Highgate Hotels - Associate Playbook - Effective January 2023

ASSOCIATE PLAYBOOK
Effective Date: January 2023
This Associate Playbook supersedes all previously issued Associate Playbooks, and all previously
issued Associate Playbooks are hereby revoked.
Some of the guidelines in this Associate Playbook may not apply to associates covered by a
Collective Bargaining Agreement.
ASSOCIATE PLAYBOOK
Contents
EQUAL OPPORTUNITY EMPLOYMENT .......................................................................................................................... 5
Accommodating Associates with Disabilities........................................................................................................ 5
Religious Accommodations................................................................................................................................... 6
Pregnancy Accommodations ................................................................................................................................ 6
Non-Harassment and Non-Retaliation of Associates ........................................................................................... 6
Responsibility for Enforcement ............................................................................................................................ 7
Procedure for Reporting Harassment or Retaliation ............................................................................................ 7
No Retaliation ....................................................................................................................................................... 7
GENERAL INFORMATION .............................................................................................................................................. 7
Keeping Us Informed ............................................................................................................................................ 7
Reporting Emergencies ......................................................................................................................................... 8
Lost and Found & Guest Property ........................................................................................................................ 8
Environmental Responsibility ............................................................................................................................... 8
Promotions and Transfers..................................................................................................................................... 8
Minimum Age Requirements ................................................................................................................................ 8
Overtime ............................................................................................................................................................... 8
Work Week ........................................................................................................................................................... 9
Meal Time and Breaks .......................................................................................................................................... 9
Associate Referral Program .................................................................................................................................. 9
Employment of Relatives ...................................................................................................................................... 9
Guest Courtesy and Privacy ................................................................................................................................10
Associate Entrance and Exit ................................................................................................................................10
Company Property & Company Issued Items .....................................................................................................10
Gratuities ............................................................................................................................................................10
Giving and Receiving Gifts and Entertainment ...................................................................................................10
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Property of © Highgate Hotels, L.P.
Separation from the Company ...........................................................................................................................10
Final Pay Check ...................................................................................................................................................11
COMMUNICATION ......................................................................................................................................................11
Associate Relations .............................................................................................................................................11
Bulletin Boards ....................................................................................................................................................11
Information/Data Security ..................................................................................................................................11
Performance Evaluations ....................................................................................................................................12
Open Door Policy ................................................................................................................................................12
Confidentiality.....................................................................................................................................................12
CONDUCT ....................................................................................................................................................................13
Standards of Appearance....................................................................................................................................13
Non-Solicitation/Distribution..............................................................................................................................14
Drug-Free Workplace ..........................................................................................................................................14
Use of Communications Devices ........................................................................................................................15
Use of Personal Electronic Devices .....................................................................................................................15
Use of Cell Phones/Other Electronic Devices While Driving ..............................................................................16
Business Ethics and Associate Integrity ..............................................................................................................16
Smoking ..............................................................................................................................................................16
Concealed Weapons Policy .................................................................................................................................16
Social Media ........................................................................................................................................................17
Attendance .........................................................................................................................................................18
Performance Management .................................................................................................................................19
Highgate Hotels Standards of Conduct ...............................................................................................................19
Biometric Information Policy ..............................................................................................................................21
SAFETY AND ACCIDENTS .............................................................................................................................................22
Safety and Accidents...........................................................................................................................................22
Hazardous Material Handling .............................................................................................................................22
Workplace Violence ............................................................................................................................................22
HEALTH AND WELFARE BENEFITS ...............................................................................................................................23
Health and Welfare .............................................................................................................................................23
Associate Assistance Program ............................................................................................................................23
Savings and Retirement Plan ..............................................................................................................................24
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Vacation Time .....................................................................................................................................................24
Sick Time .............................................................................................................................................................24
Holidays...............................................................................................................................................................25
Holiday Pay .........................................................................................................................................................25
Jury Duty .............................................................................................................................................................25
Bereavement Leave ............................................................................................................................................25
Associate Discount Room Nights ........................................................................................................................26
Associate Meals ..................................................................................................................................................26
Leaves of Absence...............................................................................................................................................26
Family and Medical Leave (FMLA) ......................................................................................................................26
Reasonable Accommodation Medical Leave ......................................................................................................31
Interaction with State Leave Laws ......................................................................................................................31
Outside Activity During Disability .......................................................................................................................31
Nursing Mothers Leave .......................................................................................................................................31
Uniformed Services Leave ..................................................................................................................................31
Other Legally Protected Absences ......................................................................................................................32
NEW JERSEY ADDENDUM – For New Jersey Associates Only .....................................................................................33
CALIFORNIA ADDENDUM – For California Associates Only ........................................................................................39
COLORADO ADDENDUM – For Colorado Associates Only ..........................................................................................53
CONNECTICUT ADDENDUM – For Connecticut Associates Only ................................................................................57
DISTRICT OF COLUMBIA ADDENDUM – For D.C. Associates Only ..............................................................................59
HAWAII ADDENDUM – For Hawaii Associates Only....................................................................................................60
ILLINOIS ADDENDUM – For Illinois Associates Only ...................................................................................................64
MASSACHUSETTS ADDENDUM – For Massachusetts Associates Only .......................................................................69
NEW YORK ADDENDUM – for New York Associates Only...........................................................................................73
OREGON ADDENDUM—For Oregon Associates Only .................................................................................................82
WASHINGTON ADDENDUM—For Washington Associates Only ................................................................................91
STATE AND CITY PREGNANCY ACCOMMODATION ADDENDUM ................................................................................96
ACKNOWLEDGEMENT OF ASSOCIATE PLAYBOOK ......................................................................................................99
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DISCLAIMER STATEMENT
Associates who are party to a Collective Bargaining Agreement may not be covered by all outlined policies in this
playbook. Should any policy contained in this playbook conflict with the applicable Collective Bargaining Agreement,
associates should operate in accordance with the terms of the Collective Bargaining Agreement. Associates covered
by a Collective Bargaining Agreement should always follow the terms of the Collective Bargaining Agreement. If an
associate covered by a Collective Bargaining Agreement is unsure about a particular policy contained in this playbook,
please contact your manager or Human Resources representative.
This playbook is designed to provide information to associates of Highgate Hotels, L.P. (“Highgate Hotels”, “Highgate”, or
the “Company”) regarding various policies, practices, and procedures that may apply to their employment. The
Company and its associates acknowledge that, unless there is a separate written employment contract stating that it is a
“contract of employment” and is signed by the Chief People Officer, their relationship is "at will" and either party can
terminate that relationship at any time and for any or no reason. The Company reserves the right to modify, alter, or
eliminate any and all of the policies and procedures set forth herein at any time, with the exception of employment "at
will." Neither this playbook nor its contents constitute, in whole or in part, either an expressed or implied contract of
employment or otherwise between The Company and any associate, and they should not be construed or interpreted as
such by anyone.
The statements contained in this playbook regarding the Company's policies, benefits, and employment practices are
necessarily in condensed form. While this playbook is not intended to state all of the conditions of employment and all of
the principles that will help to guide the Company's associates in the performance of their duties, it and any
supplementary publications will give you general information in regard to certain policies and benefits which are in
effect at this time.
The information and guidelines contained in this associate playbook supersede any prior versions or any other associate
playbook or manual that may have been used in this location. The Company shall revise policies in this playbook
periodically and it is your responsibility to stay informed of all changes to the playbook.
Oral statements on the part of Supervisors, managers, or other associates of the Company concerning an associate's
conditions of employment will be superseded by the written policies that are the basis of this playbook and thus will not
be contractual in nature unless approved in writing by the Chief People Officer. In some cases, the application of these
policies may be affected by present or future government regulations or state or local laws. In all situations, the
Company will comply with all applicable federal, state, or local laws.
EQUAL OPPORTUNITY EMPLOYMENT
Highgate Hotels, L.P. is an Equal Opportunity Employer and maintains the policy of recruiting and retaining the best
qualified personnel who demonstrate the ability to perform competently and work well with others. It is the policy of
Highgate Hotels to provide equal employment opportunity regardless of race, color, protected hair style and texture,
age, religion, sex, gender, national origin, disability, pregnancy, genetic information, uniformed services, veteran status,
sexual orientation, gender identity and expression or any other legally protected classification. This policy of
nondiscrimination prevails throughout all aspects of the employment relationship, including but not limited to
recruitment, selection, placement, transfer, promotion, layoff/recall, termination, training, working conditions, discipline,
discharge, benefits and compensation.
Accommodating Associates with Disabilities

The Company complies with the Americans with Disabilities Act (ADA) and applicable state and local laws in ensuring
equal opportunity and employment for qualified persons with disabilities. All employment practices, terms, and
conditions of employment and privileges of employment are conducted on a non-discriminatory basis.
An associate needing reasonable accommodation should inform his or her manager or a representative of Human
Resources. On receipt of an accommodation request, the Company will engage in an interactive process with the
associate to view possible reasonable accommodation options consistent with the ADA. Reasonable accommodations
which do not result in an undue hardship on the operation of the Company will be considered for all associates with
physical or mental disabilities where their disabilities affect their ability to perform the essential functions of their job. All
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employment decisions are based on the merits of the situation in accordance with applicable job criteria, not the
disability of any individual.
An associate who has questions regarding this policy or believes that he/she has been discriminated against based on a
disability should notify Human Resources. All such inquiries will be treated as confidentially as possible without impeding
the investigation process.
Religious Accommodations
The Company complies with Title VII of the Civil Rights Act of 1964 in ensuring equal opportunity in employment regardless of an
associate’s religious beliefs. If an associate needs a reasonable accommodation due to a work requirement or restriction that
interferes with a sincerely held religious belief, the associate should contact his/her supervisor or the Human Resources Department.
Upon receipt of an accommodation request, the Company will review reasonable accommodation options and will consider
accommodations for associates with sincerely held religious beliefs that do not create an undue hardship on the Company or in
accordance with applicable collective bargaining agreement. Any associate who has questions regarding this policy should
contact Human Resources.
Pregnancy Accommodations
The Company complies with employment laws applicable to mothers and expectant mothers, including the Family
Medical Leave Act, Pregnancy Discrimination Act, Americans with Disabilities Act and applicable state laws. Highgate
Hotels will consider reasonable accommodations for pregnancy, childbirth and medical and common conditions
related to pregnancy and childbirth if requested by an associate and agreed upon by the Company.
Associates that require accommodation(s) for pregnancy, childbirth, or medical or common conditions related to
pregnancy or childbirth shall make the request to her immediate supervisor or Human Resources, which will work with
them to determine any effective reasonable accommodation(s). Reasonable accommodations may include a transfer
to a temporary position if available. An accommodation(s) may not be reasonable where it poses an undue hardship
on the Company.
The associate may be required to provide documentation from her physician to support the need for the reasonable
accommodation(s). Documentation may include the medical justification for the requested accommodation(s), a
description of the reasonable accommodation(s) that is medically advisable, the date the reasonable
accommodation(s) became medically advisable, and the probable duration of the reasonable accommodation(s).
The Company prohibits discrimination, harassment, and retaliation against applicants and associates for requesting
and/or using accommodation(s). If an applicant or associate experiences such prohibited conduct, they must file a
complaint with the Company as set forth in the Company’s policies.
Non-Harassment and Non-Retaliation of Associates

