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HARBOR RAIL SERVICES OF

CALIFORNIA, INC.

EMPLOYEE HANDBOOK
TABLE OF CONTENTS

Section Page

WELCOME ..................................................................................................................................................................... 1

CODE OF ETHICS AND BUSINESS CONDUCT .................................................................................................................. 7

PURPOSE OF THIS HANDBOOK ...................................................................................................................................... 7

EQUAL OPPORTUNITY AND COMMITMENT TO DIVERSITY ........................................................................................... 8

REASONABLE ACCOMMODATIONS ............................................................................................................................... 9

PROHIBITED HARASSMENT & RETALIATION ............................................................................................................... 10

COMPLAINT PROCEDURE ............................................................................................................................................ 12

JOB TITLES AND JOB DESCRIPTIONS ............................................................................................................................ 13

OPEN COMMUNICATION ............................................................................................................................................ 13

PERSONNEL RECORDS ................................................................................................................................................. 14

CONFIDENTIALITY AND PRIVACY ................................................................................................................................. 14

OUTSIDE EMPLOYMENT .............................................................................................................................................. 15

EMPLOYEE CLASSIFICATIONS ...................................................................................................................................... 15

WORKING HOURS AND OVERTIME ............................................................................................................................. 15

TIMECARDS ................................................................................................................................................................. 16

PAY SCHEDULE AND POLICIES ..................................................................................................................................... 16

REST BREAKS AND MEAL PERIODS .............................................................................................................................. 17

LACTATION POLICY ...................................................................................................................................................... 18

ATTENDANCE............................................................................................................................................................... 19

LEAVES OF ABSENCE.................................................................................................................................................... 20

TIME OFF FOR VOTING ................................................................................................................................................ 24

VACATION/ SICK/HOLIDAY PAY ................................................................................................................................... 24

BENEFITS ..................................................................................................................................................................... 27

HIRING PROCESS AND PROCEDURES........................................................................................................................... 28

EMPLOYMENT OF RELATIVES AND DOMESTIC PARTNERS .......................................................................................... 29

PERFORMANCE EVALUATIONS .................................................................................................................................... 29

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PROMOTIONS AND ADVANCEMENT ........................................................................................................................... 30

PROGRESSIVE DISCIPLINE ............................................................................................................................................ 30

STANDARDS OF CONDUCT .......................................................................................................................................... 30

BUSINESS ATTIRE/SCENTS/FRAGRANCE ...................................................................................................................... 32

DRUGS AND ALCOHOL ................................................................................................................................................ 33

SMOKING .................................................................................................................................................................... 34

SAFETY AND EMERGENCIES ........................................................................................................................................ 34

USE OF COMPANY VEHICLES ....................................................................................................................................... 35

FIREARMS AND WEAPONS/ANTI-VIOLENCE ............................................................................................................... 35

FIRE PREVENTION AND CONTROL ............................................................................................................................... 36

SECURITY ..................................................................................................................................................................... 36

HOUSEKEEPING ........................................................................................................................................................... 36

WORKPLACE SEARCHES ............................................................................................................................................... 36

VOICEMAIL SYSTEMS ................................................................................................................................................... 37

RESTRICTIONS ON COMPUTER USE ............................................................................................................................ 37

LAPTOP POLICY ............................................................................................................................................................ 37

ELECTRONIC DEVICE POLICY........................................................................................................................................ 38

TECHNOLOGY AND SECURITY ...................................................................................................................................... 40

ELECTRONIC COMMUNICATIONS................................................................................................................................ 41

SOCIAL NETWORKING AND MEDIA ............................................................................................................................ 42

SOLICITATION AND DISTRIBUTION OF LITERATURE .................................................................................................... 43

ACKNOWLEDGMENT .................................................................................................................................................. 44

APPENDIX A ................................................................................................................................................................ 45

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WELCOME

TO HARBOR RAIL SERVICES OF CALIFORNIA, INC.

AND

COAST TRUCK CENTERS, INC.

We are pleased that you have chosen to join all the dedicated people who make Harbor Rail
Services of California, Inc. and Coast Truck Centers, Inc. the outstanding organization that it is.

Whether you are a new employee, or have been with the Company for some time, you are
part of a team of individuals dedicated to making the Company what it has become through integrity
and excellent service to our customers while providing our employees a good place to work.

You can expect challenging work, fair treatment, and individual respect. In turn, the Company
expects your best efforts in the performance of your job. Your contribution is important to your own
success, the success of others with whom you work, to the Company, and to our customers.

We welcome you to the Company and sincerely hope that you will enjoy your association
with us as a member of the Harbor Rail Services of California, Inc. and Coast Truck Centers, Inc. team.

Mark Myronowicz
President

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Our Vision
The future growth and success of Harbor Rail Services and Coast Truck Centers has at its core three
quintessential elements:
• A strong and lasting relationship with our customers
• Unequivocal commitment and dedication to our employees
• Constant honing and strengthening of the connection we have with our suppliers

When driving on the I-5 we want all commercial drivers to think of Coast Truck Centers as the authority and
expert service provider in all Carrier transit refrigeration related matters.
Coast Truck Centers will keep you cool in transit

Our Mission
To meet our vision, Harbor Rail Services and Coast Truck Centers are committed 100% to exceed every
expectation by offering superb customer service and state of the art solutions. Our professional staff will
deliver exceptional expertise and craftsmanship at competitive prices that translates into an unequaled value
to you.

Company Values
INTEGRITY
Do what is right! With truth, trust and respect, we will do what is right all the time. Our clients have peace of
mind knowing that any recommendation we make is always based on what is best for them and never based
on commissions, over-rides, or bonuses. We are building relationships for the future.

PROFESSIONALISM
We take exceptional pride and enthusiasm in everything we do for our customers. We will listen and do
whatever it takes to make you, the customer, a happy customer. Harbor Rail Services and
Coast Truck Center employees will treat you with the respect you deserve and develop a long-lasting
relationship with you.

SERVICE
Our Carrier certified team has an excellent technical background and insight, enabling us to understand your
requirements and help you select the best solution for your needs. Our service team will ensure that the
equipment we service continues to perform as expected.

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CODE OF ETHICS AND BUSINESS CONDUCT

Build Trust and Credibility


The success of our business is dependent on the trust and confidence we earn from our employees, customers
and shareholders. We gain credibility by adhering to our commitments, displaying honesty and integrity and
reaching company goals solely through honorable conduct. It is easy to say what we must do, but the proof is
in our actions. Ultimately, we will be judged on what we do.

Respect for the Individual


We all deserve to work in an environment where we are treated with dignity and respect. The Company is
committed to creating such an environment because it brings out the full potential in each of us, which, in
turn, contributes directly to our business success. We cannot afford to let anyone’s talents go to waste.

Create a Culture of Open and Honest Communication


At the Company everyone should feel comfortable to speak his or her mind, particularly with respect to ethics
concerns. Managers have a responsibility to create an open and supportive environment where employees
feel comfortable raising such questions. We all benefit tremendously when employees exercise their power
to prevent mistakes or wrongdoing by asking the right questions at the right times.

Set Tone at the Top


Management has the added responsibility for demonstrating, through their actions, the importance of this
Code. In any business, ethical behavior does not simply happen; it is the product of clear and direct
communication of behavioral expectations, modeled from the top and demonstrated by example. Again,
ultimately, our actions are what matters. To make our Code work, managers must be responsible for promptly
addressing ethical questions or concerns raised by employees and for taking the appropriate steps to deal
with such issues. Managers should not consider employees’ ethics concerns as threats or challenges to their
authority, but rather as another encouraged form of business communication. We want the ethics dialogue
to become a natural part of daily work.

Uphold the Law


The Company’s commitment to integrity begins with complying with laws, rules and regulations where we do
business. Further, each of us must have an understanding of the Company policies, laws, rules and regulations
that apply to our specific roles. If we are unsure of whether a contemplated action is permitted by law or
Company policy, we should seek the advice from the resource expert. We are responsible for preventing
violations of law and for speaking up if we see possible violations.

Competition
We are dedicated to ethical, fair and vigorous competition. We will sell our products and services based on
their merit, superior quality, functionality and competitive pricing. We will make independent pricing and
marketing decisions and will not improperly cooperate or coordinate our activities with our competitors. We
will not offer or solicit improper payments or gratuities in connection with the purchase of goods or services
for the Company or the sales of its products or services, nor will we engage or assist in unlawful boycotts of
particular customers.

Proprietary Information
It is important that we respect the property rights of others. We will not acquire or seek to acquire improper
means of a competitor’s trade secrets or other proprietary or confidential information. We will not engage in
unauthorized use, copying, distribution or alteration of software or other intellectual property.

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Selective Disclosure
We will not selectively disclose (whether in one-on-one or small discussions, meetings, presentations,
proposals or otherwise) any material nonpublic information with respect to the Company, its business
operations, plans, financial condition, results of operations or any development plan. We should be
particularly vigilant when making presentations or proposals to customers to ensure that our presentations
do not contain material nonpublic information.

Avoid Conflicts of Interest


Conflicts of Interest
We must avoid any relationship or activity that might impair, or even appear to impair, our ability to make
objective and fair decisions when performing our jobs. At times, we may be faced with situations where the
business actions we take on behalf of the Company may conflict with our own personal or family interests.
We owe a duty to the Company to advance its legitimate interests when the opportunity to do so arises. We
must never use Company property or information for personal gain or personally take for ourselves any
opportunity that is discovered through our position with the Company.

Here are some other ways in which conflicts of interest could arise:
1. Being employed (you or a close family member) by, or acting as a consultant to, a competitor or potential
competitor, supplier or contractor, regardless of the nature of the employment, while you are employed with
the Company.
2. Hiring or supervising family members or closely related persons.
3. Serving as a board member for an outside commercial company or organization.
4. Owning or having a substantial interest in a competitor, supplier or contractor.
5. Having a personal interest, financial interest or potential gain in any Company transaction.
6. Placing Company business with a firm owned or controlled by a Company employee or his or her family.
7. Accepting gifts, discounts, favors or services from a customer/potential customer, competitor or supplier,
unless equally available to all Company employees.
Determining whether a conflict of interest exists is not always easy to do. Employees with a conflict of interest
question should seek advice from management. Before engaging in any activity, transaction or relationship
that might give rise to a conflict of interest, employees must seek review from their managers or Human
Resources.

Gifts, Gratuities and Business Courtesies


The Company is committed to competing solely on the merit of our products and services. We should avoid
any actions that create a perception that favorable treatment of outside entities by the Company was sought,
received or given in exchange for personal business courtesies. Business courtesies include gifts, gratuities,
meals, refreshments, entertainment or other benefits from persons or companies with whom the Company
does or may do business. We will neither give nor accept business courtesies that constitute, or could
reasonably be perceived as constituting, unfair business inducements that would violate law, regulation or
polices of the Company or customers, or would cause embarrassment or reflect negatively on the Company’s
reputation.

Accepting Business Courtesies


Most business courtesies offered to us in the course of our employment are offered because of our
positions at the Company. We should not feel any entitlement to accept and keep a business courtesy.
Although we may not use our position at the Company to obtain business courtesies, and we must never ask
for them, we may accept unsolicited business courtesies that promote successful working relationships and
good will with the firms that the Company maintains or may establish a business relationship with.

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Meals, Refreshments and Entertainment
We may accept occasional meals, refreshments, entertainment and similar business courtesies that are shared
with the person who has offered to pay for the meal or entertainment, provided that:
• They are not inappropriately lavish or excessive.
• The courtesies are not frequent and do not reflect a pattern of frequent acceptance of courtesies from the
same person or entity.
• The courtesy does not create the appearance of an attempt to influence business decisions, such as
accepting courtesies or entertainment from a supplier whose contract is expiring in the near future.
• The employee accepting the business courtesy would not feel uncomfortable discussing the courtesy with
his or her manager or co-worker or having the courtesies known by the public.

Gifts
Employees may accept unsolicited gifts, other than money, that conform to the reasonable ethical practices
of the marketplace, including:
• Flowers, fruit baskets and other modest presents that commemorate a special occasion.
• Gifts of nominal value, such as calendars, pens, mugs, caps and t-shirts (or other novelty, advertising or
promotional items).
Generally, employees may not accept compensation, honoraria or money of any amount from entities with
whom the Company does or may do business. Tangible gifts (including tickets to a sporting or entertainment
event) that have a market value greater than $100 may not be accepted unless approval is obtained from
management. Employees with questions about accepting business courtesies should talk to their managers
or Human Resources.

Offering Business Courtesies


Any employee who offers a business courtesy must assure that it cannot reasonably be interpreted as an
attempt to gain an unfair business advantage or otherwise reflect negatively upon the Company. An employee
may never use personal funds or resources to do something that cannot be done with Company resources.
Accounting for business courtesies must be done in accordance with approved Company procedures.

Other than to our government customers, for whom special rules apply, we may provide nonmonetary gifts
(i.e., company logo apparel or similar promotional items) to our customers. Further, management may
approve other courtesies, including meals, refreshments or entertainment of reasonable value, provided that:
• The practice does not violate any law or regulation or the standards of conduct of the recipient’s
organization.
• The business courtesy is consistent with industry practice, is infrequent in nature and is not lavish.
• The business courtesy is properly reflected on the books and records of the Company.

Set Metrics and Report Results Accurately


Accurate Public Disclosures
We will make certain that all disclosures made in financial reports and public documents are full, fair, accurate,
timely and understandable. This obligation applies to all employees, including all financial executives, with
any responsibility for the preparation for such reports, including drafting, reviewing and signing or certifying
the information contained therein. No business goal of any kind is ever an excuse for misrepresenting facts or
falsifying records.

Employees should inform Executive Management and Human Resources if they learn that information in any
filing or public communication was untrue or misleading at the time it was made or if subsequent information
would affect a similar future public communication.

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Corporate Recordkeeping
We create, retain and dispose of our Company records as part of our normal course of business in compliance
with all Company policies and guidelines, as well as all regulatory and legal requirements.
All corporate records must be true, accurate and complete, and Company data must be promptly and
accurately entered in our books in accordance with the Company’s and other applicable accounting principles.

Promote Substance Over Form


At times, we are all faced with decisions we would rather not have to make and issues we would prefer to
avoid. Sometimes, we hope that if we avoid confronting a problem, it will simply go away.
At the Company, we must have the courage to tackle the tough decisions and make difficult choices, secure
in the knowledge that the Company is committed to doing the right thing. At times this will mean doing more
than simply what the law requires. Merely because we can pursue a course of action does not mean we should
do so.

Accountability
Each of us is responsible for knowing and adhering to the values and standards set forth in this Code and for
raising questions if we are uncertain about Company policy. If we are concerned whether the standards are
being met or are aware of violations of the Code, we must contact Human Resources. The Company takes
seriously the standards set forth in the Code, and violations are cause for disciplinary action up to and
including termination of employment.

Be Loyal
Confidential and Proprietary Information
Integral to the Company’s business success is our protection of confidential Company information, as well as
nonpublic information entrusted to us by employees, customers and other business partners. Confidential
and proprietary information includes such things as pricing and financial data, customer names/addresses or
nonpublic information about other companies, including current or potential supplier and vendors. We will
not disclose confidential and nonpublic information without a valid business purpose and proper
authorization.

Use of Company Resources


Company resources, including time, material, equipment and information, are provided for Company business
use. Nonetheless, occasional personal use is permissible as long as it does not affect job performance or cause
a disruption to the workplace. Employees and those who represent the Company are trusted to behave
responsibly and use good judgment to conserve Company resources. Managers are responsible for the
resources assigned to their departments and are empowered to resolve issues concerning their proper use.

Do the Right Thing


Several key questions can help identify situations that may be unethical, inappropriate or illegal. Ask yourself:
• Does what I am doing comply with the Company guiding principles, Code of Conduct and Company policies?
• Have I been asked to misrepresent information or deviate from normal procedure?
• Would I feel comfortable describing my decision at a staff meeting?
• How would it look if it made the headlines?
• Am I being loyal to my family, my company and myself?
• What would I tell my child to do?
• Is this the right thing to do?

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PURPOSE OF THIS HANDBOOK

The information and guidelines in this handbook apply to all employees of both Harbor Rail Services of California,
Inc. and Coast Truck Centers, Inc. (collectively, the “Company”).

