This is our Employee Handbook to be distributed to and acknowledged by every employee of Precision

Global Consulting, Inc. (“PGC”). Please review it and complete acknowledgement via Docusign on the first
page. This handbook supersedes all prior handbooks that the employee has received in the past by PGC.

Attached to this handbook, or as a separate document, you may find a state-specific “Appendix”. This
Appendix lists state and/or local regulations and employment laws pertaining to your work location.
These laws and regulations will act as PGC policy where the Employee Handbook is silent on matters or
where law differs from that stated in the Handbook. Note that not all states will have a corresponding
Appendix.

Any questions about PGC policies or the Employee Handbook can be answered by emailing
WorkforceSolutions@pgcgroup.com or calling 1.866.677.8060

ABOUT THIS HANDBOOK/DISCLAIMER

This Handbook is designed to acquaint employees with PGC and provide information about working
conditions, employee benefits, and some of the policies that may affect your employment with PGC.
This Handbook is not a contract and is not intended to create any contractual or legal obligations.
Employees should read, understand, and comply with all provisions of the Employee Handbook. It
describes many of the employee’s responsibilities and outlines the programs developed by PGC to
benefit employees. It is our hope to create a comfortable environment and relationship among our
employees, PGC Clients, and our internal staff.

PGC is your employer. All references to your Account Manager mean your Workforce Solutions Team
Specialist unless otherwise specified. No Handbook can anticipate every circumstance or question
about policy. As PGC continues to grow, the need may arise and PGC reserves the right to revise,
supplement, or rescind any policies or portion of the Handbook from time to time as it deems
appropriate, in its sole and absolute discretion. The only exception is our employment-at-will policy
permitting an employee or PGC to end the relationship for any reason at any time (see 1.1). Employees
will, of course, be notified of such changes to the Handbook as they occur.

Many matters covered in this handbook, such as benefit plan descriptions, are also described in
separate PGC documents. These PGC documents are always controlling over any statement made in this
handbook or by any member of management.

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1. Table of Contents

ABOUT THIS HANDBOOK/DISCLAIMER ......................................................................................................... 1

INTRODUCTORY STATEMENT........................................................................................................................ 5

1. EMPLOYMENT WITH PGC ..................................................................................................................... 6

1.1 Nature of Employment (“At Will”) ................................................................................................ 6

1.2 PGC as Employer ........................................................................................................................... 6

1.3 Employment Categories ................................................................................................................ 7

1.3.1 Exempt V. Non-Exempt ......................................................................................................... 7

1.3.2 Safe Harbor Policy for Exempt/Salaried Employees ............................................................. 7

1.3.3 Full Time Employee ............................................................................................................... 8

1.4 Employee Relations and When to Contact PGC............................................................................ 8

1.5 Immigration Law Compliance ....................................................................................................... 9

1.6 Employment Applications/Resumes ............................................................................................. 9

2. PAYMENT TERMS .................................................................................................................................. 9

2.1 Time-Sheet Submittal Process ...................................................................................................... 9

2.2 Recurring Paydays ....................................................................................................................... 10

2.3 Administrative Pay Corrections................................................................................................... 10

2.4 Pay Deductions ........................................................................................................................... 10

2.5 Per Diem and Salary Packaging ................................................................................................... 10

2.6 Business Travel Expenses ............................................................................................................ 11

3. TERMINATION ..................................................................................................................................... 11

3.1 Employment Termination ........................................................................................................... 11

3.2 Responsibilities upon Termination/Project Completion............................................................. 11

3.3 At-Will Termination..................................................................................................................... 12

3.4 Effect on Benefits and Payment.................................................................................................. 12

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 3.5 References .................................................................................................................................. 12

4. BENEFITS PROVIDED TO EMPLOYEE ................................................................................................... 13

4.1 Employee Benefits ...................................................................................................................... 13

4.2 Vacation and Leave of Absence .................................................................................................. 13

4.2.1 Family Medical Leave Act.................................................................................................... 13

4.2.2 Military Leave ...................................................................................................................... 15

4.2.3 Medical and other Benefits................................................................................................. 15

4.2.4 Return to job at end of FMLA Leave ................................................................................... 15

4.2.5 Unlawful Acts by Employers................................................................................................ 15

4.3 Holidays ....................................................................................................................................... 16

4.4 Paid Sick Leave ............................................................................................................................ 16

4.5 Health Insurance ......................................................................................................................... 16

4.5.1 Section 125 Cafeteria Plans................................................................................................. 17

4.6 Benefits Continuation (COBRA) .................................................................................................. 17

4.7 Retirement Benefits: 401(k) ....................................................................................................... 18

4.8 Workers’ Compensation Insurance............................................................................................. 18

4.9 Unemployment Compensation Insurance .................................................................................. 18

4.10 Jury Duty ..................................................................................................................................... 19

5. EMPLOYEE CONDUCT AND WORK RULES ........................................................................................... 19

5.1 Proper Employee Conduct .......................................................................................................... 19

5.2 Drug and Alcohol Use.................................................................................................................. 20

5.3 Sexual and Other Unlawful Harassment ..................................................................................... 20

5.4 Attendance and Punctuality........................................................................................................ 21

5.5 Employee Appearance and Dress ............................................................................................... 21

5.6 Conflicts of Interest ..................................................................................................................... 22

5.7 Safety in the Workplace .............................................................................................................. 22

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 5.8 Workplace Violence Prevention.................................................................................................. 23

5.9 Conflict Resolution between Employee and Client..................................................................... 23

6. ETHICAL AND LEGAL CONCERNS ......................................................................................................... 23

6.1 Business Ethics and Conduct ....................................................................................................... 23

6.2 Equal Employment Opportunity ................................................................................................. 24

6.3 Disability Accommodation .......................................................................................................... 24

6.4 Non-Disclosure ............................................................................................................................ 25

6.5 Defense of Trade Secrets Act ...................................................................................................... 26

6.6 Grievances................................................................................................................................... 26

7. PERSONAL DATA AND EMPLOYEE INFORMATION .............................................................................. 26

7.1 Access to Personnel Files ............................................................................................................ 26

7.2 Electronic Communications Policy .............................................................................................. 27

7.3 Personal Data Changes ............................................................................................................... 27

7.4 Inspections .................................................................................................................................. 27

7.5 Defense of Trade Secrets Act ...................................................................................................... 28

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For those of you who are commencing employment with PGC, we would like to extend a warm and
sincere welcome. Thank you for joining our team of professionals.

At PGC, our mission is to provide our clients with services which we refer to as “Extreme Value”. With
your dedication, perseverance, and contributions to the team, we will achieve our goal of delivering
these value-added services to our clients. Our clients depend on PGC to help them achieve their goals
and objectives. We have experienced a high success rate with the contributions of individuals like
yourself. Since the inception of our company, our objective has been to simply be the best at what we
do. We have made incredible strides towards that goal thanks to our employees.

Maintaining a positive relationship between our employees and our clients is one of PGC’s most
valuable assets. Every employee represents PGC to our clients and the public. Employees’ personal
contact with the public, manners at a worksite, and the communications with Clients and/or Client
customers are a reflection not only of themselves, but also of the professionalism of PGC. Positive client
relations not only enhance the public’s perception or image of PGC, but also pay off in greater client
loyalty and increased opportunities for PGC and its employees.

Moving forward, we hope your relationship with PGC is productive, long-term, and satisfying. Should
you need any assistance, please do not hesitate to reach out to your PGC Workforce Solutions Team
Specialist.

