Handbook 2018

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Mission

Brasco International, Inc. is a trusted designer and manufacturer of


a full line of aluminum transit, bike and custom shelters, solar
powered lighting, and streetscape furnishings that deliver value,
quality, and originality to transit agencies and commercial markets.

Vision
Brasco International, Inc. will set the standard as the most
respected, innovative designer and fabricator of aluminum
shelters and streetscape furnishings in the USA.

Values
▪ Put Our People First.

▪ Exceed Expectations

▪ Do the Right Thing, Always.

▪ Communicate Clearly, Quickly, with Kindness and Respect.

▪ Commit to Brasco’s Success- Individually and as a Team


TABLE OF CONTENTS

Section 1 - Introduction
1.1 Welcome
1.2 Equal Employment Opportunity
1.3 Employment At Will
Section 2 - Employment Policies
2.1 Classification of Employment
2.2 Probationary Period
2.3 Open Door
2.4 Immigration Law Compliance
2.5 Americans with Disabilities Act
2.6 Reasonable Accommodations for the disabled
2.7 Employee Testing
2.8 Employee Personnel Files Policy
2.9 No Expectation of Privacy/Investigations
2.1 Right of Access
2.11 Confidentiality
2.12 Company Property
2.13 Company Tool Policy
2.14 Employee Expense Report Policy
2.15 Employee Referral Bonus Policy
2.16 References
2.17 Social Security Number Privacy Policy
Section 3 - Hours of Work and Payroll Practices
3.1 Work Hours
3.2 Call in procedure
3.3 Payday
3.4 Overtime
3.5 Payroll Advances
3.6 Time Clock Procedures
3.7 Timekeeping
3.8 Employee Deductions
Section 4 - Employee Benefits
4.1 Employee Benefits
4.2 Benefit Continuation/Cobra
4.3 Tuition Reimbursement
4.4 Paid Holidays
Section 5 - Employee Leaves of Absence and Time Off
5.1 PTO
5.2 Eligibility
5.3 Use and scheduling of PTO
5.4 Unpaid Leave of absence
5.5 Bereavement Leave
5.6 Medical Leave of Absence FMLA
5.7 Jury/Witness Duty
5.8 Military Duty
Section 6 - Standards of Conduct and Employee Performance
6.1 Employee Standards of Conduct
TABLE OF CONTENTS

6.2 Prohibition of Harassment in the Workplace


6.3 Definition of unlawful sexual harassment
6.4 Workplace Violence
6.5 Weapons Policy
6.6 Workplace Bullying
6.7 Other Discriminatory Harassment
6.8 Complaint Procedure
6.9 Ethical Standards
6.10 Substance Abuse Policy
6.11 Smoking
6.12 Attendance Policy
6.13 Progressive Discipline
6.14 Social Media -- Acceptable Use Policy
6.15 Internet Use Policy
6.16 Customer Contact Policy
6.17 Moonlighting
6.18 Release of information to outsiders, press or public
6.19 Conflicts of Interest
6.20 Vehicle Policy
6.21 Cell Phone Policy
6.22 Dress Code
6.23 Performance Reviews
6.24 When you leave employment
Section 7 - Workplace Safety
7.1 Employee Health and Safety
7.2 Good Housekeeping
7.3 Workplace Security
7.4 Security Cameras in the Workplace
7.5 Safety Eye Glasses
7.6 Hearing Protection
7.7 Safety Shoes
7.8 Electronics
7.9 Injury Report
7.10 Emergency Facility
7.11 Light Duty
7.12 Workers Compensation Insurance
7.13 Dogs in the Workplace
Section 8 - Employment Dispute Resolution Policy
8.1 Employment Dispute Resolution Policy
8.2 Covered Claims
8.3 Claims not covered
8.4 Content of mediation demand: time limits
8.5 Pre-mediation Procedures
8.6 Rules for Governing the mediation
8.7 Other Provisions
Section 9 - Amendments/Acknowledgements
9.1 Amendments
TABLE OF CONTENTS

9.2 Acknowledgements
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017 EMPLOYEE HANDBOOK

SECTION 1 – INTRODUCTION
1.1 WELCOME

As an employee of BRASCO INTERNATIONAL, INC., you are an important member of a team effort. We hope
you will find your position with the Company rewarding, challenging and productive.

Because our success depends upon the dedication of our employees, we are highly selective in choosing
new members of our team. We look to you and the other employees to contribute to the success of the
Company.

This employee handbook is intended to explain the benefits, several significant policies, and terms and
conditions of employment of all employees.

1.2 EQUAL EMPLOYMENT OPPORTUNITY

BRASCO INTERNATIONAL, INC is an equal opportunity employer. Company policy prohibits unlawful
discrimination based on race, color, gender, religion, marital status, registered domestic partner status,
age, national origin or ancestry, physical or mental disability, medical condition including genetic
characteristics, sexual orientation, or any other consideration made unlawful by federal, state or local
laws. It 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.
The company is committed to compliance with all applicable laws providing equal employment
opportunities.

1.3 EMPLOYMENT “AT–WILL”

BRASCO INTERNATIONAL, INC. is an “at-will” employer. This means that you and the Company each have
the right to terminate the employment relationship at any time, with or without notice, prior warning or
discipline, and with or without cause. Neither the policies contained in this Handbook, nor any other
written or verbal communications from the Company, are intended to create a contract of
employment for any specified period of time, or to otherwise change the “at-will” nature of the
employment relationship.

.
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

SECTION 2 – EMPLOYMENT POLICIES

2.1 CLASSIFICATION OF EMPLOYMENT

For purposes of salary administration and eligibility for overtime payments and employee benefits, the
Company classifies its employees as follows:
1. Full-Time Employees. Employees hired to work the Company’s normal, full-time,
forty hour work week on a regular basis. Such employees may be “exempt” or “non-
exempt” as defined below.

2. Part-Time Employees. Employees hired to work less than forty hours per week on a
regular basis. Such employees may be “exempt” or “non-exempt” as defined below.
Such employees are not entitled to benefits.

3. Temporary Employees. Employees engaged to work for a limited period on the


Company’s payroll with the understanding that their employment will be terminated
no later than upon completion of a specific assignment. Such employees may be
“exempt” or “non-exempt” as defined below.

4. Non-exempt Employees. Employees who are required to be paid overtime at the rate
of one and one-half times their regular rate of pay for all hours worked beyond forty
hours in a work week, in accordance with applicable wage and hour laws.

5. Exempt Employees. Employees who are not required to be paid overtime, in


accordance with applicable wage and hour laws, for work performed beyond forty
hours in a work week. Executives, professional employees, outside sales
representatives, and certain employees in administrative positions are typically
exempt.

You will be informed of your initial employment classification and of your status as an exempt or non-
exempt employee by your supervisor. If you change your position during your employment as a result of
a promotion, transfer, or otherwise, you will be informed by your supervisor of any change in your
classification and exemption status.

2.2 PROBATIONARY PERIOD

Your first 90 days of employment with the Company is a period of training and adjustment. During this
probationary period, and throughout your employment with the Company, you are strongly encouraged to
ask any questions necessary to help better understand and perform your job, or to understand policies,
procedures and/or the goals of the Company. Even though the Company does have a training period,
this does not change the Company’s EMPLOYMENT “AT-WILL” policy.

After 90 calendar days of employment with the Company, employees will be eligible for all benefits given
to regular employees. (The effective date is on the employee’s 90th day of employment)
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

2.3 OPEN DOOR

It is important that Management and all employees maintain effective communication and understanding.
This is essential to the accomplishment of Company goals and objectives.
The Company maintains an open door policy and employees are urged to voice their work-related
concerns or problems to management as soon as they arise. See your immediate Supervisor first and
follow your chain of command.

2.4 IMMIGRATION LAW COMPLIANCE

It is the policy of the Company to hire and employ only United States citizens and aliens who are
authorized to work in the United States according to federal and state law. Therefore, each new
employee must complete the “Employment Eligibility Verification Form I-9” and present documentation
establishing identity and employment eligibility. It is the employees’ responsibility to keep their residency
status and work permit status up to date at all times.

2.5 AMERICANS WITH DISABILITIES ACT (ADA) AND THE ADA AMENDMENTS ACT (ADAAA)

The Americans with Disabilities Act (ADA) and the Americans with Disabilities Amendments Act, known
as the ADAAA, are federal laws that prohibit employers with 15 or more employees from discriminating
against applicants and individuals with disabilities and that when needed provide reasonable
accommodations to applicants and employees who are qualified for a job, with or without reasonable
accommodations, so that they may perform the essential job duties of the position.

It is the policy of Brasco to comply with all federal and state laws concerning the employment of persons
with disabilities and to act in accordance with regulations and guidance issued by the Equal Employment
Opportunity Commission (EEOC). Furthermore, it is our company policy not to discriminate against
qualified individuals with disabilities in regard to application procedures, hiring, advancement, discharge,
compensation, training or other terms, conditions and privileges of employment.

The company will reasonably accommodate qualified individuals with a disability so that they can perform
the essential functions of a job unless doing so causes a direct threat to these individuals or others in the
workplace and the threat cannot be eliminated by reasonable accommodation and/or if the
accommodation creates an undue hardship to Brasco. Contact the Human Resource department with any
questions or requests for accommodation.

As a consequence, applicants and employees requiring any reasonable accommodations must notify the
Company in writing as soon as they become aware of a possible need for accommodation. Please see
HR for a Request for Accommodation Form.

2.6 REASONABLE ACCOMMODATIONS FOR THE DISABLED

In carrying out its commitment to equal employment opportunity, the Company will make reasonable
accommodations for applicants and employees with known disabilities who can perform the essential
functions of the job with or without such accommodations and in conformity with applicable law.

2.7 EMPLOYEE TESTING

Employees will be required to undergo alcohol and/or drug testing when:

- New Hire: Testing is conducted to prevent the hiring of individuals who illegally use drugs. New
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

Hires that do not complete 30 days will be charged through a payroll deduction the cost of the
drug test/physical.

- Post-Accident: Testing is conducted of employees who are involved in on-the-job injuries,


accidents or near accidents, or who engage in unsafe job related activities that pose a significant
danger to themselves, other employees or the public.

- Follow-up: Testing is conducted of employees who have violated the Company’s Substance
Abuse Policy, but were given the opportunity to keep their jobs conditioned on successful
rehabilitation and no further positive tests.