This employee handbook contains the employment policies and practices of the Company and supersedes all
previous employee handbooks, policies or representations, whether verbal or written, as to any of the matters
described herein.

Neither this handbook nor any of its provisions is an employment contract. Please recognize that, as guidelines,
the information in this handbook is subject to change at any time. The Company reserves the right to revise,
modify, rescind, suspend, delete, revoke or add to any and all content, policies, procedures, work rules, or benefits
stated in this handbook, except for the policy of at-will employment, at any time, in whole or in part, with or
without notice, in the Company’s sole discretion. Employees will be notified of any changes. No oral statements
or representations in any way alter the provisions of this handbook.

Please familiarize yourself with the contents of this handbook, as they provide you with important information
about your employment, what we expect of you, and what you can expect of us. Recognize, however, that this
handbook does not contain an exhaustive list of every rule, policy, or procedure that exists in the Company, but
rather, information about things you need to know in order to successfully perform your job and have a positive
and productive work experience.

This handbook does not prohibit protected conduct or communications relating to your wages, hours or working
conditions, or any other conduct protected by Section 7 of the National Labor Relations Act.

Furthermore, nothing in this handbook prohibits an employee from reporting concerns to, filing a charge or
complaint with, making lawful disclosures to, providing documents or other information to or participating in an
investigation or hearing conducted by the Equal Employment Opportunity Commission (“EEOC”), National Labor
Relations Board (“NLRB”), Securities and Exchange Commission (“SEC”) or any other federal, state or local agency
charged with the enforcement of any laws.

If you have any questions about any of the materials described in this handbook, please direct them to Human
Resources. The final decision as to the meaning or interpretation of any particular provision in the pages that
follow lies at the sole and exclusive discretion of the Company.

“At Will” Employment Relationship


Neither the existence of this handbook, nor any of the information it contains, is intended to constitute, create,
or imply a contract of employment between you and the Company. Your employment with the Company is “at-
will” and for no definite period. The Company or its employees may terminate employment at any time, for any
reason, with or without cause, and with or without notice, except as prohibited by statute or public policy. This
also means that your terms and conditions of employment may be changed with or without notice, and with or
without cause, including but not limited to termination, demotion, promotion, transfer, compensation, benefits,
duties, and location of work. This “employment at-will” relationship remains in effect regardless of any statement
made in this handbook, company policies and practices, or any written or oral communication. No supervisor,
manager or other representative of the Company, except the Company President has the authority to make
agreements concerning length of employment, or other terms. Such agreements must be in writing and signed by
the Company President.
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EQUAL OPPORTUNITY AND COMMITMENT TO DIVERSITY

The Company is an equal opportunity employer. The Company’s policy is to provide equal employment
opportunities to all individuals regardless of race, traits historically associated with race, such as hair texture and
protective hairstyles, including braids, locks and twists, color, religious creed (including religious dress and
grooming practices), gender, sex (including married women and unmarried mothers, pregnancy, childbirth,
breastfeeding, lactation and related medical or common conditions relating to pregnancy and childbirth, past
pregnancy condition and the potential or intention to become pregnant), gender identity or expression, marital
status, familial status, domestic partnership status, age (18 and over), national origin or ancestry, citizenship
status, physical or mental disability (including gender dysphoria, or requiring the use of a trained dog guide or
service animal), medical condition including genetic information and characteristics, sexual orientation (including
actual or perceived and including transgender individuals who are transitioning, have transitioned or are perceived
to be transitioning to the gender with which they identify), military or veteran status, unfavorable discharge from
military service, Civil Air Patrol status, protective order status, HIV/AIDs or Hepatitis C status, weight and height,
certain arrest and criminal history records, homelessness (i.e. lack of a permanent mailing address or a mailing
address that is a shelter or social services provider), use of lawful products outside of work during nonworking
hours, immigration status, domestic violence victim status or any other basis prohibited by federal, state, or local
laws. The Company also prohibits unlawful discrimination based on the perception that anyone has any of those
characteristics or is associated with a person who has or is perceived as having any of those characteristics. All
such discrimination is unlawful.

The Company is committed to compliance with all applicable laws providing equal employment opportunities.
This commitment applies to all persons involved in Company operations and prohibits unlawful discrimination by
any employee of the Company, including supervisors and coworkers. This policy pertains to all Company
employment decisions, including hiring, recruitment, promotion, training, transfer, layoff, recall demotion,
discipline, termination, use of facilities, participation in Company-sponsored activities, benefits and compensation
and all other terms and conditions of employment. Discrimination can also include failing to reasonably
accommodate religious practices or qualified individuals with disabilities where the accommodation does not pose
an undue hardship to the business. Violation of this policy will result in discipline, up to and including termination.

If you have questions or concerns regarding equal employment opportunity policies, you are encouraged to bring
them to the attention of Human Resources as soon as possible.

Commitment to Diversity and Inclusion


The Company is committed to creating and maintaining a workplace in which all employees have an opportunity
to participate and contribute to the success of the business and are valued for their skills, experience, and unique
perspectives. This commitment is embodied in Company policy and the way the Company does business and is an
important principle of sound business management.

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REASONABLE ACCOMMODATIONS

To comply with applicable laws ensuring equal employment opportunities to qualified individuals with a disability,
the Company will make reasonable accommodations for the known physical or mental limitations of an otherwise
qualified individual with a disability who is an applicant or an employee unless undue hardship would result. Any
applicant or employee who requires an accommodation in order to perform the essential functions of the job,
enjoy an equal opportunity, and/or obtain equal job benefits should contact a Company representative with
day-to-day personnel responsibilities and discuss the need for an accommodation. The Company will engage
in an interactive process with the employee to identify possible accommodations, if any, that may be
appropriate. In some cases, this interactive process may be triggered without a request from the employee,
such as when the Company receives notice from its own observation or another source that a medical
impairment may be impacting the employee’s ability to perform his or her essential job functions. The
individual who believes they need an accommodation must specify, preferably in writing, what barriers or
limitations prompted the request. The Company will evaluate information obtained from the employee, and
possibly his or her health care provider or another appropriate health care provider, regarding any reported
or apparent barriers or limitations, and then will work with the employee to identify possible accommodation(s)
that may be needed, if any, that will help to eliminate or otherwise address the barrier(s) or limitation(s) in
order that the employee may perform the essential job functions. To comply with applicable laws ensuring
equal employment opportunities to qualified individuals with a disability, if an identified accommodation is
reasonable and will not impose an undue hardship on the Company and/or a direct threat to the health and/or
safety of the individual or others, the Company will generally make the accommodation, or it may propose
another reasonable accommodation which may also be effective to enable an otherwise qualified individual
with a disability who is an applicant or an employee to perform the essential functions of the job. Employees
are required to cooperate with this process by providing all necessary documentation supporting the need for
accommodation and being willing to consider alternative accommodations when applicable.

The Company will also consider requests for reasonable accommodations for medical conditions related to
pregnancy, childbirth and lactation where supported by medical documentation and/or as required by
applicable federal, state or local law.

Employees who wish to request unpaid time away from work because of a qualifying disability should speak
with Human Resources regarding a proposed accommodation. The Company will not retaliate against you for
requesting a reasonable accommodation and will not knowingly tolerate or permit retaliation by management,
employees or co-workers.

Religious Accommodations
The Company will make reasonable accommodation for employees’ religious beliefs, practices or observance,
including religious dress and grooming practices, when a need for such accommodation is identified and
reasonable accommodation is possible. A reasonable accommodation is one that eliminates the conflict between
an employee’s religious beliefs, practices or observances and the employee’s job requirements, without causing
undue hardship to the Company. Applicants or employees who perceive a conflict between job requirements and
religious belief, practice, or observance should notify Human Resources and submit a written request for
accommodation. Upon receipt of the request, the Company and employee will engage in an interactive process
to determine what, if any, reasonable accommodations exist. If an accommodation is reasonable and will not
impose an undue hardship, the Company will make the accommodation.

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PROBHIBTED HARASSMENT & RETALIATION

The Company is committed to providing a work environment that is free of illicit harassment based on any
protected characteristics. As a result, the Company maintains a strict policy that prohibits sexual harassment and
harassment or any type of retaliation against employees, applicants for employment, individuals providing
services in the workplace under a contract, or volunteers (whether paid or unpaid) on the basis of any legally-
recognized basis including their actual or perceived race, traits historically associated with race, such as hair
texture and protective hairstyles, including braids, locks and twists, color, sex (including married woman and
unmarried mothers, pregnancy, childbirth, breastfeeding and medical or common conditions related to pregnancy,
childbirth, past pregnancy condition, lactation or breastfeeding and the potential or intention to become
pregnant), gender, religious creed (including religious dress and grooming practices), marital status, familial status,
citizenship status, domestic partnership status, age (18 and over), national origin or ancestry, physical or mental
disability (including gender dysphoria, or the use of a trained dog guide or service animal), medical condition,
genetic information and characteristics, sexual orientation (including actual or perceived and including
transgender, individuals who are transitioning, have transitioned or are perceived to be transitioning to the gender
with which they identify), gender identity or expression, military service or veteran status, unfavorable discharge
from military service, Civil Air Patrol status, protective order status, HIV/AIDs or Hepatitis C status, weight or height,
certain arrest or criminal history records, homelessness (i.e., lack of a permanent mailing address or a mailing
address that is a shelter or social services provider), use of lawful products outside of work during nonworking
hours, immigration status, domestic violence victim status, or any other basis protected under federal, state, or
local laws. For purposes of this policy, discrimination on the basis of "national origin" also includes harassment
against an individual because that person holds or presents the California driver's license issued to those who
cannot document their lawful presence in the United States. All such harassment is prohibited.

This policy applies to all persons involved in the operation of the Company and prohibits proscribed harassment
by any employee of or third party interacting with the Company, including coworkers, supervisors, managers, non-
supervisory employees, temporary or seasonal workers as well as third parties such as vendors, clients, customers,
agents, independent contractors, suppliers, and any other persons. If such harassment occurs on the Company’s
premises or is directed toward an employee or a third party interacting with the Company, the complaint
procedures in this policy, below, should be followed. This policy is also part of the Company’s commitment to
diversity and inclusion, and a workplace that is free from harassment, disrespect, and divisiveness.

Violation of this policy will result in discipline, up to and including termination.

Sexual Harassment Defined


Sexual harassment warrants special emphasis and will not be tolerated by the Company. Sexual harassment
may take various forms. It may include behavior listed below with a sexual connotation, but also includes
unwelcome sexual advances, requests for sexual favors, or visual, verbal or physical conduct of a sexual nature
when:
• Submission to such conduct is made a term or condition of an individual’s employment;
• Submission to or rejection of such conduct by an individual is used as the basis for employment
decisions affecting such individual; or
• Such conduct has the purpose or effect of unreasonably interfering with an individual’s work
performance or creating an intimidating, hostile, or offensive working environment.

Sexual harassment also includes various forms of offensive behavior based on sex and includes gender-based
harassment of a person of the same sex as the harasser. The following is a partial list:
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• Unwanted sexual advances;

• Offering employment benefits in exchange for sexual favors;

• Making or threatening reprisals after a negative response to sexual advances;

• Visual conduct including leering; making sexual gestures; displaying sexually suggestive objects or
pictures, cartoons, posters, websites, emails or text messages;

• Verbal conduct including making or using derogatory comments, epithets, slurs, sexually explicit
jokes, or comments about an employee's body or dress;

• Verbal sexual advances or propositions;

• Verbal abuse of a sexual nature; graphic verbal commentary about an individual's body; sexually
degrading words to describe an individual; suggestive or obscene letters, notes or invitations;

• Physical conduct including touching, assault, impeding or blocking movements; or

• Retaliation for reporting harassment or threatening to report sexual harassment.

An employee may be liable for harassment based on sex even if the alleged harassing conduct was not motivated
by sexual desire. An employee who engages in unlawful harassment may be personally liable for harassment even
if the Company had no knowledge of such conduct.

Other Prohibited Harassment


Prohibited harassment in employment may take many different forms. Harassment on the basis of any legally
protected classification is prohibited, including harassment based on race, traits historically associated with race,
such as hair texture and protective hairstyles, including braids, locks and twists, color, religious creed, national
origin, ancestry, age (18 and over), physical or mental disability (including gender dysphoria, or the use of a trained
dog guide or service animal), medical condition, genetic information, sex (including married women and
unmarried mothers) and gender (including lactation and related medical conditions), pregnancy (including
childbirth or medical or common conditions related to pregnancy or childbirth, past pregnancy condition and the
potential or intention to become pregnant) sexual orientation (including actual or perceived), gender identity and
gender expression (including actual or perceived and including transgender individuals who are transitioning, have
transitioned, or are perceived to be transitioning to the gender with which they identify) marital status, familial
status, citizenship status, domestic partnership status, military and veteran service, unfavorable discharge from
military service, Civil Air Patrol status, protective order status, HIV/AIDs or Hepatitis C status, weight and height,
certain arrest or criminal history records, homelessness (i.e., lack of a permanent mailing address or a mailing
address that is a shelter or social services provider), use of lawful products outside of work during nonworking
hours, immigration status, domestic violence victim status or any other consideration protected by federal, state
or local law.

Prohibited harassment may include behavior similar to the illustrations above pertaining to sexual harassment.
This includes conduct such as:

• Verbal conduct such as threats, epithets, derogatory comments, slurs, unwanted comments, or
jokes based on an individual’s protected classification;

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• Visual conduct such as derogatory or inappropriate posters, photographs, cartoons, drawings,
websites or gestures based on protected classification;

• Physical conduct such as assault, blocking normal movement, restraining, unwanted touching, or
otherwise physically interfering with the work of another individual because of an individual’s
protected status; and,

• Threatening or demanding that an individual submit to certain conduct or perform certain actions
in order to keep or get a job, to avoid some other loss, or as a condition of job benefits, security,
or promotion based on an individual’s protected status.

Protection Against Retaliation


Retaliation is prohibited against any person by another employee or by the Company for using the Company’s
complaint procedure, reporting proscribed discrimination or harassment or filing, testifying, assisting or
participating in any manner in any investigation, proceeding or hearing conducted by a governmental
enforcement agency. Prohibited retaliation includes, but is not limited to, termination, demotion, suspension,
failure to hire or consider for hire, failure to give equal consideration in making employment decisions, failure to
make employment recommendations impartially, adversely affecting working conditions or otherwise denying
any employment benefit.

Policy Against Abusive Conduct


The Company prohibits abusive conduct and bullying in the workplace. Persons in the workplace are expected to
perform their jobs productively as assigned, and in a manner that meets all of management’s expectations, during
working times, and that they and refrain from any malicious, patently offensive or abusive conduct. “Abusive
conduct” includes workplace conduct that a reasonable person would find hostile or offensive based on any of
the protected characteristics described above. It may also include repeated infliction of verbal abuse, such as the
use of derogatory remarks, insults, and epithets, verbal or physical conduct that a reasonable person would find
threatening, intimidating, or humiliating, or the sabotage or undermining of a person’s work performance.

COMPLAINT PROCEDURE

If you believe that you have been the subject of harassment, discriminated against, subjected to retaliation,
abusive or other prohibited conduct by a co-worker, supervisor, agent, client, vendor, customer, or any other third
party interacting with the Company in violation of the foregoing policies, or who is aware of such behavior against
others, you should immediately provide a written or verbal report to your own or any other Company supervisor,
manager, the company President or the Human Resources administrator of the Company. Employees are not
required to make a complaint directly to their immediate supervisor. Supervisors and managers who receive
complaints of misconduct must immediately report such complaints to Human Resources who will attempt to
resolve issues internally. Supervisors must refer all complaints involving harassment or other prohibited conduct
to Human Resources or the President of the Company. When a report is received, the Company will undertake a
fair, timely, thorough and objective investigation that provides all parties appropriate due process and reaches
reasonable conclusions based on the evidence collected. The Company expects all employees to fully cooperate
with any investigation conducted by the Company into a complaint of proscribed harassment, discrimination or
retaliation, or regarding the alleged violation of any other Company policies. The Company will maintain
confidentiality surrounding the investigation to the extent possible and to the extent permitted under applicable
federal and state law.

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Upon completion of the investigation, the Company will communicate its conclusion as soon as practical. If the
Company determines that the policy has been violated, remedial action will be taken in accordance with the
circumstances involved, commensurate with the severity of the offense, up to, and including termination. A
Company representative will advise all parties concerned of the results of the investigation. Appropriate action
will also be taken to deter any such conduct in the future.

