2020 - INDEPENDENT SALES REPRESENTATIVE HANDBOOK

SPIRAL GROUP, INC.

WWW.SPIRALGROUP.ORG
773-242-0705

SPIRAL GROUP, INC. 2019 INDEPENDENT SALES REPRESENTATIVE HANDBOOK Page 1 of 9

 TABLE OF CONTENTS

INTRODUCTION 3
THE CEO 4
STANDARDS OF CONDUCT 5
 RECORDING POLICY 5
 SOCIAL MEDIA POLICY 5
 REPRESENTING OUR COMPANY 5
 ANTI-HARASSMENT POLICY AND COMPLAINT PROCEDURE 6
 CONFIDENTIALITY 8
 ALTERNATIVE LEGAL REMEDIES 8
 RESPONSIBILITIES 8
INDEPENDENT SALES REPRESENTATIVE ACKNOWLEDGMENTS 9

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 INTRODUCTION

This Independent Sales Representative Handbook defines who we are and our expectations. We encourage
diversity of thought, background, and experience because these are the main ingredients that contribute to a
positive and productive environment.

Spiral Group, Inc. is located in Chicago, Illinois and was established in April 2016 as a Not for Profit organization.
Our product portfolio includes the SG MarketPlace, the SG Listing Service, and SG Local Ad Services. Our goal is
to make useful contributions to the Small Business Community by helping other entrepreneurs succeed.

We know it takes an especially dedicated person to work in a sales capacity, that’s why we are committed to
providing you with an enriching and rewarding environment. We offer the resources, support, and autonomy
you'll need to serve our clients in the best way possible. We can’t wait to see what you will achieve with us.

Welcome to our team and warm regards,

Michelle A. Jones
Founder & CEO
Spiral Group, Inc.

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 THE CEO

Michelle Jones became an ordained minister in April 2007, but in lieu of a traditional church, she decided to
execute her ministerial duties through her Not for Profit organization, Spiral Group, Inc.

After serving time in a correctional facility in 2014, Michelle began developing an online Job Readiness Training
Program for job seekers with criminal histories. She is dedicated to helping returning citizens in achieving self-
sufficiency through useful training and by providing them with job opportunities at her company as Independent
Sales Representatives.

Michelle has over 20 years' experience in the hospitality and food-service industries as an hourly worker, cashier
supervisor, assistant manager, general manager, trainer, training manager, and business operations consultant.
She has worked with the following brands: Subway, Portillo's, Quiznos, Dock's Great Fish, Burger King, Chili's,
Target, and Jeepers.

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 STANDARDS OF CONDUCT

RECORDING POLICY
Due to the potential for issues such as invasion of privacy, sexual harassment, and loss of productivity, no ISR
may use a camera phone function on any phone while performing their tasks, unless the device is used solely for
legitimate business purposes.

The use of tape recorders or other types of voice recording devices while performing your tasks is also strictly
prohibited, unless the device is used solely for legitimate business purposes.

SOCIAL MEDIA POLICY

This policy provides a framework for using social media whether personal, or while representing our Company
through social media. It covers all varieties of social media, including blogs, social networks, chat rooms, and
forums. It provides practical advice to avoid issues that might arise by careless use of social media. Therefore, to
protect the Company interests and ensure ISR’s focus on their tasks, ISR’s must adhere to the following:
 ISR’s should not publish any information on any social networking site designated by the Company as confidential
and proprietary business information. ISR’s must not disclose any trade secret, client information, or marketing efforts.
This also applies to comments posted on other blogs, forums, and social networking sites. The Company logos and
trademarks may not be used without written consent of an officer of the Company.
 Any information that cannot be disclosed through a conversation, a note, or an e-mail also cannot be disclosed in a
blog, web page, social networking, Twitter, or similar site.
 ISR’s must refrain from conduct that is impermissible under the law if expressed through a blog, web page, social
networking, Twitter, or similar site.
 ISR’s should not post content about the Company, management, co-workers, a client, or a prospective client that is
discriminatory, defamatory, libelous, or threatening, or that is in violation of the Company’s policies against
discrimination on account of race, age, religion, sex, ethnicity, nationality, disability, or other protected class, status, or
characteristic.