- Reasonable Suspicion: Testing is conducted when there is information about an employee’s


appearance, conduct or behavior that would cause a reasonable person to believe that the
employee has used or may be impaired by drugs or alcohol.

- Random: Testing may be conducted on a neutral selection basis with all employees subject to
testing having an equal chance of being selected through computer selection of employee
identification numbers.

An employee who refuses to immediately submit to a substance test under any of the circumstances
described above may be subject to immediate termination. Substance test results shall be strictly
confidential and will not be disclosed outside of the Company for any reason, except by court order,
without the employee’s written authorization.

- Only a Substance Abuse and Mental Health Administration – certified drug-testing laboratory will
be used.

- A strict chain of custody procedure will be used to ensure the integrity of each specimen.

- The employee testing process will ensure individual privacy during the collection process and the
confidentiality of test results.

- All positive drug screens will be confirmed by a second test using a different chemical process,
and only those samples that test positive on both the screen and the confirmation will be
considered a “positive” screen.

- All confirmed positive test results will receive a professional medical review, which includes the
opportunity for employees to explain the result.

- The refusal by an employee to take a drug or alcohol test is considered equivalent to a verified
positive drug test and therefore subjects the employee to the same adverse employment actions
up to and including termination of employment.

2.8 EMPLOYEE PERSONNEL FILES POLICY

Employee files are maintained by the Human Resource department and are considered confidential.
Managers and supervisors may only have access to personnel file information on a need-to-know basis.

A manager or supervisor considering the hire of a former employee or transfer/promotion of a current


employee may be granted access to the file, or limited parts of it, in accordance with antidiscrimination
laws.
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

Personnel file access by current employees and former employees upon request will generally be
permitted within three days of the request unless otherwise required under state law. Personnel files are
to be reviewed in the Human Resource department. Personnel files may not be taken outside the
department.

Employees who submit a written request may review or copy their personnel record on company
premises and during normal business hours. Removal or correction of any information in the record may
be done by mutual agreement. If no agreement is reached, you may submit a written explanation to be
part of the record. You will be responsible to pay for reasonable reproduction costs.

Representatives of government or law enforcement agencies, in the course of their duties, may be
allowed access to file information.

2.9 NO EXPECTATION OF PRIVACY POLICY/INVESTIGATIONS

When the Company has a reasonable suspicion that a threat to the safety of our employees, visitors,
customers or property exists or that there has been a violation of Company policy or the law, the
Company reserves the right to inspect the contents of all vehicles, packages, containers, bags
and other items brought onto company premises or used while on company business, regardless
of whether the owner or user of the item is present. No one should have an expectation of privacy in any
item brought onto company premises or used while on company business. Refusal by employees to
submit to such searches may be grounds for discipline up to and including discharge.

2.10 RIGHT OF ACCESS


Company computers and other information systems and their stored contents are owned by the
Company and are to be used solely for company business and not for personal communication.
This includes use of and information accessed by e-mail and the Internet. Employees should
have no expectation that any information contained on such systems is confidential or private,
regardless of the fact that they may have passwords or other means to identify confidential
records.

The Company retains the right of absolute access to all of its computers, retrieval systems, records,
storage, projects in process, documents and voice mail systems, or other repositories of information,
regardless of their location or format. Therefore, the Company retains the right, during the course of
business, to access and search all such locations including individual employees' directories, diskettes,
files, databases, and any other electronic transmissions contained in or used in conjunction with the
Company. Refusal to permit such access by the Employee may be grounds for discipline up to and
including termination.

The Company retains the right to search employee desks or storage areas in the conduct of its business
(i.e., to locate work product) and/or where the Company has a reasonable suspicion that there has been
a violation of company rules such as those against dishonesty or drug and alcohol abuse. Employees
should understand that they should have no expectation of privacy with respect to any item on
Company property or in their desks and storage areas and that such area may be accessed or
searched at any time in either the absence or presence of the employee. Refusal to permit such
access by the Employee may be grounds for discipline up to and including termination.

2.11 CONFIDENTIALITY

During the course of your employment with the Company, you may have access to information about the
business and its Employees and Customers that is confidential. This information must be kept
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

confidential. Before sharing information with ANYONE, employees are cautioned to check with
Management for prior approval.

Keeping such information confidential plays an important part in the Company’s success. The Company
protects proprietary information in several obvious ways, such as by restricting employee and visitor
access to certain designated areas to only those who have legitimate business there and requiring all
Company property be returned upon termination of employment. Employees are expected to respect and
adhere to these rules.

The unauthorized copying of computer software, data, files, or undisclosed technical information is
considered theft. This policy affects all information, including printouts, typewritten documents,
photocopies, microfiche or any magnetic medium (e.g. disk, tapes, CDs, NV RAM) and data transmitted
electronically via fax, modem, telex, e-mail or telephone.

It is the policy of the Company to ensure that the operation, activities and business affairs of the
Company and our clients, customers, suppliers, and vendors are kept confidential. If, during the course
of your employment, you acquire confidential or proprietary information about the Company and its
clients, customers, suppliers, or vendors, such information is to be handled in strict confidence and not to
be discussed with outsiders, particularly competitors. Such confidential and proprietary information may
include, but is not limited to, information or material which relates to the Company’s purchasing,
accounting, merchandising, “know-how”, customer information, financial information, supplier information,
vendor information, personnel information and any other information which the Company treats as
proprietary and confidential. Employees who acquire confidential or proprietary information about the
Company are responsible for the internal security of such information. In accordance with this policy, the
following guidelines should be followed:
1. Access to confidential or proprietary information of the Company should be
limited to those employees who have a business “need to know” such
information.

2. Any inquiries received from persons concerning confidential or proprietary


information of the Company must be immediately directed to the President or
Vice President for appropriate disposition.

3. Nothing contained in this policy is intended to prohibit the disclosure of


information about the Company that is routinely made available to the public by
advertisement or otherwise, such as the nature of the Company’s service and its
business hours.

Employees who violate this policy are subject to disciplinary action, up to and including termination.

2.12 COMPANY PROPERTY

The Company may supply equipment to employees to use on the job. These items remain the property
of the Company and may not be used for personal matters. Employees will be responsible for the
loss or damage of Company property provided to him or her. If property is worn or damaged due to
normal use, the employee should return it to Management for replacement. If an employee’s job with the
Company terminated, all property must be returned.
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

2.13 TOOL AND EQUIPMENT POLICY

Upon hire, Brasco International will provide employees the required tools for the job and department they
are assigned. The employee should treat these tools as they would their own and is responsible for the
care and safe keeping of these company purchased items. These tools are necessary to properly perform
the assigned job duties and employees are required to have their tools for this purpose. Secure storage
locations will be provided for the employee to store his/her tools. Lost or stolen tools will be replaced
at the employees cost unless there are extenuating circumstances. For additional information on this
policy, please see a member of management or human resources.

2.14 EMPLOYEE EXPENSE REPORT POLICY

Brasco International reimburses employees for necessary expenditures and reasonable costs incurred in
the course of performing their jobs. Expenses incurred by an employee must be approved in advance by
your supervisor.

Some expenses that may warrant reimbursement include but are not limited to the following: mileage
costs, air or ground transportation costs, lodging, cell phone reimbursement, and any other reimbursable
expenses as required by law or company policy. Employees are expected to make a reasonable effort to
limit business expenses to economical options.

To be reimbursed:
• Expenses must be approved in advance by your supervisor.
• Employees must submit expense reports to VP of Finance for approval.
• The report must be accompanied by receipts or other documentation substantiating the
expenses.
• Expenses must be submitted for reimbursement within 30 days of occurrence.

Expenses deemed excessive by management may not be reimbursed and may subject the employee to
progressive discipline, up to and including termination.

Any falsification of expense reports will be grounds for immediate termination.

Expense reimbursement checks are processed every two weeks on Fridays.

Questions regarding this policy should be directed to your supervisor and/or the VP of Finance.

2.15 EMPLOYEE REFERRAL BONUS

Effective July of 2017: In the event an employee refers another employee to work for Brasco a referral
bonus will be paid. The bonus is eligible to be paid when the referred employee reaches 90 days of hire.
After the 90 days, the referring employee will receive a bonus of $200 paid as a separate payroll check
through Paychex. For additional information on this policy, please see human resources.

2.16 REFERENCES

Any request for an employment reference from the Company must be made to Management. No other
person may provide you with a reference on behalf of the Company. It is our policy to provide only an
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

Employee’s dates of service and the title of your last position when responding to requests for references.
If an Employee wants other information to be disclosed, he or she must give a written request to
Management that specifically identifies the information to be disclosed and specifically authorizes release
of the information to a third party.

2.17 SOCIAL SECURITY NUMBER PRIVACY POLICY

The Company’s goal is to ensure that personal information regarding employees will be maintained in
confidence. Social security numbers will not be released to anyone outside the Company, except as
required by law, and will only be made available internally on a “need to know” basis.

Only the last four digits of a social security number will be included on any document mailed outside the
Company, except as required by law. Social security numbers will not be used as passwords or
identifiers for any Company computer system, nor will they be used in the ordinary course of business,
except when necessary to verify an individual’s identity or to administer employee benefits. Any
documents that include social security numbers are to be shredded when discarded.

SECTION 3 – HOURS OF WORK AND PAYROLL PRACTICES

3.1 WORK HOURS

Regular working hours for employees of the Company vary depending upon their job, workload and
customer service needs. Regular work hours may be scheduled on any day, Monday through Sunday
and at any time during the 24 hours of any day.
Your supervisor will provide you with your regular work schedule. Daily and weekly regular working
schedules may be changed, at any time, at the sole discretion of the Company, as it deems necessary to
meet the varying conditions of its business. Changes in work schedules will be announced as far in
advance as practicable. However, shift assignment may occur with little notice.
Employees are entitled to a 30-minute unpaid meal break each day. If a nonexempt employee is required
to work through a meal break, he or she will be paid for the 30- minute period.

3.2 CALL-IN PROCEDURE

If you will be late, absent or unable to report for work at your regularly scheduled starting time, you must
contact your Supervisor and Human Resources before the start of your shift. If possible, state when
you expect to return to work. (313)393-0393 ext. 204. Failure to call in before the start of your shift may
result in a no call/no show and is not eligible for PTO.