Highgate Hotels is committed to maintaining a professional work environment in which all individuals are treated with
respect. Highgate Hotels has a zero-tolerance policy for harassing conduct. Accordingly, we do not tolerate any form of
discrimination, harassment, retaliation, joking remarks or other threatening conduct by or against associates, contractors,
clients, candidates, vendors, third parties or any other individuals who conduct business with Highgate Hotels because of
their race, color, sex, religion, national origin, age, disability, sexual orientation, marital status, citizenship status,
uniformed services, veteran status, or any other category protected by law, or because an individual complained of
harassment or discrimination.
Harassment can include verbal or physical conduct that demeans, denigrates or shows hostility or aversion toward an
individual because of his/her race, color, sex, religion, age, or disability, or any other legally protected category, and
that creates an intimidating, hostile, or offensive work environment, unreasonably interferes with an individual's work
performance or otherwise adversely affects an individual's employment opportunities.
Sexual harassment is the most well-recognized form of unlawful harassment and may involve individuals of the same or
opposite sex. Sexual harassment is verbal or physical conduct of a sexual nature that is unwelcome, that is personally
offensive, that debilitates morale, and that, therefore, interferes with equal employment opportunities for associates
because of the associates' gender. Although not an exhaustive list, the following are examples of conduct prohibited
by the Highgate Hotels Non-Harassment and Non-Retaliation Policy:
• Engaging in offensive, sexual or overly-familiar touching or any other physical interference with normal work or
movement;
• Requests for sexual favors;
• Continued or repeated verbal abuse of a sexual nature about an individual or his or her appearance;
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• Threatening or suggesting that continued employment, advancement, assignment or earnings depend on
whether the associate will submit to, or tolerate harassment;
• Viewing, displaying or circulating discriminatory or sexually explicit or suggestive materials, including without
limitation: cartoons, photographs, calendars, drawings, emails and screen savers;
• Jokes, pranks or other humor that is demeaning or hostile with regard to race, color, religion, gender, sex,
national origin, sexual orientation, age, handicap or disability;
• Epithets, slurs, quips or negative stereotyping that relate to race, color, religion, gender, sex, national origin,
citizenship, age, sexual orientation, physical or learning disability, marital status, veteran status, political beliefs or
any other basis prohibited by law;
• Threatening, intimidating or hostile acts that relate to race, color, religion, gender, sex, national origin, sexual
orientation, age, handicap or disability;
• Written or graphic material (including graffiti) that denigrates or shows hostility or aversion toward an individual
or group because of race, color, religion, gender, sex, national origin, sexual orientation, age, handicap or
disability and that is placed on walls, bulletin boards, computers or elsewhere on the Company’s premises, or
circulated or displayed in the workplace;
• Actions that create an intimidating, hostile or offensive work environment; or
• Retaliation, which can include harassing behavior, is an adverse action one takes against another person
because that person complained of unlawful discrimination or harassment, or otherwise engaged in legally-
protected activity.
Conduct prohibited by this policy is unacceptable whether in the workplace and/or in any work-related setting outside
the workplace, such as during business trips, business meetings and business-related social events.
Responsibility for Enforcement

Associates are obligated to adhere to policies designed to keep the workplace free of all forms of harassment. Any
associate or Supervisors must immediately report allegations of harassment to his or her Human Resources representative
or the applicable Senior Leader. Supervisors who allow or tolerate harassment are in violation of this policy and subject
to disciplinary action up to and including termination. If an associate witnesses the harassing behavior of another
associate, the associate should report the incident(s) to his or her Human Resources representative or the applicable
Senior Leader.
Procedure for Reporting Harassment or Retaliation

Any associate who believes that he or she is the victim of unwelcome harassment or retaliation or feels that his or her
work is being unreasonably interfered with by such conduct, must report the conduct as soon as possible to your Human
Resources representative or the applicable Senior Leader. At any time, an associate may also contact the Chief People
Officer at Highgate Hotels at 972.444.9700 or contact the Highgate Hotels Ethics Hotline at
reportlineweb.com/HighgateHotels (for more information please see the Ethics flyer posted in your work location). All
complaints will be investigated promptly. In investigating complaints, Highgate Hotels will attempt to maintain
confidentiality to the greatest degree possible without impeding the investigation. Following the investigation, prompt,
effective remedial action will be taken where appropriate, based on the results of the investigation. Any violation of this
policy, including inappropriate actions or failure to act, may result in corrective action, up to and including termination.
Similarly, any associate or manager who engages in conduct that violates this policy or whose conduct would violate
this policy if allowed to continue is subject to disciplinary action, up to and including termination.
No Retaliation
Retaliation for reporting harassment or participating in any investigation is strictly prohibited. All complaints of retaliation
must be reported to an appropriate member of management and will be promptly investigated with appropriate action
taken. Any associate that knowingly makes a false report of harassment or discrimination will be subject to disciplinary
action, up to and including termination.
GENERAL INFORMATION
Keeping Us Informed
When hired, you completed various forms, which contained important information. Keeping this information up-to-date
enables us to reach you in case of emergency, forward information, maintain your benefits, compute your payroll
deductions, mail your W-2s, etc.
Please notify your Human Resources representative promptly of changes.
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All information will remain strictly confidential. If someone inquiries about your employment, our policy allows us to only
verify your dates of employment and position held.
Reporting Emergencies
Highgate Hotels is committed to creating a safe environment for both its associates and its guests. The best way to
achieve this environment is to promote awareness of Highgate’s safety procedures and the appropriate steps to follow
in an emergency. Should a serious situation occur, go to the nearest telephone and dial the emergency number to
reach the operator or receptionist and provide the following information:
• Associate’s Name
• Location of Emergency
• Nature of Emergency
Assist until help arrives (if possible), but never jeopardize your safety or the safety of a guest. Remain calm and provide
guests with as much reassurance as possible. We rely on everyone’s cooperation to provide a safe work environment
and guest experience.
Lost and Found & Guest Property

As part of our responsibility to Hotel guests and your fellow associates, all articles found in any building or on the property
must be turned over immediately to the designated Lost and Found area. Detailed logs will be kept; when appropriate,
items not claimed within a reasonable time frame may be released to the finder.
Environmental Responsibility
It is everyone’s job to protect our environment and keep energy consumption to a minimum by:
• Turning off lights in unused rooms and offices

• Conserving water
• Reporting any potential energy leaks to your Supervisor
• Disposing of wastes properly
• Supporting recycling efforts
Promotions and Transfers

Highgate Hotels provides a variety of opportunities for growth and professional development. Typically, certain position
vacancies are posted for internal review before outside candidates will be offered the opportunity to apply, unless
otherwise required by a Collective Bargaining Agreement. If you are interested in a position, please contact your
Supervisor or your Human Resources representative as soon as possible. Human Resources will supply you with a Transfer
Request Form, which must be completed and approved prior to any action being taken regarding the transfer.
During a preliminary interview, a representative from Human Resources will discuss the position with you. If you have an
active warning (meaning one received in the previous six months), are currently on a performance improvement plan, or
your latest performance review was questionable, you may not be eligible to be considered for a promotion. The
Company reserves the right to hire the best qualified candidate for the job. Nothing in this policy prohibits Highgate
Hotels from considering candidates from outside the Company.
Minimum Age Requirements

Under certain conditions, the Company will employ individuals who are under 18 years of age, but at least 16 years or
older. The employment of such minors requires the advance approval of the Chief People Officer in accordance
federal and state requirements.
Overtime
Due to the nature of the hotel business, your Supervisor may ask you to work beyond your normal shift. The Company will
pay for overtime work in accordance with the requirements of local, state, or federal laws, or applicable Collective
Bargaining Agreement. Although an attempt will be made to give you advance notice where it is feasible to do so, this
is not always possible due to business needs. You must have your Supervisor’s approval before any overtime can be
worked. Personal time, holiday, and vacation hours paid but not worked are not included in calculating overtime.
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Overtime is based only on actual hours worked as required by law. Overtime hours are normally compensated at one
and one-half the associate’s regular rate of pay for all hours worked over 40 hours in a week unless otherwise required by
applicable state law or the terms of a Collective Bargaining Agreement.
Certain positions at the Company have been designated as exempt under the Fair Labor Standards Act (FLSA). The
Company prohibits deductions from an exempt associates’ salary except as allowed by the FLSA. If an associate is
aware of improper deductions from his/her salary, this violation should be reported immediately to their Manager. All
reported or suspected improper deductions from an exempt associates’ pay will be promptly and thoroughly
investigated. If the Company determines that improper deductions were made from an exempt associates’ salary, the
Company will promptly reimburse the associate the amounts improperly deducted. The Company will also ensure that
improper deductions from pay do not occur in the future.
The Company wants to be sure that hourly associates are compensated for all worked hours. Hourly associates should
NEVER work off the clock. If an hourly associate is asked to work off the clock, the associate should report it immediately
to the associate’s human resources representative or corporate Human Resources.
Work Week
Due to our vast location base, please see your Human Resources representative to understand your designated payroll
cycle and your designated workweek. Your Human Resources representative will inform you of the work week at your
particular location for purposes of calculating overtime. The pay cycle may fluctuate based upon business demands in
accordance with applicable state law.
Meal Time and Breaks

It is important that each associate take a break from his or her duties throughout a consecutive shift. Associates should
be directed to follow mandated local, state, or federal laws, or applicable Collective Bargaining Agreement terms.
Associate must punch in and out for their lunch breaks. Unless otherwise stated in the Collective Bargaining Agreement,
meal breaks are normally unpaid and must be a minimum duration of at least thirty minutes. Associates are prohibited
from performing any compensable work during their meal breaks. If an associate does not receive a meal break,
he/she must inform his/her manager. Your manager will provide you specific information regarding meal and rest breaks
at your particular work location. IF your work location has a state meal or rest break law, those requirements are also in
the employment posters posted at the Property.
Associate Referral Program