Best Regards,
PGC

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1. EMPLOYMENT WITH PGC

1.1 Nature of Employment (“At Will”)

Employment with PGC is voluntarily entered into and is “at-will,” which means that the employee is free
to resign at will at any time, with or without notice or cause. Similarly, PGC may terminate the
employment relationship at any time, with or without notice or cause, so long as there is no violation of
applicable federal, state, or local laws. No one has the authority to make verbal statements that change
the at-will nature of employment, and the at-will relationship cannot be changed or modified for any
employee except in a written agreement signed by that employee and an authorized PGC person(s).
PGC requests from all employees at least 2 weeks’ notice of termination, or of any Client required
termination notice as presented to the employee in the “Schedule”, Work Order or otherwise.

These provisions supersede all existing policies and practices and may not be amended or added to
without the express written approval of the CEO or person designated and authorized by the CEO of
PGC.

1.2 PGC as Employer

Employment with PGC is contingent on performing work for a designated PGC Client. It is important for
the employee to note that he/she is an employee of PGC and not the Client, regardless of the nature of
the relationship between the employee and the Client. For each role assigned to an employee, specific
project and Client information will be provided to by a Schedule, Work Order, or Assignment letter from
PGC that designates place of work, hourly/salary rate, additional benefits, and other detail specific to
the placement. Employees should make sure they receive the following information in regards to each
position:
1. Client Company’s name
2. Location, hours, length of assignment
3. Specific tasks you will be doing
4. Hourly/Daily/Weekly/Salaried rate
5. Name of person to whom you report
6. Any other details that will help you on your assignment

All information provided in the Schedule, Work Order or Assignment Letter supersedes the employment
agreement if it differs. This document may include specific requirement of the Client that employee will
abide by including but not limited to hours required, leave benefits, termination requirements, etc.

PGC is normally open for business from 9:00 a.m. to 6:00 p.m. Monday through Friday. However, work
schedules for employees vary throughout our organization. Employee’s work schedule and expected
hours will be verified by the Client and provided to the employee for each project. Staffing needs and
operational demands may necessitate variations in starting and ending times, as well as variations in the
total hours that may be scheduled each day and week. Employees are entitled to any federal or state
required break periods, including any legally required break time for nursing mothers.

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 1.3 Employment Categories
It is the intent of PGC to clarify the definitions of employment classifications so that employees
understand their employment status and benefit eligibility. These classifications do not guarantee
employment for any specified period of time. Accordingly, the right to terminate the employment
relationship at will at any time is retained by both the employee and PGC.

1.3.1 Exempt V. Non-Exempt

Each employee is designated on “Schedule” to an Employment Agreement as either
NONEXEMPT or EXEMPT from federal and state wage and hour laws under the Fair Labor
Standards Act. FLSA is the federal labor law that covers minimum wage provisions, overtime
pay, the Equal Pay Act, child labor laws, and other employment laws. Further information can
be found at http://www.dol.gov/compliance/minwage.htm. NONEXEMPT employees are
entitled to overtime pay under the specific provisions of federal and state laws while EXEMPT
employees are excluded from specific provisions. An employee’s EXEMPT or NONEXEMPT
classification may be changed only upon written notification by PGC management. Please note
that employee’s EXEMPT or NONEXEMPT status may change from project to project or even
during the course of one project depending on employee’s duties and pay rate. If employee
feels they have been incorrectly classified as either EXEMPT or NON-EXEMPT please contact
your PGC Workforce Solutions Team Specialist at WorkforceSolutions@pgcgroup.com to discuss
any concerns.

All non-exempt employees must receive permission from Client in order to work overtime
hours. Failure to receive permission or the falsification of worked hours can result in disciplinary
action including termination. Overtime compensation is paid to all nonexempt employees at
1.5x their regular rate for all hours worked in excess of 40 hours per week, unless state or local
laws require otherwise. Overtime is based on actual hours worked. For purposes of calculating
overtime for NONEXEMPT employees, the workweek begins on Monday and ends on Sunday,
unless otherwise specified. Time taken for meals is not included as time worked for purposes of
overtime. Holidays, sick leave, vacation leave, personal leave, or any other leave of absence will
not be factored in as hours when calculating overtime.

1.3.2 Safe Harbor Policy for Exempt/Salaried Employees

If employee is classified as an exempt employee and receives a recurring salary, this salary will
be a predetermined amount that will not be subject to deductions for variations in quantity or
quality of the work performed.

Under federal and state law, an employee’s salary is subject to certain deductions. For example,
unless state law requires otherwise, salary can be reduced for the following reasons:

• Full-day absences for personal reasons

• Full-day absences for sickness or disability
• Full-day disciplinary suspensions for infractions of safety rules of major significance; or
for unpaid disciplinary suspensions of one or more full days imposed in good faith for
workplace conduct rule infractions

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 • Family and Medical Leave absences (either full- or partial- day absences)
• To offset amounts received as payment for jury and witness fees or military pay
• The first or last week of employment in the event you work less than a full week
• Any full work week in which employee do not perform any work
Employee’s salary may also be reduced for certain types of deductions such as their portion of
health, dental or life insurance premiums, federal, state, or local taxes, social security, or
voluntary contributions to a 401(k) or pension plan.

In any work week in which employee performed any work, salary will not be reduced for any of
the following reasons:
• Partial day absences for personal reasons, sickness or disability
• Absence on a day because Client has decided to close a facility on a scheduled work day
• Absences for jury duty, attendance as a witness, or military leave in any week in which
employee has performed any work
• Any other deductions prohibited by state or federal law.
However, unless state law provides otherwise, deductions may be made to employee’s accrued
leave for full or partial day absences for personal reasons, sickness, or disability.

1.3.3 Full Time Employee

All Employees are considered employees of PGC and not an employee of PGC’s Client.
Regardless of the temporary nature of work performed, all Employees will be considered Full-
Time Employees of PGC if they meet the criteria of completing a 30 hour work-week or greater
on a regular basis. All Full-Time employees receive all legally mandated benefits (such as
worker’s’ compensation insurance and Social Security), and are eligible for a Patient Protection
and Affordable Care Act compliant, company sponsored Group Health Plan.

1.4 Employee Relations and When to Contact PGC

PGC believes that the work conditions, wages, and benefits it offers to its employees are competitive
with those offered by other employers in this area and in this industry as well as in the area and industry
of work performed for Client. If an employee has concerns about work conditions, Client
Manager/Supervisor, or compensation, they are strongly encouraged to voice these concerns openly
and directly to their PGC Workforce Solutions Team Specialist.

If it is unclear as to whether an employee should contact a PGC Workforce Solutions Team Specialist or
Client Manager, always feel free to contact a PGC Workforce Solutions Team Specialist for clear
direction. The following are examples of when to contact PGC directly:
1. If employee is requested to perform any duties other than the ones described to
employee when he/she accepted the assignment
2. Upon the completion of the project contact a PGC Workforce Solutions Team Specialist
3. If employee is injured while on a project
4. If a client offers employee a full-time position
5. If employee changes name, telephone number, or address

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 6. If employee believes he/she is experiencing any type of harassment, unlawful
discrimination, or discrimination prohibited by PGC policy while on a project with a
Client
7. If employee has a complaint or dispute about your pay, exemption status, assignment,
or working conditions

1.5 Immigration Law Compliance

PGC is committed to employing only United States citizens and aliens who are authorized to work in the
United States. PGC does not unlawfully discriminate on the basis of citizenship or national origin.