3.3 PAYDAY

Hourly employees are paid weekly on Fridays. If a payday falls on a holiday, payroll is paid one day
earlier. Payroll is paid through direct deposit to an account of your choice or chase visa pay card only.
Paystubs can be viewed by registering at www.paychecx.com. If you need to contact Paycheckflex,
please call 1-800-472-0072 or 1-877-244-1771.
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

3.4 OVERTIME

Non-exempt employees are eligible for time and a half pay for time worked over 40 hours in a work week.
The work week begins on Sunday at midnight and ends Saturday at 11:59 pm. Holiday and PTO hours
do NOT count towards the 40 hours worked in one week.
On occasion, overtime may be deemed necessary by the Company. Employees are expected to work
beyond their scheduled hours (overtime) when requested to do so, often times with little advance notice.
The Company will try to give advance notice as soon as practicable. Overtime shall be assigned by an
employee’s supervisor and no employee is permitted to work overtime without the prior approval of
his/her supervisor. Authorized overtime in excess of 40 hours per week will be paid at the rate of 1.5
times the regular rate of pay for non-exempt –hourly employees only.

3.5 PAYROLL ADVANCES

The Company does not print paychecks or give advances on payroll. This includes loans requested by
employees, which is not permitted due to company policy.

3.6 TIME CLOCK PROCEDURES

All employees must punch-in their own time according to their work schedule; it is fraudulent behavior for
an employee to punch another employee’s time. At the time the employee punches-in their time they
must be dressed and ready for work. An employee is to clock in at the start of their shift. An employee
will not be given credit for time punched-in before their scheduled starting time unless the employee is
given prior authorization by the Company. Each employee must punch-out at the scheduled end of their
shift.
In the event an employee misplaces or forgets their badge, resulting in not punching in or out for their
shift, it is the employee’s responsibility to ensure HR is notified of the missed punch. If HR is not notified
and payroll is ran, it is not the company’s responsibility to produce manual checks for missed hours. If a
missed punch occurs, it may result in an unpaid day unless the employee notifies HR immediately.
Violations of this policy may result in discipline up to and including discharge.

3.7 TIMEKEEPING

Production Employees: Production employees are paid based on the actual number of hours worked.
Employees are required to punch a time clock upon arrival and punch a time clock upon departure.

Sales Representatives: Sales representatives are paid a salary, plus sales commission based on sales.
Sales representatives are expected to keep regular office hours. If you have any questions about your
hours, please contact Management.

Administrative/Office Employees: No-exempt Administrative employees are paid an hourly wage and
expected to keep regular office hours, from 8:00 a.m. to 4:30 p.m. Exempt Administrative employees are
paid a salary and expected to keep regular office hours, from 8:00 a.m. to 4:30 p.m. If you have any
questions about your hours, please contact Management.

Flex-Time is permitted between the hours of 7:00 a.m. and 5:00 p.m. with prior approval of Management.

3.8 EMPLOYEE DEDUCTIONS

The Company as authorized by federal and state law will deduct the following from your paycheck:
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

- Government Deductions: We may be ordered by the court to deduct funds from your
paycheck for Friend of the Court payments, garnishments, etc.

- Insurance Premiums: Deductions will be made each pay period to cover premiums for
eligible, enrolled employees.

- Lost Equipment: If Company equipment is lost, stolen or damaged due to misuse; you will
be responsible for paying for it. This includes the cost of employee badges.

- Purchases: If you purchase Brasco clothing and/or safety equipment: costs of these items
will be deducted from your paycheck by signing a receipt and deduction form.

Each employee must sign all employee deduction forms. It is important that these are reviewed and
signed in a timely manner and returned to Management. If you refuse to sign and have a valid claim to
back up your refusal, please note your claim on the back and turn it in to Management for review. At that
time or at an arranged time, we will discuss the proposed deduction.

Also, if you choose to throw away the deduction sheet or do not return it in a timely manner, you will be
deemed to have refused to sign the form.

It is Company policy and practice to pay employees in compliance with federal and state law. The
Company prohibits improper deductions from employee salaries and is prepared to correct any mistakes
or improper deductions. Employees who believe any mistakes or improper deductions have been made
to their pay should report their concerns immediately to Human Resources. The Company will make all
appropriate corrections as soon as reasonably possible.

SECTION 4 – EMPLOYEE BENEFITS


4.1 EMPLOYEE BENEFITS

The Company has established a variety of employee benefit programs designed to assist employees and
their eligible dependents in meeting the financial burdens that can result from illness and disability, and to
help you plan for retirement.

The Company reserves the right to amend, modify or terminate, in whole or in part, any or all of the
provisions of the benefit plans described herein, including any health benefits that may extend to
employees and their dependents, within the limits of the law. Further, the Company reserves the
exclusive right, power and authority, to administer, apply and interpret the benefit plans described herein,
and to decide matters arising in connection with the operation or administration of such plans.

For more complete information regarding any of our benefit programs, please refer to the Summary Plan
Descriptions, which were provided to you separately, or contact HR. If you lost or misplaced those
descriptions, please contact HR for another copy. Following is a list of benefit programs which may be
offered by the Company.

- Health Insurance
- Dental Reimbursement
- Group Life Insurance
- Supplemental Insurance
- 401(k) Plan
- Tuition Reimbursement
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

4.2 BENEFIT CONTINUATION/COBRA

In certain circumstances, when you leave employment or when coverage under the health plan would
otherwise end, you will have the opportunity for a temporary extension of health coverage at group rates.
If you have any questions regarding continuation of coverage, please contact HR.

4.3 TUITION REIMBURSEMENT

Brasco will reimburse any full time, permanent employee, 75% of the cost including relevant fees per
class up to $1,000. Classes must in some way be relevant to Brasco’s work environment.
Reimbursement requires proof of successful completion with a passing grade of C or better.

4.4 PAID HOLIDAYS

Regular employees receive the following eight paid holidays each year. To receive holiday pay, you are
required to work your full shift the day before and the day after a Holiday, unless you have pre-approved
time off or the entire Company is closed. Occasionally, Customer requirements will need to be met on a
holiday. If you work a holiday, you will be paid holiday time at the regular rate and additionally at a rate
that would normally be paid for the hours worked.
For purposes of this policy, holidays are:

- New Year’s Day


- Good Friday
- Memorial Day
- Independence Day
- Labor Day
- Thanksgiving Day
- Friday after Thanksgiving
- Christmas Day

SECTION 5 – EMPLOYEE LEAVES OF ABSENCE AND TIME OFF


5.1 PAID TIME OFF (PTO):

Brasco believes that employees should have opportunities to enjoy time away from work to help
balance their lives. Brasco recognizes that employees have diverse needs for time off from work.
Brasco has established this paid time off (PTO) policy to meet those needs. The benefits of PTO are
that it promotes a flexible approach to time off. Employees are accountable and responsible for
managing their own PTO hours.
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

5.2 ELIGIBILITY

Eligible employees are entitled to paid time off after successful completion of 90 days of full time
employment, which will be prorated their first year of hire. Eligible employees must be scheduled to
work at least 40 hours per week on a regular basis. Employees working less than 40 hours per week
on a regular basis are not eligible to accrue PTO. Service years will consist of continuous calendar
years commencing on January 1st of each year.

5.3 USE AND SCHEDULING OF PTO

Arrangements for Paid Time Off should be requested and approved by your supervisor no later than
48 hours in advance. Employees should submit vacation plans to their supervisor at least 4 (four)
weeks in advance of the requested vacation date.

The Company reserves the right to refuse any PTO requests that conflict with business staffing
requirements or previously approved PTO of colleagues. Management will return the request within
3 business days of the date it is submitted indicating that the request has been approved or denied.
If the request has been denied, Management will provide a response on the form returned to the
employee.

• Employees who are sick for 3 (three) consecutive days should present a doctor’s note
to his/her supervisor.

Per 6.12 Attendance Policy:

• Unapproved Absence: Time lost from a scheduled work day that was not approved in
advance, or approved by management.

• Approved Absence: Time lost from a scheduled work day for: scheduled paid time
off, holiday, approved bereavement leave, jury duty, military service, temporary layoff,
on-the-job injury, approved short term/long term disability, approved leave of absence.
A written excuse is not automatically an approved absence.

• Calling in is an Unapproved Absence.

PTO will be taken in (4) hour increments. PTO is not part of any overtime calculation. Employees
are required to use available PTO when taking time off from work with the exception of a company-
required absence due to low workload or absences occasioned by the company.
Under the company's Family and Medical Leave Act (FMLA) policy, all accrued PTO time is to be
taken before the start of the unpaid FMLA time.

Paid time off will not be accrued during an unpaid leave of absence. Employees may not borrow
against their PTO banks; therefore, no advance leave will be granted. Any PTO earned may not be
carried over to the next year. It will be lost if not used. Employees who terminate their employment,
or whose employment is terminated, will not be paid for any remaining PTO.
PTO is earned on an annual basis. PTO will be granted on the 1st of the calendar year.

Non-Exempt Employees will earn PTO based on the following schedule:

Length of Employment PTO Entitlement


After 90 days of service 40 Hours (prorated the 1st year of employment)
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January 1, 2017

Beginning the 2nd calendar year 80 Hours


Beginning the 5th calendar year 120 Hours

Exempt Employees will earn PTO based on the following schedule:

Length of Employment PTO Entitlement


After 90 days of service 80 Hours (prorated the 1st year of employment)
Beginning the 2nd calendar year 80 Hours
Beginning the 5th calendar year 120 Hours

Salaried (Exempt) Employees will be given an additional (3) days of sick time per calendar year,
which is not to be used in lieu of PTO. Employees who terminate their employment, or whose
employment is terminated, will not be paid for any remaining sick time.
*A doctor’s note may be requested by HR if needed depending on the circumstance.

Employees eligible for more than ten (80) hours PTO are NOT permitted to be absent from the
Company for longer than two (2) consecutive weeks at one time.

5.4 UNPAID LEAVE OF ABSENCE

If you wish to take a Leave of Absence, a request must be made in writing. Please see
Management to discuss the proper procedure and paperwork. Leave of Absence may be granted
for extenuating situations that temporarily prevent an employee from working. They are not granted
to allow an Employee to seek other employment. Probationary employees are not entitled to take an
unpaid leave of absence.