Current associates will receive a referral incentive after a new associate whom they had referred has successfully
completed 90 days of continuous employment with the Company and is in good performance standing. The amount
of the referral incentive is determined by the level of position filled by the candidate. The referring associate must be
employed with the Company at the time the 90-day period of the new associate is completed in order to qualify for the
incentive. For more information regarding the Associate Referral Program, please see a representative of the Human
Resources Department.
Employment of Relatives
Highgate Hotels does not employ or permit the continued assignment of individuals, including relatives, where potential
problems of supervision, safety, security, morale, or potential conflict of interest exist. Relatives include an associate’s
spouse, domestic partner, parent, grandparent, child, grandchild, brother, sister, in-laws, and step-relationships.
Relatives are prohibited from working in a supervisory-subordinate relationship. The Company is entitled to reasonably
regulate the working conditions of an associate or applicant. If two associates become subject to the restrictions of this
policy after they are hired, one or both associates must seek a transfer or reassignment to eliminate the actual or
potential conflict of interest specified in this policy.
The Company strictly prohibits supervisors and managers from dating or engaging in romantic or sexual relationships with
associates that report directly or indirectly to them. This restriction on romantic relationships applies regardless of the
sexual orientation of the associates involved. This applies equal to opposite-sex and same-sex relationships.
The Company reserves the right to determine whether other relationships not specifically covered by this Employment of
Relatives Policy represent actual or potential conflicts of interest as well. Should the Company determine that the
relationship between associates presents an actual or potential problem or conflict of interest, appropriate action may
be taken, including - but not limited to – execution of a relationship agreement, transfers, reassignments, shift changes,
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or if necessary, termination. Associates that are in a romantic relationship that is not in violation of this policy must still act
professionally in the workplace. Public displays of affection in the workplace are prohibited.
Guest Courtesy and Privacy

When our guests depart one of our properties, all they take with them is an experience that – as a Highgate Hotels
associate – you helped to create. Our commitment to our guests requires us to provide attentive, courteous and efficient
service at all times, and in all circumstances. How we greet our guests, treat them, care for their safety and welfare, and
anticipate their needs will be determining factors of our success. Treat our guests as you would wish to be treated.
Always have a smile and a greeting to extend when you come in contact with one of our guests. They will appreciate it
and you will enjoy it, too. Associates are prohibited from disclosing any information about a guest to any third party and
must never divulge guest names or room numbers to anyone. As an associate, you are in a position to observe the
personal lives of many people. It is mandatory that you refrain from discussing your personal observations with guests or
in the presence of guests. The privacy of our guests is paramount and the failure to maintain the privacy of all guest
information will result in disciplinary action up to and including discharge.
Associate Entrance and Exit

All associates of the Hotel will enter and exit the building through the designated associate entrance only. You are not
allowed to enter the property earlier than 15 minutes prior to your scheduled shift and you should leave the property
within 15 minutes after the end of your shift. While waiting for transportation, associates must remain in the property
designated area. Associates are prohibited from working “off-the-clock.” Associates must accurately record all time
worked.
Company Property & Company Issued Items

When hired, you will be issued various items that you will need to successfully complete your job. These items are sole
property of the Company and may include, but are not limited to, a nametag, Associate discount cards, identification,
keys, technology equipment including but not limited to laptops, desktops, mobile phones, tablets, uniforms, tools, etc.
that are necessary to perform your job. If you should leave the employment of Highgate Hotels, you will be required to
return all Company property and Company issued items upon your departure. Associates should take extra precautions
to ensure the safety and security of these items while employed with The Company, as replacing these items is often very
costly. Careless or negligent handling of these items may result in disciplinary action.
Gratuities
In addition to your wages, you may receive tips or gratuities from guests. Tips are considered a part of your income and,
by law all associates who receive tips must report them for income tax purposes. Please consult your Supervisor or your
Human Resources representative for additional clarification of the tip-reporting procedure. Direct solicitation of gratuities
from guests or vendors will result in disciplinary action up to and including termination.
Giving and Receiving Gifts and Entertainment

Business gifts and entertainment are appropriate mechanisms to build relationships with those whom we do business.
However, when gifts have the potential to influence a business decision, they are no longer acceptable. You may not
accept a business gift or entertainment if it could impair your ability to make an impartial decision or appear as such, or
it exceeds a nominal value. When giving gifts or entertainment, we must not create a conflict of interest. Gifts should be
given infrequently and their value should be modest. You may not give business gifts or entertainment:
• To influence a business decision

• With the expectation of receiving anything of value in return
• If it exceeds accepted business practices.
Cash or cash equivalents are never acceptable business gifts. If you receive a gift that is not of nominal value, consult
Human Resources for guidance and approval before accepting the gift.
Separation from the Company

Should you choose to resign from Highgate Hotels, a completed voluntary resignation form is required and a minimum of
two-week’s notice is expected. Associates are expected maintain the highest level of professionalism throughout the
notice period. It is expected that associates will work the full notice period up to the expectations of the job unless
directed otherwise by management. Associates may not use any paid time off during the notice period in lieu of
working out the notice period. Any associate that fails to meet the requirements of the job during the notice period
maybe asked to leave prior to the completion of the notice period.
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Final Pay Check
Terminated associates will be paid for time worked through termination and any earned or accrued vacation pay as
required by law, on the next regularly scheduled pay date or as otherwise required by local laws. Deductions will be
made from final checks to the extent permitted by law. Continuation or conversion of insurance coverage will be
permitted in accordance with applicable state or federal laws.
COMMUNICATION
Associate Relations
Highgate Hotels demonstrates mutual respect, honesty and commitment to resolving associate issues or concerns to
ensure that we maintain a positive work environment. Highgate Hotels is committed to solving any issues or concerns
directly with associates.
Bulletin Boards
Bulletin boards are to be used for official Company business only. For associates subject to a Collective Bargaining
Agreement, a union bulletin board may be provided for the union to communicate with you regarding employment
matters. Personal use of Company bulletin boards by associates is prohibited. Referencing the bulletin boards located in
the associate areas of the hotel each day will enable you to stay informed about property announcements and
activities. It is your responsibility to check the bulletin boards each day for associate schedule information and various
hotel updates. You are prohibited from tampering with, removing or defacing any information posted on Company
bulletin boards.
Information/Data Security
The Company takes information/data security very seriously, including security of all financial information including credit
card data (Payment Card Industry Compliance), personal information, as well as other sensitive data and Intellectual
Property. While the Company makes every effort to implement strong information security standards and policies,
security is truly a team effort. Understanding this, Associates will be trained on an annual basis and should reference and
comply with the Information Security Policy, as well as other appropriate IT policies and procedures. Authorized versions
of these can be found on The Company’s Business Intelligence (BI) Portal and/or from Human Resources.
Associates are obligated to maintain as confidential the personal and private information of the Company’s guests,
including credit card numbers. Associates are prohibited from copying or otherwise recording or duplicating a guest’s
credit card number, including taking pictures of the credit card numbers with their cellphones, copying down the credit
card number or otherwise inappropriately accessing or using a guest’s credit card number. Information from a guest
credit card should not be written down or copied in any way. Violations if this policy will result in disciplinary action up to
and including discharge.
The Company owns the computers and software making up the e-mail/internet/intranet systems and permits associates
to use them primarily in the performance of their jobs. Records contained within these systems are Company property
and should be transmitted only to individuals who have a business need to know. Associates may use the email system
for personal reasons during nonworking hours as long as such personal use does not interfere with work.
The Company computers, including e-mail and Internet access, voice mail, telefax machines, and cellular telephones
are the property of the Company. These systems of technology, as well as communications transmitted by, received
through or stored in these systems, are property and assets of the Company. As such the Company reserves the right to
monitor both the use of the technological systems and the content of the communications at its discretion. Associates
have no reasonable expectation of privacy regarding their use of these services.
E-mail messages sent and received using the Company’s computers are not private, despite any contrary designation
either by the sender or the recipient. Accordingly, associates have no expectation of or privacy in their e-mail messages
nor when accessing the Internet on Company computers. The Company has the right to monitor e-mail messages at its
sole discretion in the ordinary course of its business, even if associates use a password or the system’s delete function.
Associates who have access to Company email may use Company email for personal reasons during non-working time
as long as such personal use does not interfere with work. In addition, the Company may monitor access to the Internet.
Threatening, harassing, or intimidating material shall not be entered into the computer or sent by electronic means. Also
prohibited are any messages that are sexually oriented/explicit, racial slurs, gender-specific comments or any other
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comments that address someone’s age, sexual orientation, religious or political beliefs, national origin, or disability in an
unlawful or discriminatory manner. These prohibitions also apply to any communication sent or displayed on any social
media, including but not limited to, internet blogs, Twitter, and Facebook if being used for Company business. When
accessing these sites, an associate should make sure it is clear that the associate is speaking his/her own opinion and
not as a designated representative of the Company if an associate is discussing Company business. Nothing in this
policy is intended to inhibit an associate’s rights under federal or state labor law rights, including any and all rights under
the National Labor Relations Act, or any whistleblower protections under federal or state law.
Records of an associate’s use of Company computers are Company property and are subject to review, disclosure to
law enforcement, government officials or other parties through subpoena or other process without notification to or
permission from associates. Associates have no right or expectation of privacy with regard to e-mail/ internet/ intranet
records generated using Company-owned computers.
Associates are prohibited from installing or downloading any unauthorized software such as shareware, screen savers,
time synchronizers and search tools bars, onto Company computer equipment. Associates may not copy software from
Company computers and install it on their home or other computers without the express written permission of
Management. The Company does not allow the unauthorized use, installation, copying, or distribution of copyright,
trademark, or patented material on any Company communication tool. Associates whose communication activity
violates state or federal law or Company policies are subject to disciplinary action up to and including termination of
employment.
Performance Evaluations
Evaluating job performance is critical to your professional growth. Full-time and part-time associates will generally have
their performance evaluated a minimum of once each year where they will meet with their Supervisor to discuss the
quality and quantity of their work, professionalism, dependability, cooperation with others, initiative, objectives, goals,
etc. This process for hourly associates takes place on the Company’s common review date. Wage reviews are at the
discretion of Highgate Hotels and, if granted, are performed annually and based on actual job held and performed,
results, merit and the company’s financial performance. Associates subject to a Collective Bargaining Agreement may
have different performance evaluation criteria and timelines.
Open Door Policy