In compliance with the Immigration Reform and Control Act of 1986, each new employee, as a condition
of employment, must complete the Employment Eligibility Verification Form I-9 and present
documentation establishing identity and employment eligibility. If the I-9 is completed by agents
authorized by PGC to complete the form on PGC’s behalf outside of the PGC Headquarters in NYC, the
completed I-9 must be returned to PGC within 3 days of the start of employment. Former employees
who are rehired must also complete the form if they have not completed an I-9 with PGC within the past
three years, or if their previous I-9 is no longer retained or valid.

Employees with questions or seeking more information on immigration law issues are encouraged to
contact PGC. Employees may raise questions or complaints about immigration law compliance without
fear of reprisal.

1.6 Employment Applications/Resumes

As the employer, PGC relies on the accuracy of information contained in employee’s or potential
employee’s applications, resumes, and other data presented through the hiring process or obtained
during employment. Any misrepresentations, falsifications, or material omissions in any of this
information or data may result in disqualification from further consideration for employment or, if
employee has been hired, termination of employment.

2. PAYMENT TERMS

2.1 Time-Sheet Submittal Process

Although an employee may be doing work for a variety of PGC clients, PGC is the employer. Employee’s
timecard and paycheck is processed by PGC and a PGC Workforce Solutions Team Specialist is
Employee’s contact for all work assignments. Employees are required to record their daily work
attendance. Exempt employees are to report full days of absence from work for reasons such as leaves
of absence, sick leave, or personal business to WorkforceSolutions@pgcgroup.com. Non-exempt
employees must record the time work begins and ends, as well as the beginning and ending time of any
departure from work for any non-work-related reason on Client provided timesheets or PGC provided
timesheets. Non-exempt employees may not start work until their scheduled starting time.

Employee must submit client-approved time sheets for all hours worked to
WorkforceSolutions@pgcgroup.com on a weekly basis unless otherwise agreed. Payment will be
determined based on the hours worked as stated on submitted timesheets including all regular and

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overtime hours. In order to ensure their paycheck is accurate employees must record their time
completely and without errors. Any errors in employee’s time record should be reported immediately
to PGC Workforce Solutions Team Specialist, who will attempt to correct legitimate errors.

2.2 Recurring Paydays

All employees are paid in accordance with the respective Schedules, Work Order, or Assignment Letter
provided for each assignment and is based on the amount agreed upon with the Client. For this reason,
hourly wages may vary from project to project. Each paycheck will include earnings for all work
performed through the end of the previous payroll period.

In the event that a regularly scheduled payday falls on a day off, such as a weekend or holiday,
employees will receive pay on the last day of work before the regularly scheduled payday.

If a regular payday falls during an employee’s vacation, the employee will receive all wages on the
regular pay day during the vacation. Any complaints or disputes regarding your pay must be brought to
employee’s PGC Workforce Solutions Team Specialist.

2.3 Administrative Pay Corrections

PGC takes all reasonable steps to ensure that employees receive the correct amount of pay in each
paycheck and that employees are paid promptly on the scheduled payday.

In the unlikely event that there is an error in the amount of pay, employee should promptly bring the
discrepancy to the attention of your PGC Workforce Solutions Team Specialist so that investigation and
corrections can be made as quickly as possible.

2.4 Pay Deductions

The law requires that PGC make certain deductions from every employee’s compensation. Among these
are applicable federal, state, and local income taxes. PGC must also deduct Social Security taxes on each
employee’s earnings up to a specified limit that is called the Social Security “wage base.” All employees
will be provided with a W-2 Wage and Tax Statement by January 31 of the following year. Please inform
a PGC Workforce Solutions Team Specialist of any address changes immediately in order to ensure
timely delivery of your W-2 form. State taxes will be held for the state where work is performed by the
employee unless otherwise discussed between the employee and PGC.

In accordance with the Fair Labor Standards Act regulations (FLSA), exempt employees who are required
to be paid on a salary basis may not have their pay reduced for variations in the quantity or quality of
work performed and in accordance with the Safe Harbor Policy of this handbook (section 1.3.2).
Employees who feel their pay has been improperly reduced should report this immediately to their PGC
Workforce Solutions Team Specialist at WorkforceSolutions@pgcgroup.com. PGC will investigate the
complaint, take all steps necessary to ensure improper deductions are not made in the future, and will
not retaliate against an employee for making such a complaint.

2.5 Per Diem and Salary Packaging

PGC employees may elect to use Per Diem to lower their taxable income if the employee has relocated
from outside the US or has relocated a material distance away from their city/residence. In order to

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qualify for per diem, the employee must work more than 100 miles away from their residence and be
employed for a temporary period of time (less than 1 year), and complete the Declaration of Per
Diem/Salary Packaging Form provided by PGC Workforce Solutions Team Specialist. If employee meets
the eligibility requirements, employee will be able to reduce taxable income by the amount allowed
under the IRS guidelines.

2.6 Business Travel Expenses

PGC will reimburse all approved employee expenses that have been approved and paid by the Client as
long as expenses are submitted to PGC with corresponding receipts. PGC still can deny the expenses
regardless of Client approval, if expenses are not allowable under IRS guidelines. If PGC does not
approve the expenses, but they are paid by Client, PGC will provide the funds to Employee as taxable
income less any PGC management fee as agreed upon between PGC and the Client.

If Client requires employee to travel, such travel must be approved in advance by Client Manager, must
be clearly defined as required travel, and must be submitted to PGC with documents of proof of travel.
Other expenses not approved by Client may be submitted to PGC in order to reduce taxable income.
PGC can deny the submitted expenses for any reasons.

3. TERMINATION

3.1 Employment Termination

Termination of employment is an inevitable part of personnel activity within any organization and many
of the reasons for termination are routine. Below are examples of some of the most common
circumstances under which employment is terminated:
• Resignation—voluntary employment termination initiated by an employee.

• Discharge—involuntary employment termination initiated by PGC.

• Layoff—involuntary employment termination initiated by PGC of an organizational change.

• Retirement—voluntary employment termination initiated by the employee meeting age,

length of service, and any other criteria for retirement from the organization.

• End of contract – as per Client’s request, there is no longer a need for the Employee’s services
due to the completion of the project, adherence to contract End date, or any other reason as
determined by the Client.

If there are concerns with employee’s performance raised by PGC and/or Client or changes in the need
for employee’s services, it is within the power of PGC to terminate the employee.

3.2 Responsibilities upon Termination/Project Completion

The manner in which employee completes an assignment is not only reflective of the employee, but also
on PGC. Do not walk off the job without contacting PGC at WorkforceSolutions@pgcgroup.com. Upon
completion of an assignment, employee must contact our office within 24 hours to be considered

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available for work. Failure to report your availability will be viewed as a voluntary resignation, and may
affect your ability to receive unemployment compensation.

Resignation is a voluntary act initiated by the employee to terminate employment with PGC. Although 2
weeks’ notice is requested by PGC, Client may require additional advance notice as described in
Schedule provided for each project. When resignation occurs, the employee must contact PGC
Workforce Solutions Team Specialist and provide information regarding last day of work for the Client.

Upon completion of an assignment or termination, all personal property should be gathered when
leaving the assignment. Any personal property left at the client worksite will be collected and returned
by a PGC representative. Prior to leaving Client worksite, or within 5 days of termination/completion for
employees who worksite outside of a Client worksite, employee must return all Client or PGC
proprietary equipment such as access badges, remote access equipment, computers, phones, etc. If the
equipment is lost or damaged when returned, the cost of equipment for replacement or repair will be
deducted from the employee’s final paycheck, to the extent permitted by law.

Upon termination, PGC and Client strictly prohibit employee to return to Client site or communicate
with Client or other PGC Employees at the Client site for any reason, unless otherwise allowed by the
Client.