The Company encourages all employees to report any incidents of harassment or other prohibited conduct
forbidden by this policy immediately so that complaints can be quickly and fairly resolved. You also should be
aware that the federal Equal Employment Opportunity Commission (EEOC) will accept and investigate charges of
unlawful discrimination or harassment at no charge to the complaining party. Information may be located by
visiting the agency website at www.eeoc.gov. California employees may also contact the California Department
of Fair Employment and Housing (DFEH), which will also accept and investigate charges of unlawful discrimination
or harassment at no charge to the complaining party. Information may be located by visiting the agency website
at www.dfeh.ca.gov. Washington employees may contact the Washington State Human Rights Commission
(WSHRC) www.hum.wa.gov. New York employees may contact the Division of Human Rights (DHR) at (888) 392-
3644 or visit dhr.ny.gov/complaint for more information. Employees in other states may also contact any similar
state agency.

JOB TITLES AND JOB DESCRIPTIONS

Job titles and/or job descriptions have been established for each job. Because of changes in business needs and
job content, all job titles and/or job descriptions are subject to periodic evaluation and revision. Operating
requirements may necessitate employees to perform job tasks which do not normally fall within a job title, or
outside of the scope of an established job description.

OPEN COMMUNICATION

The Company strongly encourages open and direct lines of communication between employees and management
as we believe such communication is a critical aspect of the success of any company. If any employee has an
unresolved issue or a question about the information in this handbook or any other aspect of employment, he/she
should proactively and directly communicate their concern or question to the appropriate individual within the
Company, be it his/her supervisor, manager, human resources, or upper management. The employee is not
required to direct concerns to his or her direct supervisor but may bring a concern to any member of management
or Human Resources.

Where a conflict arises with a specific individual, please attempt to peacefully resolve the conflict with that
individual first. However, if this is not fruitful, please speak with your immediate supervisor or Human Resources
about the issue. If necessary, your supervisor may ask you to take the issue to another member of the
management team to ensure the resolution of any situation. Unless established otherwise in this handbook (e.g.,
harassment claims and code of conduct), it is important that any issues be promptly resolved in this manner.

An employee’s information will be treated confidentially to the extent possible, and no employee will be
discriminated against for reporting, in good faith, any concerns or questions relating to any of the terms or
conditions of employment.

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PERSONNEL RECORDS

Every employee is responsible to keep personnel records up to date. All changes in personal information including
change of address, telephone numbers, email address, emergency contacts or family status, must be reported by
the employee immediately and/or updated in Employee Self Service in ADP, or such other payroll system that the
Company may adopt from time to time. Any updates to marital status or number of dependents should be reported
promptly and in no event later than 30 days following a change. Appropriate documentation may be required. All
medical information will be kept in separate, confidential files, and access will be limited to individuals in “need to
know” positions.
Access to the information contained in personnel files is made available to authorized personnel only who have a
legitimate reason to review information in a file. If an employee wants the Company to provide information to
any outside company or individual, the employee must provide to the Company a written authorization and
release in advance in order for such an action to take place.

Employees have the right to inspect their personnel records. An employee and in some cases an employee-
authorized representative (designated in writing) may review and in some cases obtain a copy the contents of his
or her personnel file upon written request and with prior reasonable notice to Human Resources. You may add
your comments to any disputed item in the file. You also have a right to inspect or copy payroll records, as provided
by law, at a mutually convenient time. Employees will generally be granted access to their file in accordance with
applicable law within 3 business days or as otherwise required by law. Representatives of government or law
enforcement agencies, in the course of their duties, may be allowed access to file information.
CONFIDENTIALITY AND PRIVACY

During your employment with the Company, you may be working with our customer lists, business systems,
future, research and development data, and other information that we consider confidential. Maintaining this
confidentiality is important to our competitive position in the industry and ultimately to our ability to achieve
financial success and provide employment stability. Protect this information by safeguarding it when in use, filing
it properly when not being used, and discussing it only with those who have a legitimate business need to know.
Never discuss or disclose such trade secrets, confidential information or property, either directly or indirectly with
or in the presence of persons outside the Company, or those employees who do not have a need to know, either
during employment or at any time thereafter. As condition of your employment, each employee shall sign and
comply with the Protection of Company Assets Agreement: Confidentiality, Non-disclosure and Non-solicitation.
Improper disclosure of confidential information may result in disciplinary action.

Privacy
The Company safeguards personal employee information in its possession to ensure the confidentiality of the
information. The Company will only collect personal information that is required to pursue its business operations
and to comply with government reporting and disclosure requirements. Personal information collected includes
employee names, addresses, telephone numbers, e-mail addresses, emergency contact information, EEO data,
social security numbers, date of birth, employment eligibility data, benefits plan enrollment information, which
may include dependent personal information, and school/college or certification credentials.

Business purposes for which such personal employee information is collected may include the following:

• to comply with state and federal law requiring employers to maintain certain records;
• to effectively process payroll;
• to administer and maintain group insurance benefits, 401K, overall benefit programs; and

November 11, 2019 14 | P a g e


• to manage employee performance of their job duties.

Personal employee information will be considered confidential and as such will be shared only as required and
with those who have a need to have access to such information. All hard copy confidential records will be
maintained in locked, secure areas with access limited to those who have a business need for such access. Any
breach of material involving the confidentiality of employee personal information should be immediately brought
to the attention of Human Resources.
OUTSIDE EMPLOYMENT

Outside employment is not forbidden by the Company, except in those instances where a conflict of interest exists
(such as employment by a competitor) or appears to exist. Employment at the Company is considered primary
and any additional outside employment must not interfere with an employee’s assigned work schedule or impact
their ability to perform at their highest potential. Employees must inform the Company of the nature of any
outside work to ensure against a conflict of interest situation.

EMPLOYEE CLASSIFICATIONS

Employees are classified as “exempt” or “non-exempt” for purposes of overtime status and to ensure compliance
with federal and state regulations. The Company will inform you of your employment classification and status at
time of hire, and/or in the event of a job change such as a promotion or transfer, that affects your classification
or status. The Company may review or change employee classifications at any time. If you have any questions
about your classification or status, please contact Human Resources.

Full-time employees: Full-time employees are those normally scheduled to work at least 30 hours per week, as
determined by the Company in its sole discretion.

Part-time employees: Employment with the Company is full-time; however, part-time employment may be
considered on an infrequent, exception basis should business needs require, as determined by the Company in its
sole discretion. Employees who are regularly scheduled to work fewer than 30 hours weekly, and who maintain
continuous employment status, are considered part-time. Part time employees are not eligible for benefits or
paid vacation.

Exempt employees: Exempt employees are employees whose positions qualify as “exempt” under specific tests
established by state and federal law, including the Fair Labor Standards Act. Exempt employees are not eligible
for overtime pay, regardless of the amount of time worked.

Non-exempt employees: Non-exempt employees are employees whose positions do not satisfy state and federal
exemption tests. Non-exempt employees are subject to and eligible for, among other things, overtime
compensation for hours worked in excess of forty in a workweek and as otherwise required by applicable law,
record keeping requirements, meal periods, and rest breaks.

WORKING HOURS AND OVERTIME

Working hours
Business hours begin at 8:00am and end at 5:00pm, local time. The workweek begins on a Monday at 8:00am and
ends on Friday at 5:00pm, local time. Business hours will be used for purposes of calculating overtime.

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Because of the nature of work performed for the Company, work hours may vary between individual employees
and locations. The Company cannot guarantee a consistent work schedule. Each employee’s specific work
schedule will be established by management. Employees will be notified of their normal work schedules upon hire
and notified of any changes to that schedule prior to the change taking effect. Employees must be willing to work
weekends and or overtime as needed.

Overtime
At times, employees may be asked to work beyond their normal shift. The Company will pay hourly employees’
overtime in accordance with applicable federal and state laws. The Company will make an effort to give advance
notice of overtime whenever possible. Employees are not permitted to work overtime without their supervisor’s
prior approval. If an employee works overtime without obtaining preapproval, the employee will still be paid for
the time worked, but may be subject to discipline, up to and including termination of employment.
Only hours actually worked will be considered in calculating overtime. Hours paid that are not worked (e.g.
vacation days) are not counted as hours worked when computing overtime pay. If employees are required to work
on paid holidays, they will be paid for the holiday, plus actual hours worked.

TIMECARDS

Accurately recording time worked is the responsibility of every employee. All non-exempt employees are required
to report all hours worked; off-the-clock work at any time is strictly prohibited and can lead to disciplinary action.
Altering, falsifying, tampering with time records, or recording time on another team member’s time record will
result in disciplinary action, up to and including termination of employment.

Authorized personnel will review time records each week. Any changes to an employee’s time record must be
approved by his/her supervisor or appropriate person. Questions regarding the timekeeping system should be
directed to the Human Resources team.

Meal periods may vary by Company location. Check with your supervisor regarding your meal period. When an
employee takes a meal period they must punch out and punch in to the timekeeping system. An employee may
not punch another employee’s timecard or allow someone else to punch his or her timecard or enter any false
information on any timecard. Violation of this policy may result in disciplinary action, up to and including
termination of employment.

PAY SCHEDULE AND POLICIES

All employees are paid on a semi-monthly basis on the 7th and 22nd day of the month for time worked from the
16th of the month through the 30th or 31st, and the 1st of the month thru the 15th, respectively. In the event a pay
day falls on a weekend or a holiday, the pay checks shall be distributed on the previous business day. The Company
offers direct deposit to all employees. Any employee who chooses not to utilize direct deposit will be issued a
check or if an employee voluntarily agrees, the employee will be issued a pay card and pay will be deposited onto
the pay card in accordance with applicable law.
Payroll Deductions
The law requires that the Company make certain deductions from your compensation. Among these are
applicable federal, state, and local income taxes. The Company also must deduct Social Security taxes on your
earnings up to a specified limit and will deduct all authorized voluntary deductions, such as health insurance
contributions, which will be withheld automatically from paychecks. Other deductions may be required by law.
For questions about deductions, please see the Payroll Department or Human Resources.

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Pay Policies
The Company is committed to abiding by all applicable state and federal wage and hour statutes and regulations.
As part of this commitment, the Company does not make improper deductions from exempt employees’ salary
payments and complies with the salary basis requirements of the Fair Labor Standards Act (FLSA). Employees
classified as exempt from the overtime pay requirements of the FLSA will be notified of this classification at the
time of hire or change in position.

Generally, an exempt employee must be paid his/her weekly salary, without deduction, for any workweek during
which the employee performs work. However, an exempt employee's salary may be reduced in certain situations.
For example, an exempt employee’s salary may be reduced for complete days of absence due to unpaid time off
for personal need and incomplete initial and final weeks of work.

An exempt employee's salary will not be reduced due to partial weeks of work due to service as a juror,
subpoenaed witness, military service, or for lack of work. This salary pay policy is intended to comply with the
salary pay requirements of federal and state law, including the FLSA and shall be construed in accordance with
the FLSA. Exempt employees are encouraged to bring any question concerning their salary pay to Human
Resources.

If you believe you have been improperly classified as exempt; have been prevented from taking or have not been
authorized or permitted to take a meal or rest period; or otherwise believe you have been compensated
incorrectly, you must report such concerns immediately to Human Resources.

Every report will be fully investigated, and corrective action will be taken where appropriate. In addition, the
Company will not allow any form of retaliation against individuals who report alleged violations of this policy or
who cooperate in the Company’s investigation of such reports. Any form of retaliation in violation of this policy
will result in disciplinary action, up to and including termination.

REST BREAKS AND MEAL PERIODS

Rest Breaks
Non-exempt employees are required to take a 10-minute paid rest break for every four hours worked, or major
fraction thereof. The Company authorizes and permits rest breaks according to the schedule below. In any case,
the employee’s supervisor will establish the rest break time schedule for each employee. One rest break will be
scheduled in the morning and the second rest break will be scheduled after the mid-day meal period and prior to
end of the scheduled workday. Rest breaks cannot be combined and must be taken as described below. You are
responsible for taking the rest breaks as described in this policy and in compliance with applicable law.

Duration of Shift in # of 10 Minute


Comments
Hours Rest Breaks
A non-exempt employee who works less than 3.5 hours in a
0 to < 3.5 0 workday is not authorized and permitted to take a rest
break.
A non-exempt employee who works 3.5 hours or more in a
workday but who does not work more than 6 hours in a
> 3.5 to < 6 1
workday is authorized and permitted to take one 10-minute
rest break.

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A non-exempt employee who works more than 6 hours in a
workday but who does not work more than 10 hours in a
> 6.0 to < 10.0 2
workday is authorized and permitted to take two 10-minute
rest breaks.
A non-exempt employee who works more than 10 hours in a
workday but who does not work more than 14 hours in a
> 10.0 to < 14.0 3
workday is authorized and permitted to take three 10-
minute rest breaks.

Day of Rest - California


Non-exempt employees in California are entitled to one day of rest within a given work week. An employee
cannot work more than six days in a given week without at least one day of rest.

Meal Periods
All hourly employees working five or more hours in a day are required to take one 30-minute unpaid meal period,
in accordance with applicable local or state law. The Company provides a second meal break of at least 30-minutes
to employees who work more than 10 hours in a workday. Employees must take their first meal period before the
end of the fifth hour of work. A meal period that starts after an employee has worked in excess of 5 hours is
considered late. Employees should take their second meal period before the end of the tenth hour of work. A
second meal period that starts after an employee has worked in excess of 10 hours is considered late. Company
management will establish the mealtime schedule for each employee. It is the employee’s responsibility to take
the required meal periods.

Meal periods cannot be taken at the beginning or end of shifts in order to arrive to work late or leave work early.
Employees will be relieved of all of their duties during meal periods and are permitted to leave the premises. The
Company does not pay non-exempt employees for meal periods, and consequently, non-exempt employees must
record the start and stop times of their meal periods.
Any non-exempt employee who is required to work through some or all of a 30-minute meal period, or who is
required to take a late meal period, should notify Human Resources by no later than the end of the pay period to
ensure s/he is compensated properly. If an employee does not notify Human Resources, the Company will assume
that any non-exempt employee who fails to record a meal period, records a less-than-30-minute meal period, or
takes and records a late meal period, did so voluntarily. Failing to take a meal before the fifth hour, taking a meal
shorter than 30 minutes, or not taking a meal break can result in disciplinary actions up to and including
termination.
The Company will comply with all federal, state and local laws regarding rest breaks and meal periods, as
applicable.

LACTATION POLICY

The Company complies with all applicable state and local laws in accommodating lactating employees by providing
a reasonable amount of break time to any employee who desires to express breast milk for the employee’s infant
child. Generally, a reasonable amount of break time for purposes of this policy will, each time such employee has
need to express milk, be at least 20 minutes in every three-hour period, if requested by the employee. Longer break
times will be provided when the room designated for expression of breast milk is not in close proximity to the
employee’s workstation. The break time shall, if possible, run concurrently with any break time already provided
to the employee. Any break time provided to express breast milk that does not run concurrently with break time
already provided to the employee and shall be unpaid.
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The Company will provide employees who need a lactation accommodation with the use of a room or other
private location other than a bathroom or toilet stall that is located close to the employee's work area. Employees
with private offices will be required to use their offices to express breast milk. The Company will provide
employees with the use of a room or a private area, other than a bathroom or toilet stall, in close proximity to
their work area that is shielded from view and free from intrusion from co-workers and the public (the “Lactation
Location”). The Lactation Location may be the employee's normal work area, if suitable. The Lactation Location
will: be safe, clean and free from toxic or hazardous materials; contain a surface (e.g., a table or shelf) to place a
breast pump and other personal items; contain a place to sit; and have access to electricity or alternative devices,
including, but not limited to, extension cords or charging stations needed to operate an electric or battery-
powered breast pump. The Company will also provide access to a refrigerator where employees can suitably store
breast milk (or another cooling device) in close proximity to employee’s work area and access to a sink with
running water. If the Lactation Location is a multipurpose room used for lactation among other uses, the use of
the room for lactation shall take precedence over the other uses, but only for the time it is being used for lactation
purposes.