At Highgate Hotels, we have created an environment in which open communication between associates and
management can, and does, exist. We encourage you to communicate your ideas, suggestions, and problems to your
department manager on a daily basis. When people work together, we know that misunderstandings may occur. If such
a situation or problem should arise, we encourage you to talk first with your immediate Supervisor and give him or her an
opportunity to work it out with you. If your complaint involves your Supervisor, or you are not satisfied with your
Supervisor’s response, or if for any reason you do not wish to bring the problem to your Supervisor’s attention, you may
present your concern to your department manager or Human Resources representative. What follows is an outline of the
open-door steps available to you:
• Talk first with your immediate Supervisor to discuss the issue. Your Supervisor should listen and investigate
the issue to find an agreeable solution in a timely manner. If needed, the discussion will include the
department head.
• If you do not wish to bring this issue to your Supervisor’s attention for any reason, you may present you
concern directly to the department head, Human Resources representative or applicable Senior Leader.
• If the issue is not resolved, you may contact the Chief People Officer at Highgate Hotels (972-444-
9700).
• If your concerns relate to business records, travel expenses, gifts and entertainment, business systems,
property, external inquiries, accounting and financial reporting, auditing matters and/or conflicts of
interest, then you may also contact the confidential Highgate Hotels Ethics Hotline. Please contact your
HR department for more information.
• The corporate office will make a final determination regarding the appropriate action, if any, to be taken.
Applicable Collective Bargaining Agreement rights may be applicable.
Confidentiality
During your employment you may work with or have access to Confidential Information of the Company or the Company’s
customers. Such information may include, but is not limited to, customer or supplier data, customer lists, product specifications,
production techniques, financial data, sales and marketing activities, strategic forecasting and planning, and other proprietary
information that is maintained as confidential and is not readily available to the public. You may also have access to trade secret
information of the Company as defined by applicable law and the Defend Trade Secret of 2016. You must keep such information
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confidential. Any violation of confidentiality seriously injures the Company’s reputation and effectiveness. You must also keep
confidential any personal or private information of the Company’s customers. This means that you will not disclose such information
to coworkers who have no need to know about the information or persons outside the workplace. Any associate who violates this
policy is subject to disciplinary action, up to and including termination.
The federal Defend Trade Secrets Act of 2016 provides immunity in certain circumstances to Company associates,
contractors, and consultants for limited disclosures of Company Trade Secrets. Specifically, Company associates,
contractors, and consultants may disclose Trade Secrets:
(1) in confidence, either directly or indirectly, to a Federal, State, or local government official, or to an attorney,
“solely for the purpose of reporting or investigating a suspected violation of law,” or
(2) “in a complaint or other document filed in a lawsuit or other proceeding, if such filing is made under
seal.”
Additionally, Company associates, contractors, and consultants who file retaliation lawsuits for reporting a suspected
violation of law may also use and disclose related Trade Secrets in the following manner:
(1) the individual may disclose the Trade Secret to his/her attorney, and
(2) the individual may use the information in related court proceeding, as long as the individual files
documents containing the Trade Secret under seal and does not otherwise disclose the trade secret
“except pursuant to court order.”
CONDUCT
Standards of Appearance
At Highgate Hotels, we value and embrace the individualism and diversity of all our associates. It’s everyone’s
obligation to maintain a balance between individual expression and a consistent standard of appearance that ensures
our brand image is maintained throughout the Company. To help address questions you may have about what is
appropriate for the workplace, we’ve provided basic guidelines for appearance. Please recognize that each property
is unique and thus each property may have more specific appearance guidelines applicable to your work location.
Personal Hygiene
Daily showers and antiperspirant or deodorant should be used to prevent body odor. Light or mild scents may be used
sparingly; however excessive use should be avoided as some associates and guests may be allergic to strong
deodorants or colognes. After using the restroom associates MUST always wash his/her hands before reporting back to
work. Eating candy, chewing gum, or the use of tobacco products while on the job is not permitted.
Hair
May be stylish but must be professional and well groomed . Extreme or dramatic hairstyles, coloring, dyeing or bleaching
may not be permitted depending on your work location. Your manager will inform you any specific guidelines
applicable at your property. Accommodations will be made to this policy as required by applicable law. Associates
working in Food & Beverage and Housekeeping departments may be required to adhere to more stringent standards to
ensure sanitary conditions.
Tattoos
Associates should refer to their local property policy on tattoos.
Footwear
Uniformed Associates - Uniformed associates are required to coordinate with the uniform and to adhere to safety
standards. Appropriate footwear for uniformed associates will be reviewed in Orientation and by Department Heads. All
associates must wear a polishable shoe free of scuffs, stains, or debris at all times. If associates are wearing either a dress
or skirt, a shoe with at least a 1-inch heel but no higher than a 3-inch heel must be worn.
Non-uniformed Associates - Shoes for non-uniformed associates are to be in good business taste, professional and classic
in style. Shoes may be closed toe and closed back, or closed toe with a sling back. Shoes with a small peep-toe and
closed back are permitted only in summer months. Sandals, boots, thongs, tennis shoes, moccasins, or any other similar
footwear including "mules" with a complete open back are not acceptable. Shoes must be kept in good repair and be
polished at all times. Safety and comfort should be a consideration when selecting shoes.
Attire
Uniformed Associates — Uniformed associates will be fitted for his/her uniform and will be provided for use while on shift.
Associates are to be aware that uniforms are property of the hotel and must only be used for business purposes.
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Associates are to ensure that uniforms are never lent to anyone nor left unattended. Any discrepancies in uniforms
should be immediately communicated to Department Heads and Uniform Room Attendants for assistance. Uniformed
associates should wear white/black t-shirts with no colors or markings under their uniforms. T-shirts may be crew cut or V-
neck depending on uniform style.
Non-uniformed Associates
Non-uniformed Associates are expected to dress appropriately and professionally for their job position. Associates will be
provided further guidance at the local hotel level. We support individuality and self-expression but also are in a
customer facing business. Please use good judgment with your work attire and grooming.
Our network of hotels has many different locations, brands and services. Because of this, individual departments and/or
locations may have different appearance standards and uniform guidelines or requirements. Your supervisor will advise
you of the standards, including nametags, established for your department and location.
Management will discuss exceptions to the dress code policy as a reasonable accommodation for sincerely held
religious beliefs. Any associate that believes that this appearance policy interferes with a sincerely held religious belief
should contact Human Resources.
Non-Solicitation/Distribution
In order to maintain and promote efficient operations, Highgate Hotels has established rules, which govern both
solicitation and the distribution of written or printed material. Failure to obey these rules may result in corrective action,
up to and including immediate termination. Any associate who is in doubt concerning the application of these rules
should consult with his/her Supervisor or the Human Resources department.
• No associate shall solicit support for any cause or organization during his/her working time or during the working
time of the associate or associates to whom such solicitation activity is directed.
• No associate shall distribute or circulate any written or printed material during his/her working time or during the
working time of the associate or associates to whom such activity is directed in non-work areas, or in work areas
at any time.
• Non-associates may not solicit or distribute any written or printed material on Company property at any time.
Working time is the time an associate is expected to be performing job duties and does not include meal times or break
periods. These rules are established for the purpose of preventing interference with work duties and apply to associates
engaged in the solicitation or distribution as well as to associates being solicited or receiving distributions.
These rules do not apply to activities that are part of an associate’s regular job duties or that are necessary to carry out
such job duties. These rules do not apply to Company-authorized charitable solicitations such as the annual United Way
and blood drives. No merchandise, other than approved by Highgate Hotels, may be sold on Company premises.
Drug-Free Workplace
Highgate Hotels is committed to encouraging optimum productivity and protecting its associates from accident, injury,
and property damage, including incidents that may result because an individual’s faculties are impaired from the use of
alcohol, drugs, or any controlled substance, legal or illegal. Highgate Hotels has, therefore, adopted the following
policies:
• All associates are prohibited from being under the influence of alcohol, illegal drugs, or legal drugs which are
unlawfully obtained or used, when reporting for work, during working hours, while conducting Company business
or on Company property (defined as: buildings, facilities, parking areas, and/or vehicles owned, operated, or
leased by the Company and/or all places where the Company conducts business).
• The use, sale, transfer, possession, manufacture, or dispensing of any illegal drugs or alcoholic beverages on
Company property or anywhere while conducting Company business or activities is strictly prohibited.
• The Company recognizes that marijuana is legal for medical and/or recreational use under state law in certain
states where we operate. However, the company prohibits the use, possession, sale, transfer, or storage of any
illegal drugs or controlled substances as defined by federal law. Therefore, positive drug tests showing the
presence of marijuana in an associate’s system will be a violation of this policy and may result in disciplinary
action up to and including termination of employment. The Company will consider accommodations for
associates that may be taking marijuana for medical purposes if such use does not impact the ability of the
associate to safely perform the essential functions of the job and as directed by applicable law.
• The use or possession of prescription drugs which have been illegally obtained, or are intended for another
person, or are used in a manner, combination, or quantity other than as prescribed by a licensed
medical/dental practitioner, or the abuse or misuse of over-the-counter drugs is strictly prohibited.
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• Any associate who is taking medication that may affect his/her ability to work safely must notify the appropriate
Human Resources representative. Associates who suffer the effects of substance abuse are encouraged to seek
assistance before engaging in conduct, which would be a violation of Company policy. Please refer to the
additional Drug Free Work Place document outlining this policy in detail, which can be found in your new hire
paperwork.
Violation of this policy will subject an associate to disciplinary action, up to and including immediate termination.
Discipline may be based not only on a violation of this policy, but also on prior poor performance, workplace
misconduct, or other rule violations as determined by the Company.
Use of Communications Devices

All Company communications services and equipment, including the messages transmitted or stored by them, are the
sole property of the Company. Associates have no expectation of privacy when using Company communication
devices or the Company’s electronic communication systems.
• The Company will access and monitor associate communications and files as it considers appropriate.
Communications equipment and services include – but are not limited to - mail, electronic mail, courier services,
facsimiles, telephone systems, computer networks, internet, on-line services computer files, video equipment,
pagers, two-way radios, cellular phones, and bulletin boards (herein referred to as “Communication Devices”).
• Personal cell phones, laptops, smartphones or other similar communication devices should be used with
discretion during work hours and should be stored in lockers or other secured areas. When on break, associates
are allowed to use these items in break rooms and designated smoking areas only.
• Company communications services and equipment for personal purposes should be limited and reserved for
emergencies or when extenuating circumstances warrant it. The associate pay phones should be used for all
personal telephone calls.
• To maintain the security of our premises and the confidentiality of our trade secrets, processes and customers’
information, associates are prohibited from using communication devices that have the capability of taking
photographs during working time or in work areas.
• Hotel and public phones are restricted to business and guest use only.
• Communication Devices that have the capacity to take a photograph or video must not be used in guest
rooms or in the presence of guests and such functions may only be used on Company property in accordance
with applicable law.
• Incoming personal telephone calls should not occur while you are on duty. Please ask family members and
friends not to phone while you are on duty unless it is an extreme emergency. Emergency calls will be directed
to your Human Resources representative.
• Company communications property or equipment may not be removed from the premises without written authorization
from the associate’s Supervisor.
• You should exercise care so that no personal correspondence appears to be an official communication of the
Company. You may not use the Company stationery for personal letters. If you must use the Company’s address
for receiving personal mail, you must have permission from your applicable Senior Leader.
• You are prohibited from making your own audio recordings of any work place conferences, meetings or
discussions.
• Associates should have no expectation of privacy in using Company network, communications services and/or
equipment.
• Improper use of Company Communication Devices or unauthorized use of personal communication or
recording equipment may result in disciplinary action up to and including termination.
Use of Personal Electronic Devices