The Company reserves the right to grant or decline leaves of absence depending on business
demands at the time of the request. The Company will also consider the purpose of the leave, and
the number of employees seeking leave for the same period of time. Employees will be entitled to
only one (1) leave of absence during a 12 month period. Any employee who uses a leave of
absence for a purpose other than for which it was granted, or does not return to work after the
approved leave, may be subject to termination effective on the last day worked.

Any PTO time available to the employee must be used as part of the leave. Employees who have
exhausted PTO time may be granted a leave based on extenuating circumstances.

While on an unpaid leave of absence, the employee’s medical coverage will end on the 1st day of the
month following the start of such leave. Employees will have an opportunity to continue their
benefits for a maximum of 18 months by paying the monthly premiums as required by COBRA.

Unemployment Insurance benefits cannot be collected while on a leave of absence without pay.
Any planned salary increase for an employee returning from a leave of absence without pay will be
deferred by the length of the leave.

Due to the nature of our business, the Company cannot guarantee either that an employee’s job will
remain available or that a comparable position will exist when return from an unpaid leave is sought.
When an employee is ready to return from an unpaid leave, the Company will attempt to reinstate
the employee to his/her former position if it is available, or to another open position with similar
responsibilities.

If the position or similar position is not available, the company reserves the right to terminate the
employee’s employment.
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January 1, 2017

Any employee who returns to work following an unpaid leave will be considered as having
continuous service. If an employee does not return from an unpaid leave of absence, the
termination date is the last day of the authorized leave or the date the employee notifies
Management that he/she is not returning, whichever is earlier.

5.5 BEREAVEMENT LEAVE

In the unfortunate event of a death in the immediate family, a paid bereavement leave will be
granted according to the following schedule:

• Employees are allowed to 3 (three) consecutive days off from regularly scheduled duty with
regular pay in the event of the death of the employee’s spouse, child, father, father in law,
mother, mother in law, son-in-law, daughter in law, brother, sister, stepfather, stepmother,
stepbrother, stepsister, stepson or stepdaughter. To be eligible for paid bereavement leave,
the employee must attend the funeral of the deceased relative.

• Employees are allowed 1 (one) day off from regular scheduled duty with regular pay in the
event of death of the employee’s brother-in-law, sister-in law, aunt, uncle, grandparent,
grandchild or spouse’s grandparent. To be eligible to paid bereavement leave, the employee
must attend the funeral of the deceased relative.

Employees should make the Company aware of their situation. The employee must record his or
her absence as a Bereavement Leave. Proof of death and relationship to the deceased will be
required.

5.6 MEDICAL LEAVE OF ABSENCE (FMLA)

Unpaid medical leaves of absence may be requested by an employee for an illness or disability
(including a condition related to pregnancy). Earned paid time off must be taken before
commencement of an approved medical leave. All medical leave requests must be accompanied by
appropriate medical certification from your physician indicating the condition necessitating your
leave request and your projected date of return to work.
Leaves of absence are at the sole discretion of the Company and after approval, are subject to
further review and approval on a month-to-month basis. If your leave request is granted, you are
required to provide the Company with additional physician’s statements, if requested, attesting to
your continued disability and inability to work. You may also be required to provide the Company
access to your medical records or to submit to a medical examination at any time by a medical
facility designated by the Company at its discretion.
Before being permitted to return from a medical leave, you are required to present the Company with
a note from your physician indicating that you are capable of returning to work. The Company may
require you to submit to a medical examination by a medical professional designated by the
Company before the commencement of job duties.
Reinstatement cannot be guaranteed to employees returning from medical leaves of absence,
except as otherwise provided under state or federal law. However, the Company endeavors to
place employees returning from approved medical leaves in their former positions or positions
comparable in status and pay, subject to, including but not limited to, budgetary restrictions, the
Company’s need to fill vacancies, and the ability of the Company to find qualified temporary
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

replacements.
Subject to federal and state law, the Company will continue its regular premium contributions for
group health insurance benefits through the first 3 full calendar months of an approved medical
leave. Before commencement of your leave, please consult your manager regarding the
continuation of health insurance benefits during your medical leave.
An approved medical leave does not affect seniority or anniversary dates. Additional vacation days,
are not earned during a medical leave, but will be treated as if earned upon an employee’s return to
work.

5.7 JURY/WITNESS DUTY

A paid leave of absence for jury/witness duty will be granted to any employee who has been notified
to serve for the first 3 (days) of jury duty and unpaid time off for additional days. An employee on
jury/witness duty is expected to report to work any day he/she is excused from jury/witness duty.

Upon receipt of the notice to serve jury/witness duty, the employee should immediately notify
Management. Additionally, a copy of the notice to serve should be attached to the employee’s
attendance record for attendance purposes.

To receive compensation for the absence, the employee must notify Management and submit a
signed Certificate of Jury/Witness Service indicating the number of days served immediately upon
return.

5.8 MILITARY DUTY

A leave of absence will be granted for military or reserve duty in accordance with the Uniformed
Services Employment and Reemployment Rights Act of 1994 (USERRA). This includes Employees
called for annual or special Reserve or National Guard duty training during their regularly scheduled
work days.

In accordance with applicable law, employees on military leave will be reinstated upon satisfactory
completion of military service and timely notice of intent to return to work, provided the employee is
qualified and the Company’s circumstances have not changed to the extent that it would be
impossible or unreasonable to provide re-employment.

SECTION 6 – STANDARDS OF CONDUCT AND EMPLOYEE


PERFORMANCE

6.1 EMPLOYEE STANDARDS OF CONDUCT

All employees are expected and required to meet acceptable performance standards and otherwise
conduct themselves in an appropriate manner during the course of their employment. The rules
discussed below are to guide your conduct on a day-to-day basis. The list is not meant to be all-inclusive,
and various other circumstances may arise that will see discipline and/or immediate termination of an
employee. The rules described below do not create any contract between the Company and its
employees as to the procedures to be followed concerning any rule violation and does not change the
“AT WILL” policy above.
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January 1, 2017

Employees should be aware that violation of any of the following employee standards of conduct might
result in disciplinary action, up to and including discharge. The following behaviors are prohibited.

- Insubordination, including the refusal to obey or carry out verbal or written instructions of
Management.

- Violation of company rules or policies or government rules and regulations.

- Engaging in criminal conduct.

- Deliberate careless acts that cause damage to the property of the Company, other employees, or
Customers.

- Theft or attempted theft from other employees, vendors, suppliers, customers and
company property.

- Punching the time card of another employee or authorizing another person to punch your
time card.

- Leaving the company premises during working hours without authorization from your
supervisor.

- Falsifying records or other acts of fraudulent behavior, including but not limited to, false
statements made at time of hire or on employment applications, personnel records and
information in connection with the obtaining of employee benefits or misuse of such benefits
whether related to the Company or not.

- Unsatisfactory work performance.

- Excessive absenteeism or tardiness, including violation of any rules pertaining to attendance.

- Failure to return to work upon expiration of authorized leave without a valid extension of that
leave.

- Loafing, sleeping on the job, or dilatory or intentional restriction of output.

- Engaging in any acts of violence, fighting, threats of violence, assault, battery, or other disorderly
conduct, horseplay, intimidating conduct, practical jokes, or otherwise interfering with another
employee's work activities.

- Violation of the Company’s Substance Abuse Policy. Also, possession of or bringing


alcoholic beverages, drugs, or any controlled substances onto Company premises; selling or
consuming alcoholic beverages or drugs or any controlled substances on Company premises
(including lunch and work breaks); or entering the premises subject to the effects thereof.

 (Exceptions, as appropriate, will be made by Management regarding alcoholic


beverages, such as when they may be provided for Company special events.)

 Employees required to use prescription drugs that might affect work performance shall
notify Management, in writing, prior to reporting to work under the influence of such
drugs.

- Harassment directed at any person associated with the Company, or discriminatory treatment of
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

employees or applicants. (See Harassment Policy.)

- The use of Company time, materials, facilities, or equipment for purposes not related to Company
business.

- Engaging in any commercial activity, including outside employment that conflicts with or gives the
appearance of conflicting with the interests of the Company, without first having obtained the
written consent to such activity by Management.

- Failure to report any accident, injury, and/or known damage to any property, equipment, facility,
or person.

- Intentionally damaging or defacing Company property, employee property, or the property


entrusted to the Company, including but not limited to, marking, writing, or drawing on said
property, including defacing bulletin boards or notices posted thereon.

- Possession or engaging in the sale or purchase of any weapon, legal or illegal, while on
Company time or on Company premises.

- Abuse of the Company’s computer resources, including accessing, creating, downloading,


transmitting, or possessing pornographic, sexually explicit or otherwise offensive materials or
messages (e.g. hate materials, “jokes”, or the like that demean people on the basis of any of their
attributes).

- Unauthorized use of the property, equipment or facilities of the Company or others, including
unauthorized use of telephones, possession of another Employee’s personal equipment or
possessions without the Employee’s consent, removal of the Company’s or other’s property
or records from the business premises without permission.

- Revealing confidential Company information to unauthorized persons.

- Refusal or failure to observe work schedule.

- Any conduct that may jeopardize the Company’s business or the personal safety, security or
welfare of the Company’s employees.

- Smoking (or chewing tobacco) on Company time or on Customer property.

- Use of cell phones for non-business purposes during Company time is prohibited.

6.2 PROHIBITION OF HARASSMENT IN THE WORKPLACE

The Company is committed to maintaining a work environment in which activities and employment
opportunities are based solely on an employee's ability and performance. Our commitment includes the
preservation of a productive climate free from unlawful harassment based on an individual's, race, color,
religion, national origin, sexual orientation, age, disability, sex, weight, height or other protected status. It
is Company policy to affirmatively investigate and resolve all complaints of unlawful harassment, or other
possibility of unlawful activity by Management or fellow employees.

Any employee who commits unlawful discrimination or harassment will be disciplined, up to and including
discharge.