3.3 At-Will Termination

Nothing in this policy is intended to change PGC’s at-will employment policy. Since employment with
PGC is based on mutual consent, both the employee and PGC have the right to terminate employment
at-will, with or without cause, at any time. Employees will receive their final pay in accordance with
applicable state law.

3.4 Effect on Benefits and Payment

Employee’s last pay check will be paid according to PGC payment schedule for services through
termination unless otherwise required by state law.

Employee benefits will be affected by employment termination in the following manner:

• 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 (See the “Benefits
Continuation (COBRA)” policy section 4.6).

3.5 References
PGC will respond to reference requests through the PGC Human Resources Department. PGC will
provide general information concerning the employee such as date of hire, date of termination, and
positions held. Requests for reference information must be in writing.

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4. BENEFITS PROVIDED TO EMPLOYEE

4.1 Employee Benefits

Eligible employees at PGC are provided a wide range of benefits to choose from. A number of the
programs (such as Social Security, workers’ compensation, state disability, and unemployment
insurance) cover all employees in the manner prescribed by law.

Benefits eligibility is dependent upon a variety of factors, including employee classification. A PGC
Workforce Solutions Team Specialist can identify the programs for which an employee is eligible.

Some benefit programs require contributions from the employee and/or may be dependent on
contribution from the Client. Many benefits are described in separate Summary Plan Descriptions, or
Plans, which may change from time to time. The Summary Plan Description will control over any policy
in this Handbook. Each employee will receive a copy of each Summary Plan Description applicable to
them. If employee needs a Summary Plan Description or has any questions, contact a PGC Workforce
Solutions Team Specialist.

4.2 Vacation and Leave of Absence

Employees may take leave as provided by their employment agreement and Client Schedule, Work
Order, or Assignment Letter. Leave will be unpaid regardless of the circumstances for taking said leave,
unless otherwise agreed and paid by the Client. When employee is taking leave of more than 3
consecutive days, the employee must get approval from Client and must submit a request to their PGC
Workforce Solutions Team Specialist at least two (2) weeks in advance. It is within the deference of the
Client to allow leave at time requested. It will be agreed at the start of the project as to whether or not
Client will pay for leave and aspects of such leave (including accrual, rollover, maximum cap, and payout
on termination) will be determined by Client policy.

4.2.1 Family Medical Leave Act

The federal Family and Medical Leave Act (FMLA) allows employees to take an unpaid leave of
absence up to a maximum of twelve (12) weeks in connection with:

1. the birth of an employee’s child,

2. placement of a child with an employee for adoption or foster care,
3. a serious health condition of an employee or an employee’s immediate family member
(child, spouse, parent)1,

1Serious Health condition: A serious health condition is an illness, injury, impairment or physical or mental condition that involves either an
overnight stay in a medical care facility or continuing treatment by a health care provider for a condition that either prevents employee from
performing the functions of the job, or prevents qualified family members from participating in school or daily activities. Continuing treatment
may be met by a period of incapacity of more than three (3) consecutive calendar days combined with at least two (2) visits to a health care

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 4. a qualifying situation that may arise for a parent’s, child’s, spouse’s active duty or call to
active duty in support of a contingency operation,
5. up to a maximum of twenty-six (26) weeks in a case involving leave to care for a qualifying
recovering parent, child, spouse, or next of kin who is a service member of the armed
forces.

Employee may be entitled to additional leave in accordance with state law depending on the state
where employee is performing work for the Client. No greater or lesser leave benefits will be
granted than those provided by relevant state or federal laws, unless otherwise granted by Client.
In any case, employee will be eligible for the most generous benefits available under either federal
or state law.

Employee may substitute any accrued vacation or personal leave time for family and medical
leave. Employee’s total FMLA leave time, which may include paid time off if provided for by
client, may not exceed 12 weeks. PGC and/or the Client has the right to designate any accrued
vacation or personal leave, including but not limited to paid sick leave, paid time off, disability
leave, and workers compensation as absences running concurrently with FMLA.

In order for PGC to determine an employee’s eligibility for FMLA leave, the employee must make
a specific request for such leave. The criteria an employee must meet to qualify for FMLA leave
is as follows (additional criteria may apply):

• Eligibility requirements: Employee must have been employed by PGC for at least 12
months and worked at least 1,250 hours in the preceding 12 months and at a worksite with
at least 50 employees within 75 miles. Please note, that not all employees will meet
eligibility requirements for FMLA. Employee is to contact PGC at
WorkforceSolutions@pgcgroup.com to find out if he/she is eligible for FMLA based on
location of employment and length of service as a PGC employee. Additionally, leave due
to the birth or placement of a child in your home for adoption or foster care must be taken
in one continuous 12-week segment and must be taken within 12 months of the birth or
placement of the child.

• Notice and Certification required: If need for leave is foreseeable, employee must provide
PGC and Client 30 days prior notice of intention to take FMLA leave. If leave is not
foreseeable, employee must request leave as soon as possible and no later than 2 business
days after the need for leave arises. Employee must submit appropriate documentation
supporting own serious health condition and the length of such condition (from a physician
or practitioner), or documentation supporting immediate family member’s own serious
health condition, and length of such condition (from a physician or practitioner), or

provider or one visit and a regimen of continuing treatment, or incapacity due to pregnancy, or incapacity due to a chronic condition. Other
conditions may meet the definition of continuing treatment.

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 documentation supporting the adoption or foster placement of a child, or documentation
supporting the contingency operation, if available. Leave may be denied if employee does
not provide satisfactory certification. If employee intentionally misrepresents the reasons
for requesting family and medical leave, employee may be discharged at PGC’s discretion.

• Married couples: A husband and wife who are eligible for FMLA leave and are employed by
the same covered employer may be limited to a combined total of 122 weeks leave during
any 12-month period of leave is taken for placement of employee’s child or to care for child
after placement, for birth of employee’s child or care after birth or to care for employee’s
parent with a serious health condition.

4.2.2 Military Leave

If employee is called into active military service or enlists in uniformed services, he/she will be
eligible to receive unpaid military leave of absence. To be eligible, employee must provide their
PGC Workforce Solutions Team Specialist with advance notice of service obligation unless
employee is prevented from providing such notice by military necessity or it is otherwise
impossible or unreasonable to provide such notice. Provided absence does not exceed
applicable statutory limitations, employee retains reemployment rights and accrue seniority and
benefits in accordance with applicable federal and state laws.

4.2.3 Medical and other Benefits

During an approved family medical leave, PGC will maintain the employee’s health benefits as if
the employee continued to be actively employed. If paid leave is substituted for unpaid family
medical leave, PGC will deduct employee’s portion of the health plan premium as a regular
payroll deduction. Health insurance benefits will not be maintained after the twelve (12) week
FMLA period expires if the employee does not return to work; however, employee will be
entitled to his or her applicable rights under COBRA. During FMLA leave, PGC will maintain the
employee’s health coverage under any “group health plan” on the same terms as if the
employee had continued to work. Seniority and employment benefits do not accumulate during
an FMLA, but any such benefits that have accumulated before the leave is taken will not be lost.

4.2.4 Return to job at end of FMLA Leave

Upon return from FMLA leave, employees will be restored to their original or equivalent
position with equivalent pay, benefits, and other employment terms. If an employee fails to
return to work on the day noted on the leave request (or on such date subsequently agreed for
return), it will be considered a voluntary resignation by the employee. A leave request may be
investigated at the discretion of PGC, and any deliberate falsification of an FMLA leave request
or medical certification may result in disciplinary action, up to and including termination.