Employees have a right to request lactation accommodation. Employees who desire lactation accommodations
should contact their supervisor or Human Resources to request accommodations. The Company will respond to a
request for accommodation within five business days and will engage in an interactive process with the employee
to determine the appropriate break periods and the Lactation Location for the employee. If the Company denies
a request for lactation accommodation, it will provide a written statement identifying the reason(s) for doing so.

The Company prohibits retaliation against employees who request a lactation accommodation, file a complaint or
otherwise report an alleged violation of any applicable law, cooperate in an investigation of an alleged violation
of applicable law or inform another person about his or her rights under applicable law.
Lactation is considered a pregnancy-related condition under certain applicable laws. The Company will otherwise
treat lactation as a pregnancy-related medical condition and address lactation-related needs in the same manner
that it addresses other non-incapacitating medical conditions, including requested time off for medical
appointments, requested changes in schedules and other requested accommodations.

ATTENDANCE

Business hours begin at 8:00am and end at 5:00pm, local time. Punctuality and regular attendance are essential
to the proper operation of our business. The Company recognizes that circumstances beyond your control
sometimes may cause you to be absent from or late to work. However, if you are going to be late or absent, you must
call your manager in advance and notify him/her of the reason for your absence or tardiness. Excessive absenteeism
or tardiness in connection to your scheduled work time, breaks, and meal periods will result in disciplinary action, up
to and including discharge.

If you are unable to report for work due to illness, you must notify your immediate supervisor as soon as possible
but not later than within one (1) hour of your scheduled start time, unless the need is unforeseeable or prevents
you from doing so, in which case you must notify your supervisor as soon as practicable. If unable to give your
expected date of return to work, you must call in each day. Failure to properly notify the Company may result in an
unexcused absence. However, any legally protected time off taken by an employee including available sick time or
protected leave (e.g., FMLA, workers’ comp, pregnancy disability leave, etc.) will be considered an excused absence
and will not count against an employee under this policy.
If an employee fails to call in, follow their department procedure or otherwise fail to notify the Company of an
absence within 2 days and is absent 3 or more consecutive days or 72 hours from their last scheduled work day,

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we will presume the employee has voluntarily terminated employment and will be processed as “voluntary
resignation.”

If an employee is absent for three or more consecutive workdays due to illness or injury, a statement from a physician
may be required before the employee is permitted to return to work to the extent allowable and in accordance with
applicable law.
Excessive Absence/Tardiness
Any significant unexcused absence may result in discipline or discharge. “Significant” may mean the number of
instances, may mean one instance of unexcused absence at a crucial time, or in an overt manner. Please see your
supervisor to determine if you have a department specific attendance policy.

An employee who believes that his/her absence or tardiness is legally protected must notify his/her manager or
supervisor at the time of the absence or tardiness or, in the case of paid sick leave, as soon as practicable.
Employees are not required to reveal the nature of any underlying medical condition. An employee who believes
they have been mistakenly subject to disciplinary action for an absence or for tardiness that the employee believes
is legally protected should promptly discuss the matter with their supervisor or Human Resources.

LEAVES OF ABSENCE

Family and Medical Leave Act


Under the federal Family and Medical Leave Act (FMLA), eligible employees are entitled to up to 12 weeks of unpaid,
job-protected leave in a rolling 12-month period measured backward from the date the employee uses any FMLA
leave. Leave under FMLA may be taken for any of the following reasons:
• for incapacity due to pregnancy, prenatal medical care or childbirth;

• to care for the employee’s child after birth, or placement for adoption or foster care;

• to care for the employee’s spouse, son, daughter or parent, who has a serious health condition;

• for a serious health condition that makes the employee unable to perform the employee’s job;

• to address qualifying exigencies related to a covered service member’s call to active duty in the armed
forces1; or

• up 26 weeks of total leave, to care for an ill or injured covered service member2.

1
Eligible employees whose spouse, son, daughter or parent is on covered active duty or call to covered
active duty status may use their 12-week leave entitlement to address certain qualifying exigencies. Qualifying
exigencies may include attending certain military events, arranging for alternative childcare, addressing certain
financial and legal arrangements, attending certain counseling sessions, and attending post-deployment
reintegration briefings.
2
A covered servicemember is: (1) a current member of the Armed Forces, including a member of the
National Guard or Reserves, who is undergoing medical treatment, recuperation or therapy, is otherwise in
outpatient status, or is otherwise on the temporary disability retired list, for a serious injury or illness*; or (2) a
veteran who was discharged or released under conditions other than dishonorable at any time during the five-

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year period prior to the first date the eligible employee takes FMLA leave to care for the covered veteran, and
who is undergoing medical treatment, recuperation, or therapy for a serious injury or illness.*

*The FMLA definitions of “serious injury or illness” for current servicemembers and veterans are distinct
from the FMLA definition of “serious health condition”.

Definition of Serious 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 the employee from performing the functions of the employee’s job, or prevents the qualified
family member from participating in school or other daily activities.

Subject to certain conditions, the continuing treatment requirement may be met by a period of incapacity of more
than 3 consecutive calendar days combined with at least 2 visits to a health care 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.

Benefits and Protections


During FMLA leave, the Company will maintain the employee’s health coverage under any group health plan on
the same terms as if the employee had continued to work. Employees must pay their portion of any insurance
premium while on leave. Failure to pay your share of the premium may result in loss of coverage. The Company
may require employees who fail to return to work following expiration of their leave to reimburse it for insurance
premium payments made by the Company on behalf of the employee during leave, unless the employee does not
return because of a serious health condition that prevents the employee from performing his/her job, or
circumstances beyond the employee’s control.

Use of FMLA leave will not result in the loss of any employment benefit that accrued prior to the start of an
employee’s leave. Consistent with the other kinds of unpaid leaves offered by the Company, paid leave will not
accrue during unpaid portions of an employee’s FMLA leave. As such, the employee will not receive holidays,
bereavement leave, or jury duty pay during unpaid FMLA leave.

Upon return from FMLA leave, the employee will be restored to their original or a substantially equivalent position
with equivalent pay, benefits, and other employment terms.

Eligibility Requirements
Employees are eligible if they have worked for the Company for at least 12 months, have 1,250 hours of service
with the Company in the previous 12 months, and if at least 50 employees are employed by the Company within
75 miles of where the Employee works.

Use of Leave
An employee may take a maximum of 12 weeks of FMLA leave in a 12-month period, or 26 weeks for specific
military family leave-related situations explained above. The Company uses the following 12-month period for
purposes of calculating FMLA leave: measured back from the first day that FMLA qualifying leave is taken.

An employee does not need to use this leave entitlement in one block. Leave can be taken intermittently or on a
reduced leave schedule when medically necessary. Employees must make reasonable efforts to schedule leave
for planned medical treatment so as not to unduly disrupt the Company’s operations. Leave due to qualifying
exigencies may also be taken on an intermittent basis.

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The Company may ask employees taking leave intermittently or on a reduced schedule for planned medical
treatments to transfer temporarily to a different position with the same pay and benefits that more effectively
accommodates the leave. The Company may request the same of employees who take FMLA leave on a reduced
schedule per an agreement with the Company.

The Company may require employees to use all accrued paid vacation at the beginning of their FMLA leave.
Employees must comply with the Company’s normal paid leave policies when using paid leave concurrently with
FMLA leave. Once an employee exhausts his or her paid leave benefits, or if no paid leave benefits are available,
the FMLA leave is without pay.

Employee Responsibilities
Employees must provide 30 days’ advance notice of the need to take FMLA leave when the need is foreseeable.
When 30 days’ notice is not possible, the employee must provide notice as soon as practicable and generally must
comply with the Company’s normal call-in procedures (unless unusual circumstances prevent you from doing so).
Employees must provide sufficient information for the Company to determine if the leave may qualify for FMLA
protection and the anticipated timing and duration of the leave. Sufficient information may include that the
employee is unable to perform job functions, the family member is unable to perform daily activities, the need
for hospitalization or continuing treatment by a health care provider, or circumstances supporting the need for
military family leave. Employees also must inform the Company if the requested leave is for a reason for which
FMLA leave was previously taken or certified.

Employees also may be required to provide a medical certification and periodic recertification supporting the need
for leave, consistent with any applicable law. In certain circumstances, the Company may request a second or
third medical opinion, which it will obtain at its own expense. The Company may also require documentation
confirming family relationship, foster care, or adoption for employees taking FMLA leave. If the employee fails to
timely provide the appropriate certification, the Company may delay or deny approval for leave.

Employees must contact Human Resources at least two days before expiration of their FMLA leave to indicate
whether they are able or intend to return to work. If the leave was taken for a serious medical condition of the
employee, the Company will require a return to work certification from the Employee’s health care provider.

Employer Responsibilities
The Company will inform employees requesting leave whether they are eligible under FMLA. If they are, the notice
will specify any additional information required, as well as the employees’ rights and responsibilities. If they are
not eligible, the Company will provide the employee with a reason for the ineligibility.

The Company will also inform employees if leave will be designated as FMLA-protected and the amount of leave
counted against the employee’s leave entitlement. The Company will also notify the employee if it determines
that the leave is not FMLA-protected.

Unlawful Acts
FMLA makes it unlawful for any employer to:
• interfere with, restrain, or deny the exercise of any right provided under FMLA; and
• discharge or discriminate against any person for opposing any practice made unlawful by FMLA or for
involvement in any proceeding under or relating to FMLA.

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Enforcement
An employee may file a complaint with the U.S. Department of Labor or may bring a private lawsuit against an
employer. FMLA does not affect any federal or state law prohibiting discrimination or supersede any state or local
law or collective bargaining agreement which provides greater family or medical leave rights.

Occupational Injuries and Illnesses


An employee who suffers a work-related injury which also constitutes a serious health condition will be required to
comply with the FMLA requirements of this policy, if otherwise applicable, and any absence exceeding 3 days will be
designated as FMLA leave and counted against the employee’s annual leave entitlement.

Confidentiality
Medical information of employees is treated confidentially. All employees have a responsibility to respect and
maintain the confidentiality of employee medical information. Any employee inappropriately disclosing confidential
medical information will be subject to disciplinary action, up to and including termination of employment.

Other Employment
If you are on leave, you may not accept other employment without prior approval from management.

Military Leave
Employees who wish to serve in the military and take military leave should contact Human Resources for
information about their rights. An employee who returns from service in the Armed Forces of the United States
of America will be re-employed in accordance with applicable laws. An employee who is a member of a Reserve
Military organization of the United States of America or of the National Guard and who attends a regular military
training camp, will be given necessary time off without pay for such training, which will not be considered vacation
time. If desired, an employee may choose to use accrued vacation time, if any exists. Proof of service may be
requested by the Company.

Bereavement Leave
Full time employees may receive up to three (3) days of paid bereavement leave, which should include the day of
the funeral, upon the death of the following persons: spouse, parent/step-parent, child/step-child, brother/sister,
parent-in-law, brother/sister-in-law, son/daughter-in-law, grandparent, or grandchild. Employees may receive up
to one (1) day of paid bereavement leave, which should include the day of the funeral, upon the death of the
following persons: aunt/uncle, or niece/nephew. The employee must provide proof of relationship and/or proof
of attendance at the funeral, such as an obituary clipping, funeral card, or other similar document if requested by
the Company.

The employee is responsible for notifying his or her supervisor/manager as soon as possible when death occurs in
the immediate family. In the event an employee requests additional time off or attends the funeral of other family
members or friends, the supervisor/manager may permit time off without pay or permit the employee to use
accrued sick or vacation. In all cases the employee is responsible for keeping the supervisor/manager informed of
the anticipated duration of absence.

State Leave Entitlements


The Company operates in multiple states and will comply with all federal, state and local laws that govern leaves
of absence. Please see Human Resources for information on state-specific leaves of absence, and reference posted

November 11, 2019 23 | P a g e


information relating to leaves of absence for California, New York and Illinois employees. Please see Human
Resources in the event you have questions about your rights to leave of absence, generally.

TIME OFF FOR VOTING

The Company believes that it is the responsibility and duty of employees to exercise the privilege of voting in
elections. In accordance with this philosophy, the Company will grant its employees approved time off to vote, if
necessary, due to work schedules. Employees should be able to vote either before or after regularly assigned work
hours. However, when this is not possible due to work schedules, managers are authorized to grant a reasonable
period of time, up to three hours, during the workday to vote. Such time off shall be taken at the beginning or the
end of the regular working shift, whichever allows for more free time, and the time taken off shall be combined
with the voting time available outside of working hours. Under these circumstances, an employee will be allowed
a maximum of three hours of time off during an election day without loss of pay. When possible, an employee
requesting time off to vote shall give his or her supervisor at least two days’ notice.

VACATION/SICK/HOLIDAY PAY

Vacation
Effective January 1, 2020, the Company is retiring its current PTO policy and replacing it with the Vacation Policy
set forth below. Additionally, effective January 1, 2020, paid sick leave entitlement will be available to those
employees who work in cities and states that mandate paid sick leave. Any PTO accrued as of January 1, 2020, will
remain available for use under the new Vacation Policy.

Regular full-time employees accrue vacation hours from the first day they work at the Company and will be eligible
to use vacation hours after completing 90-days of continuous employment. Vacation hours may be used for
vacation or, personal time. Vacation time must be scheduled in advance and approved by your supervisor.

Effective January 1, 2020, vacation time is earned based on the following schedule:

Months of Accrual per Pay Maximum Vacation Time Maximum Balance of


Service Period Accrued Per Year Accrued Vacation Time
0 - 12 2.00 6 days / 48 hours 84 hours
13 - 83 3.33 10 days / 80 hours 140 hours
84+ 5.00 15 days / 120 hours 210 hours

Employees may not utilize vacation time before it has been accrued. Vacation benefits do not accrue during unpaid
leaves of absence or other periods of inactive service.

Employees are encouraged to use all earned vacation time each year as a well-deserved rest from their work and
opportunity to recharge. The maximum vacation time balance an employee may have at any time shall not exceed
the maximum amounts set forth in the table above. Once the maximum accrual amount has been reached, no
additional vacation time will be earned until previously accrued vacation time is used. If the employee later uses
enough vacation time to fall below the accrual cap, he or she will resume accruing vacation benefits from that day
forward, subject to maximums.

Employees may also cash in up to 40 hours of accrued and unused vacation time at the end of each year. Please
contact Human Resources for details.

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Employees may schedule their time off for vacation by submitting their desired dates to their immediate
supervisor in the form of a Vacation Request Form (available in the Human Resources Department). Approval for
time off for vacation should be sought as far in advance as possible and no less than two (2) weeks prior to the
planned absence. Requests for time off for vacation will be granted on the basis of availability of the requested
dates and in coordination with prior requests from other employees, subject to the operational needs of the
Company. Vacation hours taken should be reported on the employee timecard as “Vacation Hours.” Hours
reported will be charged to the employee’s accrued vacation time bank.

The minimum increment for vacation requests is 1 hour per day. Any employee who has questions regarding the
revised policies, benefits, or practices may contact Human Resources.

Any employee who terminates employment for any reason whatsoever and has earned and accrued vacation
time, will be paid for such accrued unused vacation time at his or her final rate of pay at the time of termination.

Paid Sick Leave


Employees may occasionally be unable to work due to illness or injury, and where required by law, the Company
provides paid sick time as described below. Sick days are not intended to be used as a substitute for vacation days.
Employees may use paid sick time for their own qualifying need or for that of a “family member,” for (1) diagnosis,
care, or treatment of an existing health condition; or (2) preventative care. Paid sick leave may also be used for a
public health emergency or absence due to domestic violence, sexual violence, abuse or stalking involving the
employee or any family member. This policy applies unless applicable state or local law provides for greater or
different benefits, in which case applicable law will apply. “Family member” includes a biological, adopted, or foster
child, stepchild, or legal ward, or a child to whom the employee stands in loco parentis; a biological, adoptive, or
foster parent, stepparent, or legal guardian of any employee or the employee’s spouse or registered domestic
partner, or a person who stood in loco parentis when the employee was a minor; spouse, registered domestic
partner, or party to a civil union with the employee; grandparent; grandchild; or sibling. A “family member” includes
any individual related by blood or affinity whose close association with the employee is the equivalent of a family
relationship.
Sick leave is not for “personal” absences not identified in the preceding paragraph, and may not be used for personal
absences, vacations, or for hours of work outside an employee's regular schedule. Employees must exhaust all paid
sick leave before being absent without pay for medical reasons.