6.3 DEFINITION OF UNLAWFUL SEXUAL HARASSMENT


Specifically, sexual harassment in the workplace includes unwelcome sexual advances, requests for
sexual favors, or other verbal or physical conduct of a sexual nature by any employee where:
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

1. Submission to such conduct is either an express or implied term or condition of employment; or

2. Submission to or rejection of such conduct is used as the basis for employment-related decisions
such as hiring, promotion, performance evaluations, pay adjustment, discipline, work
assignments, etc.; or

3. Such conduct creates an offensive, intimidating, or hostile environment that unreasonably


interferes with work performance.

Examples of such conduct, particularly if the conduct is pervasive or extreme, might include: display of
sexually-suggestive calendars or pictures, off-color language, jokes, cartoons, nicknames, propositions,
e-mail messages, repeated unwanted social invitations or gifts, crude gestures, suggestive or insulting
comments or sounds, whistling or leering, or unwelcome touching. Such conduct is prohibited.

Even conduct that is not overtly sexual in nature may create a hostile environment. Any unequal
treatment of an employee that would not occur but for the employee’s gender may, if severe and
pervasive, constitute a hostile environment. Such conduct is prohibited. Whether or not such conduct
constitutes unlawful hostile environment sexual harassment is based on the totality of the circumstances.

6.4 WORKPLACE VIOLENCE

The Company strives to maintain a working environment that encourages mutual respect, promotes civil
relationships among employees and is free from all forms of harassment and violence. The Company
does not tolerate any type of workplace violence committed by or against employees. Employees are
prohibited from making threats or engaging in violent activities while on the job. This list of behaviors,
while not all inclusive, provides examples of conduct that is prohibited.

• Causing or attempting to cause physical pain or injury to another person


• Making threatening or intimidating remarks, or fighting
• Aggressive or hostile behavior that creates a reasonable fear of injury to another person or
subjects another person to emotional distress
• Intentionally damaging or threatening to damage company property or property of another
employee
• Possession of a weapon while on company property or while on company business
• Committing acts motivated by, or related to, unlawful harassment or domestic violence
• Sabotaging another person’s work
• Verbal, physical or gesture bullying, including non-verbal offensive and threatening gestures

Any potentially dangerous situations must be reported immediately to Management. Employees


displaying violent behavior or found to have engaged in violence will be disciplined, up to and including
termination.

6.5 WEAPONS POLICY


The Company acknowledges that certain individuals may be properly licensed to lawfully carry a
concealed weapon. However, the Company has a legitimate business interest in maintaining a workplace
free from weapons of any kind. Therefore, it is Company policy that NO employee, consultant, contractor,
visitor, subcontractor or client, other than law enforcement, shall possess a weapon of any kind,
concealed or otherwise, at the workplace.

All employees are prohibited from carrying a weapon while in the course and scope of performing their
job, whether or not they are on the Company property, and whether or not they are licensed. Company
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

vehicles are covered by this policy at all times.

For purposes of this policy, the term “weapon” includes, but is not limited to: firearms, daggers, dirks,
stilettos, knives with blades over 3 inches in length, pocket knives opened by mechanical devices, iron
bars, paintball guns, any explosive device, brass knuckles, or any other item defined as a “dangerous
weapon” under state or federal law. Company issued tools or items approved by Management in writing,
such as box cutters, are excluded from this policy.

The prohibition applies on any company property, including offices, buildings, parking lots or structures,
communal areas, and company vehicles, as well as other work sites at which the Company conducts its
business. Employees and contractors should be advised that violation of this policy may result in
disciplinary action, including discharge, and a formal report to local law enforcement.

6.6 WORKPLACE BULLYING

Brasco defines bullying as “repeated inappropriate behavior, either direct or indirect, whether verbal,
physical or otherwise, conducted by one or more persons against another or others, at the place of work
and/or in the course of employment.” Such behavior violates the company Code of Ethics, which clearly
states that all employees will be treated with dignity and respect.

The purpose of this policy is to communicate to all employees, including supervisors, managers and
executives, that the company will not tolerate bullying behavior. Employees found in violation of this policy
will be disciplined up to and including termination.

Bullying may be intentional or unintentional. However, it must be noted that where an allegation of
bullying is made, the intention of the alleged bully is irrelevant and will not be given consideration when
meting out discipline. As in sexual harassment, it is the effect of the behavior upon the individual that is
important. [Company Name] considers the following types of behavior examples of bullying:

• Verbal bullying: Slandering, ridiculing or maligning a person or his/her family; persistent name
calling that is hurtful, insulting or humiliating; using a person as the butt of jokes; abusive and
offensive remarks.

• Physical bullying: Pushing, shoving, kicking, poking, tripping, assault or threat of physical
assault; damage to a person’s work area or property.

• Gesture bullying: Nonverbal threatening gestures or glances that convey threatening messages.

• Exclusion: Socially or physically excluding or disregarding a person in work-related activities.

6.7 OTHER DISCRIMINATORY HARASSMENT


In general, ethnic or racial slurs and other verbal or physical conduct relating to a person's race, color
national origin, age, marital status, veteran status, disability, religion, height, weight, sex, or other
protected characteristic, constitutes harassment when they unreasonably interfere with the person's
performance or create an intimidating or hostile environment. Such conduct is prohibited.

6.8 COMPLAINT PROCEDURE

The Company has made an affirmative commitment to a neutral, unbiased investigation process for all
work-related problems, including complaints of unlawful harassment. If you believe that you or another
employee has been the subject of discrimination or harassment, you should report the situation to your
Supervisor promptly (using the Confidential Complaint Form, available from HR). If you wish to remain
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

anonymous, please use the Confidential Complaint Form and check the anonymous box. If you feel that
your Supervisor has failed to address the situation adequately or would rather not approach your
Supervisor, you should speak directly with the Human Resource Manager. This policy applies to all
employees, full-time and part-time, and to actions by co-workers and Management, as well as conduct or
concerns of, or relating to leased employees, independent contractors, vendors and clients. Under no
circumstances will you be required to file a complaint with a harassing individual.

In every case, it is helpful if you can provide the following preliminary information:

 the nature of the complaint, including time, location and specific conduct of concern;
 the identity of the parties, including witnesses;
 a good time and the best phone number or location for us to communicate with you.

A prompt investigation of all complaints will be undertaken. To the extent practicable under the
circumstances, efforts will be made to maintain the confidences and privacy of the complaining party and
other involved parties during the investigation. Any employee who, after investigation, is determined to
have participated in or engaged in discrimination or harassment may be subject to discipline up to and
including discharge.
The Company prohibits any retaliation against an employee who, in good faith, has made a complaint
under this procedure. Any employee of the Company who, after reasonable investigation, has been
determined to have retaliated against an employee for making a good faith complaint under the complaint
procedure may be subject to discipline up to and including discharge. If an employee believes he or she
has been the subject of retaliation, the employee should use the complaint procedure described above.
Violation of this anti-retaliation clause is grounds for immediate discipline, up to and including discharge.

6.9 ETHICAL STANDARDS

The Company has an excellent reputation and strives to conduct all business activities with integrity,
fairness, and in accordance with the law and high ethical standards. As an employee, you enjoy the
benefits of that reputation and are obligated to uphold it in every business activity. If you are ever in
doubt whether an activity of yours, a colleague or Management fails to meet these ethical standards or
compromises the Company's reputation, please bring your concern to the attention of the Company or file
a confidential written report to the Human Resource Manager.

6.10 SUBSTANCE ABUSE POLICY

The Company maintains a drug free workplace. We follow the guidelines of the United States
Department of Transportation and reserve the right to test all employees within our Company.

The Company has established the following policy:

1. Each employee will report to work free from impairment by alcohol and free from the use of illegal
drugs or narcotics. Employees are prohibited from entering Company or client premises or any
Company or client worksite while under the influence of alcohol or while illegal drugs may be
detected in their bodies.

2. Use, consumption, possession, or presence in one’s body, sale or distribution of alcohol or any
illegal drug/narcotic or controlled substance on Company or client premises/worksites or in
Company vehicles is strictly prohibited.

3. Employees using legal drugs are responsible for being aware of any adverse effects such drugs
may have on their ability to safely and efficiently perform their duties. The use of any legal drugs
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

that may have such effects must be reported in writing to Management, who will then determine
the employee’s fitness for duty.

4. The possession, manufacture, sale, transfer or purchase of any illegal drug or controlled
substance on Company or client time or property or while performing Company or client business
will result in immediate termination and will be reported to law enforcement officials.

Disciplinary Action:
Violation of any part of this Substance Abuse Policy will result in severe disciplinary action, up to and
including termination, at the Company’s sole discretion. The refusal to submit to a test or test results that
report an unacceptable level of alcohol, illegal drugs or narcotics, may be the basis for immediate
termination.

6.11 SMOKING

In order to maintain a comfortable working environment, smoking inside the building, regular or electronic
cigarettes is prohibited. Smoking is only permitted during break and lunch time. Employees violating the
policy will be subject to disciplinary action, up to and including discharge. Proper disposal of cigarette
remains is expected and required.

6.12 ATTENDANCE POLICY

GENERAL: Absenteeism, including tardiness, is a serious concern for the Company. It increases costs,
disrupts work schedules, contributes to poor quality and is a factor with inefficiency. Each of these things
negatively affects our relationships with customers. The Company expects all employees to show up on
time when scheduled.

EMPLOYEE SCHEDULES: The Company will determine work schedules based on production needs
and/or to meet customer requirements. Employee attendance at meetings and training programs will be
considered scheduled time.

ATTENDANCE POLICY DEFINITIONS:

• Unapproved Absence: Time lost from a scheduled work day that was not approved in
advance, or approved by management.

• Approved Absence: Time lost from a scheduled work day for that was approved in
advance: scheduled paid time off, holiday, approved bereavement leave, jury duty, military
service, temporary layoff, on-the-job injury, approved short term/long term disability,
approved leave of absence.

• Tardy: Time lost due to late arrival at the beginning of a scheduled work day or returning
from breaks or lunch.

• Early Departure: Time lost due to leaving prior to the end of an employee’s work shift.

• No Call / No Show: Failure of an employee to use the Call-In Procedure to of an absence


prior to the start of the workday.
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January 1, 2017

• Date of Hire 12 Month Period: A 12 month period commencing with the date of hire.

• Scheduled Paid Time Off: Paid time off that has been requested and approved, no later
than 24 hours. Employees should submit vacation plans to their supervisor at least 4 weeks
in advance of the requested vacation date.