4.2.5 Unlawful Acts by Employers

FMLA makes it unlawful for any employer to (1) interfere with, restrain, or deny the exercise of
any right provided under FMLA and (2) discharge or discriminate against any person for
opposing any practice made unlawful by FMLA or for involvement in any proceeding under or

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 relating to FMLA. If an employee feels there was an unlawful act by PGC, employee may file a
complaint with the U.S. Department of Labor or may bring a private lawsuit against PGC. FMLA
does not affect any federal or state law prohibiting discrimination, or supersede any state or
local law which provides greater family or medical leave rights.

4.3 Holidays
PGC Employees will be given holidays off in accordance with Client’s policies. All holidays will be unpaid,
unless agreed to be paid by the Client. Employees are often granted time off for the holidays listed
below, but is dependent on Client’s policy:

• New Year’s Day (January 1)

• Martin Luther King, Jr. Day (third Monday in January)
• Presidents’ Day (third Monday in February)
• Memorial Day (last Monday in May)
• Independence Day (July 4)
• Labor Day (first Monday in September)
• Thanksgiving (fourth Thursday in November)
• Christmas (December 25)
• New Year’s Eve (December 31)

4.4 Paid Sick Leave

Employee will only be entitled to paid sick leave when performing work in a city and/or state where such
pay is legally required or when Client has agreed to provide paid sick leave. PGC will follow the minimum
requirements as provided in the law or regulation. In order to remain eligible for paid sick leave, employee
is required to contact WorkforceSolutions@pgcgroup.com at least 5 days before a foreseeable absence
(such a scheduled appointment), or at some time before the start of employee’s scheduled work shift for
an unforeseeable absence. Failure to provide a request to PGC may result in lack of pay for the period
requested. If employee is absent for 3 consecutive days or if there is a suspicion of abuse of this policy,
PGC is entitled to request documentation from the appropriate verification source. If employee is entitled
to any form of paid time off from PGC and/or the Client that covers the minimum state and/or city
requirements for paid sick leave, then no additional payment is required from PGC. For purposes of paid
sick leave, an employees employment year begins on the date the employee began employment with PGC
and runs 12 consecutive months.

4.5 Health Insurance

PGC’s health insurance plan provides employees access to medical, dental, vision, life, and disability. To
be eligible for most benefits, employee must work on average more than 30 hours per week. Upon hire,
Employee will be provided with an enrollment window in which they must enroll in medical benefits if
they wish to receive. Each year, there will be an “open enrollment” in which an employee may change
their benefits selection. Employee may enroll outside of the initial enrollment window or open
enrollment if a qualifying event occurs such as a change in employee’s employment status, change in
marital status, change in number of eligible family members, changes affecting family members’
employment, or other special circumstances. Once enrolled, Employee will be entitled to benefits the
first of the month following 30 days from the first day of employment. For example, if an employee

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begins employment on January 15th, the first day of benefits will begin March 1st. For further questions
about qualifying events or eligibility contact WorkforceSolutions@pgcgroup.com.

Eligible employees may participate in the health insurance plan and are subject to all terms and
conditions of the agreement between PGC and the insurance carrier.

A change in employment classification that would result in loss of eligibility to participate in the health
insurance plan may qualify an employee for benefits continuation under the Consolidated Omnibus
Budget Reconciliation Act (COBRA).

Details of the health insurance plan are described in the Summary Plan Description (SPD) provided to
each employee. An SPD and information on cost of coverage will be provided in advance of enrollment
to eligible employees. Contact a PGC Workforce Solutions Team Specialist for more information about
health insurance benefits.

4.5.1 Section 125 Cafeteria Plans

The Pre-Tax Premium account provided by PGC allows employee the opportunity to reduce
taxable earnings by setting aside part of your earnings before federal income taxes, Social
Security, Medicare, and in most cases state and local taxes that are withheld from employees’
paychecks. This is known as a Section 125 plan and is most commonly used to pay for
employee’s portion of healthcare premiums. Each employee who participates in PGC’s
insurance plan(s), and has a cost share to that insurance plan coverage, will automatically be
enrolled in this pre-tax program. If employee does not wish to participate, thereby paying group
sponsored insurance premiums with after-tax dollars, employee should contact their PGC
Workforce Solutions Team Specialist to sign the necessary waiver form prior to each plan year.

Having your insurance premium(s) deducted pre-tax does not change any provisions of
coverage; it only affects the way you pay contribution of the premiums. It is important to note
that once insurance premiums are deducted on a pre-tax basis, you cannot change your
deduction until the start of the next plan year, unless you experience a qualified change in
status. PGC plan years currently run from August – August. Changes in family status must be
reported to the Benefits Administrator within thirty (30) days of the event in order to modify or
revoke this benefit election.

4.6 Benefits Continuation (COBRA)

The federal Consolidated Omnibus Budget Reconciliation Act (COBRA) gives employees and their
qualified beneficiaries the opportunity to continue health insurance coverage under PGC’s health plan
when a “qualifying event” would normally result in the loss of eligibility. Some common qualifying
events are resignation, termination of employment, death of an employee, a reduction in an employee’s
hours, a leave of absence, an employee’s divorce or legal separation, and a dependent child no longer
meeting eligibility requirements.

Under COBRA, the employee or beneficiary pays the full cost of coverage at PGC’s group rates plus an
administration fee. PGC provides each eligible employee with a written notice describing rights granted

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under COBRA when the employee becomes eligible for coverage under PGC’s health insurance plan. The
notice contains important information about the employee’s rights and obligations. Contact a PGC
Workforce Solutions Team Specialist for more information about COBRA.

4.7 Retirement Benefits: 401(k)

Employees may have the option to enroll in a 401(k) retirement savings plan via Platinum 401(k) and
John Hancock Investments, provided he or she meets the eligibility requirements of the plan. There will
not be an employer match, unless they are directly advised otherwise. Should PGC provide an employer
match or profit share, this may be subject to change at any given time. Detailed information about the
401(k) plan that is available through PGC may be found in the Summary Plan Description. A copy of the
most current SPD is available on the 401(k) web portal at http://www.theplatinum401k-pgc.com/
or by contacting WorkforceSolutions@pgcgroup.com.

4.8 Workers’ Compensation Insurance

Workers’ Compensation is defined by a set of rules determined by each state which outlines benefits to
employees who have sustained work-related injuries/illnesses. The laws provide for payment of medical
bills for treatment due to such injuries and illnesses and reasonable income benefits for employees who
may lose time from work. Employees who are seriously injured on the job may be entitled to additional
benefits.

Funds for these benefits are provided by PGC through its Workers’ Compensation claims administrator,
as required by law. Employees who sustain work-related injuries or illnesses should inform their PGC
Workforce Solutions Team Specialist immediately. No matter how minor an on-the-job injury may
appear, it is important that it be reported immediately. This will enable an eligible employee to qualify
for coverage, if needed, as quickly as possible. For further information on how to file a workers’
compensation claim with PGC claim administrator contact WorkforceSolutions@pgcgroup.com.

PGC provides benefits, as required by law, to every employee injured during the course of their
employment. However, if we determine that any employee has provided falsified information to PGC,
the physician, the claim administrator, or to their PGC Workforce Solutions Team Specialist for the
purpose of fraudulently obtaining workers’ compensation benefits, we will take the strongest possible
action to prosecute that employee to the fullest extent of the law and such employee will no longer be
eligible for employment with PGC.

4.9 Unemployment Compensation Insurance

Unemployment compensation insurance is a temporary financial benefit to employees who have lost
their jobs due to no fault of their own. The amount of the benefit is based on past work and earnings
and administered by the state the employee works in. Each state has its own set of rules which outline
eligibility criteria and benefit amount, and PGC complies with the state laws.