REPRESENTING OUR COMPANY

An ISR may be tasked with representing the Company by handling our corporate social media accounts or speaking
on our Company’s behalf. We expect him/her to act carefully and responsibly to protect our Company’s image and
reputation. The designated ISR should:
 Be respectful, polite, and patient when engaging in conversations on behalf of the Company. He/she should be extra
careful when making declarations or promises toward clients, prospective clients, and stakeholders.
 Avoid speaking on matters outside his/her field of expertise whenever possible. The ISR tasked with representing the
Company should be careful not to answer questions or make statements that fall under someone else’s responsibility.
 Follow our confidentiality and data protection policies and observe laws on copyright, trademarks, plagiarism, and
fair use.
 Inform our PR/Marketing department when he/she is about to share any major-impact content.
 Avoid deleting or ignoring comments without probable cause. He/she should listen and reply to criticism
professionally and responsibly; without alienating any of the Company’s clients, prospective clients, stakeholders, or
any industry that is represented in the SG MarketPlace.
 Never post discriminatory, offensive, or libelous content and commentary.
 Correct or remove any misleading or false content as quickly as possible.

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ANTI-HARASSMENT POLICY AND COMPLAINT PROCEDURE
Spiral Group, Inc. strives to create and maintain a work environment in which people are treated with dignity,
decency, and respect. The environment of the company should be characterized by mutual trust and the absence
of intimidation, oppression, and exploitation. Spiral Group, Inc. will not tolerate unlawful discrimination or
harassment of any kind. Through enforcement of this policy and by education of ISR’s, Spiral Group, Inc. will seek
to prevent, correct, and discipline behavior that violates this policy.

All ISR’s are covered by and expected to comply with this policy and take appropriate measures to ensure that
prohibited conduct does not occur. Appropriate action [Refer to Section 2 (b) (iii) of your Independent Sales
Representative Agreement] will be taken against any Independent Sales Representative who violates this policy.

PROHIBITED CONDUCT UNDER THIS POLICY

Spiral Group, Inc., in compliance with all applicable federal, state, and local anti-discrimination and harassment
laws and regulations, enforces this policy in accordance with the following definitions and guidelines:

1. HARASSMENT
Workplace harassment is a form of discrimination that violates Title VII of the Civil Rights Act of 1964 and other
federal regulations. The EEOC defines harassment as unwelcome verbal or physical behavior that is based on race,
color, religion, sex (including pregnancy), gender/gender identity, nationality, age, physical or mental disability, or
genetic information.

Harassment becomes unlawful when enduring the offensive conduct becomes a prerequisite to continued
employment, or the conduct is severe or pervasive enough that a reasonable person would consider the
workplace intimidating, hostile, or abusive. Spiral Group, Inc. prohibits harassment of any kind and will take
appropriate and immediate action in response to complaints or knowledge of violations of this policy.

The following examples of harassment are intended to be guidelines and are not exclusive when determining
whether there has been a violation of this policy:
 Comments that are offensive or unwelcome regarding a person’s national origin, race, color, religion, gender, sexual
orientation, age, body, disability or appearance, including epithets, slurs, and negative stereotyping.
 Distribution, display, or discussion of any written or graphic material that ridicules, denigrates, insults, belittles, or
shows hostility, aversion, or disrespect toward an individual or group because of national origin, race, color,
religion, age, gender, sexual orientation, pregnancy, appearance, disability, sexual identity, marital status, or other
protected status.
 Sabotaging someone’s work on purpose.
 Engaging in frequent or unwanted advances of any nature.
 Starting or spreading rumors about a person’s personal life.
 Ridiculing someone in front of others or singling them out to perform tasks unrelated to their job against their will.

2. SEXUAL HARASSMENT
Sexual harassment is a form of sex discrimination that violates Title VII of the Civil Rights Act of 1964. It applies to
employers with 15 or more employees, including state and local governments. It also applies to employment
agencies and to labor organizations, as well as to the federal government. Sexual harassment is prohibited under
Spiral Group, Inc.’s anti-harassment policy.

Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature
constitute sexual harassment when this conduct explicitly or implicitly affects an individual's employment,
unreasonably interferes with an individual's work performance, or creates an intimidating, hostile, or offensive
work environment.

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Sexual harassment can occur in a variety of circumstances. The victim or the harasser may be a woman or a man.
The victim does not have to be of the opposite sex. The harasser can be an agent of the Company, co-worker, or
non-employee. The victim does not have to be the person harassed; it could be anyone affected by the offensive
conduct. Unlawful sexual harassment may occur without economic injury to or discharge of the victim. The
harasser's conduct must be unwelcome.

The following examples of sexual harassment are intended to be guidelines and are not exclusive when
determining whether there has been a violation of this policy.
 Innuendoes, suggestive comments, jokes of a sexual nature, sexual propositions, lewd remarks and threats;
requests for any type of sexual favor (this includes repeated, unwelcome requests for dates); and verbal abuse or
“kidding” that is oriented toward a prohibitive form of harassment, including that which is sexual in nature and
unwelcome.
 The distribution, display, or discussion of any written or graphic material, including calendars, posters, and cartoons
that are sexually suggestive or show hostility toward an individual or group because of sex.
 Suggestive or insulting sounds; leering; staring; whistling; obscene gestures; content in letters, notes, facsimiles, e-
mails, photos, text messages, tweets, and Internet postings; or other forms of communication that are sexual in nature
and offensive.
 Unwelcome, unwanted physical contact including touching, tickling, pinching, patting, brushing up against, hugging,
cornering, kissing, fondling, and forced sexual intercourse or assault.