Repetitive absenteeism or tardiness is not acceptable, and will subject employees to discipline as follows:

Disciplinary Procedures

Unapproved Absenteeism –– Company actions will consist of the following within a rolling 12 month
period:

All absences are tracked and recorded for each employee.

• 3 incidents – Verbal Warning (Documented)


• 6 incidents – Written Warning
• 9 incidents – Unacceptable. Management will review discipline, up to and including
termination.

Tardy/Early Departure – Disciplinary Procedures – Company actions will consist of the following within
a rolling 12 month period:

All tardies are tracked and recorded for each employee.

• 3 incidents – Verbal Warning (Documented)


• 6 incidents – Written Warning
• 9 incidents – 2nd Written Warning
• 12 incidents – Unacceptable. Management will review discipline, up to and including
termination.

No Call/No Show – Disciplinary Procedures – Company actions will consist of the following within a
rolling 12 month period:

Any no call / no shows are recorded for any and all employees.

• 1 incident – Verbal Warning


• 2 incidents –Written Warning
• 3 incidents – Unacceptable. Management will review discipline, up to and including
termination.
• If you fail to report to work without appropriately notifying the Company for a period of three
(3) consecutive workdays, you will be considered to have voluntarily terminated your
employment.

6.13 PROGRESSIVE DISCIPLINE


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January 1, 2017

The Progressive Discipline Procedure is intended to be constructive in correcting an employee’s


unacceptable conduct or habits. This policy does not in any way change the “AT-WILL” nature of the
employment relationship.

Every employee has the duty and the responsibility to be aware of and abide by existing rules and
policies. Employees also have the responsibility to perform his/her duties to the best of his/her ability and
to the standards as set forth in his/her job description or as otherwise established.

Brasco supports the use of progressive discipline to address issues such as poor work performance or
misconduct. Our progressive discipline policy is designed to provide a corrective action process to
improve and prevent a recurrence of undesirable behavior and/or performance issues. Our progressive
discipline policy has been designed consistent with our organizational values, HR best practices and
employment laws.

Outlined below are the steps of our progressive discipline policy and procedure. Brasco reserves the right
to combine or skip steps in this process depending on the facts of each situation and the nature of the
offense. The level of disciplinary intervention may also vary. Some of the factors that will be considered
are whether the offense is repeated despite coaching, counseling and/or training; the employee's work
record; and the impact the conduct and performance issues have on our organization.

The following outlines Brasco’ s progressive discipline process:

• Written warning: Written warnings are used for behavior or violations that a supervisor considers
serious or in situations when a verbal warning has not helped change unacceptable behavior.
Written warnings are placed in an employee’s personnel file. Employees should recognize the
grave nature of the written warning.

• Performance improvement plan: Whenever an employee has been involved in a disciplinary


situation that has not been readily resolved or when he/she has demonstrated an inability to
perform assigned work responsibilities efficiently, the employee may be given a final warning or
placed on a performance improvement plan (PIP). PIP status will last for a predetermined amount
of time not to exceed 90 days. Within this time period, the employee must demonstrate a
willingness and ability to meet and maintain the conduct and/or work requirements as specified by
the supervisor and the organization. At the end of the performance improvement period, the
performance improvement plan may be closed or, if established goals are not met, dismissal may
occur. Also payroll reduction and/or demotion may occur.

Brasco reserves the right to determine the appropriate level of discipline for any inappropriate conduct,
including oral and written warnings, suspension with or without pay, demotion and discharge.

Progressive discipline documentation will remain active in an employee’s file and considered for
promotions and further disciplinary action on a rolling 12 month basis, unless circumstances dictate that
the documentation should remain active for a longer period of time.

6.14 SOCIAL MEDIA—ACCEPTABLE USE POLICY

Note: As used in this policy, “ social media” refers to blogs, forums, and social networking sites; such as
Twitter, Facebook, LinkedIn, Instagram, You Tube among others.

Below are guidelines for social media use.


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January 1, 2017

Employees may not post financial, confidential, sensitive or proprietary information about the
company, clients, employees or applicants.

Employees may not post obscenities, slurs or personal attacks that can damage the reputation
of the company, clients, employees or applicants.

When posting on social media sites, employees must use the following disclaimer when
discussing job-related matters, “The opinions expressed on this site are my own and do not
necessarily represent the views of Brasco”

Brasco will monitor content out on the Internet. Policy violations will result in discipline up to and
including termination of employment.
Solicitations, Distributions and Posting of Materials

Brasco prohibits the solicitation, distribution and posting of materials on or at company property by any
employee or nonemployee, except as may be permitted by this policy. The sole exceptions to this policy
are charitable and community activities supported by Brasco management and company-sponsored
programs related to Brasco’s products and services.

Provisions:
• Nonemployees may not solicit employees or distribute literature of any kind on company
premises at any time.
• Employees may only admit nonemployees to work areas with management approval or as part of
a company-sponsored program. These visits should not disrupt workflow. An employee must
accompany the nonemployee at all times. Former employees are not permitted onto company
property except for official company business.
• Employees may not solicit other employees during work times, except in connection with a
company-approved or sponsored event.
• Employees may not distribute literature of any kind during work times or in any work area at any
time, except in connection with a company-sponsored event
• The posting of materials or electronic announcements are permitted with approval from Human
Resources.

Violations of this policy should be reported to Human Resources.

6.15 INTERNET USE POLICY

Certain employees may be provided with access to the Internet to assist them in performing their jobs.
The Internet and e-mail are to be used solely for company business and not for personal communication.

The Company has the right to monitor any and all aspects of its computer system, including, but not
limited to, monitoring sites visited by employees on the Internet, monitoring chat groups and news groups,
reviewing material downloaded or uploaded by users to the Internet, and reviewing e-mail sent by users.

The Company may use software to identify inappropriate or sexually explicit Internet sites. Material that is
fraudulent, harassing, embarrassing, sexually explicit, profane, obscene, intimidating, defamatory or
otherwise unlawful, inappropriate or offensive may not be downloaded from the Internet or displayed or
stored on Company computers. Employees encountering or receiving this kind of material should
immediately report the incident to Management. The Company’s equal employment opportunity policy
and its policies against sexual or other harassment fully apply to the use of the Internet and any violation
of those policies is grounds for discipline up to and including discharge.

Employees may not use Company computers to download games or other entertainment software.
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

Illegal Copying: Employees may not illegally copy material protected under copyright law or make that
material available to others for copying. You may not agree to a license or download any material for
which a registration fee is charged without first obtaining written permission from Management.

Virus Detection: Employees should never download files from the Internet, accept email attachments
from outsiders, or use disks from a non-Company source without first scanning the material with
Company approved virus checking software. If you suspect a virus has been introduced to the Company
network, notify Management immediately.

6.16 CUSTOMER CONTACT POLICY

Telephone calls are normally the first contact our Customers have with the Company. Anyone answering
the telephone should use a cheery voice, and say, “Good Morning/Afternoon, BRASCO. This is
(name) . How may I help you?” Always use please and thank you.

The Company appreciates that our employees do a great job of representing the company with our
Customers and other business associates. Occasionally, there will be problems that arise through no
fault of the employee who is involved in the situation. The Company understands the pressure of being
on the front lines. Therefore, when problems arise, please focus on what needs to be done to solve the
problem and keep it from reoccurring, rather that pointing fingers at who is to blame.

- If a problem should arise due to an internal Company error, limit your communications
with your Customer contacts to identifying the problem and addressing its prompt
correction;

- DO NOT discuss your personal feelings or conclusions with the Customer regarding how
a problem occurred or suggest there is inferior work. Those matters are internal
Company concerns and will be addressed internally; and

- DO communicate to your Customer that the Company, as an organization, and you, as its
representative, will promptly address and correct any problems which occur.

If you have any complaints, problems, grievances, disappointments, apprehensions, or other concerns,
regarding the quality of work performed by other Company personnel, you must present your concerns to
Management. The only exception to this policy is that you are free to file a complaint with the appropriate
law enforcement agency in the unlikely event that a criminal act is involved.

In addition, please remember:

- Do NOT accept gifts from a Customer.


- Do NOT smoke or chew tobacco in front of a Customer or on a Customer’s premise.
- Never argue with a Customer or with a colleague in the Customer’s presence.
- Never discuss your wages in front of or with a Customer.
- Never swear in front of the Customer.
- Never horseplay or make derogatory or inappropriate comments.
- Do NOT use a personal cell phone on Company time, especially in front of a Customer.
Employees who do not comply with this policy will be subject to discipline, up to and including discharge.
If you have additional questions about Customer Relations, please ask Management.
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

6.17 MOONLIGHTING

You are expected to devote your primary work efforts to BRASCO INTERNATIONAL, INC. business. Although
you are not prohibited from working for other Employers, you may not engage in other employment that
could be inconsistent with the business interest of BRASCO INTERNATIONAL, INC. (such as employment with
a competitor or employment that could otherwise have a detrimental impact on the image of the Company
or its business with its customers or the public). In addition, you may not be employed for a business that
requires you to devote a level of time and effort that adversely affects your work at the Company. If you
are planning to accept an outside position, please notify the CEO in writing.

6.18 RELEASE OF INFORMATION TO OUTSIDERS, PRESS OR PUBLIC

All inquiries from outsiders such as vendors, Customers, the press or general public must be immediately
directed to Management.

To provide consistent, prompt and correct information to others outside the Company, and to protect
confidential Company information, no employee is authorized to provide confidential information or to
speak with persons outside the Company regarding Company business or personnel without specific
Company approval.

Except for records and information that the Company is legally required to provide to government
agencies, no information about employees will be released unless there is a signed authorization form on
file, and the request is in writing.