An employee who has sick leave absence in excess of three consecutive working days must present medical
documentation for the absence or release to return to work.

If the employee is absent unexpectedly due to illness or family member’s illness, he/she must call their supervisor
(or Human Resources, if the supervisor is unavailable) by no later than the earlier of 9:00 a.m. or within 1 hour of
commencement of the workday on the day of expected absence.

Sick leave is to be used in an initial increment of no less than two (2) hours and is paid at the employee’s regular rate
of pay or as required by applicable law. Subsequent use may be taken in lesser increments.
Newly hired employees are granted the full amount of sick leave hours upon hire. Thereafter, the full amount sick
leave hours are granted to employees every January 1st. Paid sick leave hours are granted annually at the beginning
of the calendar year in amounts depending on the city and state where the employee is based, in compliance with
the state or city paid sick leave laws, as set forth below.

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In some cases, if all the available sick hours are not used by the end of the calendar year, accrued and unused
leave, up to a maximum identified in the schedule below, may be carried over to the new year. Employees are not
paid for unused sick leave upon termination of employment.

Usage Cap, Carryover to Next


State Requiring Paid Sick Leave Annual Grant
Annual Year
Arizona 24 24 No
California 24 24 No
Illinois (Cook County) 60 40 No
Oregon 40 40 No
Washington (Tacoma) 52 No cap 40

Employers are prohibited from discriminating against or subjecting any person to retaliation for: (1) asserting any
claim or right to paid sick time, including requesting or using earned paid sick time; (2) assisting any person in
doing so; or (3) informing any person of their rights under applicable law. Each employee has the right to file a
complaint with the relevant labor authority alleging employer violation. Certain time limits apply.

Holidays
The following is a list of paid holidays for all eligible employees who have completed at least 90 days of
employment:
New Year’s Day
Presidents’ Day (Coast Truck Centers work on this day in lieu of Christmas Eve off)
Memorial Day
Independence Day
Labor Day
Thanksgiving Day
Christmas Day

If an employee does not report to work the day before and/or after the holiday, unless the employee is on an
approved leave of absence, he/she will not be eligible for holiday pay. The holiday schedule may vary by location
within the Company.

When a holiday occurs during the scheduled vacation period of an employee, the employee will receive regular
holiday pay in lieu of vacation pay.

Jury Duty
The Company encourages all regular full-time employees to fulfill their civic responsibilities and to respond to jury
service summons or subpoenas, attend court for prospective jury service or serve as a juror or grand juror. The
Company will provide employees time off to serve on a jury. Employees must notify their supervisor within twenty-
four (24) hours of receiving a jury duty or juror orientation notice to allow planning for the employee’s absence.
Employees may be required to provide the Company with written proof of jury duty. Hourly (non-exempt)
employees will not be paid by the Company while serving on a jury, unless required by applicable law. A salaried
(exempt) employee's salary will not be reduced for partial weeks of work due to service as a juror. However, a
salaried employee will not be paid by the Company if he or she misses an entire week of work due to jury duty.
Under no circumstances will employees be terminated, threatened, intimidated, coerced or penalized because
they request or take leave in accordance with this policy.

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Time for appearance in court for personal business will be the individual employee’s responsibility. Normally,
vacation days will be used for this purpose.

BENEFITS
Benefits Overview
While this handbook provides a general overview of the Company’s benefits, the plan features, exclusions,
limitations or conditions of all the benefit programs are not included. More detailed information regarding many
of these benefits is contained in plan booklets, summary plan descriptions, group insurance policies, and the
Company’s official plan documents. If there is any conflict between the brief summaries in this handbook and the
terms, conditions and limitations of the official plan documents, the provisions of the official plan documents will
control. You are encouraged to review the official plan documents for further information, which are available
from Human Resources.

Group Medical Insurance


All full-time employees (minimum of 30 hours per week) are eligible for the Company subsidized health insurance
program after being employed for 90 days. Employees become eligible for benefits the first of the month following
60 days of employment.

401(K) Retirement Savings Plans


All full-time employees who meet the minimum requirements will be eligible to participate in the Company’s
401(k) plan after 90 days of employment. Please contact Human Resources for information on how to enroll.

Unemployment Insurance
State unemployment insurance may provide you unemployment benefits if you are eligible. If you need to file,
contact the local unemployment agency office near you.

Workers’ Compensation Insurance and Injuries on the Job


Workers’ compensation is a “no-fault” system that provides compensation for medical expenses and wage losses
to employees who are injured or who become ill because of employment. All employees are covered by our
Workers’ Compensation insurance, which pays for certain expenses as dictated by applicable state law for
qualifying job-related injuries. It is your duty to report a job-related injury as soon as reasonably practicable to
your supervisor. In cases of true medical emergencies, report to the nearest emergency room. Workers’
compensation benefits (paid or unpaid) will run concurrently with FMLA leave, if applicable, where permitted by
state and federal law. Our Workers’ Compensation Insurance is paid for entirely by the Company to provide you
with benefits if you are hurt on the job. While working, you must observe all safety and health rules and
regulations. It is crucial that you work safely to avoid any injury to yourself or your co-workers. You are required
to report all unsafe working conditions and/or unsafe behaviors to your immediate supervisor.

If you are injured while at work, promptly notify your department manager and obtain first aid or medical
attention as needed. After having received proper medical attention, you must report to the safety officer and
complete all necessary accident forms. This procedure will qualify you to receive Workers’ Compensation
Insurance benefits, which are paid for by the Company through our workers’ compensation carrier.

On the job safety is one of our most important goals. Maintaining an injury free work environment remains our
biggest challenge. While the Company can come up with safety rules to protect your wellbeing, it is your common
sense while working that will keep you free of accidents and injuries as well. The single most important way to
avoid an injury is to use your common sense while working.

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Should an accident occur while you are on the job (customer injury, damage to customer’s vehicle and/or
property), you must report it to your department manager as soon as practicable. If you are away from the facility,
promptly call your department manager.

Please use common sense while working. Observe safety regulations and operate any equipment in a safe manner.
You are responsible for complying with safety policies and any applicable regulations of the city, state, and federal
governments and of the Company.

EVERY ACCIDENT AND INJURY MUST BE REPORTED AS SOON AS PRACTICABLE TO A SUPERVISOR/MANAGER. AN


ACCIDENT/INJURY REPORT MUST TO BE FILLED OUT AND SENT TO THE SAFETY OFFICER AND TO THE CORPORATE
OFFICE.

Your employment application lists who should be notified in case of an accident with injury. Please see that this
information is always current, so that the Company may contact this person when necessary.

HIRING PROCESS AND PROCEDURES

Personnel requisitions
Personnel requisitions must be completed to fill Company positions. Requisitions must be initiated by the
department supervisor/manager, approved by the division vice president and then forwarded to Human
Resources.

Personnel requisitions should indicate the following:


• Position title
• Position hours/shifts
• Exempt or nonexempt status of the position
• Reason for the opening
• Essential job functions and qualifications (or a current job description may be attached)
• Any special recruitment advertising instructions

Intake Meetings
Human Resources will arrange a meeting with the hiring manager to conduct an intake meeting prior to posting a
job opening to learn more about the position, the requirements and the profile of the ideal candidate. The
recruiting strategy will be set during this meeting and expectations established with all the key stakeholders.

Job Postings
Human Resources will create job postings that briefly describe the job opening and communicate the Company
brand. All job openings will be posted concurrently on the internal intranet and externally with sources
appropriate for the position being filled. Jobs will remain posted until the position is filled. Human Resources will
be responsible for tracking all applicants and retaining applications and resumes as required.

Internal Applicants
Current employees with a satisfactory employment status may apply for internal job openings. The consents of
the employee’s manager and Human Resources may be necessary for employees with less than one year of service
with the Company. All applicants for a posted vacancy will be considered based on their qualifications and ability
to perform the job successfully. Internal candidates who are not selected will be notified by Human Resources.

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Interview Process
Human Resources and the hiring manager will screen applications and resumes prior to scheduling interviews.
Initial interviews are generally conducted by Human Resources and the hiring

manager using behavior-based interview questions and a structured interview process. Candidate evaluation
forms will be completed after each interview and retained with the application. Human Resources will notify
applicants who are not selected for positions with the Company.

Reference Checks
Human Resources will conduct professional reference checks and employment verification on the top candidates
based on the results of the candidate evaluation forms completed by the interviewers. A minimum of three
professional references are required from each candidate.

Job Offers
After a decision has been made to hire a candidate, an offer will be made contingent on the satisfactory
completion of required background checks and testing. Background checks will vary depending on the position
and may include criminal history, credit history, driving record, drug testing or any other relevant information for
the job. All offer letters will be issued by Human Resources.

Internal applicants must complete required background checks or tests not previously completed. Once Human
Resources receives satisfactory results from all required background checks and tests, candidates will be provided
with a final job offer. If a candidate fails to accept an offer of employment within 7 calendar days, the offer may
be rescinded by the Company.

EMPLOYMENT OF RELATIVES AND DOMESTIC PARTNERS

Relatives and domestic partners of employees may be eligible for employment with the Company only if
individuals involved do not work in a direct or indirect supervisory relationship, if the employment will not pose
difficulties for supervision, security, safety or morale, or in job positions in which a conflict of interest could arise.
The Company defines “relatives” as spouses, children, siblings, parents, in-laws, aunts, uncles, cousins, nieces,
nephews, grandchildren, and step-relatives. A “domestic partnership” is generally defined as a committed
relationship between two individuals who are sharing a home or living arrangements.

Present employees who become romantically involved, marry, or become involved in a domestic partnership will
be permitted to continue working in the job position held only if they do not work in a direct or indirect supervisory
relationship with one another, otherwise pose difficulties mentioned above, or in job positions involving conflict
of interest. If the employees are in a direct or indirect reporting relationship, the Company will attempt to transfer
one of the employees to another available position for which he or she is qualified if such a position is available.
However, if no alternative position is available, one of the employees may be required to resign his or her
employment with the Company. The employees will be required to decide which of the individuals in the
relationship will resign.

PERFORMANCE EVALUATIONS

The Company’s intent is to formally review employees’ performance in a written format at least once per year.
An employee may be reviewed more or less often at their manager’s discretion. The purpose of the performance
review is to assess the employee’s job performance, and to provide individual feedback on progress in meeting
job duties, responsibilities, and establishing future goals. A wage or salary review may or may not coincide with
November 11, 2019 29 | P a g e
the performance review, and an increase in salary or wage at any time is not automatic. Increases in pay are
dependent upon individual job performance, market and business conditions. Performance evaluations and any
ratings or comments therein do not in any way alter the at-will nature of employment.

PROMOTIONS AND ADVANCEMENT

It is the policy of the Company to promote from within the Company whenever possible. Therefore, the Company
encourages employees to apply for promotions to positions for which they are qualified. The employee’s
qualifications, past performances, potential, and his/her capacity to assume the increased responsibilities of the
position will be evaluated.

The policy is based on the recognition that in the course of meeting business objectives, the duties and functions
of an employee may change in complexity and responsibility. Promotions, therefore, are based primarily on
business need and employment status changes will involve increasing responsibility levels.

PROGRESSIVE DISCIPLINE

The Company will use the following format in dealing with performance, behaviors and attendance issues and is
not limited to using them in a progressive manner and may use any version of these letters depending upon this
issues that need to be addressed. There are three (3) letters that will be used to address these matters and they
will stay in the employee’s file for one year from the date they are issued,

The steps for Progressive Discipline are as follows:

1) Letter of Understanding will be utilized to spell out the job performance matters, behaviors and
conduct as well as attendance issues related to the employee’s position and what prompted the
letter.

2) Letter of Reprimand will be utilized to follow up with either the first and second letters or may be
due to a serious matter that requires the company to suspend the employee based on the serious
nature of the matters and situations that have occurred. In this case employees may be suspended
for up to three (3) days without pay.

3) Letter of Termination will be utilized when either steps one through three did not resolve the
matters or could be issued immediately, based on the severity of the situation and which polices
had been broken or conduct and attendance issues were not resolved.

This policy is not intended to nor will it be applied to interfere in any way with an employee’s right to engage in
protected, concerted activity under Section 7of the National Labor Relations Act.

STANDARDS OF CONDUCT

It is important that our employees be aware of their responsibilities to the Company and to their co-workers. It is
our intention to take a constructive approach to disciplinary issues to ensure that any type of actions which
interfere with operations or an employee’s job, are not continued nor tolerated.

Violations of our standards of conduct may result in one of the following disciplinary actions: verbal warning,
written warning, suspension without pay, or termination. The nature of the discipline imposed will depend on all
of the circumstances. The Company has the right to determine what disciplinary action is appropriate based on
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the facts of each case. Not all available forms of discipline are appropriate to every disciplinary situation, and it is
not required that the Company treat each form of discipline as a step in a series to be followed with an employee
before discharge. The Company’s practice of employee discipline does not imply that “progressive” discipline is
required or that employment may be terminated only for good cause.

The following are examples of unacceptable conduct, which may result in disciplinary action, up to and including
immediate termination of employment. This list is illustrative only and does not reflect all conduct that may be
subject to discipline:

• Falsification of Company records, including, but not limited to, employment applications, or
timecards. In addition, an employee may not punch another employee’s timecard or allow
someone else to punch his or her timecard.

• Unauthorized possession of Company or another employee’s property.

• Fraud, gambling, possession of weapons or explosives, or violation of criminal laws on Company


premises.

• Insubordination or refusal to comply with lawful management requests or instructions, or failure


to perform job duties assigned.

• Fighting, throwing things, horseplay, engaging in practical jokes or any other type of disorderly
conduct which may endanger the wellbeing of any employee or of Company operations.

• Threatening, intimidating, using abusive language or interfering with the work performance of
fellow employees.

• Use, possession, sale, purchase, or being under the influence of alcoholic beverages, illegal drugs,
or other intoxicants at any time on company premises.

• Improper behavior during and after working hours at Company functions, meetings, or during
customer visits.

• Theft or unauthorized removal of property from the Company, fellow employees, customers or
anyone on Company property.

• Misusing, damaging, or destroying property of the Company, a fellow employee, a customer or a


visitor.

• Performance that does not meet the minimum requirements of the position as deemed by the
Company.

• Violating the posted Safety or Work rules or Company Safety Policy.

• Use of Company materials, time, or equipment for the manufacture or production of an article
for unauthorized purposes.

• Conduct which, in the Company’s good faith, reflects adversely on any employee, customer, or on
the Company.
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• Failure to comply with any Company policy.

• Failure to complete tasks as assigned by management.

• Improper use of Company electronic devices including but not limited to desktop and laptop
computers, cell phones, tablets or any other electronic device with internet access.

• Unauthorized access to Company electronic files stored on the Company’s computers stored
without authorization on a thumb drive or portable media storage device.

• The use of personal devices or Company devices for streaming video and other entertainment
content is strictly prohibited during working hours and can only be done on personal devices
during meal periods away from the work area.

• Employees working in the railyards must place all cellphones, tablets and other electronics devices
not issued by the Company in their storage lockers or personal vehicles and must comply with
FRA Federal Regulation Guidelines regarding the use of electronic devices.

• If you must carry your personal cellphone on your person in the work area, and have no other
form of communication, it must only be used to conduct business and in cases of emergencies
and must not be used for personal use.

BUSINESS ATTIRE/SCENTS/FRAGRANCE

The Company strives to maintain a workplace environment that functions well and is free from unnecessary
distractions and annoyances. The Company requires employees to maintain a neat and clean appearance
appropriate for the workplace setting and for the work being performed. Further, natural or artificial scents that
could be distracting or annoying to others may be restricted in use.

All employees are expected to present a professional, businesslike image to clients, visitors, customers and the
public. Acceptable personal appearance, like proper maintenance of work areas, is an ongoing requirement of
employment. Supervisors should communicate any department-specific workplace attire and grooming guidelines
to staff members during new-hire orientation and evaluation periods. Any questions about the department’s
guidelines for attire should be discussed with the immediate supervisor.

Any employee who does not meet the attire or grooming standards set by his or her department will be subject
to corrective action and may be asked to leave the premises to change clothing. Hourly paid employees will not
be compensated for any work time missed due to failure to comply with designated workplace attire and grooming
standards.