It is the responsibility of the employee, should the project end or decide to voluntary quit, to notify PGC
Workforce Solutions Team Specialist within 48 hours, unless this policy is inconsistent with employee’s
state’s unemployment compensation laws. Failure to contact PGC at the end of project or within 48
hours may result in a voluntary quit and/or the loss of unemployment.

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 4.10 Jury Duty
PGC encourages employees to fulfill their civic responsibilities by serving jury duty when required.
Employees may request unpaid jury duty leave for the length of absence, or will receive pay when
required by law. PGC will not dismiss an employee from a project purely because they are assigned jury
duty and will be absent, as long as they provide advance notice to their Workforce Solutions Team
Specialist regarding the duration of the absence. If desired, employees may use any available paid time
off (for example, vacation benefits). Employee is to be aware that PGC or Client may require additional
documentation relating to service of jury duty.

5. EMPLOYEE CONDUCT AND WORK RULES

5.1 Proper Employee Conduct

To ensure orderly operations and provide the best possible work environment, PGC expects employees
to follow rules of conduct that will protect the interests and safety of all employees and the organization.
Personal conduct, including conversations at the Client work site, must not violate PGC policies including
but not limited to PGC Anti-Harassment policies. Employment with PGC requires all employees to comply
with our policies and procedures.

It is not possible to list all the forms of behavior that are considered unacceptable in the workplace. The
following are examples of infractions of rules of conduct that may result in disciplinary action, up to and
including termination of employment:

• Theft or inappropriate removal or possession of property

• Falsification of timekeeping records
• Working under the influence of alcohol or illegal drugs
• Possession, distribution, sale, transfer, or use of alcohol or illegal drugs in the workplace,
while on duty
• Fighting or threatening violence in the workplace or at Client worksite
• Boisterous or disruptive activity in the workplace or at Client worksite
• Negligence or improper conduct leading to damage of employer-owned or Client-owned
property
• Insubordination or other disrespectful conduct
• Violation of safety or health rules
• Sexual or other unlawful or unwelcome harassment
• Possession of dangerous or unauthorized materials, such as explosives or firearms, in the
workplace or Client worksite
• Excessive absenteeism or any extended absence without notice to PGC Workforce Solutions
Team Specialist
• Unauthorized disclosure of business “secrets” or confidential information of PGC and/or
Client
• Violation of personnel policies
• Unsatisfactory performance or conduct

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Nothing is this policy is intended to change PGC’s at-will employment policy. Employment with PGC is at
the mutual consent of PGC and the employee, and either party may terminate that relationship at any
time, with or without cause, and with or without advance notice.

5.2 Drug and Alcohol Use

It is PGC’s desire to provide a drug-free, healthful, and safe work environment for all employees
whether at PGC offices or on-site Client workplace. To promote this goal, employees are required to
report to work in appropriate mental and physical condition to perform their jobs in a satisfactory
manner.

While on PGC and/or Client premises or while conducting any business-related activities of PGC, no
employee may use, possess, distribute, sell, or be under the influence of alcohol or illegal drugs. The
legal use of prescribed drugs is permitted on the job only if it does not impair an employee’s ability to
perform the essential functions of the job effectively and in a safe manner that does not endanger other
individuals in the workplace.

PGC may conduct investigations into the use of alcohol or drugs while employee performed services in
the event that there is an accident or injury effecting employee’s workers’ compensation claims, when
there is reasonable suspicion to believe employee has violated this policy or when circumstances or
workplace conditions justify such investigation.

Violations of this policy may lead to disciplinary action, up to and including immediate termination of
employment, and/or required participation in a substance abuse rehabilitation or treatment programs.
Such violations may also have legal consequences.

Employees with questions on this policy or issues related to drug or alcohol use in the workplace should
raise their concerns with their PGC Workforce Solutions Team Specialist.

5.3 Sexual and Other Unlawful Harassment

PGC is committed to providing a work environment that is free from all forms of discrimination and
conduct that can be considered harassing, coercive, or disruptive, including but not limited to sexual
harassment. Actions, words, jokes, comments, or unfair treatment based on an individual’s sex, race,
gender, color, national origin, age, religion, disability, sexual orientation, or any other characteristic
protected by federal, state, or local law will not be tolerated.

Sexual harassment is defined as unwanted sexual advances, or visual, verbal, or physical conduct of a
sexual nature. This definition includes many forms of offensive behavior and includes gender-based
harassment of a person of the same sex as the harasser. The following is a partial list of sexual
harassment examples:

• Unwanted sexual advances

• Offering employment benefits in exchange for sexual favors
• Making or threatening reprisals after a negative response to sexual advances
• Visual conduct that includes leering, making sexual gestures, or displaying of sexually
suggestive objects or pictures, cartoons, or posters

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 • Verbal conduct that includes making or using derogatory comments, epithets, slurs, or
jokes
• Verbal sexual advances or propositions
• Verbal abuse of a sexual nature, graphic verbal commentaries about an individual’s
body, sexually degrading words used to describe an individual, or suggestive or obscene
letters, notes, or invitations
• Physical conduct that includes touching, assaulting, or impeding or blocking movements

Unwelcome sexual advances (either verbal or physical), requests for sexual favors, and other verbal or
physical conduct of a sexual nature constitute sexual harassment when: (1) submission to such conduct
is made either explicitly or implicitly a term or condition of employment; (2) submission to or rejection
of the conduct is used as a basis for making employment decisions; or (3) the conduct has the purpose
or effect of interfering with work performance or creating an intimidating, hostile, or offensive work
environment.

If employee experiences or witnesses sexual or other unlawful harassment in the workplace by either a
PGC employee and/or Client employee, report to a PGC Workforce Solutions Team Specialist
immediately. Employee can raise concerns and make reports without fear of intimidation, reprisal or
retaliation. At the same time, employees have an obligation to cooperate with PGC in enforcing this
policy and investigating and remedying complaints.

All allegations of harassment will be quickly and discreetly investigated. To the extent possible,
employee confidentiality and that of any witnesses and the alleged harasser will be protected against
unnecessary disclosure. When the investigation is completed, employee will be informed of the
outcome of the investigation. Anyone engaging in sexual or other unlawful behavior will be subject to
disciplinary action, up to and including termination of employment.

5.4 Attendance and Punctuality

To maintain a safe and productive work environment, PGC expects employees to be reliable and to be
punctual in reporting for scheduled work. Absenteeism and tardiness place a burden on other
employees, on PGC, and on PGC’s Client. Poor attendance and excessive tardiness are disruptive. Either
may lead to disciplinary action, up to and including termination of employment.

We recognize that there are times when absences and tardiness cannot be avoided. In such cases, you
are expected to notify your PGC Workforce Solutions Team Specialist and the Client as early as possible,
but no later than the start of your work day. When providing information on absences, please state the
nature of absence and expected duration. Unreported absences of two (2) consecutive work days will
generally be considered a voluntary resignation of your employment with PGC.

5.5 Employee Appearance and Dress

Employees are expected to report to work well groomed, clean and dressed according to the
requirements of his/her position. Some employees may be required to wear business casual clothing or
to comply with the client work site code. Please contact your Workforce Solutions Team Specialist for
specific information regarding acceptable attire for your position. If employee reports to work dressed

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or groomed inappropriately, you may be prevented from working until you return to work well groomed
and wearing proper attire.

5.6 Conflicts of Interest

Employees have an obligation to conduct business within guidelines that prohibit actual or potential
conflicts of interest. This policy establishes only the framework within which PGC wishes the business to
operate. The purpose of these guidelines is to provide general direction so that employees can seek
further clarification on issues related to the subject of acceptable standards of operation.

