CODE OF CONDUCT

CONDUCT AND BEHAVIOR

GENERAL CONDUCT GUIDELINES

Employees are expected to exercise common sense and courtesy at all times, for the benefit of clients, co-workers, and the Company as a whole. Professionalism is expected, as is respect for the safety and security of people and property. Failure to meet these expectations may be grounds for discipline, up to and including termination. The following are examples of unacceptable conduct, but this is not an exhaustive list.

• Failure to follow the policies outlined in this handbook.
• Negligent, careless, or inconsiderate treatment of clients or their information.
• The, misappropriation, or unauthorized possession or use of any property that does not belong to the employee.
• Unauthorized removal of Company property from the premises.
• Sharing trade secrets or other confidential business information with anyone who does not have an official need to know.
• Accessing, without authorization, confidential information pertaining to clients or employees.
• Falsifying or changing any type of Company, client, or employee document or record without authorization.
• Willfully, negligently, or carelessly damaging, defacing, or mishandling property of the Company, a client, or an employee.
• Taking or giving bribes of any nature.
• Entering Company premises without authorization.
• Violating security, safety, or fire prevention regulations, or tampering with safety equipment.
• Unauthorized use of a personal vehicle for Company business.
• Conduct that is illegal under federal, state, or local law.
• Creating a disturbance on Company premises.
• Use of abusive language.
• Any rude, discourteous, or unbusinesslike behavior, on or off Company premises, which is not protected by Section 7 of the National Labor Relations Act and that
adversely affects the Company services, operations, property, reputation, or goodwill in the community, or interferes with work.
• Insubordination or refusing to follow instructions from a supervisor or manager; refusal or unwillingness to accept a job assignment or to perform job requirements.
• Leaving during scheduled work hours without permission; unauthorized absence from assigned work area during regularly scheduled work hours.
• Sleeping during regular working hours.
• Recording time for another employee or having time recorded by another employee.
• Use or possession of illegal drugs on Company premises at any time.
• Use of alcohol or illegal drugs during working hours, or working under the influence of intoxicants.
• Unauthorized possession of a weapon on Company premises.
• Illegal gambling on Company premises.
• Soliciting, collecting money, vending, and posting or distributing bills or pamphlets during working hours in work areas. Such activity by employees during non-working time, including meal and rest periods, is not restricted so long as such activity does not interfere with the regular operation of business, is orderly, lawful, in good taste, conducted in an orderly manner, and does not create a safety hazard or a mess. Non-employees are prohibited from all forms of solicitation on Company
property at all times.

SEXUAL AND OTHER UNLAWFUL HARASSMENT

The Company is committed to providing a work environment free of harassment in any form, including inappropriate and disrespectful behavior, intimidation, and other unwelcome conduct directed at an individual because of their inclusion in a protected class. Applicable federal and state law defines harassment as unwelcome behavior based on someone’s inclusion in a protected class. Sometimes language or actions that were not expected to be offensive or unwelcome actually are, so employees should err on the side of being more sensitive to the feelings of their co-workers rather than less.

The following are examples of harassment; behaviors not in this list may also be considered harassment:

• Unwanted sexual advances;
• Offering employment benefits in exchange for sexual favors;
• Retaliation or threats of retaliation for refusing advances or requests for favors;
• Leering, making sexual gestures or jokes, or commenting on an employee’s body;
• Displaying sexually suggestive content;
• Displaying or sharing derogatory posters, photographs, or drawings;
• Making derogatory epithets, or slurs;
• Ongoing teasing about an employee’s religious or cultural practices;
• Ongoing teasing about an employee’s sex, sexual orientation, or gender identity;
• Physical conduct such as touching, assault, or impeding or blocking movements

Sexual harassment on the job is unlawful whether it involves coworker harassment, harassment by a manager, or harassment by persons doing business with or for the Company, such as clients, customers or vendors.