Personal electronic devices such as mobile telephones, e-readers, or tablets may not be used while working unless
required for business purposes. In order to encourage open communication, free exchange of ideas, spontaneous and
honest dialogue and an atmosphere of trust, the Company has adopted the following policy concerning audio and/or
video recording in the workplace. It is a violation of the Company’s policy to record conversations, phone calls, or
company meetings, or to take any pictures of the Company’s proprietary information or processes, with any recording
device (including but not limited to a cellular telephone, smart phone, PDA, digital recording device, camera, digital
camera, video recorder, etc.), unless the photograph or recording is designed to document a safety hazard, to
document claims that the Company’s rules have been inconsistently applied, to memorialize protected concerted
activity which may, for example, include discussions concerning terms and conditions of employment, to record
evidence to be presented in administrative or judicial forums in employment-related matters, or for other similar
purposes that are protected by applicable law. A violation of this policy may result in corrective action, up to and
including termination of employment.
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Please note that the Company has security or surveillance cameras operating in areas throughout the Company’s
facility, including areas where Company meetings or conversations may occur. The purpose of such security devices or
surveillance cameras is not to record conversations but, rather, is to protect legitimate trade secrets such as proprietary
processes and products, to discourage theft and/or robbery, or to aid in the investigation of such allegations.
Use of Cell Phones/Other Electronic Devices While Driving

This policy provides standards for safe use of cell phones and other electronic communication devices (blackberries,
and other handheld devices) by associates when operating Company vehicles, leased or rented vehicles, or personal
vehicles while conducting Company business. Associates must adhere to all federal, state, and local rules and
regulations regarding the use of cell phones and other handheld electronic devises when driving on Company time, for
Company purposes, and/or within a Company vehicle. Associates must not use cell phones or other handheld
electronic devises if such conduct is prohibited by state or local law. Please check with the Human Resource
Department if you are unsure as to whether cell phones or other handheld electronic devices may be used in your
particular state.
Associates should not use handheld cell phones or other handheld electronic devices for any purpose when driving on
Company time for Company purposes and/or within a Company vehicle. If an associate needs to make or receive a
call while driving, the associate should make or receive the call only after parking in a lawfully designated area. If an
associate has a hands-free device that allows the associate to talk on a cell phone or other electronic device, the
associate may make and receive calls using the hands-free device, but such calls should be limited to five minutes or
less. Associates are strictly prohibited from texting, e-mailing, surfing the internet, or otherwise using any other electronic
communication device while driving on Company time, for Company purposes, and/or within a Company vehicle.
Associates are further prohibited from taking notes or writing when talking on a cell phone while operating a Company
vehicle or private vehicle while conducting Company business.
Business Ethics and Associate Integrity

Highgate Hotels is committed to conducting business in accordance with the highest moral, ethical and legal standards
and expects associates to strictly observe all laws and regulations applicable to the Company’s business. The Company
assumes the responsibility to operate at all times in a manner which conforms to both the letter and spirit of all local laws
and regulations, to conduct all activities openly and to deal with the government and other local institutions in a
cooperative and forthright manner. Obeying the law is a minimum requirement. Ethical business conduct should
normally exist at a level well above the minimum required by law and Company policy. If you have a business ethics
and/or associate integrity concern, you may contact the Confidential Highgate Ethics Hotline at
reportlineweb.com/HighgateHotels (for more information please see the Ethics flyer posted in your work location or
contact your HR Department.)
Smoking
We are dedicated to providing and promoting a healthy, comfortable, productive work environment for our associates.
Smoking is prohibited in work areas, public areas and restrooms. This prohibition includes electronic cigarettes and
smokeless tobacco. Associates who wish to smoke may do so during normal authorized breaks and in authorized non-
guest smoking areas only. Please note that associates who smoke are not granted additional smoking breaks.
Applicable State regulations are strictly enforced.
Concealed Weapons Policy

Associate s of the Company are not permitted to carry (either openly or in a concealed manner) any firearms while on
the Company’s premises or property, while at client work locations on Company business, while in Company vehicles, or
while acting as a Company representative at any work-related activities, meetings, or functions. This prohibition against
the possession or carrying of firearms applies even if the associate is licensed to carry a handgun by applicable state law
or regulation. Associate s licensed to carry a handgun, or who otherwise lawfully possesses a firearm, are permitted to
transport and store in a safe and discrete manner a lawfully possessed firearm and/or ammunition in his or her locked,
privately-owned vehicle while the vehicle is in the Company parking lot, garage, or other parking area provided by the
Company for associates. This policy is intended to comply with all applicable state laws concerning associate rights to
possess and carry firearms and shall be interpreted and enforced accordingly.
Any associate who carries a firearm onto the Company’s premises will be considered to be committing a trespass and
the proper authorities may be notified. Any violation of this policy may lead to discipline up to and including
termination.
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Social Media
At Highgate Hotels, we understand that social media can be a fun and rewarding way to share your life and opinions
with family, friends and co-workers around the world. However, use of social media also presents certain risks and carries
with it certain responsibilities. To assist you in making responsible decisions about your use of social media, we have
established these guidelines for appropriate use of social media.
This policy applies to all associates who work for Highgate Hotels, in the United States.
Guidelines
In the rapidly expanding world of electronic communication, social media can mean many things. Social media
includes all means of communicating or posting information or content of any sort on the Internet, including to your own
or someone else’s web log or blog, journal or diary, personal web site, social networking or affinity web site, web bulletin
board or a chat room, whether or not associated or affiliated with Highgate Hotels, as well as any other form of
electronic communication. The same principles and guidelines found in Highgate Hotels’ policies apply to your activities
online. Ultimately, you are solely responsible for what you post online. Before creating online content, consider some of
the risks and rewards that are involved. Keep in mind that any of your conduct that adversely affects your job
performance, the performance of fellow associates or otherwise adversely affects customers, suppliers, people who work
on behalf of Highgate Hotels or Highgate Hotels’ legitimate business interests may result in disciplinary action, up to and
including termination.
Know and follow the rules

Carefully read these guidelines, the Standards of Conduct, the Highgate Hotels Harassment and Retaliation Policy, and
ensure your postings are consistent with these policies. Inappropriate postings that may include discriminatory remarks,
harassment, and threats of violence or similar inappropriate or unlawful conduct will not be tolerated and may subject
you to disciplinary action, up to and including termination.
Be respectful
Always be respectful to fellow associates, customers, members, suppliers or people who work on behalf of Highgate
Hotels. Also, keep in mind that you are more likely to resolve work-related complaints by speaking directly with your co-
workers or by utilizing our Open-Door Policy than by posting complaints to a social media outlet. Nevertheless, if you
decide to post complaints or criticism, avoid using statements, photographs, video or audio that reasonably could be
viewed as malicious, obscene, threatening or intimidating, that disparage customers, members, associates or suppliers,
or that might constitute harassment or bullying. Examples of such conduct might include offensive posts meant to
intentionally harm someone’s reputation or posts that could contribute to a hostile work environment on the basis of
race, sex, disability, religion or any other status protected by law or Company policy.
Post only appropriate and respectful content

• Maintain the confidentiality of Highgate Hotels’ trade secrets and private or confidential information. Trades
secrets may include information regarding the development of systems, processes, products, know-how and
technology. Do not post internal reports, policies, procedures or other internal business-related confidential
communications
• Respect financial disclosure laws. It is illegal to communicate or give a “tip” on inside information to others so
that they may buy or sell stocks or securities.
• Do not create a link from your blog, website or other social networking site (such as Linkedin) to a Highgate
Hotels website
• Express only your personal opinions. Never represent yourself as a spokesperson for Highgate Hotels. If Highgate
Hotels is a subject of the content you are creating, be clear and open about the fact that you are an
associate and make it clear that your views do not represent those of Highgate Hotels, fellow associates,
members, customers, suppliers or people working on behalf of Highgate Hotels. If you do publish a blog or post
online related to the work you do or subjects associated with Highgate Hotels, make it clear that you are not
speaking on behalf of Highgate Hotels. It is best to include a disclaimer such as “The postings on this site are my
own and do not necessarily reflect the views of Highgate Hotels”
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Using social media at work
Refrain from using social media while on work time or on equipment we provide, unless it is work-related as authorized by
your manager or consistent with the Company Property Policy. Do not use Highgate Hotels email addresses to register on
social networks, blogs or other online tools utilized for personal use.
Retaliation is prohibited
Highgate Hotels prohibits taking negative action against any associate for reporting a possible deviation from this policy
or for cooperating in an investigation. Any associate who retaliates against another associate for reporting a possible
deviation from this policy or for cooperating in an investigation will be subject to disciplinary action, up to and including
termination.
Media contacts
Associates should not speak to the media on Highgate Hotels’ behalf without contacting Highgate Hotels’ Legal
Department and Marketing Department as identified in the Crisis Management Guidelines or SOP. All media inquiries
should be directed to the General Manager or Managing Director.
For more information