Certain employees may be required to meet special dress, grooming and hygiene standards, such as wearing
protective clothing, depending on the nature of their job. Protective clothing may be required for certain positions
and will be provided to employees by the Company.

At the discretion of the department lead, in special circumstances, such as during unusually hot or cold weather
or during special occasions, employees may be permitted to dress in a more casual fashion than is normally
required. On these occasions, employees are still expected to present a neat appearance and are not permitted

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to wear ripped, frayed or disheveled clothing or athletic wear. Likewise, tight, revealing or otherwise workplace-
inappropriate dress is not permitted.

Reasonable accommodation of religious beliefs


The Company recognizes the importance of individually held religious beliefs to persons within its workforce. The
Company will reasonably accommodate an employee’s religious beliefs in terms of workplace attire unless the
accommodation creates an undue hardship. Accommodation of religious beliefs in terms of attire may be difficult
in light of safety issues for employees. Those requesting a workplace attire accommodation based on religious
beliefs should be referred to Human Resources.

Addressing workplace attire and hygiene problems


Violations of this policy can range from inappropriate clothing items to offensive perfumes and body odor. If an
employee comes to work in inappropriate dress, he or she will be required to go home, change into conforming
attire or properly groom, and return to work.

If an employee’s poor hygiene or use of too much perfume/cologne is an issue, the supervisor should discuss the
problem with the employee in private and should point out the specific areas to be corrected. If the problem
persists, supervisors should follow the normal corrective action process.

DRUGS AND ALCOHOL

The Company is committed to maintaining a productive, safe, and healthy work environment, free of any
unauthorized drug and alcohol use. The misuse of drugs and alcohol impairs employee health and productivity.
Drug and alcohol abuse can result in unsafe working conditions for all employees and our customers. As such, the
Company has adopted a zero-tolerance drug and alcohol policy, including testing protocol.

The following rules and standards of conduct apply to all employees either on Company property or during the
workday (including meal periods and rest breaks). The Company strictly prohibits the following:

• Possession, use of, or being under the influence of alcohol;

• Distribution, sale, or purchase of an illegal or controlled substance;

• Possession, use of, or being under the influence of an illegal or controlled substance, unless under
the direction of a certified physician.

This policy also applies to the possession, distribution, use of, or being under the influence of marijuana, regardless
of its legal status. Violation of the above rules and standards of conduct will not be tolerated. The Company may
bring violations of this policy to the attention of appropriate law enforcement authorities.

Any employee who is using prescription or over-the-counter drugs that may impair the employee’s ability to safely
perform his or her job duties, or that may affect the safety or wellbeing of others, is encouraged to discuss any
potential side effects and work restrictions with his or her health care provider before starting or resuming work.
If the employee has work restrictions, he or she should discuss them with his or her supervisor. The employee
should not, however, disclose any underlying medical condition requiring the prescription or medication. The
Company has developed and maintains a Drug and Alcohol Testing Policy, which is required to be signed by each
employee as a condition of employment. Please see Human Resources for your copy.

November 11, 2019 33 | P a g e


SMOKING

Smoking is not allowed in the facility or work areas at any time. This includes the use of any tobacco products
(including chewing tobacco), e-cigarettes and vaporizers. Please smoke outside the building in designated areas
and not directly next to one of the facility’s doors, and please be especially attentive to the sensitivities of fellow
employees or customers who may object to smoking. Employees using these areas are expected to dispose of any
smoking debris safely and properly.
SAFETY AND EMERGENCIES

Employee Safety
We make every effort to provide safe working conditions for our employees. We observe the safety laws of the
governmental bodies within whose jurisdiction we operate. No employee will knowingly be required to work in
any unsafe manner. Safety is everyone’s responsibility. Therefore, all employees are requested to do everything
reasonable and necessary to keep the Company a safe place to work. Employees are required to immediately
report any unsafe or hazardous conditions directly to their supervisor.
Safety is generally common sense, and each employee must be aware of safe and unsafe work practices. In
addition to your own good judgment concerning safety, your supervisor may provide you with specific safety rules
applicable to your work area. By way of example, the following are some specific safety standards and practices
which we expect each of you to follow:

1. Any employee temporarily taking medication which substantially alters his/her attention span,
alertness, or physical dexterity is required to notify his/her supervisor. While the employee is taking the
medication, he/she will not be permitted to operate moving equipment or work around moving machinery.

2. All injuries, no matter how minor, must be reported to the supervisor as soon as practicable after an
injury. First aid and/or medical attention will be provided for all work-related injuries or illnesses.

3. Any employee who suffers a major injury at work should notify other employees to call 911 and
receive medical transport to a health care facility. Under no circumstances is an employee who has suffered an
injury to transport themselves to a health care facility.

4. Lifting should be done with the legs. Do not lift more weight than can be controlled safely. Get help
from another employee when lifting heavy or awkward objects. Bend your knees when lifting.

5. Know the safe way to operate each machine and obtain permission and instructions from your
supervisor before operating it the first time. Always be sure of observing safety precautions before starting. If you
have any questions, ask your supervisor.

6. Company-owned motor vehicles shall be operated only by authorized employees holding all necessary
licenses, or who have completed special operating classes.

6. Forklifts shall only be operated by authorized, trained personnel. Forklifts are to be operated in a safe
manner and their operation shall not exceed a speed of 5 miles per hour. All traffic control signals shall be obeyed.

7. No employee shall be lifted on the forks of a lift truck at any time, for any reason, without the use of
a safety platform.

8. Be alert for forklifts and other moving equipment. Do not assume that the operator will see you.

November 11, 2019 34 | P a g e


9. Running within the plant or designated work area is not permitted unless directly involved in an
emergency.

10. Use proper hand tools and make sure they are in good condition. Do not use hand tools for the
purposes other than those for which the tool was designed. Ensure that each power hand tool is grounded.

11. Use air hoses with caution. Air hoses should not be used to sweep floors, clean off your clothing, or
for additional ventilation. Never direct an air nozzle toward another person or to yourself.

12. Any employee requiring prescription glasses and working in an area requiring eye protection shall
wear glasses or a safety shield with the same protective qualities as the Company – provided safety glasses over
their prescription glasses.

13. Personal protective equipment and clothing necessary for your safety shall be used as required.

USE OF COMPANY VEHICLES

Any employee for whom driving is an essential job duty must be authorized and approved by Human Resources
to drive Company owned vehicles. The employee driver of a Company vehicle is to ensure that the vehicle is in full
operational condition before each use. The employee driver will sign a vehicle log report noting any problems
with, or damage to, the vehicle before each use. Should the employee return the vehicle to the Company with
damage to the vehicle, the vehicle log report will be used as support evidence of the condition of the vehicle
before it was used by the employee driver. Any vehicle found to be unsafe will be removed from the operational
fleet until appropriate maintenance or repairs have occurred.

FIREARMS AND WEAPONS/ANTI-VIOLENCE

The Company is committed to providing a working environment free of workplace violence, which includes verbal
or physical threats of violence, aggressive behavior, violent outbursts, threats, or use of weapons of any kind.
Workplace violence will not be tolerated under any circumstances and will lead to disciplinary action, up to and
including termination.

Employees, may not, at any time while in the workplace or on the grounds of any property owned, leased or
controlled the Company including anywhere that Company business is conducted, such as customer locations,
client locations, trade shows, Company event venues, and so forth, or in any Company-owned or leased vehicles,
carry, possess or use any weapon. Weapons include, but are not limited to, guns, knives, or swords with blades
over four inches in length, explosives, electric weapons and any chemical whose purpose is to cause harm to
another person. Employees who violate this policy will be subject to disciplinary actions, up to and including
employment termination.

Any employee who has been subjected to or witnessed inappropriate behavior by anyone, including supervisors,
co-workers, guests, or visitors, should report the incident promptly to his or her supervisor and to management.
Employees that fear they are in immediate danger should dial 911. Supervisors who receive complaints from
employees or who observe inappropriate behavior should inform his or her supervisor and management
immediately. Every complaint of workplace violence that is reported to a member of Company management will
be investigated in as confidential a manner as possible. In addition, the Company will not tolerate retaliation
against any employee for cooperating in an investigation of inappropriate behavior or for making a complaint.

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Specific examples of conduct which may be considered a threat or an act of inappropriate behavior under this
policy include, but are not limited to:

• Intimidating or threatening physical or aggressive conduct directed toward another individual;


• Threatening an individual or his or her family, friends, associates, or property with physical harm;
• The destruction or threat of destruction of Company property or another’s property;
• Harassing or threatening phone calls;
• Surveillance;
• Stalking;
• Veiled threats of physical harm or like intimidation.
Violations of this policy may lead to disciplinary action, up to and including termination.

FIRE PREVENTION AND CONTROL

Report all fires immediately. Fire extinguishers are located in designated areas. You are responsible for
acquainting yourself with their location and operation.

SECURITY

The Company has developed guidelines to help maintain a secure workplace. Be aware of persons loitering for no
apparent reason in parking areas, walkways, entrances and exits, and service areas. Report any suspicious persons
or activities to management. Secure your desk or office at the end of the day. When called away from your work
area for an extended length of time, do not leave valuable and/or personal articles in or around your workstation
that may be accessible. The security of facilities as well as the welfare of our employees depends upon the
alertness and sensitivity of every individual to potential security risks. You should immediately notify your
supervisor when unknown persons are acting in a suspicious manner in or around the facilities, or when keys,
security passes, or identification badges are missing.

HOUSEKEEPING

Good housekeeping is the responsibility of every employee. In order to have an attractive and safe workplace,
good housekeeping practices must be a high priority for everyone. Following are some of the main areas to
consider, but are not limited to:

• Work areas should be kept in neat and orderly condition.


• Trash should be disposed of in trash containers, not on the floor. Cold drink cans should not be visible.
• Wooden pallets should be stacked in one area in a straight and orderly manner. Office areas and desks
should be kept orderly and uncluttered.
• The floor should be kept clean and clear of trash and debris. We must all do our part to keep our workplace
clean and safe.
WORKPLACE SEARCHES

All Company facilities, computers, lockers, furnishings, equipment, desks and vehicles are property of the
Company and are provided to employees for their use in the conduct of Company business. No employee has a
right to or expectation of privacy in such property. The Company retains the right to search and inspect all
Company property, as well as other items brought onto Company premises at any time, with or without notice or
employee consent.

November 11, 2019 36 | P a g e


Accordingly, we reserve the right to:
• Search Company property, including an employee’s locker, office, desk, files, computer, laptop, flash drive,
electronic organizer, cell phone, or any other electronic devices.
• Search any Company owned or leased car or vehicle.

Searches and inspections may be conducted at any time at the discretion of the Company, regardless of whether
the property sought to be searched is locked or unlocked, password protected or encrypted, and/or whether the
lock belongs to the Company or employee.

Any employee, who refuses to permit, obstructs or fails to cooperate with any search requested under this policy
may be refused access to the building or premises and/or subject to discipline, up to and including immediate
termination. The Company also reserves the right to request the intervention of law enforcement personnel in
the event it has reason to believe a crime has been or is in the process of being committed.

VOICEMAIL SYSTEMS

The Company's voicemail system should be used for business-related purposes only. The Company may review,
access, disclose, and monitor any and all messages sent over the Company's voicemail system for any purpose.
As such, employees should have no expectation of privacy when using the Company's voicemail system.

RESTRICTIONS ON COMPUTER USE

The Company provides employees with computers and/or laptops where appropriate. Employees may be
expected to use the internet to perform their job duties. Employees may only use the internet for work-related
purposes during work time. Employees should not use the internet for personal matters during work hours but
may access it for personal matters on breaks or before or after work, assuming that such use is not excessive and
does not interfere with the employee's own work performance or the work performance of others.

The Company may monitor employees' use of the internet. As such, employees should have no expectation of
privacy when using the Company's computers or networks. The Company expects employees to abide by all
Company policies and procedures when using Company computers, laptops and electronic devices, including but
not limited to the prohibition on displaying, transmitting, or downloading any material in violation of Company
policies and guidelines, or that is otherwise pornographic, obscene, offensive, discriminatory, derogatory,
harassing, or unlawful. No employee may knowingly disable any network software or system in use as a monitoring
tool.

LAPTOP POLICY

Each employee provided with a laptop by the Company is responsible for the physical security and proper use of
the laptop in accordance with all Company policies and restrictions. All laptops acquired for or on behalf of the
Company are deemed to be company property.

All employees must take the following actions to ensure the physical security of Company laptops:
▪ When not in use, the laptop must be locked with a password and caution taken when entering any
Company passwords on the laptop.
▪ Store the laptop in a locked cabinet or desk when not in use.

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▪ Do not leave your laptop in your vehicle. If it is necessary to leave the laptop in your vehicle for a very
short period of time, the laptop must be locked in the trunk of the vehicle.
▪ When using the laptop in public areas, do not leave the laptop unattended for any length of time.

During travel:
▪ Do not pack your laptop in checked luggage.
▪ Attach a name tag or business card to your laptop to easily identify it during security checks or if lost.
▪ Store the laptop in a hotel room safe or locked suitcase when you are not in the room.

Prohibited Use:
• Nonexempt employees should not check for, read, send or respond to work-related e-mails outside their
normal work schedules unless specifically authorized based on job duties or direction by management to
do so.
• Employees on leave of absence are not to take home and use Company laptops until they are released to
return back to work with their normal work schedule. Laptops must be left with your direct supervisor
before the leave start date.
Enforcement:
• Nonexempt employees using laptops for work-related correspondence during unauthorized times may
be subject to discipline for violating this policy. Supervisors requiring nonexempt employees to use
laptops for electronic communications for work-related correspondence must adhere to the overtime
requirements, including prior approval.

ELECTRONIC DEVICE POLICY

Electronic Device shall mean an electronic or electrical device used to conduct oral, written, or visual
communication; place or receive a telephone call; send or read an electronic mail message or text message; look
at pictures; read a book or other written material; play a game; navigate the internet; navigate the physical world;
play, view, or listen to a video; play, view or listen to a television broadcast; play or listen to music; execute a
computational function; or, perform any other function that is not necessary for the health or safety of the person
and that entails the risk of distracting the employee or another employee from a safety related task.

Use of Any Electronic Devices:


While at work employees must exercise the same discretion in using personal or Company provided electronic
devices. Personal communications during working hours, regardless of the device used, can interfere with
employee productivity and be distracting to others. All employees are asked to make personal communications
during breaks and meal periods and to ensure that friends and family members are aware of Company policy.
• Personal electronic devices are not to be carried or used in place of Company provided electronic
devices on the job without specific permission from management.
• The Company will not be liable for the loss of personal electronic devices brought into the
workplace.
• Electronic devices are not to be used within ten feet (10ft) of rail tracks.

Electronic Device Use While Operating A Vehicle / Equipment


The dangers of distracted driving are of increasing concern to the Company. Recent deadly crashes involving
drivers distracted by talking and texting while driving highlight a growing danger on our roads. Numerous studies
have demonstrated how the use of hand-held cell phones while driving creates a significant safety risk to
motorists, their passengers and others on the road. Not to mention the higher costs of insurance.
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The Company will enforce this policy without an exception and will not tolerate texting or talking on a hand-held
phone while operating any Company equipment or while using a Company issued cell phone while operating a
personal vehicle, or while driving any vehicle on Company business. This includes, but is not limited to, answering
or making phone calls, engaging in phone conversations, reading or responding to e-mails and text messages.

The Company’s main concern is the safety of its employees. It is the Company’s goal to lead by example, and
that the practice of no texting or talking on hand-held cell phones while behind the wheel will spread
throughout the community. Violations of this policy will be subject to disciplinary action up to termination of
employment.

While operating a motor vehicle, cell phone use (when allowed per GCOR Rule 2.21) is permitted when:
- A Hands-free device is used, and voice activated dialing or speed dialing is used, or
- Stopped on other than a roadway.
Prior to operating the equipment / vehicle, Company employees are required to:
- Connect device to hands free system.
- Put aside and out of reach your cellular telephone before starting the car.
The following should also be considered:
- Modifying voice mail greeting to indicate the date and approximate time you will be unavailable to
answer calls or return messages while driving.
- Pulling over to a safe place and turn off the engine to review missed calls or text messages.
- Informing clients, associates and business partners of this policy as an explanation of why calls may
not be returned immediately.
If your position requires continuous use of your cellular telephone, please advise your manager to evaluate
the need of a Bluetooth which will be provided by the Company.
Company Supplied Electronic Devices
Employees may use company supplied electronic devices to send or receive work related information with:
- Company supervisors
- Company customers
- Railroad dispatchers
- Company customer service employees, or
- Other Company employees as necessary in the performance of their duties.