Retaliation
Any form of retaliation against someone who has expressed concern about any form of harassment, refused to partake in harassing behavior, made a harassment complaint, or cooperated in a harassment investigation, is strictly prohibited. A complaint made in good faith will under no circumstances be grounds for disciplinary action. Individuals who make complaints that they know to be false may be subject to disciplinary action, up to and including termination.

Enforcement
All managers and supervisors are responsible for:

• Implementing the Company’s harassment policy;
• Ensuring that all employees they supervise have knowledge of and understand the Company policy;
• Reporting any complaints of misconduct to the designated company representative, the Owners, so they may be investigated and resolved internally;
• Taking and/or assisting in prompt and appropriate corrective action when necessary to ensure compliance with the policy; and
• Conducting themselves in a manner consistent with the policy.

Addressing Issues Informally
Employees who witness offensive behavior in the workplace – whether directed at them or another employee – are encouraged, though not required, to immediately address it with the employee whose behavior they found offensive. An employee who is informed that their behavior is or was offensive should stop immediately and refrain from that behavior in the future, regardless of whether they agree that the behavior could have been offensive.

Harassment Complaint Procedure
Employees are encouraged to use the Complaint Procedure to report behavior that they feel is harassing, whether or not that behavior is directed at them. The Complaint Procedure provides for immediate, thorough, and objective investigation of claims of harassment. Appropriate disciplinary action will be taken against those who are determined to have engaged in harassing behavior.

ABUSIVE CONDUCT

Abusive conduct means malicious conduct in the workplace that a reasonable person would find hostile or offensive and unrelated to an employer’s legitimate business interests. Abusive conduct may 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. A single act will generally not constitute abusive conduct, unless especially severe.

The Company considers abusive conduct in the workplace unacceptable and will not tolerate it under any circumstances. Employees should report abusive conduct to a manager or Human Resources. Managers are responsible for ensuring that employees are not subjected to abusive conduct. All reports will be treated seriously and
investigated when appropriate. Employees who are found to have engaged in abusive conduct will be subject to discipline, up to and potentially including termination. Retaliation against an employee who reports abusive conduct or verifies that it took place is strictly prohibited.

COMPLAINT PROCEDURE

The Company has established a procedure for a fair review of complaints related to any workplace controversy, conflict, or harassment. Employees may take their complaint directly to the person or department listed in Step 2 if the complaint is related to their supervisor or manager or if the employee feels the supervisor or manager would not provide an impartial resolution to the problem.

Step 1
The complaint should be submitted orally or in writing to a supervisor or manager within three working days of the incident or as soon as possible. Sooner is better, as it will assist in a more accurate investigation, but complaints will be taken seriously regardless of when they are reported. Generally, a meeting will be held within three business days of the employee’s request, depending upon scheduling availability. Attempts will be made to resolve the issue during the meeting, but regardless of whether there is an immediate resolution, the supervisor or manager will give the employee a written summary of the meeting within three business days. Resolution may take longer if further investigation of the complaint is required. If the employee is not satisfied with the resolution, they may proceed to Step 2.

Step 2
The employee may submit an oral or written request for review of the complaint and Step 1 resolution to the Owners or a designated investigator. This request should be made within three working days following the receipt of the Step 1 resolution. The Owners or the designated investigator will review the complaint and resolution and may call an additional meeting to explore the problem. If warranted, additional fact-finding will be undertaken. A final decision will be rendered within 10 working days after receiving the Step 2 request, and a written summary of the resolution will be provided to the employee who filed the complaint.

CORRECTIVE ACTION

A high level of job performance and professionalism is expected from each employee. In the event that an employee’s job performance does not meet the standards established for the position, they violate company policies or procedures, or their behavior is otherwise unacceptable, corrective action may ensue. Corrective action may include, but is not limited to: coaching, oral or written warnings, performance improvement plans, paid or unpaid suspension, demotion, and termination. The type and order of actions taken will be at management’s sole discretion and the Company is not required to take any disciplinary action before making an adverse employment decision, including termination.