If you have questions or need further guidance, please contact Human Resources.
Attendance
Dependable associates are an integral component to successful business operations. All associates are expected to
know and adhere to their posted work schedule. If, due to an emergency, you cannot arrive to work on the scheduled
day/time, you must call your Supervisor, department manager or the Manager on Duty (MOD) to explain your absence
at least two hours in advance of the time you are scheduled to report to work.
Your work schedule will be posted when the business for the upcoming week can be forecasted. We do reserve the
right to alter your schedule based on business demands. Absences, tardiness, late returns from breaks and lunch during
the day, and early leaves at the end of the shift will be considered unacceptable deviations from the work schedule.
Consistent attendance and punctuality ensures a consistent product and service to our guests. When you are absent,
late, leave early or are a no call/no show, the service to our guest is negatively impacted.
Hand-punch, time sheets, biometric time clocks, and/or electrical attendance systems are used to insure the correct
accounting of hours worked. You will be required to record your own working time, which will then be verified by your
manager. You must always do this. If you fail to record your starting or concluding work time or there is an error, be sure
to notify your Supervisor immediately. Associates are prohibited from working “off-the-clock.” Associates must
accurately record all time worked.
Falsifying your attendance is strictly prohibited and will subject the violator to immediate dismissal. You should not clock
in or out more than 10 minutes before or after your shift. You will not be paid for any extra time that you are not
authorized to work. All overtime must be authorized in advance by your department head. You are required to punch in
and out for your lunch break.
If you should be unable to report to work or will be delayed in arriving, you must personally telephone your Supervisor at
least two (2) hours in advance of your shift and notify him/her that you will be delayed. Give the reason and some
indication as to the length of time that you will be out. Your manager will provide you with the department telephone
number for your convenience for use in emergencies. Unexplained and/or excessive absenteeism or lateness can lead
to disciplinary action up to and including dismissal. Please remember to leave a phone number where your manager
can contact you.
If you are out sick for three or more consecutive shifts, you must bring a doctor’s note to the department head in order to
return to work. This note is to confirm that you are able to return to work without restrictions.
Poor attendance, excessive tardiness, and excessive early departures are disruptive to productivity and negatively
impact customer service. Poor attendance and tardy violations may lead to disciplinary action, up to and including
termination.
If you are absent for three consecutive workdays without calling in and speaking with your supervisor, you will be
considered a “no-call/no-show” and will be deemed to have voluntarily quit employment, absent extenuating
circumstances.
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Your department manager will explain the pay period. You will learn how you will receive your paycheck and the various
deductions required by law and/or under the Union contract.
Performance Management
Highgate Hotels maintains the belief that proper standards of conduct, performance, and attendance are crucial to the
welfare of our Company, our guests, and our associates. Management reserves the right to take any form of disciplinary
action at any time. While the circumstances of a particular case may result in termination for a first offense, other cases
may result in other forms of disciplinary action. The type of disciplinary action that may be imposed may range from
verbal warning to written warning to suspension and/or termination of employment. Nothing in this playbook creates an
obligation to follow any particular disciplinary procedure. Management retains the right and absolute discretion to
discipline associates based on the facts of each case. Management may skip certain disciplinary steps and/or repeat
certain disciplinary steps, depending on the particular facts of each situation.
Highgate Hotels Standards of Conduct

It is the policy of Highgate Hotels to expect all associates to abide by certain work rules in general conduct and
performance at all times. Managers are expected to monitor and enforce these work rules on a consistent basis.
Associates are subject to disciplinary action for any of the offenses listed below and for failing to perform their job duties
in a satisfactory manner. Associates subject to a Collective Bargaining Agreement may have specific disciplinary
actions set forth for violating one or more of the standards of conduct set forth below.
1) I understand that the first priority of business is to give our guests consistent, attentive, courteous and efficient
customer service.
2) I have been shown the designated associate entrance and parking area and agree to use only that entrance
and parking area.
3) I agree not to enter the Hotel earlier than 15 minutes before my scheduled shift and to leave the property
within 15 minutes after the end of my shift. I agree only to clock in and out for myself and never for another
associate.
4) I understand that all personal effects (i.e., purses, duffel bags, etc.) may be subject to a random security check
in accordance with applicable state law.
5) If I have been assigned a locker, I understand that this benefit is provided to me to store my personal
belongings. I will not place valuable belongings in the locker or desk (if assigned), as I understand that the hotel
cannot accept responsibility for loss of or damage to such items. Perishable items should not be stored in
lockers or desks for prolonged periods.
6) I understand there may be periodic, unannounced inspections of lockers and its contents by management,
security personnel or associate delegate representation.
7) Subject to the terms of any CBA applicable to my employment, I understand that my schedule may be posted
as soon as the business for the upcoming week can be forecasted and that my attendance is mandatory on
those days scheduled.
8) I also understand that if, due to an emergency, I cannot arrive at work on the scheduled day/time, I will call my
Supervisor, department manager or the Manager on Duty to explain my absence at least two hours in
advance of the time I am scheduled to report to work. I will work according to my schedule and will not work
overtime unless authorized by my manager.
9) I understand that books, newspapers, or other non-Company sponsored publications are not to be read in any
location in view of the public while on duty.
10) I understand that my uniform must be maintained in proper condition and a nametag will be worn at all times
so as to present a professional appearance.
11) I will not take time off during regularly scheduled work hours without authorization from my department head.
12) I will work in a safe manner and comply with fire department regulations, safety and civil defense regulations
and hotel safety rules.
13) I agree to perform the duties of my job in the prescribed safe manner and to immediately report all job-related
injuries to my Supervisor.
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14) I will adhere to local/city mandated smoking ordinances. If permitted, I will smoke only in designated
associate smoking areas.
15) While on duty, or in public contact areas, I will not wear insignia, badges, buttons, or similar items unless
authorized by management or permissible by NLRA.
16) I am expected to familiarize myself regularly with these guidelines and with other publications and bulletins as
required by management.
17) I agree not to violate the Company’s non-solicitation policy.
18) I agree not to disrupt other associates during my work time or during their work time.
19) I will not falsify Company documents and/or records, including time records.
I UNDERSTAND THAT I MAY BE IMMEDIATELY DISCHARGED IF I COMMIT ANY OF THE FOLLOWING ACTS:
• Use, possession, sale, transfer, or storage of an illicit drug or drug paraphernalia by an associate while in the
course of employment, on Company property or in Company vehicles. Further, an associate is strictly prohibited
from reporting for work or working under the influence of a drug or alcohol, or in an impaired condition.
• Unauthorized possession or consumption of alcohol by an associate while in the course of employment, on hotel
property or in Company vehicles. This does not apply to authorized business activities such as a manager
entertaining clients or at Company-sponsored social functions with the approval of the applicable Senior
Leader.
• Attempted or actual theft, embezzlement and/or pilferage (unauthorized removal, storage, transfer, utilization)
of Company, guest or associate property. This includes failure to report lost articles, which are found on the
premises.
• Willful destruction, gross negligence or carelessness regarding Company property, associates’ property or guests’ property.
• Gambling, or participating in gambling as a spectator during work hours or on Company property.
• Any language or conduct which has the purpose of threatening or intimidating fellow associates or guests, or
causes fellow associates or guests to have concern about personal and/or physical safety. Using offensive or
threatening language such as swearing or other inappropriate language in the presence of guests, or provoking
a fight on Company or Hotel time.
• Hitting, pushing, or otherwise striking another person or possessing a dangerous weapon while on Company
premises.
• Willful falsification of Company records including, but not limited to, employment applications, payroll
documents, time cards, financial reports, etc.
• Failure to report to work for three consecutive scheduled shifts/days is considered a voluntary resignation,
without proper notification to immediate Supervisor or Human Resources
• Insubordination.
• Failure to remain in work area during working time, unless authorized by management.
• Unauthorized use of guest rooms or guest facilities. Unauthorized presence at guest functions or in guest areas,
including, but not limited to, guest rooms, restaurants, bars, lounges or meeting rooms. Associates may not
actually socialize with, date, or meet with guests, associates or visitors, unless part of a bona fide job
responsibility.
• Unauthorized acquisition, distribution or disclosure of Company Confidential Information, as defined herein.
• Sleeping or malingering during scheduled workday.
• Unlawful, immoral conduct or behavior otherwise deemed unbecoming a Highgate Hotels associate.
• Failure to provide attentive, courteous and efficient guest service or failure to satisfactorily perform work or job
assignments.
• Failure to comply with Highgate Hotels’ Policy on Non-Harassment and Non-Retaliation in the workplace.
• Failure to maintain accurate and proper accountability and control of cash banks or related Company cash.
Excessive or continuous cash shortages or other irregularities are unacceptable.
• Failure to report accidents, breakage or damage to equipment and machinery, which occurs when you are
assigned to drive or use equipment and machines. Giving false information when accidents are being
investigated, receiving traffic violations when operating Company vehicles or driving a Company vehicle
without a valid license.
• Failure to comply with Company or Hotel policies and/or directives, including, without limitation, the policies and
procedures outlined in the Associate Playbook.
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These rules and policies are not all-inclusive, but indicate the type of policies and rules, which apply to your employment
at Highgate Hotels. Violation of these and other established work or safety rules may result in possible disciplinary actions
including counseling, formal warnings, suspension, probation, and immediate discharge. The specific action taken will
depend on the nature of the offense, the circumstances and your previous employment record. Nothing in this
playbook creates an obligation to follow any particular disciplinary procedure. Management retains the absolute
discretion to discipline associates on a case by case basis unless otherwise set forth in a Collective Bargaining
Agreement.
Biometric Information Policy

This Biometric Information Policy (“Policy”) summarizes the policies and procedures for Highgate Hotels, L.P. its parent or affiliated
companies, vendors and customers (collectively, “Highgate”) follow for the collection, use, safeguarding, storage, retention and
destruction of biometric data. Highgate does not concede that any data it collects is biometric data subject to state enacted
biometric information legislation, but Highgate is committed to protecting the collection, use and storage of all personnel data it
requires for employment in accordance with all applicable laws. This Policy is intended to comply with laws currently in effect in the
States of Illinois, Texas and Washington. It applies to all employees who are required to use devices that collect or may collect
biometric data (such as for time-keeping or security access) covered by this Policy. This Policy may be amended from time to time
to comply with laws in the aforementioned states or with laws enacted in other states.
Highgate’s policy and procedure is as follows:
Definition of Biometric Data

As used in this policy, biometric data includes but is not limited to “biometric identifiers” and “biometric information” as defined in
the Illinois Biometric Information Privacy Act, 740 ILCS 14/1, et seq. To the extent that other state laws include definitions different
from those set forth herein, those definitions shall govern in those states. Under the Illinois statute, “biometric identifier” means a
retina or iris scan, fingerprint, voiceprint, or scans of hand or face geometry. Biometric identifiers do not include writing samples,
written signatures, photographs, human biological samples used for valid scientific testing or screening, demographic data, tattoo
descriptions, or physical descriptions such as height, weight, hair color, or eye color.
“Biometric Information” means any information, regardless of how captured, converted, stored or shared, based on an individual’s
biometric identifier used to identify an individual. Biometric Information does not include information derived from items or
procedures excluded under the definition of biometric identifiers.
Highgate’s Collection of Biometric Data

