and related policies and procedures govern tbe business activities of National Reimbursement Group Inc .. The Compliance Officer's responsibilities are to develop, implement and maintain the plan, oversee the staff member education, investigate issues in a confidential manner, and report periodically to the Board of Directors or other governing body of the organization. Designation of a Compliance Committee or Compliance Officer does not lessen each staff member's responsibility to comply with the Code and related policies and procedures.

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B.

REPORTING OF VIOLATIONS

It is important to first attempt to resolve issues within the area of responsibility in which they arise. If the staff member knows of a violation or possible violation of the Code or related policies and procedures, it is the staff member's responsibility to report that information inunediately to the staff member's Supervisor (if applicable) or Compliance Officer.

Ultimately, potential violations should be brought to the attention of an appropriate Administrator or Manager within the organization. The Administrator or Manager, in turn, should report potential violations to the Compliance Officer. If the staff member cannot report a possible violation to their Supervisor or Administrator, the staff member may report such violations anonymously to the confidential "hotline" established under the compliance program. Information on making "hotline" reports shall be disseminated to all personnel. Hotline reports may be made via telephone, e-mail or in other forms established by National Reimbursement Group Inc.. Reported violations should be logged, assigned a tracking number and investigated by the Compliance Officer. In reporting violations to the Compliance Officer, if staff members wish to remain anonymous, they may do so by either not disclosing identifying information or by requesting that their confidentiality be protected. The Compliance Officer should make an effort not to identify an individual making an anonymous report, unless it is subsequently determined that the person engaged in improper conduct. Reasonable efforts shall be expended to assure confidentiality of anonymity requests; however, there may be a point where the individual's identity may become known in connection with the investigation or may have to be revealed if governmental authorities become involved. C. DISCIPLINARY ACTIONS

Failure to comply with the standards established by the Code may have severe consequences. Appropriate discipline for violations of the Code, up to and including suspension or termination, may be imposed. Personnel will be subject to disciplinary action if they authorize or participate directly or indirectly in actions that constitute a violation of the law, the Code or related policies and procedures. D. NO RETALIATION FOR GOOD FAITH REPORTING OF VIOLATIONS

The success of any compliance policy, including this Code, depends on the prompt and accurate reporting of violations and suspected violations without fear of retaliation. National Reimbursement Group Inc.'s policy, as well as both federal and state law, does not condone retaliation against a staff member for reporting, in good faith, an actual or suspected violation of the law. Reports should remain confidential except when the nature of the complaint requires disclosure and then should be disclosed only to the extent necessary or advisable to resolve the complaint. E. MONITORING OF COMPLIANCE EFFORTS

An integral component of the Compliance Code and Compliance Plan is the continual monitoring, auditing and evaluation of National Reimbursement Group Inc.'s compliance efforts. An initial audit of compliance should be conducted to determine the areas in which area-specific compliance programs should be focused. Thereafter, audits may be authorized by the Compliance Committee or Compliance Officer in response to reports received through the compliance reporting system or through other means. In addition, overall compliance efforts should be reviewed on an annual basis.
QUESTIONS REGARDING THE CODE

National Reimbursement Group Inc. wants to provide timely guidance to its staff members with respect to the Code. If staff members have a question concerning the Code or related policies or feel the need to seek guidance with respect to a particular issue, staff members should consult their supervisor, administrator or manager, or the Compliance Officer.

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ACKNOWLEDGMENT All employees, volunteers, vendors, contractors, consultants and others with a business relationship to National Reimbursement Group Inc. shall complete an acknowledgement statement stating he/she has received, read and understands this code of conduct.

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NRG EMPLOYEE HANDBOOK RECEIPT

I ACKNOWLEDGE THAT I HAVE RECEIVED A COPY OF THE REVISED NRG EMPLOYEE HANDBOOK. I UNDERSTAND THAT MY EMPLOYEE HANDBOOK IS FOR INFORMATION PURPOSES ONLY ON NRG POLICIES RELATED TO MY EMPLOYMENT, AND DOES NOT CHANGE THE AT WILL STATUS OF MY EMPLOYMENT; AND THAT NRG MAY MODIFY, REVOKE, SUSPEND OR TERMINATE ANY AND ALL POLICIES, RULES, PROCEDURES, AND BENEFITS DESCRIBED OR SET FORTH IN THIS HANDBOOK AT ANY TIME WITHOUT PRIOR NOTICE. TillS HANDBOOK AND ITS STATEMENTS DO NOT CREATE A CONTRACT BETWEEN NRG AND ITS EMPLOYEES. IF I NEED CLARIFICATION AND/OR HAVE ANY QUESTIONS REGARDING NRG PROGRAMS AND POLICIES, I WILL ASK MY SUPERVISOR, DEPARTMENT MANAGER OR THE HUMAN RESOURCES REPRESENTATIVE AT MY FACILITY. I UNDERSTAND THAT COMPANY POLICIES ARE REVISED FROM TIME TO TIME AND THAT IT IS MY RESPONSIBILITY TO ACCESS AN ELECTRONIC COPY IN PUBLIC FOLDERS OR ASK MY SUPERVISOR OR HUMAN RESOURCE REPRESENTATIVE FOR THE MOST RECENT EDITION OF THE EMPLOYEE HANDBOOK. BY SIGNING BELOW, I AGREE TO ABIDE BY AND FOLLOW THE POLICIES AND PROCEDURES SET FORTH IN MY EMPLOYEE HANDBOOK. I FURTHER UNDERSTAND THAT IF I VIOLATE ANY POLICY AND PROCEDUCRE, I WILL BE SUBJECT TO DISCIPLINARY ACTION UP TO AND INCLUDING TERMINATION FROM EMPLOYMENT.

EMPLOYEE:

PRINT NAME:

SIGNATURE

DATE:

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