Courteous, mutually respectful, pleasant, non-coercive interactions between ISR’s that are appropriate and
acceptable to and welcomed by both parties are not considered to be harassment, including sexual harassment.

3. RETALIATION
No hardship, loss, benefit, or penalty may be imposed on an ISR in response to:
 Filing or responding to a bona fide complaint of discrimination or harassment.
 Appearing as a witness in the investigation of a complaint.
 Serving as an investigator of a complaint.

COMPLAINT PROCEDURE
Spiral Group, Inc. has established the following procedure for lodging a complaint of harassment. The company
will treat all aspects of the procedure confidentially to the extent reasonably possible.
1. Complaints should be submitted as soon as possible after an incident has occurred, preferably in writing.
2. Upon receiving a complaint, Spiral Group, Inc. will review the complaint.
3. Spiral Group, Inc. will initiate an investigation to determine whether there is a reasonable basis for believing
that the alleged violation of this policy has occurred.
4. During the investigation, Spiral Group, Inc. will interview the complainant, the accused, and any witnesses to
determine whether the alleged conduct occurred.
5. Upon conclusion of an investigation, and if it is determined that a violation of this policy has occurred, Spiral
Group, Inc. will enforce appropriate disciplinary action [Refer to Section 2 (b) (iii) of your Independent Sales
Representative Agreement]. If the investigation is inconclusive, or if it is determined that there has been no
violation of this policy but potentially problematic conduct may have occurred, Spiral Group, Inc. may
recommend appropriate preventive action.

Lodging a bona fide complaint will in no way be used against the ISR or have an adverse impact on the status of
the individual’s Independent Sales Representative Agreement. However, filing groundless or malicious complaints
is an abuse of this policy and will be treated as a violation. Any person who is found to have violated this aspect of
the policy will be subject to termination of his/her Independent Sales Representative Agreement.
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CONFIDENTIALITY
All complaints and investigations are treated confidentially to the extent possible, and information is disclosed
strictly on a need-to-know basis. The identity of the complainant is usually revealed to the parties involved during
the investigation, and Spiral Group Inc. will take adequate steps to ensure that the complainant is protected from
retaliation during and after the investigation. All information pertaining to a complaint or investigation under this
policy will be maintained in secure files within the company’s HR department.

ALTERNATIVE LEGAL REMEDIES

Nothing in this policy may prevent the complainant or the respondent from pursuing formal legal remedies or
resolution through local, state, or federal agencies or the courts.

RESPONSIBILITIES
This policy applies to all ISR’s, vendors, customers, and anyone else with whom ISR’s come into contact while
performing their tasks. We are committed to maintaining a workplace that’s free of harassment. ISR’s are
responsible for complying with this policy by reporting all instances of alleged harassment and cooperating in any
investigation of alleged harassment.

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 INDEPENDENT SALES REPRESENTATIVE ACKNOWLEDGEMENTS

A LINK TO COMPLETE THIS SECTION ELECTRONICALLY IS LOCATED ON PAGE 8 OF THE SPIRAL GROUP, INC. 2020 - NON-EXCLUSIVE ISR AGREEMENT.

I acknowledge that I have received a copy of the Spiral Group, Inc. Independent Sales Representative Handbook.
PLEASE INITIAL

I understand that the contents of this handbook are confidential and may not be distributed in any way nor discussed
with anyone who is not an agent of Spiral Group, Inc.
PLEASE INITIAL

I have read and understood the Standards of Conduct expected by Spiral Group, Inc. and I agree to act in accordance with
these standards as a condition of my Spiral Group, Inc. Independent Sales Representative Agreement.
PLEASE INITIAL

I have read and understood the Spiral Group, Inc. Anti-Harassment Policy and Complaint Procedure, and I agree to act in
accordance with this policy as a condition of my Spiral Group, Inc. Independent Sales Representative Agreement.
PLEASE INITIAL

I have read and understood the Spiral Group, Inc. Sexual Harassment Policy and I agree to act in accordance with this
policy as a condition of my Spiral Group, Inc. Independent Sales Representative Agreement.
PLEASE INITIAL

I understand that if I have questions or concerns at any time about the contents of this handbook, I will consult the
Human Resources Manager for clarification.
PLEASE INITIAL

INDEPENDENT SALES REPRESENTATIVE SIGNATURE INDEPENDENT SALES REPRESENTATIVE PRINTED NAME DATE

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