Highgate, in some instances may collect, store and use biometric data for purposes of identifying employees for payroll, security,
access or other purposes. The biometric devices measure and collect unique data points and create unique mathematical
representations to verify the employee’s identity. Highgate collects, stores and uses this data solely for employee identification,
security, and fraud prevention.
Currently, Highgate uses devices and software provided by a third-party vendor. These devices use a secure technology that
generates the mathematical representation described above. Highgate securely stores these mathematical representations on
Highgate controlled site or server or secure space made available to Highgate by a third party vendor in a cloud environment.
Disclosure
To the extent that Highgate or any of its vendors and/or the licensors of the devices or software Highgate uses, or may decide to use
in the future, to collect, capture or otherwise obtain biometric data regarding its employees, Highgate:
(a) Will inform the employee about the collection, storage, and use of such biometric data;
(b) Will inform the employee of the specific purpose and length of time for which the biometric data is being collected,
stored and used;
(c) Will secure a written authorization/consent from the employee (or the employee’s legally authorized representative)
allowing Highgate or any vendors and/or the licensors of the devises or software Highgate uses, or may decide to
use in the future, to collect, store and use employee’s biometric data for the specific purposes disclosed by
Highgate. This authorization will allow Highgate to provide such information to vendors and/or the licensor of the
devices or software used as needed to comply with all legal requirements.
(d) Will not disclose, re-disclose, or otherwise disseminate an employee’s biometric data unless:
1. The employee or the employee’s legally authorized representative consents to such disclosure or re-
disclosure;
2. The disclosure or re-disclosure completes a financial transaction requested or authorized by the employee
or the employee’s legally authorized representative;
3. The disclosure or re-disclosure is required by state or federal law or municipal ordinance; or
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4. The disclosure is required pursuant to a valid warrant or subpoena issued by a court or agency of
competent jurisdiction.
Retention Schedule
Highgate is responsible for the destruction of data once retention of the data is no longer required. Highgate will retain employee
biometric data until:
(a) The initial purpose for collecting or obtaining such biometric data has been satisfied such as the end of the
employee’s employment with Highgate or the transfer of the employee into a job or role with Highgate for which
the biometric data is not used; OR
(b) The applicable statutory time-period governing retention following the employee’s last interaction with Highgate as
an employee in a classification where such data is required.
Data Storage, Transmission, and Protection

Highgate will store, transmit and protect biometric data using a reasonable standard of care. Such storage, transmission, and
protection from disclosure will be performed in a manner that is the same as or more protective than the manner in which Highgate
stores, transmits, and protects from disclosure other confidential and sensitive information of Highgate and its employees.
Highgate vendors and other contractors have publicly represented that they do not sell, lease, trade or profit from the use,
collection or storage of this data, and that they use reasonable standards of care to protect any biometric information provided to
them. You may these vendor policies on the vendor’s website.
Policy Enforcement
All employees are required to abide by this Policy as a condition of employment. Refusal to comply and provide the required
consent to use biometric information will result in termination. Highgate’s Human Resources Department is responsible for the
enforcement and administration of this Policy. If you have any questions about the Policy, please contact Human Resources.
SAFETY AND ACCIDENTS
Safety and Accidents

If you see an unsafe condition in your work environment, be sure to report it to your Supervisor or manager so it can be
attended to as soon as possible. We need everyone’s participation to create a safe work environment for all associates.
If you have an on-the-job accident, regardless of the simplicity, report it at once to your Supervisor so it can be reported
and, if necessary, you can receive proper care. An accident report must be completed on all accidents. Associates will
not be retaliated against for reporting an on-the-job injury. Highgate Hotels complies with OSHA’s non-retaliation
provisions.
Because even minor accidents could be an indication of unsafe conditions or practices that could result in a more
serious injury, it is important to communicate all incidents of accidents or unsafe conditions to your Supervisor. If outside
medical treatment is necessary, an authorization form must be obtained from your Human Resources representative prior
to receiving treatment. It is your responsibility to keep your Human Resources representative advised of your doctor’s
orders when missing work as a result of an accident. We want you back on the job as soon as possible!
Depending upon your location, if you should suffer a qualifying, work-related injury or disease, you may receive benefits
through the Company’s Worker’s Compensation benefits. These benefits may include payment for medical expenses
and weekly compensation payments. If you are hurt on the job, notify your Supervisor and Human Resources
representative immediately, regardless of the severity of the injury. Knowingly making false claims is a serious act of
misconduct subject to corrective action, including termination. For more information regarding workers’ compensation
rights, please see a member of the Human Resources Department.
Hazardous Material Handling

Before you handle any cleaning agents or other potentially hazardous chemicals, you must review the Material Safety
Data Sheets (MSDS) on the products and also be trained in the use of the products. The Hazardous Materials Manual,
outlining the proper handling procedures, is available to all associates through the Engineering Department.
Workplace Violence
Highgate Hotels strives to maintain a work environment free from intimidation, coercion, threats or violent acts. If any
individual commits a violent act or threatens violence against another associate or guest, Highgate Hotels will respond
quickly and in a manner intended to maximize the safety of all parties involved. Law enforcement authorities will be
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notified, if necessary. Highgate Hotels has a zero tolerance policy for workplace violence and is committed to providing
its associates and guests with safe properties. All associates are asked to remain vigilant regarding your surrounding and
to report any suspicious activity or potentially violent situation. Associates should notify their manager or Human
Resources if an associate has reason to believe that any personal relationships or events occurring outside of work could
result in a potentially incident of workplace violence. At all times, associates should avoid violent situations and take
their own safety into consideration.
Highgate Hotels prohibits acts of violence of threats of violent behavior including, but not limited to:
• Physical violence, threats of physical violence, or harassment towards associates or guests

• Any verbal, written or physical acts of intimidation, threats, or retaliation
• Threats of violence
• Any damage or threat of damage to any associate, guest, or Company property
• Any threats of physical harm or any actual physical harm
• Any threats of psychological or emotional harm or any actual psychological or emotional harm
• Bringing or threatening to bring weapons of any kind into the workplace
This prohibition against threats and acts of violence applies to all individuals whether at the corporate office, or at any of
our hotels, including but not limited to, associates, contractor or temporary workers, and anyone else on hotel property.
If you are aware of an act or threat of physical violence, it is your responsibility to report to your supervisor, manager or
the Human Resources department and/or Executive Offices. If the situation warrants, call the local police department or
dial 911. Associates should always put their personal safety first. If an act of violence ensues, please contact your
supervisor or manager right away. Do not attempt to intervene in a violent or potentially violent situation if you feel the
situation may put you in personal harm. Associate and guest’s safety are of upmost importance to Highgate Hotels.
No associate will be retaliated against for reporting any conduct that an associate reasonable believes to be in violation
of this policy. We need to cooperation and participation of all associates to create and maintain a safe working
environment for everyone.
HEALTH AND WELFARE BENEFITS

This playbook is not an official plan document for any associate benefit plan and is not intended to provide specific
information with regard to the benefits described below. It is also not a guarantee of any benefit described below. If
there is any conflict between the official plan documents and the associate playbook, the official plan documents will
control.
Health and Welfare

Associates who are party to a Collective Bargaining Agreement may not be covered by all outlined benefit options.
Benefit information for union associates can be located in the applicable Collective Bargaining Agreement.
Aside from offering associates an enjoyable work environment, Highgate Hotels also provides a comprehensive and well-
designed benefits program for associates and their families. The type of benefits associates are eligible for is based on
their specific classification referenced below. Full-time associates are eligible for benefits, which may include Medical,
Dental, Vision, Life Insurance, Accidental Death & Dismemberment Insurance, Short Term Disability, Long Term Disability,
Retirement Savings, Vacation, Personal time and many more. For detailed information about Highgate Hotels’ benefits
offerings, you may refer to the Benefits Guide. All benefits are at the sole discretion of Highgate Hotels and may be
altered or discontinued at any time. Should you have questions about your benefits, feel free to ask your Human
Resources representative or consult the applicable Summary Plan Description.
Associate Assistance Program