An actual or potential conflict of interest occurs when an employee is in a position to influence a

decision that may result in a personal gain for that employee or for a relative as a result of PGC’s or PGC
Client’s business dealings. For the purposes of this policy, a relative is any person who is related by
blood or marriage or whose relationship with the employee is similar to that of persons who are related
by blood or marriage.

No “presumption of guilt” is created by the mere existence of a relationship with outside PGC Client or
Client customers. However, if employees have any influence on transactions involving purchases,
contracts, or leases, it is imperative that they disclose to an officer of PGC as soon as possible the
existence of any actual or potential conflict of interest so that safeguards can be established to protect
all parties.

Personal gain may result not only in cases where an employee or relative has a significant ownership in a
firm with which PGC and/or PGC Client does business, but also when an employee or relative receives
any kickback, bribe, substantial gift, or special consideration as a result of any transaction or business
dealings involving PGC and/or PGC Client.

5.7 Safety in the Workplace

Our employees are PGC’s most valuable asset and it is important that employee always exercise due
care when working for PGC. It is the responsibility of the on-site Client Manager to ensure safety of all
PGC employees when PGC employee is performing services at the site of the Client.

If an Employee feels concerned for their safety while on a client work-site bring it to the attention of a
PGC Workforce Solutions Team Specialist immediately. Reports and concerns about workplace safety
issues may be made anonymously if the employee wishes. All reports can be made without fear of
reprisal.

Each employee is expected to obey safety rules provided to them by PGC and/or the Client and to
exercise caution in all work activities. Employees who violate safety standards, who cause hazardous or
dangerous situations, or who fail to report or, where appropriate, remedy such situations may be
subject to disciplinary action, up to and including termination of employment.

In the case of accidents that result in injury, regardless of how insignificant the injury may appear,
employees should immediately notify their PGC Workforce Solutions Team Specialist. Such reports are
necessary to comply with laws and initiate insurance and workers’ compensation benefits procedures.
It is important that the employee become familiar with each client’s safety procedures and equipment.

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 5.8 Workplace Violence Prevention
PGC is committed to preventing workplace violence and to maintaining a safe work environment, free
from all forms of violence. Any acts or threats of physical violence occurring on PGC and/or Client
premises, or while conducting PGC and/or Client business is strictly prohibited. PGC has adopted the
following guidelines to deal with intimidation, harassment, or other threats of (or actual) violence that
may occur during business hours or on PGC and/or Client premises.

All employees of PGC and employees of Client should be treated with courtesy and respect at all times.
Employees are expected to refrain from fighting, “horseplay,” or other conduct that may be dangerous
to others. Firearms, weapons, and other dangerous or hazardous devices or substances are prohibited
from the premises of PGC or Client. Conduct that threatens, intimidates, or coerces another employee,
a customer, or a member of the public at any time, including off-duty periods, will not be tolerated. This
prohibition includes all acts of harassment, including harassment that is based on an individual’s sex,
race, age, or any characteristic protected by federal, state, or local law.

All threats of (or actual) violence, both direct and indirect, should be reported as soon as possible to
your PGC Workforce Solutions Team Specialist. This includes threats by PGC employees, Client
employees, customers, vendors, solicitors, or other members of the public. When reporting a threat of
violence, you should be as specific and detailed as possible. No employee will be subjected to
retaliation, intimidation, or disciplinary action as a result of reporting a threat in good faith under this
policy.

5.9 Conflict Resolution between Employee and Client

With regard to workplace disagreements, concerns, or complaints, PGC employees are expected to
handle the situation in a mature and professional manner. PGC expects the employee to attempt
resolution of any issues with calm demeanor and discretion. PGC’s recommended protocol is for the
employee to first address the matter with the individuals involved in one-on-one private discussion. If
such private discussion does not lead to resolution, the employee is to address the issue with their PGC
Workforce Solutions Team Specialist. In the case of conflicts between or related to PGC personnel at the
client site, a PGC employee is not to approach the Client but rather address the matter with PGC.
Should the matter require the Client’s attention, PGC will engage the Client directly. Although PGC
cannot guarantee that every issue will be resolved to the employee’s satisfaction, all matters will be
investigated thoroughly, consistently, and without bias, regardless of the individuals involved. To the
extent possible, PGC will keep conflicts, concerns, complaints, and their resolution confidential.

6. ETHICAL AND LEGAL CONCERNS

6.1 Business Ethics and Conduct

The successful business operation and reputation of PGC are built upon the principles of fair dealing and
ethical conduct of our employees. Our reputation for integrity and excellence requires careful
observance of the spirit and the letter of all applicable laws and regulations, as well as a scrupulous
regard for the highest standards of conduct and personal integrity.

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The continued success of PGC is dependent upon our clients’ and outside parties’ trust and we are
dedicated to preserving that trust. Employees owe a duty to PGC, its clients, and any outside parties
whom have a relationship with PGC to act in a way that will merit the continued trust and confidence of
the public.

PGC will comply with all applicable laws and regulations and expects its directors, officers, and
employees to conduct business in accordance with the letter, spirit, and intent of all relevant laws and
to refrain from any illegal, dishonest, or unethical conduct.

In general, the use of good judgment, based on high ethical principles, will guide you with respect to
lines of acceptable conduct. If a situation arises where it is difficult to determine the proper course of
action, the matter should be discussed openly with your and, if necessary, with the your PGC Workforce
Solutions Team Specialist for advice and consultation.

Compliance with this policy of business ethics and conduct is the responsibility of every PGC employee.
Disregarding or failing to comply with this standard of business ethics and conduct could lead to
disciplinary action, up to and including possible termination of employment.

6.2 Equal Employment Opportunity

In order to provide equal employment and advancement opportunities to all individuals, employment
decisions at PGC will be based on merit, qualifications, and the needs of the company. PGC does not
unlawfully discriminate in employment opportunities or practices on the basis of race, color, religion,
sex, national origin, age, disability, ancestry, medical conditions, family care status, sexual orientation
political affiliations, genetic information, or any other basis prohibited by federal, state, or local law.

PGC will endeavor to accommodate the sincere religious beliefs of its employees to the extent such
accommodation does not pose an undue hardship on PGC’s operations. If you wish to request such an
accommodation, speak with a PGC Workforce Solutions Team Specialist.

Any employees with questions or concerns about any type of discrimination in the workplace are
encouraged to bring these issues to the attention of their PGC Workforce Solutions Team Specialist.
Employees can raise concerns and make reports without fear of intimidation, reprisal, or retaliation.
Anyone found to be engaging in any type of unlawful discrimination will be subject to disciplinary action,
up to and including termination of employment.

Title II of the Genetic Information Nondiscrimination Act (GINA) of 2008 protects applicants and
employees from discrimination based on genetic information in hiring, promotion, discharge, pay, fringe
benefits, job training, classification, referral, and other aspects of employment. GINA also restricts
employers’ acquisition of genetic information and strictly limits disclosure of genetic information.
Genetic information includes information about genetic tests of applicants, employees or their family
members; the manifestation of diseases or disorders in family members (family medical history); and
requests for or receipt of genetic services by applicants, employees or their family members.

6.3 Disability Accommodation

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PGC is committed to complying fully with applicable disability laws and ensuring equal opportunity in
employment for qualified persons with disabilities in accordance with the Americans with Disabilities
Act. PGC and Client will make reasonable accommodations for qualified individuals with known
disabilities unless doing so would result in an undue hardship, on PGC or the Client, to the extent
required by law. This policy governs all aspects of employment, including selection, job assignment,
compensation, discipline, termination, and access to benefits and training. All employment decisions
are based on the merits of the situation and the needs of the company and client, not the disability of
the individual.