Employees in possession of Company supplied electronic devices are expected to protect the equipment from
loss, damage and theft.

Personal use of such equipment is not permitted.

If an employee experiences a personal emergency that requires use of the Company cell phone, they are
required to report this to their supervisor.

Upon resignation or termination of employment, or at any time upon request, the employee must return the
equipment.

Failure to comply with this policy may result in disciplinary action up to and including termination.
November 11, 2019 39 | P a g e
Personal Electronic Devices
Personal Electronic Devices may be used as necessary:
- To respond to an emergency involving the Company,
- To respond to an emergency encountered while on duty,
- As a communication device in the event of radio malfunction.
Except when on breaks, away from the work site, or in a safe location, employees on duty (includes
supervisors) must have each electronic device turned off and stowed out of sight with any earpiece removed
from the ear when:
- On moving rolling equipment or on-track equipment.
- Any member of the crew is on the ground performing safety related duties, or
- Any employee is assisting in preparation of the train, engine(s) or on-track equipment.

Personal electronic devices may only be used for voice communication when:
- Rolling and on-track equipment is stopped,
- A safety briefing is conducted with all crew members to confirm that it will not interfere with any
safety related or required duty,
- No member of crew will foul any track.

The Company prohibits employees using iPods, MP3 players, and other portable music devices during
working hours as other employees could find it disruptive, hampering their ability to concentrate. Use will
be restricted to breaks and meal periods.
The following are strictly prohibited by the Company:
- Use of the Company’s computers to download music onto employees’ iPod or other portable music
device. Transferring files from a computer to these devices opens networks to potential viruses and
security breaches.

- Downloading confidential or proprietary information from Company computers including personnel


records, customer data, and trade secrets onto personal iPod or other portable music device.

- Listening to an iPod or other portable music device through headphones while working and/or driving
a Company-issued motor vehicle. This is an unsafe practice as headphones can inhibit one’s ability to
hear alarms, warning signals, or shouts by co-workers informing them of potential harm.

- Streaming videos that are not Company related.

- Browsing the internet.

- Posting on any personal social media accounts during regular working hours. Regardless of whether
it’s on personal cellphone, tablet or any other type of personal device including watches, it also
includes Company provided devices that can access the internet.

TECHNOLOGY AND SECURITY

It may be necessary to assign and/or change “passwords” and personal codes for e-mail, voicemail, and
computers. The Company may keep a record of all passwords and codes used and/or may be able to override any
November 11, 2019 40 | P a g e
such password system. These investigative measures are not intended to be unreasonably intrusive but may be
necessary where there is a need to protect information, property, Company assets, or to maintain a safe work
environment. An employee has no right or expectation to privacy in electronic communication or information
sent or received through Company networks, or on PDAs issued or paid for by the Company.

Employees should not use cell phones, smart phones, iPads, cordless phones, portable computers and fax
communications for communicating “confidential” or sensitive information or any “trade secrets.” (As used
herein, “trade secrets” is defined as information, including a formula, pattern, compilation, program, device,
method, technique, or process, that derives independent actual or potential economic value from not being
generally known to the public or to other persons who can obtain economic value from its disclosure or use, and
is the subject of efforts that are reasonable under the circumstances to maintain its secrecy.)

Employees in possession of Company cell phones are expected to protect the equipment from loss, damage or
theft, and to return the phone and any related equipment to the Company upon termination of employment or
whenever demanded by the Company. Use of Company-owned mobile devices require password protection.
Employees are required to immediately report any lost, stolen or damaged equipment.

ELECTRONIC COMMUNICATIONS

The Company provides employees with access to the internet, which is to be used for business purposes only.
Employees are prohibited from accessing any sites not necessary for business purposes. Violations of this policy
can and will result in discipline, up to and including discharge. Employees who access pornographic websites will
be terminated.
Employees are also prohibited from downloading any software or other information not necessary for business
purposes or authorized by the Company’s system administrator. This includes, but is not limited to, screensavers,
icons, wallpaper, games, etc.
All employees are responsible for using common sense and good judgment in visiting websites and choosing the
content and recipients of e-mail messages. Your internet and e-mail usage cannot violate the Company’s policies
against discrimination, harassment, solicitation, or protection of confidential, sensitive, or trade secret
information. In addition, your use of the internet and e-mail may not violate applicable laws, such as copyright
and trademark laws. Because access to the internet is provided by the Company, the Company also reserves the
right to inspect and retrieve information from PDAs, personal computers, and phones which are regularly used to
conduct Company business. The electronic and information systems, which include all desktop and laptop
computers, servers, printers, laptops, routers, other peripherals, software and data files, are the property of the
Company. An employee has no right or expectation to privacy in electronic communication or information sent
or received through Company systems. Employees are prohibited from copying, destroying or deleting files or
information stored in the system without specific authorization from the Company; from accessing files and
information without authorization; and/or from installing or removing files or programs without specific
authorization from the Company’s system administrator. The Company reserves the right to access and review
electronic files, messages, mail, and other digital archives, and to monitor the use of electronic communications
as necessary to ensure that no misuse or violation of Company policy or any law occurs.
The Company reserves the right to control e-mail and internet use for business or productivity purposes. The
Company may monitor e-mail messages as a routine matter, as directed by business requirements, or in the course
of an. The Company also reserves the right to capture and use internet correspondence, personal file directories,
and other information stored on Company computers, to support operational, maintenance, auditing, security,
and investigative activities.

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SOCIAL NETWORKING AND MEDIA

The Company acknowledges that employees may utilize the internet outside of work time or the workplace for
personal business. In some circumstances, however, such use may impact the Company. Therefore, whether or
not the Company’s resources or internet system are used to do so, employees publishing information on the
internet in any fashion, including but not limited to websites, chat rooms, message boards, weblogs (“blogs”), or
social and/or professional networking sites such as Facebook, Twitter, Snapchat, Instagram, or LinkedIn are
expected to do so responsibly and must adhere to the following guidelines when such activities relate to or
mention the Company:

Only designated members of the Company may communicate with the media. Employees’ communications
concerning the Company must not violate any Company policies, practices, or guidelines, whether or not your
status as an employee is specifically mentioned in such communication.

Employees may not personally attack, nor post any personal information about Company employees, clients, or
vendors or make any statement or posting that violates the privacy of publicity rights of any other person.

Employees may not post any material that is obscene, defamatory, libelous, threatening, harassing, abusive, or
hateful, including, but not limited to, statements concerning the Company, its partners, employees, clients,
customers, and vendors. At minimum, employees are prohibited from posting any content or statements
inconsistent with the Company’s anti-discrimination and harassment policy and the Company’s policy protecting
confidential information.

Employees may not disclose any sensitive, proprietary, confidential, or financial information about the Company
or any Company client or former client/customer.

Employees may not imply Company endorsement of any statement or posting, or attribute views or opinions
expressed in such statements or postings to the Company.

The Company’s trademarks, copyright-protected material, and other images or intellectual property owned by the
Company may not be used without prior written consent. Employees must respect and comply with all copyright
laws and terms of use on the sites to which information is published.

Employees should not make referrals or recommendations for friends/associates if their site indicates that they
are associated with Company. It may give the appearance that the Company endorses the individual being
recommended.

Each employee is personally and legally responsible for all content the employee may post or publish on the
internet. Regardless of the employee’s position or compliance with these policies, practices, and guidelines, the
Company will not indemnify any employee from legal action that may result from that employee’s personal
internet use or online activities.

Before you post, remember:


• Be transparent, use #HarborRailEmployee or otherwise identify your relationship to the Company when
posting about or endorsing the Company on social media.
• Play fair, be respectful of others, including competitors and right to privacy.
• Be tasteful, don’t use obscenities or make comments inconsistent with the Company brand reputation.
• Stick to the facts and correct mistakes quickly.
• Use discretion, do not disclose Company trade secrets or confidential information.
November 11, 2019 42 | P a g e
• Be original, and don’t infringe copyrights or trademarks.
• Be aware, don’t use a Company email address to register accounts for personal use.

Employees should expect the Company to monitor compliance with this policy, including accessing any
information posted, created, or exchanged on social media, without prior notice to the employee, to the extent
permitted by law. Failure to comply with these policies could lead to discipline up to and including termination.
The above policies, practices, and guidelines are not intended to be exhaustive, and Company reserves the right
to take appropriate action in any circumstance involving an employee’s posting of content on the internet, in
accordance with applicable law.

SOLICITATION AND DISTRIBUTION OF LITERATURE

In order to ensure efficient operation of the Company’s business and to prevent disruption to employees, we have
established control of solicitations and distribution of literature on Company property. The Company has enacted
rules applicable to all employees governing solicitation, distribution of written material, and entry onto the
premises and work areas. All employees are expected to comply strictly with these rules. Any employee who is in
doubt concerning the application of these rules should consult with his or her supervisor or with Human
Resources.

No employee shall solicit or promote support for any cause or organization during his or her working time or
during the working time of the employee or employees at whom such activity is directed. “Working time” is
defined as time during which an employee is not at a meal, on break, or on the premises immediately before or
after his or her shift. Employees are also prohibited from distributing written materials, handbills, or any other
type of literature on working time and, at all times, in “working areas,” which includes all office areas. “Working
areas” do not include break rooms, parking lots, or common areas shared by employees during nonworking time.

No employee shall distribute, circulate, or post any written or printed material in work areas at any time, or during
his or her working time or during the working time of the employee or employees at whom such activity is directed.

Under no circumstances will non-employees be permitted to solicit or to distribute written material for any
purpose on Company property.

TRAVEL EXPENSE POLICY

Expenses incurred must comply with the Company Travel Expense Policy, attached to this handbook as Appendix
A, as updated from time to time.

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ACKNOWLEDGMENT
I hereby acknowledge that I have received my copy of the Harbor Rail Services of California, Inc. and Coast
Truck Centers, Inc.’s (the “Company”) employee handbook. I understand and agree that it is my responsibility to
read and familiarize myself with the policies and procedures contained in the handbook. If I have any questions
about any of the information and materials contained in the handbook, it is my responsibility to address them
with Human Resources or management.

I also understand that the purpose of this handbook is to provide me with information and guidelines
about the Company’s benefits, policies and procedures. I understand and agree that nothing in this employee
handbook creates or is intended to create a promise or representation of continued employment, a guarantee of
rights or benefits or a contract of employment between the Company and me. I understand and acknowledge that
my employment at the Company is and will be considered employment at-will; employment may be terminated
by either the Company or me at any time, with or without notice, except as prohibited by statute or public policy.
My signature certifies that I understand that the foregoing at-will status is the sole and entire agreement between
the Company and me concerning the duration of my employment and the circumstances under which my
employment may be terminated. It supersedes all prior agreements, understandings, and representations
concerning my employment with the Company.

The Company has provided me with an electronic or booklet form of the Handbook on this day. The
company may update the Handbook on occasion, from time to time, and you will find the most current handbook
online. Please be certain to use the most current version of the Handbook that’s online.

Without limiting the foregoing representations, by signing below, I certify that I have reviewed and understand
the specific policies of the Company and acknowledge their applicability to me and my employment with the
Company.

Please initial next to each of the policies listed below, sign/date the bottom of the form and return the form to
Human Resources.
(initials)
1. Equal Employment Opportunity ____________
2. Anti-Harassment _____________
3. Electronic Communications / Workplace Searches _____________
4. Electronic Device Policy _____________
5. Travel Expense Policy _____________

_________________________________________
EMPLOYEE NAME (Print)

________________________________________ _________________________
EMPLOYEE (Signature) DATE

_________________________________________
COMPANY REPRESENTATIVE (Print)

November 11, 2019 44 | P a g e


Appendix A

Travel Expense Policy

Introduction
Overview
It is the policy of Harbor Rail Services Company and Coast Truck Center, Inc. (“Company”) to reimburse
employees for reasonable and necessary expenses incurred in connection with approved travel on behalf
of the Company. The Company strongly encourages use of travel discounts when making travel
arrangements.

Travelers seeking reimbursement should incur the lowest reasonable travel expenses and exercise care
to avoid impropriety or the appearance of impropriety. Reimbursement is allowed only when
reimbursement has not been, and will not be, received from other sources. If a circumstance arises that
is not specifically covered in this travel policy, then the most conservative course of action should be
taken.

Business travel policies are aligned with Company reimbursement rules. All business-related travel paid
for with Company funds must comply with Company expenditure policies.

Authorization and responsibility


Employee travel must be authorized. Travelers should verify that planned travel is eligible for
reimbursement before making travel arrangements. Within 15 days of completion of a trip, the
employee must submit a Travel Reimbursement form and supporting documentation to obtain
reimbursement of expenses.

An individual may not approve his or her own travel or reimbursement. All travel requires
executive\director approval. The Travel Reimbursement form must be signed by the executive director
or the director of finance.

Travel and reimbursement for members of the management team must be approved by the executive
director or the director of finance (if not for that individual), and will be reviewed annually by the internal
auditor.

Designated approval authorities are required to review expenditures and withhold reimbursement if
there is reason to believe that the expenditures are inappropriate or extravagant.

Personal funds
Employees shall review reimbursement guidelines before spending personal funds for business travel to
determine if such expenses are reimbursable. See Travel Expenses/Procedures below for details. The
Company reserves the right to deny reimbursement of travel-related expenses for failure to comply with
policies and procedures.
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Travelers who use personal funds to facilitate travel arrangements will not be reimbursed until after the
trip occurs and proper documentation is submitted.

Vacation in conjunction with business travel


In cases in which vacation time is added to a business trip, any cost variance in airfare, car rental or
lodging must be clearly identified on the Travel Request form. The Company will not prepay any personal
expenses with the intention of being “repaid” at a later time, nor will any personal expenses be
reimbursed.

Exceptions
Occasionally it may be necessary for travelers to request exceptions to this travel policy. Requests for
exceptions to the policy must be made in writing and approved by the executive director or by the
director of finance. Exceptions related to the director’s or the director of finance’s expenses must be
submitted to the opposite person or to the treasurer of the board of trustees for approval. In most
instances, the expected turnaround time for review and approval is five business days.

Travel Expenses/Procedures
General information
Authorized business travel for staff that includes prepayments must be pre-approved. Reimbursement
of mileage, and ferry or bus passes do not require requests if they are under $10. Requests for
reimbursement of expenses over $10 are to be submitted on a Travel Reimbursement form.

Permissible prepaid travel expenses


Before the travel, the Company may issue prepayments for airfare, rail transportation, rental vehicles,
conference registration fees and cash advances. Applicable policies and methods of payments for these
prepayments follow.

Airfare. Travelers are expected to obtain the lowest available airfare that reasonably meets business
travel needs. Airfare may be prepaid by the business office. Travelers are encouraged to book flights at
least 30 days in advance to avoid premium airfare pricing. First-class tickets are not reimbursable. Coach
class or economy tickets must be purchased for domestic or international flights (defined as flight time
totaling less than five consecutive hours excluding layovers). A higher-priced coach ticket cannot be
purchased for a subsequent upgrade in seating. A less-than-first-class ticket (i.e., business class) may be
purchased at the Company’s discretion for domestic or international flights (defined as flight time
exceeding five consecutive hours excluding layovers). Airfare may be purchased with a credit card or
check through the business office with a Request for Payment form.

Rail transportation. The Company will prepay rail transportation provided that the cost does not exceed
the cost of the least expensive airfare.

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Rental vehicles. The Company will pay for approved use of a rental vehicle. See the section on
reimbursements below in this section.

Conference registration fees. Conference registration fees can be prepaid with a credit card or check
through the business office with a Request for Payment form. Business-related banquets or meals that
are considered part of the conference can be paid with the registration fees; however, such meals must
be deducted from the traveler’s per diem allowance. See Meals (per diem) for more detail.