6.19 CONFLICTS OF INTEREST

Purpose — To avoid activities by employees which create conflicts of interest with their responsibilities to
the Company and to the companies to which they are assigned. To require all employees to observe the
highest ethical standards in any and all dealings with this Company or the customer to whom they are
assigned.
Policy — The Company realizes that employees engage in personal activities outside the scope of their
employment. In general, this does not create a problem. However, each employee also has an
obligation to refrain from activities which conflict or interfere with the interests or day-to-day operations of
the Company and/or the assigned customers. The Company reserves the right to determine when an
activity conflicts with the Company’s interests and to take whatever action is necessary to resolve the
conflict. If deemed appropriate by the Company, this action may include discipline, up to and including
termination.
Examples — The following are some examples of conflicts of interest. These examples are merely
illustrative and not exclusive.
a. Outside Employment: No employee of this Company shall accept simultaneous employment
with another company when the other company is either a competitor or supplier of this Company
or a customer. A conflict might also arise if the hours or conditions of the other job interfere with
the employee’s performance for this Company or for the customer to whom the employee is
assigned.
b. Outside Business Interest: No employee should establish or maintain an outside business
interest that would entail the types of conflicts described above in “outside Employment”. In
addition, no employee may have any personal financial dealings with any individual or business,
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

other than a regulated financial institution that furnishes merchandise, supplies, property or
services to this Company or to the customer to whom the employee is assigned.
c. Accepting Gifts and Entertainment: No employee shall accept gifts of more than a nominal
value from any individual or business who does business, or seeks to do business, with this
Company or the customer to whom the employee is assigned. Also, no employee shall accept
any travel, living or entertainment expenses from any such persons or business organizations,
either in kind or as an expense allowance. Nominal gifts are those whose value is so small that
they are unlikely to influence a business decision.
d. Lawful Action: No employee will do anything while conducting business for the Company
which would violate any local, state or federal law.

6.20 VEHICLE POLICY

An employee shall not operate any Company vehicle or customer vehicle unless he/she has a valid
driver’s license for the operation of the vehicle assigned and has received prior authorization from the
Company for the operation of the vehicle. All drivers are expected to operate the vehicle in a safe
manner and must comply with all applicable laws, regulations and ordinances governing the use and
operation of the vehicle. Personal use of Company or customer vehicles is PROHIBITED.

6.21 PERSONAL USE OF CELL PHONES, COMPUTERS, OR OTHER ELECTRONIC EQUIPMENT


AT WORK

While at work, employees are expected to refrain from personal use of cell phones or computers.
Personal calls, personal instant messaging, personal text messaging or tweeting during the work day --
regardless of whether the equipment used is company-provided or not -- interferes with employee
productivity, is distracting to others, and can become a safety hazard. Employees are at work essentially
to provide value to the company.
Employees are expected to refrain from personal interactions during work time. Employees should make
personal calls and/or send personal text messages, tweets or instant messages on non-work time and to
ensure that friends and family members are aware of this company policy.
If employee use of a personal cell phone causes disruptions or loss in productivity, the employee may
become subject to disciplinary action up to and including termination. The company is not liable for the
loss of personal cell phones, or other personal electronic equipment brought into the workplace.
Brasco International has a zero-tolerance policy regarding using a cell phone while driving any vehicle for
work purposes. For the safety of employees and others it is imperative that employees pull over and stop
at a safe location to dial, text, receive or converse on the cell phone in any way. Should the call be
business related is not a qualification to violate this policy. In the event an employee is driving a company
vehicle and receives a phone call from the company, the call can be returned when the vehicle is stopped
and parked. Brasco International reserves the right to amend or alter the terms of this policy. Violations of
this policy will be subject to the highest forms of discipline, including termination.
Office telephones are for business purposes.

6.22 DRESS CODE

Our Customers establish many of their opinions of the Company by their contacts with our employees.
Employees contribute to a positive public image through proper attire and a high degree of cleanliness
and neatness. Employees who do not comply with the Dress Code will be subject to discipline.
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

Management reserves the right to decide what is or is not appropriate work attire; however, the following
guidelines apply.

OFFICE STAFF:
• Business casual wear.
• Company shirts are acceptable, though not required.
• When appropriate, compliance with the Employee Safety and Health Policy is required.

PRODUCTION EMPLOYEES:
• Compliance with the Employee Safety and Health Policy is required (i.e. safety eye glasses,
hearing protection, appropriate foot wear, no open toe shoes and tape measure). Safety PPE
where designated.
• No wild/inappropriate hairstyles.
• No clothing with offensive designs/text.
• No loose long hair, neckwear or jewelry due to safety around machinery. (Stud earrings only.)

The Company’s Dress Code policy applies at all time spent on premises and/or conducting Company
business. The policy is designed to help all employees maintain a safe, consistent and business-like
atmosphere.

6.23 PERFORMANCE REVIEWS

The aim of our performance appraisal process is to provide you with guidance, to help you to achieve
your job and career goals, to recognize your achievements and to ensure Brasco’ s strategic and
business goals are achieved. You will have the opportunity to participate in planning your work and
setting your goals in conjunction with your manager on a regular basis and formally during your annual
appraisal meeting. Your manager will provide you with regular coaching and feedback. The performance
appraisal process is an opportunity for two way communication and honest feedback about your work and
your future career with Brasco.

Evaluation of your performance is important to you and the Company. Annually, Management will review
your job progress within our Company and help you to set new job performance plans and goals. You
may be asked to do a self-assessment and to review and comment on the previous year’s evaluation.
Good communication of responsibilities and objectives, an opportunity to address the future, as well as
past and present performance, should be a part of this experience. Our performance review program
provides the basis for better understanding between you and Management, with respect to your job
performance, potential and development within the company.

6.24 WHEN YOU LEAVE EMPLOYMENT

When you leave your employment with us, we ask that you provide the Company with at least (2) two
weeks’ advance notice. When reasonable, the Company will provide the same courtesy. Your
thoughtfulness is appreciated and will be noticed favorably should you ever wish to reapply for
employment with the Company.

All company property, including but not limited to, this Handbook, phone list and keys, must be returned
upon termination. The Company may take further action to recoup any costs or expenses and/or seek
the return of company property through appropriate legal recourse.

When you leave Brasco you will be invited to attend an exit interview with the Human Resource Manager.
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

The interview will be scheduled in your last week with us. This is a confidential interview aimed at helping
us to understand how we can improve our organizational performance. It focuses on aspects of our
employment relationship with you including remuneration, training, working conditions, benefits,
management practises etc. We aim to learn from your comments and use these to make improvements
where appropriate.

Please notify the company if your address changes during the calendar year in which termination
occurs so that your tax information will be sent to the proper address

SECTION 7 – WORKPLACE SAFETY


7.1 EMPLOYEE SAFETY AND HEALTH

The Company is committed to protecting the safety and health of every employee. The Company and
every employee have a role in establishing and maintaining a safe work environment. You must
familiarize yourself with the Company’s safety policies before you start working. Follow all of these
general rules:

1. Obey all safety rules.


2. Follow all instructions pertaining to the use of tools and equipment.
3. Report any unsafe condition of equipment, vehicles or property immediately to Management.
4. Report any injury, no matter how slight, to Management immediately.
5. Keep your tools in good working order. Maintain a neat and clean working environment.
6. Employees must follow all state and federal OSHA laws that apply to their work.
7. Employees must follow all safety rules and procedures for their work as communicated to
them from time to time.

7.2 GOOD HOUSEKEEPING

Good work habits and a neat place to work are essential for job safety and efficiency. You are expected
to keep your place of work organized and materials in good order at all times. Limit personal items
please. Report anything that needs repair or replacement to Management.

7.3 WORKPLACE SECURITY

Employees must be alert and aware of any potential dangers to themselves or their coworkers. Take
every precaution to ensure that your surroundings are safe and secure. Guard personal belongings and
company property. Visitors should be escorted at all times. Report any suspicious activity to a supervisor
immediately.

7.4 COMPANY VIDEO SURVEILLANCE MONITORING


CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

Brasco International reserves the right to install security cameras in work areas for specific business
reasons, such as security, theft protection or protection of proprietary information. Brasco International
may find it necessary to monitor work areas with security cameras when there is a specific job- or
business-related reason to do so. Reasonable suspicion of onsite drug use, physical abuse, theft or
similar circumstances would be possible motives to view previously recorded video surveillance footage.
The company will do so only after first ensuring that such action is in compliance with state and federal
laws. Employees should contact their supervisor or the human resource (HR) department if they have
questions about this policy.

7.5 SAFETY EYE GLASSES


At all times, while in the production area, ALL employees and visitors MUST wear MIOSHA approved
industrial safety eyewear. The Company will supply one (1) pair of non-prescription safety eye glasses
on the date of hire. Employees wishing to use their own safety eye glasses must check with
management to ensure that the eyewear meets MIOSHA standards.

7.6 HEARING PROTECTION


When appropriate, ALL employees and visitors MUST wear hearing protection. Earplugs will be supplied
by the Company through your supervisor.

7.7 SAFETY SHOES


At all times, while in the production area, ALL employees are required to wear appropriate footwear, no
open toe or high heeled shoes allowed.

7.8 ELECTRONICS
Use of earphones for personal music or other entertainment is prohibited on the shop floor. They are
never to be used while operating a vehicle or heavy machinery. Radios at work stations are permitted at a
volume that does not disrupt operations or pose a safety issue.

7.9 INJURY REPORT


For any injury suffered while on the job, an injury report is to be completed immediately and treatment is
to be sought. Any and all conversation and information regarding the injury is to be documented.
Authorization to seek treatment can be obtained by Management.

7.10 EMERGENCY FACILITY


CONCENTRA –TROY # 2332
627 East Maple Road Suite 200
Troy, MI 48083
P:( 248) 524-1912
F:( 248) 524-3901

AFTER HOURS:
CONCENTRA – FRASER
33089 Groesbeck Hwy
Fraser, MI 48026
P: (586) 296-2800

7.11 LIGHT DUTY


If you are injured or suffer a medical condition that prevents you from working, a medical release will be
required before you can return to work. Under some circumstances, the Company may allow you to
return to work under light duty, to perform office functions to help subsidize loss of hours when such work
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

is available and is within the employees’ ability.

7.12 WORKERS’ COMPENSATION INSURANCE

All employees are covered by Workers’ Compensation Insurance as requires by law. Workers’
compensation provides benefits to employees who sustain legitimate work-related injury or illness.
Employees may be eligible for temporary total disability benefits, medical treatment and other coverage
prescribed by state law depending on the circumstances of each case.

Employees must report all injuries/illnesses that occur in the work place to Management
immediately on the day of the injury/illness. Abuse of worker’s compensation may result in
disciplinary action up to and including discharge.