Hiring procedures have been reviewed and provide persons with disabilities meaningful employment
opportunities. Pre-employment inquiries are made regarding only an applicant’s ability to perform the
duties of the position. If assistance is needed to perform job duties because of a physical or mental
condition, employee is to inform their PGC Workforce Solutions Team Specialist or PGC’s main office.
Employees are expected to cooperate with PGC and engage in an interactive process to determine what
reasonable accommodations might be available.

PGC is also committed to not unlawfully discriminating against any qualified employees or applicants
because they are related to or associated with a person with a disability.

This policy is neither exhaustive nor exclusive. PGC is committed to taking all other actions necessary to
ensure equal employment opportunity for persons with disabilities in accordance with the ADA and all
other applicable federal, state, and local laws.

6.4 Non-Disclosure
The protection of confidential business information and trade secrets is vital to the interests and the
success of PGC and PGC Client Companies. Such confidential information includes, but is not limited to,
the following examples:

• acquisitions
• compensation data
• computer processes
• computer programs and codes
• customer lists
• customer preferences
• financial information
• investments
• labor relations strategies
• marketing strategies
• new materials research
• partnerships
• pending projects and proposals
• proprietary production processes
• research and development strategies
• scientific data

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 • scientific formulae
• scientific prototypes
• technological data
• technological prototypes

Employees may be required to sign a non-disclosure agreement as a condition of employment at the

request of PGC and/or PGC Client. Employees who improperly use or disclose trade secrets or
confidential business information will be subject to disciplinary action, up to and including termination
of employment and legal action, even if they do not actually benefit from the disclosed information.

Further, employees are prohibited from any unauthorized use of PGC’s intellectual property, including
but not limited to audio and video recordings, print materials, and software.

6.5 Grievances
Employees are encouraged to bring concerns, problems, and grievances regarding Client, Client
employees, working conditions, or any further grievance to the attention of their PGC Workforce
Solutions Team Specialist. Employee is also obligated to report any wrongdoing of which he/she
becomes aware of to their PGC Workforce Solutions Team Specialist or other PGC authority.

7. PERSONAL DATA AND EMPLOYEE INFORMATION

7.1 Access to Personnel Files

PGC maintains a personnel file on each employee. The personnel file includes such information as the
employee’s résumé, I-9 Employment Verification, work authorization documents, submitted reports
from employee and/or Client, records of training, documentation of performance appraisals and salary
increases, and other employment records.

Personnel files are the property of PGC and access to the information may be restricted in accordance
with federal and state law. Generally, only supervisors and management personnel of PGC who have a
legitimate reason to review information in a file are allowed to do so. Employees who wish to review
their own file should contact their PGC Workforce Solutions Team Specialist. With reasonable advance
notice, employees may review their own personnel files under supervision and discretion of an
individual appointed by PGC to maintain the files.

PGC may share certain personnel/human resource data concerning its employees with nonaffiliated
third parties, including but not limited to third party administrators, when they are acting on our behalf,
or acting jointly with PGC for the purpose of processing payroll, workers’ compensation claims,
unemployment benefits, or any other such matter related to employment. Such data may include
name, address, social security number, employee ID number, job description, and related information.
PGC may also share such data with our Clients in connection with providing services to them. In
addition, such data may be shared with other parties as permitted or required by law such as credit
bureaus, government entities, in responding to subpoenas and other legal processes, and those with
whom you have requested us to share information.

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 7.2 Electronic Communications Policy
During the course of your project at PGC Clients, employee may have access to clients’ computers
and/or other electronic communications systems, including but not limited to voicemail, email, client
databases, internet, and intranet systems. Such systems are intended for business use related to client
business, and not personal use. No users of client systems from any location have any expectation of
privacy as between the PGC Employee and Client, and all communications made with or on client
systems or equipment are subject to client surveillance, use and disclosure, in client’s sole discretion.
When working at a client site, employees are required to follow the guidelines that are provided by
the client regarding their communication and computer systems.

PGC policies prohibiting harassment, in their entirety, apply to the use of PGC’s communication and
computer systems. No one may use any communication or computer system in a manner that may be
construed by others as harassing or offensive based on race, national origin, sex, sexual orientation, age,
disability, religious beliefs or any other characteristic protected by federal, state or local law.

Unauthorized duplication of copyrighted computer software violates the law and is strictly prohibited.
No employee may access, or attempt to access, another employee’s computer system without
appropriate authorization.

Any PGC provided or Client provided portable communication devices (PCDs) including cell phones and
personal digital assistants, should be used primarily for business purposes. Employees have no
reasonable expectation of privacy in regard to such devices, and all use is subject to monitoring to the
maximum extent permitted by applicable law. Employee may not use their personal PCD for business
unless they agree to submit the device to PGC on or before their last day of work for resetting and
removal of PGC information. This is done to ensure all PGC information is removed from the device at
time of termination is it is crucial to ensure compliance with PGC confidentiality and proprietary
information policies and objectives.

7.3 Personal Data Changes

It is the responsibility of each employee to promptly notify PGC of any changes in personal data.
Personal mailing addresses, telephone numbers, number and names of dependents, individuals to be
contacted in the event of an emergency, all must be up to date and accurate. Additionally, proper
United States work authorization must remain active at all times. Unreported changes of address,
marital status, etc. could affect your withholding tax and benefit coverage. If any personal data has
changed, employee must notify PGC Workforce Solutions Team Specialist immediately.

7.4 Inspections
PGC reserves the right, as permitted by law and dictated by the circumstances at hand, to require
employees while on PGC property or on Client property, to agree to the inspection of their persons,
personal possessions and property, personal vehicles parked on PGC or client property, and work areas.
This includes, as permitted by law and dictated by the circumstances at hand, lockers, vehicles, desks,
cabinets, work stations, packages, handbags, briefcases, and other personal possessions or places of

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concealment, as well as personal mail sent to PGC or its clients. Employees are expected to cooperate in
the conduct of any search or inspection

7.5 Defense of Trade Secrets Act

Defense of Trade Secrets Act: An individual shall not be held criminally or civilly liable under any Federal
or State trade secret law for the disclosure of a trade secret that—(A) is made—(i) in confidence to a
Federal, State, or local government official, either directly or indirectly, or to an attorney; and (ii) solely
for the purpose of reporting or investigating a suspected violation of law; or (B) is made in a complaint
or other document filed in a lawsuit or other proceeding, if such filing is made under seal. Accordingly,
the parties to this Agreement have the right to disclose in confidence trade secrets to Federal, State, and
local government officials, or to an attorney, for the sole purpose of reporting or investigating a
suspected violation of law. The parties also have the right to disclose trade secrets in a document filed in
a lawsuit or other proceeding, but only if the filing is made under seal and protected from public
disclosure. Nothing in this Agreement is intended to conflict with 18 U.S.C. § 1833(b) or create liability
for disclosures of trade secrets that are expressly allowed by 18 U.S.C. § 1833(b).

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The PGC EMPLOYEE HANDBOOK describes expectations of our employees and outlines the
policies, programs, and benefits available to eligible PGC employees. Additionally, the Handbook
prepares employees for placement on projects with our Clients. Employees should familiarize
themselves with the contents of the Handbook as it will answer many questions about
employment with PGC.

I acknowledge that I have read and understand PGC’s employee handbook and stated policies
including any provided state specific appendices.

_____________________________________
Signature

Khoa Pham
_____________________________________
Name

_____________________________________
Date

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