Travel advances. Cash advances are authorized for specific situations that might cause undue financial
hardship for business travelers. These situations are limited to staff traveling on behalf of the Company.
A maximum of 80 percent of the total estimated cost can be advanced. Expenses associated with the
travel must be reconciled and substantiated within two weeks of the return date. The traveler must
repay the Company for any advances in excess of the approved reimbursable expenses. The department
initiating the travel is responsible for notifying the business office to deposit any excess funds into the
appropriate departmental account. Travel advances are processed by submitting a completed Request
for Payment form and Travel Request form to the business office. Reimbursement for any remaining
expenses is processed on a Travel Reimbursement form approved by the designated approval authority.

Reimbursements
Requests for reimbursements of travel-related expenses are submitted on a Travel Reimbursement form.
This form must be accompanied by supporting documentation. If the requested reimbursement exceeds
20 percent of the total pre-trip estimate, the Travel Reimbursement form must be signed by the
executive director or the director of finance. These forms must be submitted to the business office within
two weeks after the trip is completed. Travel Reimbursement forms not submitted within this time frame
require exception approval from the executive director or from the director of finance. Reimbursement
of travel expenses is based on documentation of reasonable and actual expenses supported by the
original, itemized receipts where required.

Airfare. If the airfare was not prepaid by the business office, an original itemized airline receipt, an e-
ticket receipt/statement or an Internet receipt/statement is required. The receipt must show the
method of payment and indicate that payment was made. Travelers are expected to obtain the lowest
available airfare that reasonably meets business travel needs. Travelers are encouraged to book flights
at least 30 days in advance to avoid premium pricing. Coach class or economy tickets must be purchased
for domestic or international flights (defined as flight time totaling less than five consecutive hours
excluding layovers). A higher-priced coach ticket cannot be purchased for a subsequent upgrade in
seating.

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A less-than-first-class ticket (i.e., business class) may be purchased at the Company’s discretion for
domestic or international flights (defined as flight time exceeding five consecutive hours excluding
layovers). First-class tickets are not reimbursable.

Rail transportation. The Company will pay for rail transportation provided that the cost does not exceed
the cost of the least expensive airfare. If rail transportation was not prepaid by the business office, an
original itemized receipt, original e-ticket receipt/statement or Internet receipt/statement is required.
The receipt must show the method of payment and indicate that payment was made.

Automobile (personally owned—domestic travel). A valid driver’s license issued within the United
States and personal automobile insurance are required for expenses to be reimbursed. Drivers should
be aware of the extent of coverage (if any) provided by his or her automobile insurance company for
travel that is business or not personal in nature. Reimbursement for use of a personal automobile is
based on the Company mileage rate. The Travel Reimbursement form is required for reimbursement for
all vehicle-related expenses, including gasoline, wear and tear, and personal auto insurance. As of
December 31, 2018, the IRS rate is $0.58 per mile. Travelers may opt to request reimbursement for
gasoline in lieu of the Company mileage rate. In these instances original, itemized receipts are required.

Conference registration fees. If the conference fee was not prepaid, the Company will reimburse these
fees, including business-related banquets or meals that are part of the conference registration. Original
receipts to support the payment are required. If the conference does not provide a receipt, then a
cancelled check, credit card slip/statement or documentation that the amount was paid is required for
reimbursement. A prorated amount for the meals provided must be deducted from the traveler’s per
diem. See Meals (per diem) for more detail. Entertainment activities such as golf outings and sightseeing
tours will not be reimbursed. Registration fees paid directly by an individual will not be reimbursed until
the conference is completed.

Lodging (commercial). The cost of overnight lodging (room rate and tax only) will be reimbursed to the
traveler if the authorized travel is 45 miles or more from the traveler’s home or primary worksite.
Exceptions to this restriction may be approved in writing by the executive director or by the director of
finance. The Company will reimburse lodging expenses at reasonable, single occupancy or standard
business room rates. When the hotel or motel is the conference or convention site, reimbursement will
be limited to the conference rate. Only single room rates are authorized for payment or reimbursement
unless the second party is representing the agency in an authorized capacity. If the lodging receipt shows
more than a single occupancy, the single room rate must be noted. If reimbursement for more than the
single room rate is requested, the name of the second person must be included.

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Meals (per diem). Per diem allowances are reimbursable for in-state overnight travel that is 60 miles or
more from the traveler’s home or primary worksite. Per diem allowances are applicable for all out-of-
state travel that is 60 miles or more from the traveler’s home or primary worksite.
The Company’s per diem rate is $45.00. In addition to meals, this rate includes incidental expenses such
as laundry, dry cleaning and service tips (e.g., housekeeping or porter tips). Incidental expenses, unless
specifically cited in this policy, will not be reimbursed. Per diem reimbursements are based on departure
and return times over the entire 24-hour day and are prorated accordingly. If a free meal is served on
the plane, included in a conference registration fee, built into the standard, single hotel room rate or
replaced by a legitimate business meal, the per diem allowance for that meal may not be claimed.
Receipts are not required for per diem allowances. Per diem allowances are reimbursed after the trip is
completed.

Business Meals. Travelers are required to follow Company expenditure policies when requesting
reimbursement for business meals. Original itemized receipts are required. When taking customers and
clients out for dinners and entertainment, the following guidelines must be applied:
• Restaurants and entertainment that exceed the normal costs of meals and entertainment must
be preapproved by the Department Manager and Controller’s office when practical.
• The most senior employee at the event should pay for the meal, entertainment and expenses
• The receipt must show all in attendance at the event including internal and external guests and
employees or Company services.
• Alcohol purchases must be kept within reason and if required, alternate transportation provided.

Business expenses. Business expenses, including faxes, photocopies, Internet charges, data ports and
business telephone calls incurred while on travel status, can be reimbursed. Original itemized receipts
are required.

Parking. Original receipts are required for parking fees (including airport parking). The lodging bill can
be used as a receipt when charges are included as part of the overnight stay.

Telephone calls. The costs of personal telephone calls are the responsibility of the individual.

Tolls. Original receipts are required for tolls.

Miscellaneous transportation. Original receipts are required for taxi, bus, subway, metro, ferry and
other modes of transportation if costs are $10 or more for each occurrence.

Visa, passport fees and immunizations. If these items are required for international travel, their
reimbursement is left to the discretion of your supervisor. If approved by the designated authority,
original itemized receipts are required.

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Frequent Traveler Benefits
The frequent traveler benefits received by an employee in conjunction with business travel are generally
considered Company property, and the employee may not retain the benefits for personal use. As a
result, the employee should accept the benefits on behalf of the Company and turn them over to the
Company for general use to maximize their value to the Company. The fundamental rule is that an
employee is obligated to account for any gift, gratuity, or benefit received from third party sources
incident to the performance of their jobs. Any such gifts, gratuities, or benefits tendered to the employee
are viewed as having been received on behalf of the Company. This policy specifically provides that any
awards granted under such a frequent traveler program accrued through business travel shall be used
only for business travel to benefit the Company in cost-saving efforts. These include the benefits offered
by airlines, hotels, and car rental vendors.

Non-reimbursable Travel Expenses


The following items that may be associated with business travel will not be reimbursed by the
Company:
▪ Airline club memberships
▪ Airline upgrades. (may want to exclude Southwest Early Bird Check in)
▪ Business class for domestic flights or first class for all flights
▪ Childcare, babysitting, house-sitting, or pet-sitting/kennel charges
▪ Commuting between home and the primary work location
▪ Costs incurred by traveler’s failure to cancel travel or hotel reservations in a timely manner
▪ Evening or formal wear expenses
▪ Haircuts and personal grooming
▪ Laundry and dry cleaning
▪ Passports, vaccinations and visas when not required as a specific and necessary condition of the
travel assignment
▪ Personal entertainment expenses, including in-flight movies, headsets, health club facilities,
hotel pay-per-view movies, in-theater movies, social activities and related incidental costs
▪ Travel accident insurance premiums or purchase of additional travel insurance
▪ Other expenses not directly related to the business travel

TRAVEL FOR NON-EMPLOYEES


Additional costs for travel, lodging, meal or other travel expenses for spouses or other family members
will not be reimbursed unless the individual has a bona fide Company purpose for engaging in the travel
or attending the event. Such travel is generally limited to senior management and should occur
infrequently.

CORPORATE CREDIT CARD POLICIES & PROCEDURES


Purpose
The JPMorgan Chase MasterCard (Corporate Card) is designed to provide efficient payment for
Company travel, entertainment, meeting expenses, and supplies. The Corporate Card will be corporate
liability and your transactions will be posted and approved online in the Concur site. The charges are
considered advances and timely submission of expense reports with complete documentation
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supporting the business purpose of the expense is required per this policy and the IRS Accountable Plan
to clear this advance.

The Corporate Card is a privilege extended to those employees that must travel or entertain on behalf
of the Company. The Corporate Card cannot be used to purchase items that are not reimbursable
business expenses. Fraudulent or intentional misuse of the Corporate Card will result in disciplinary
action including reimbursement of disallowed or undocumented expenses, card cancellation and
possible termination of employment. Only reimbursable business or travel expenses can be charged to
the Corporate Card. The Company will conduct routine audits of a cardholder’s transactions.

Cardholders must recognize that their Corporate Card could be unavailable for use for a multiple of
reasons such as lost or stolen, closed due to fraudulent activity or security breach, etc. In the event of
a decline, cardholders should contact JPMorgan Chase Cardmember Services for problem resolution.
Cardholders must also be prepared to transact any business expenses personally and seek
reimbursement until a replacement card can be provided.

Applying for a Corporate Card


Application packets may be obtained by contacting the Program Administrator at 626-398-4065.
Department Heads are required to validate that an applicant requires a corporate card in order to
conduct business on behalf of the Company and must also recommend a monthly credit limit for each
applicant in their department. Applications and credit limits are subject to the approval of the CEO.
Card applicants are required to have access and able to process in Accounts Payable Concur system
prior to receiving a card.

Any questions or concerns can be directed to the Program Administrator at 626-398-4065 ext. 3102.

Accounting Treatment of Monthly Activity


It is the cardholder’s responsibility to review and reconcile the monthly activity of the transactions
posted in the Accounts Payable Concur site to the Electronic Statement in the JPMorgan Chase website.
The billing cycle ends on the 26th of each month.

Cardholders must assign their card charges in Concur within 5 days of the charge. All transactions
must be assigned to an expense report monthly. Current month’s expense reports must be submitted
in the month the charges apply to. Charges for future events are saved to Concur reports named with
the period the expense applies to and submitted when that time has come. Non-compliance will result
in loss of card privileges and other audit procedures.

Delegates cannot submit reports for cardholders, and it is the cardholder’s responsibility to ensure
timely submissions. Failure to observe deadlines will result in the suspension of the cardholder’s account.

Authorized Corporate Card Use


Upon approval, the cardholder will receive a card with his/her name embossed on it and the card is to
be used only by the cardholder. Card sharing (allowing others access to card) is prohibited. The
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cardholder may initiate transactions for their own expenses only. The cardholder is required to sign the
back of the card. The cardholder is bound by and subject to the terms and conditions of the Credit Card
Agreement and is responsible for all charges on the card.

The Corporate Card may be used only for reimbursable Company travel and entertainment expenses.
Examples of typical Corporate Card uses are: airplane tickets, hotel or rental car expenses, catering or
food purchases for meeting expenses, restaurant bills or facility or meeting room rentals incurred in
connection with Company business. Please note that spousal or companion expenses are not allowed
even if reimbursement is intended. Personal means must be used for those expenses and not
intermingled with business transactions.

Unauthorized Corporate Card Use


Transactions with certain types of merchants are blocked from use with the Corporate Card. These
merchants operate businesses or provide services that may not be charged to the Corporate Card. The
following is a list of categories of expenditures that are prohibited.

Prohibited Purchases:
A. Gift cards, gift certificates and other cash or gift instruments
B. Office supplies or computer and computer related equipment, unless you have prior written
approval
C. Capital equipment
D. Clothing
E. Consulting or personal services
F. Fines, penalties or similar fees including parking and moving violations
G. Leases except rental cars provided prior approval is obtained
H. Personal purchases including spousal or companion traveler expenses
I. Recreational or social memberships or other related expenses
J. Utilities except telecommunication devices provided prior approval is obtained
K. Maintenance agreements
L. Unapproved entertainment for Company customers or clients (prices should not be exorbitant)
M. Personal subscriptions (Apple, SiriusXM, or any other application)

Transactions
The cardholder should take reasonable steps to obtain the best pricing available at the time of purchase.
Cardholders should utilize those companies that the Company has worked with to provide company-
wide discounted pricing. For information on preferred travel partners and providers, please contact the
Plan Administrator at 626-398-4065 harboraccounting@harborservices.com or
accounting@coasttr.com.

Cardholder Record Keeping and Retention


Each department should ensure that cardholders maintain adequate documentation for all transactions
made with Corporate Cards. This documentation will be used to reconcile the purchases and credits and
must be retained for a period of three years.
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A. When a purchase is made in person, the cardholder will retain the invoice and customer copy of
the charge receipt. The cardholder is responsible for checking that the merchant lists the purchase
details such as quantity and full descriptions of the item(s). This particularly applies to meals or catered
events where specific items ordered must be listed and included with the charge receipt slip.

B. When making a purchase via telephone, Internet, or mail order, the cardholder must request that
a receipt or confirmation of the order be provided directly to the cardholder.

C. If a transaction is for catering or miscellaneous meeting expense, additional documentation


listing the date, list of attendees, and the business purpose of the meeting is required.

D. In the event of missing receipts or supporting documentation, cardholders must contact the
merchant for a duplicate receipt or invoice. If merchant is unable to provide this, contact Dulce Jarvina
for direction in obtaining the necessary specific approval for that transaction. It is possible that without
documentation or a clear business purpose for the charge, reimbursement by the cardholder may be
required.

E. Incidental personal charges on hotel or restaurant bills may be paid using the Corporate Card.
These amounts due the Company must be deposited with Accounts Receivable department and attach
copies of deposit form and check to the expense report. Only these charges are excluded from the
personal use prohibition. Out of pocket expenses not paid on the Corporate Card are to be included in
the expense report for reimbursement. These items are not to be combined for a net amount due to or
from the Company.

Disputes
Cardholders by contract are required to contact merchants directly regarding disputes or potentially
disputed transaction. Usually this resolves any question. If the card has been used without authorization,
this is fraudulent activity, not a dispute, and the account must be closed. Before submitting a dispute,
cardholder must contact the Program Administrator with details. Disputes filed without this prior notice
will be undone.

If the cardholder is unable to resolve the situation, the transaction must be disputed within 60 days of
the date of the charge. This dispute should occur only after a diligent attempt has been made to correct
the discrepancy and the merchant has failed to respond.

Notes: When there is fraudulent activity on a card, the cardholder needs to contact JP Morgan Chase
immediately in order to review transactions for validity and place a hold on the card. In the past,
affidavits have been sent directly to the cardholder by the fraud department. The cardholder needs to
work with Chase directly in these cases, and Chase will do the leg work on their end.

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Audit Procedures
The Company will perform routine reviews of Corporate Card transactions. Such audits will be designed
to verify that card transactions are authorized and appropriate, to verify that required documentation
has been properly accumulated, approved, and filed, and that no fraudulent or personal use of the card
has occurred. In the event of an audit finding, any of the following actions, depending on the severity
of the finding, may be taken by Harbor Rail:

A. Warning letter issued to cardholder and Supervisor and/or Department Head


B. Card is suspended for up to 3 months
C. Card use terminated
D. Reimbursement
E. Sanction or termination of employment

If termination is warranted, a cardholder’s supervisor will make a recommendation to Human Resources.

Corporate Card Security


Immediately upon receipt of a Corporate Card, the cardholder must sign the back of the card.

It is the cardholder’s responsibility to safeguard the Corporate Card and account number. Cardholders
must not allow anyone to use his/her card or account number. If a Corporate Card is lost or stolen, the
cardholder shall immediately notify JPMorgan Chase as well as advise the Program Administrator.

A new Corporate Card will be issued promptly to the cardholder after the reported loss or theft. A card
that is subsequently found by the cardholder after being reported lost or stolen must be cut in half and
forwarded to the Program Administrator.

Returning the Corporate Card


In the event of transfer or termination of employment, cardholders are required to return their
JPMorgan Chase Corporate Card to either the Program Administrator at the corporate office or their
department head. Accordingly, departments are responsible for the timely notification for the
cancellation of cards for any transferred or terminated employee cardholders. This notice must be
provided within two business days of the termination date.

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