Employees filing a Worker’s Compensation claim for a work-related injury/illness must:

1. Immediately notify Management.


2. Be examined, if needed, by a physician selected and approved by the Company
3. Complete an accident report form provided by The Company with the member of Management
completing the accident investigation. The completed form must be faxed to The Company
4. Except in cases of extreme emergency, the accident report form must be completed before the
employee leaves work on the day of the accident.
5. All employees reporting a work place injury/illness which requires outside medical treatment will
be required to submit to a post-accident controlled substance test on the first visit to the medical
provider.

The accident report form will be reviewed by the Company, completed and submitted to the state workers’
compensation office and the insurance adjuster and a copy returned to the employee. Note: It is very
important that any Workers’ Compensation claim be filed promptly in order for the insurance carrier to
accept and process the claim. Any delay in filing may result in delayed benefits or a rejection of a claim.

If an employee is injured on the job and is provided return-to-work restrictions which cannot be honored
the day of the injury, the Company will pay for the hours remaining in his/her work day, up to a maximum
of 8 hours total for the day.

7.13 DOGS IN THE WORKPLACE


Dogs in the workplace can be beneficial for morale. However, employees must be cognizant of the nature
of Brasco business. Dogs and any animals are not permitted on the shop floor, which includes offices on
the shop floor.

Should a dog be on Brasco premises, this is only permissible with previous permission by management.
Dogs may only access the building through the front door administrative area and are prohibited at all
times to enter the shop area, regardless if the dog is just passing through. In the event a dog is on Brasco
premises and distracting operations, the dog will be required to leave and may result in an unscheduled
absence for the owner of the dog.

If you have any questions about this, please see HR.

SECTION 8 – EMPLOYEMENT DISPUTE RESOLUTION POLICY


8.1 EMPLOYMENT DISPUTE RESOLUTION POLICY
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

Private mediation is a more efficient, less expensive, and usually faster way to resolve disputes than
through a traditional lawsuit in court. Accordingly, we require that all employees sign an agreement
promising that all disputes arising out of employment with us or the termination of employment will be
submitted to an impartial mediator under the Rules of the American Arbitration Association. The
agreement makes clear that employees are still protected by all applicable laws, and are merely agreeing
to have employment-related claim heard by a private mediator to attempt to resolve the dispute prior to a
judge or jury. This policy in no way changes the at-will nature of the employment relationship.

8.2 COVERED CLAIMS

This Agreement covers the following potential claims:

1. Any dispute regarding whether any such claim is appropriate for mediation;

2. Any dispute regarding this Agreement, including but not limited to, its enforceability, scope or
terms;

3. Any claim that could be asserted in court or before an administrative agency, including without
limitation, claims for breach of any contract or covenant, express or implied; assault, battery,
invasion of privacy, defamation of character, infliction of emotional distress, tortuous interference
with contract, or other tort claims, including any claim that I was injured or damaged because of
the negligence of the Company or any of its employees; and claims for wrongful discharge and/or
violation of any federal, state or local law, statute, ordinance or regulation, or common law;

4. Any claim for discrimination, including but not limited to, discrimination because of sex,
pregnancy, race, national or ethnic origin, age, religion, creed, marital status, sexual harassment,
sexual orientation, mental or physical disability or medical condition or other characteristics
protected by statute;

5. Any claim that arises from discrimination or retaliation for opposing the violation of any federal,
state or local statue or ordinance, including but not limited to, the Fair Labor Standards Act, Title
VII of the Civil Rights of 1964, the Age Discrimination in Employment Act, the Americans
Disabilities Act, the state workers’ compensation law or any “whistleblower’ law; and

6. Any claim for commissions or wages.

8.3 CLAIMS NOT COVERED

This Agreement does not cover:

1. Claims for workers’ compensation benefits;

2. Claims for unemployment compensation benefits;

3. Claims by the Company for injunctive and/or other equitable relief, including but not limited to,
claims to enforce a covenant not to compete or for unfair competition or use or unauthorized
disclosure of trade secrets or confidential information; or

4. Claims for benefits based upon the Company’s employee welfare benefit plans if they contain a
final and binding appeal procedure for the resolution of disputes under the plan.

8.4 CONTENT OF MEDIATION DEMAND; TIME LIMITS


CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

Under this Agreement, a party wishing to submit a claim for mediation must serve written notice on the
other which expressly:

1. States the precise nature of each claim (e.g., breach of contract, sex discrimination, etc.) for
which mediation is sought;

2. Sets forth a short and plain statement of the operative facts supporting each such claim (who,
what, when, etc.); and

3. Specifically requests mediation of the claim(s).

This notice shall be deemed served when sent to the other party by certified mail, return receipt
requested, at the other party’s last known address.

The written notice described herein must be mailed within the statute of limitations prescribed by law for
the claim. If the demand for mediation is served beyond the statute of limitations, the underlying claim(s)
shall be deemed waived and considered void.

8.5 PRE-MEDIATION PROCEDURES

Within 30 days after the mailing of the mediation demand, the other party shall serve a written answer
upon the party demanding mediation, by certified mail, return receipt requested. The answer shall:

1. Admit or deny of the facts alleged in the mediation demand; and

2. Provide a short and plain statement of any other legally cognizable defenses to the claim(s),
including affirmative defenses.

After service of the answer, the parties shall promptly make joint request to the American Arbitration
Association for a list of mediators. Upon receipt of the list, the parties shall jointly select the impartial
mediator in accordance with the Rules of the American Arbitration Association.

The parties are encouraged to agree to any informal discovery that may take place prior to the mediation
hearing. Any discovery shall be conducted in the most expeditious and cost-effective manner possible
and shall be limited to that which is clearly relevant and material to the dispute and for which the party
has a substantial, demonstrable need.

Upon request, either party shall be entitled to receive at least thirty (30) days prior to the mediation
hearing, information and copies of documents, which meet the criteria for discovery.

If the parties cannot agree on the discovery required to affect due process, a petition for such discovery
shall be submitted to the mediator, whose decision, consistent with the rules governing employment
disputes and the law, will determine the response to the request.

8.6 RULES FOR GOVERNING THE MEDIATION

Any mediation conducted pursuant to this Agreement will take place in the state where the employee is
principally employed by the Company. The parties may, however, agree on an alternative location. The
parties must agree that the law of the state where they are principally employed by the Company will
govern any substantive claims.

The mediation hearing will be conducted within 120 days after the parties’ appointment of the impartial
mediator, or as soon thereafter as the mediator shall deem reasonable.
CONFIDENTIAL BRASCO INTERNATIONAL
January 1, 2017

The mediator shall have authority to interpret and apply to the dispute any statue, ordinance, regulation,
or principle of common laws as may be applicable, and may award such relief as would be available if the
claim(s) were brought in a court of law, to the extent the mediator deems appropriate. The mediator shall
have no authority to disregard later the Company’s rules or policies, however, unless he/she determines
that a rule or policy violates existing law.

The employee is responsible for paying a $100 mediation filing fee. All other costs and expenses
associated with the mediation, including but not limited to, any attorney’s fees, shall be borne by the
Company. However, if a party is entitled to attorney’s fees under any federal, state or local statute or law,
the mediator may award those fees pursuant to the governing law, at his/her discretion.

8.7 OTHER PROVISIONS

The Company promises that it will neither undertake nor permit any discrimination or retaliation against
anyone for good faith efforts to resolve any dispute or for invoking the procedures in this Agreement.

This Agreement does not, in any way, alter an employee’s status as an at-will employee. The employee
understands that either the employee or the Company may terminate the employment relationship at any
time, with or without reason or prior notice. Employment is not for any specific or definite duration.

The employee warrants that this Agreement sets forth the complete agreement between the employee
and the Company on the subject of mediation of the covered claims defined above and supersedes any
prior or contemporaneous oral or written understanding on these subjects. The employee is not relying
on any oral or written representations concerning the effect or meaning of this Agreement, except as
specifically set forth herein.

SECTION 9 – AMENDMENTS/ACKNOWLEDGEMENTS
9.1 AMENDMENTS

The Company reserves the right to alter, modify or amend this Handbook when it determines it is
necessary to do so. Unless otherwise stated, changes will be effective as of the date the changes are
published. Only the CEO of the Company in a written document signed by him/her, has the authority to
enter into any agreement contrary to the provisions of this Handbook.

9.1 ACKNOWLEDGEMENTS

Employee Handbook Acknowledgment and Receipt


Employment Dispute Resolution Agreement
No expectation of privacy and substance abuse policy acknowledgment
Employee Handbook Acknowledgment and Receipt
I have received my copy of the Employee Handbook.

The employee handbook describes important information about Brasco International, Inc. and I
understand that I should consult my manager or Human Resources regarding any questions not
answered in the handbook. I have entered into my employment relationship with Brasco
voluntarily and acknowledge that there is no specified length of employment. Accordingly,
either I or Brasco can terminate the relationship at will, with or without cause, at any
time, so long as there is not violation of applicable federal or state law.

I understand and agree that, other than the president of company, no manager, supervisor or
representative of Brasco has any authority to enter into any agreement for employment other
than at will; only the president of the company has the authority to make any such agreement
and then only in writing signed by the president of Brasco.

This handbook and the policies and procedures contained herein supersede any and all prior
practices, oral or written representations, or statements regarding the terms and conditions of
my employment with Brasco. By distributing this handbook, the company expressly revokes any
and all previous policies and procedures that are inconsistent with those contained herein.

I understand that, except for employment-at-will status, any and all policies and practices may
be changed at any time by Brasco and the company reserves the right to change my hours,
wages and working conditions at any time. All such changes will be communicated through
official notices, and I understand that revised information may supersede, modify or eliminate
existing policies. Only the president of Brasco has the ability to adopt any revisions to the
policies in this handbook.

I understand and agree that nothing in the Employee Handbook creates, or is intended to
create; a promise or representation of continued employment and that employment at
Brasco is employment at will, which may be terminated at the will of either Brasco or
myself. Furthermore, I acknowledge that this handbook is not a contract of employment.
I understand and agree that employment and compensation may be terminated with or without
cause and with or without notice at any time by Brasco or myself. I agree to abide by the
Confidentiality and Company Property provisions contained in this handbook.

I have received the handbook, and I understand that it is my responsibility to read and comply
with the policies contained in this handbook and any revisions made to it.

________________________________________
Employee's Signature

________________________________________
Employee's Name (Print)

____________________
Date
TO BE PLACED IN EMPLOYEE'S PERSONNEL FILE

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