All associates may use the Associate Assistance Program (EAP) immediately upon hire. This program provides
confidential resources to enable you to work through personal or family distress that you or a dependent living in your
home with you may be experiencing. Associates are encouraged to utilize this program when problems of a personal
nature exist. Voluntary self-referral to the EAP will not insulate an associate for violation of the Company’s policies and
procedures, including the Drug Free Workplace policy. Contact your Human Resources Representative for more
information on plan specifics.
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Savings and Retirement Plan
Highgate Hotels Hotel Management Associate Savings Plan allows you to contribute a percentage of your earnings into
a 401(k) Plan on a pre-tax basis. Highgate Hotels may match part of your contributions. You decide how your account is
invested between the multiple funds offered under this plan. Contact Human Resources for more details.
Vacation Time
Vacation time is considered a retreat from your duties at Highgate Hotels. We encourage you to use it as a period of rest
and relaxation. Earned vacation time must be taken within 12 months following the previous anniversary date or it will be
forfeited unless prohibited by applicable state law. Payment for vacation time in lieu of actual time off is not available
for active associates. In the event that staffing requirements or other business reasons prevent an associate from taking
vacation time within this 12-month period, the associate must submit a written request for an extension of time to use the
vacation benefit and obtain approval from the Chief Executive Officer or Chief People Officer.
Vacation time may only be taken in full-day increments.
The number of vacation days that a full-time associate is entitled to receive each year is determined by the associate’s
length of service at his/her anniversary date and hours actually worked the preceding year. Vacation time not used
during the appropriate anniversary year, or without an approved extension, will be forfeited (applicable state and local
laws, and/or applicable Collective Bargaining Agreements will supersede). If state or local laws prohibit the forfeiture of
vacation time, associates shall not be allowed to accrue vacation in subsequent years in excess of the applicable
annual vacation accrual cap. For example, if an associate is permitted 10 vacation days in a year, but only uses 2, the
associate cannot accrue more than 2 additional vacation days in the subsequent year. Once the associate reaches
the accrual cap, the associate will accrue additional vacation up to the accrual cap only after using vacation and
dropping below the cap.
The Company wishes to take this opportunity to encourage associates to use available vacation time. This leave is very
important for your health and wellbeing, as well as allowing you time to relax away from the workplace. Please submit
all requests 10 days in advance in writing to your supervisor for approval and be reminded, due to fluctuating needs of
our business, it is encouraged to make vacation plans well in advance. Subject to any collective bargaining
agreement, state and /or local law, associates who do not take advantage of this time will forfeit their accrued but
unused vacation hours or PTO/Sick balances when they separate from the company. All unused vacation time will be
forfeited and will not be paid unless required by applicable state or local vacation laws/ordinances.
For associates working in Nevada, associates can use vacation and/or sick time to comply with the Nevada Mandatory
Paid Leave Law. For more information, please contact Human Resources.
Sick Time
Associates who are party to a Collective Bargaining Agreement are not covered by this policy and shall be paid
personal leave in accordance with the terms of the applicable Collective Bargaining Agreement. Please contact your
supervisor for specific on sick time as this policy may vary by location.
All regular, full-time associates are eligible for paid sick time-off after one full year of employment. Paid sick time off
accrues in the current year for use in the next year. Associates will receive all available sick time on January 1 of each
year based on the number of weeks worked the prior year. All requests are to be submitted to the Supervisor
requesting approval for leave. Any leave not approved will result in no pay for the absence. Sick leave may be taken in
hourly increments. At no time shall sick leave be “advanced”; all requests for payment of sick time are subject to the
amount of time available. Any sick leave time not used at termination is forfeited unless otherwise required by
applicable state law. Associates must exhaust any personal sick leave concurrent with FMLA.
Associates who are in jurisdictions that have paid sick leave laws, the Company will comply with all applicable local paid
sick leave ordinances. Your supervisor will instruct you of the paid sick leave available to you if you are working in a
jurisdiction that provides for mandated paid sick leave. This includes any part-time or seasonal associates working in
paid sick leave jurisdictions. Associates working in paid sick leave jurisdictions will be provided paid sick leave in
accordance with applicable law and will not be eligible for sick time under this policy. Associates will be provided a
written summary of the applicable sick time available to associates from the Property. Depending on applicable state
law, paid sick leave may be used for an associate ’s own health condition, an immediate family member’s health
condition, or because the associate or immediate family member is a victim of domestic violence, sexual assault, or
stalking. Other reasons to use paid sick leave may be set forth under applicable state or local law.
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“Child” shall include, where consistent with any applicable paid sick leave law, an associate’s biological, adopted, and
foster children, stepchildren, legal wards, or children for whom the associate stands “in loco parentis.”
“Eligible family member” shall include, where consistent with any applicable paid sick leave law, an associate’s: (1)
spouse, domestic partner, registered domestic partner, civil union partner, life partner, or designated person of the
associate’s choice, (2) child, (3) parent, (4) grandparent, (5) grandchild, and (6) sibling, including a step-sibling, half-
sibling, and spouses of siblings, step-siblings, and half-siblings, and, (7) in limited jurisdictions, any individual related by
blood or affinity whose close association with the worker is the equivalent of a family relationship.
“Parent” shall include, where consistent with any applicable paid sick leave law, the biological, adopted, and foster
parents or stepparents of an associate or an associate’s spouse, domestic partner, registered domestic partner, civil
union partner, life partner, or designated person of the associate’s choice, or a person who stood “in loco parentis” to
an associate or an associate’s spouse or registered domestic partner.
“Sibling” shall include, where consistent with any applicable paid sick leave law, step-siblings, half-siblings, and spouses
of siblings, step-siblings, and half-siblings.
The Company prohibits discrimination or retaliation against associates because of an associate’s request for, or use of,
any legally-mandated paid sick leave. If you believe that you have been treated unfairly on account of your use of
legally-mandated paid sick leave, or your request for legally-mandated paid sick leave, please report this concern to
Human Resources so it may be reviewed and appropriate corrective action taken.
If you have questions regarding whether you are in a jurisdiction that has mandated paid sick leave, please contact a
Human Resources representative.
Holidays
Highgate Hotels observes a variety of holidays to provide eligible associates with paid time off to observe and enjoy
designated observances. Associates who are party to a Collective Bargaining Agreement are not covered by this policy
and shall instead be paid holiday pay in accordance with the terms of an applicable Collective Bargaining Agreement.
Only regular full-time associates are eligible for holiday pay. Please see your Human Resources Representative for
details.
Holiday Pay
If a holiday falls on a regularly scheduled day off, during vacation or approved personal leave, eligible associates will be
paid for the holiday (based on their current rate of pay) in lieu of the vacation or personal leave. All regular full-time
associates who have completed their 90-day orientation are eligible for Holiday Pay as outlined below:
• Associates who work their regularly scheduled day/shift before and after the holiday will be eligible for eight
hours holiday pay (based on a 40 hour work week) at their current rate of pay.
• Associates regularly scheduled to work over 30 hours but less than 40 hours will receive holiday pay based on the
number of hours typically scheduled on a regular workday, excluding over-time.
• Hourly associates who work the holiday will receive holiday pay in addition to any pay earned on the holiday.
• Holiday pay is not included in total hours worked for the purposes of calculating overtime.
Jury Duty
Highgate Hotels believes it is each associate’s duty to serve when summoned for Jury Duty. Full-time associates, who
have completed their 180-day orientation, are eligible for Jury Duty up to a maximum of 5 days in a 12-month period
without loss of pay as per local law, subject to documentation from the court. Any associate requiring more than 5 days
of jury duty in a 12-month period will be unpaid unless required by applicable state law. Associates serving Jury Duty will
be paid regular wages for each day of Jury Duty that falls on a day they would otherwise have been scheduled to work,
up to a maximum of 5 days in a 12-month period.
Bereavement Leave
Full-time associates are eligible for up to three days off with pay (at regular hourly rate) in the event of a death in their
immediate family occurs in the U.S. If the funeral services are outside the U.S., the associate may have up to five days off
with pay. Associates who are party to a Collective Bargaining Agreement are not covered by this policy and shall be
paid bereavement pay in accordance with the terms of the Collective Bargaining Agreement. Immediate family
members are defined as parents, grandparents, in-laws, step-parents, spouse, domestic partner, child, grandchild,
stepchild, and siblings (brother, sister, brother-in-law, sister-in-law). In this case, additional unpaid time off may be
granted depending on circumstances such as distance, the individual's responsibility for funeral arrangements, and the
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associate's responsibility for taking care of the estate of the deceased. All requests for bereavement leave must be
made by completing a Benefit Request Form and submitting to the supervisor/manager for approval.
Associate Discount Room Nights

As a Highgate Hotels’ associate, you can take advantage of specially discounted rates at all Highgate Hotels locations
around the world. This benefit is designed to provide you with the opportunity to experience our many different brands
and accommodations first-hand. Eligible Highgate Hotels’ associates may be able to purchase discounted rooms –
subject to availability at participating Highgate Hotels. Please contact your applicable Senior Leader or Human
Resources representative for details.
Associate Meals
Associates may be eligible for discounted meals in the associate break room for each full shift they work. Availability and
offerings may vary by location.
Leaves of Absence
Whenever possible, leave is to be requested in advance. Associates must contact Human Resources to request a Leave
of Absence. An associate is not entitled to accrue any additional benefits including vacation and any service
entitlements during any type of Leave of Absence (some exceptions may apply as required by local, state, and/or
federal laws). Associates who are party to a Collective Bargaining Agreement are not covered by this policy and shall
be paid in accordance with the terms of the Collective Bargaining Agreement.
Under rare circumstances, a personal Leave of Absence without pay may be granted to full-time associates who have
been employed one year or more, and approvals will be based on business needs. This is time off for non-medical
reasons and approval rests solely in the business judgment of the Company. Nothing in this policy guarantees an
associate a personal leave of absence. Any leave under this policy is not job protected. A personal leave cannot be
used to extend FMLA leave. Any leave extension of FMLA will be handled as part of the reasonable accommodation
process under the ADA. If approved, you must first use all of your accrued vacation time. You are responsible for the
full premium for health benefits during a personal leave. The maximum length of a personal leave is 30 days. Based on
business needs, your position may be filled in your absence. In such cases, you will be considered for available
positions upon your return to work.
Family and Medical Leave (FMLA)

Under the Family and Medical Leave Act of 1993, as amended (FMLA), associates may be eligible for a period of job-
protected unpaid leave for certain family and medical reasons as described below. An associate is not entitled to
accrue any additional benefits including vacation and any service entitlements during any type of Leave of Absence
(some exceptions may apply as required by local, state, and/or federal laws). This Family Medical Leave Act Policy
("Policy") provides an overview of associates' rights and responsibilities under the FMLA as well as the Company’s own
policies regarding FMLA Leave. The Company has posted notices of the FMLA at all Company facilities. The information
in those posters is incorporated into this policy by reference.
Associates will be required to exhaust any available accrued paid time off upon the commencement of FMLA leave in
accordance with administrative state and local law policies. Using paid time off does not add to the total length of the
leave. Any paid and unpaid leave under this policy will run concurrently. After paid leave has been exhausted, any
period of the associate’s 12 – week FMLA entitlement remaining will be unpaid, excluding any period of the leave during
which the associate receives disability or Workers Compensation benefits (and therefore is not “otherwise unpaid”
leave).
General Eligibility
To be eligible for FMLA Leave under this Policy, an associate must have worked at the Company for at least 12 months
and must have worked at least 1,250 hours during the 12-month period prior to the commencement date of any leave
requested under this Policy. Eligibility will be determined as of the date the leave commences. Associates who work at
a site at which fewer than 50 associates are employed within a 75-mile radius are not eligible for leave under this policy.
When a request for FMLA is made, the company will advise of the associate’s eligibility and the associate’s rights and
responsibilities.
Types and Duration of FMLA Leave

• Basic FMLA Leave and Active Duty Leave
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An associate may be eligible for up to 12 weeks of unpaid leave during a rolling 12-month period (measured backward
from the date an associate uses FMLA leave) for the following reasons:
1. the birth of the associate’s child and to bond with the child; or for placement through
adoption or foster care and to bond with the newly placed child. Such leave must be
concluded no later than 12 months after the birth or placement of the child with the
associate;
2. to care for an immediate family member (spouse, child under 18 years old or a child 18 and
over who is incapable of self-care because of a disability, or parent) with a serious health
condition;
3. because of a serious health condition which renders the associate unable to perform the
functions of his/her job; or
4. because of any qualifying exigency arising out of the fact that an associate's spouse, son (of
any age), daughter (of any age) or parent, who is serving in any branch of the military
(including the National Guard or Reserves), has been deployed or called to active duty in a
foreign country ("Active Duty Leave").
• Military Caregiver Leave
An associate also may be eligible for Military Caregiver Leave to care for a spouse, son (of any age), daughter (of any
age), parent or next of kin who is: 1) a current member of the Armed Forces, including the National Guard or Reserves,
and who is undergoing medical treatment, recuperation, or therapy, is otherwise in outpatient status, or is otherwise
on the temporary disability retired list, for a serious injury or illness, which is incurred in the line of duty (or for a pre-
existing injury or illness which is aggravated in the line of duty) and that renders the service member medically unfit to
perform the duties of his or her office, grade, rank or rating, or 2) a veteran who was a member of any branch of the
Armed Forces, including the National Guard or Reserves, and who is undergoing medical treatment, recuperation, or
therapy, for a serious injury or illness that occurred in the line of duty (or for a pre-existing injury or illness which was
aggravated in the line of duty) at any time within 5 years preceding the treatment, recuperation or therapy. A
covered veteran incurs a serious illness or injury for purposes of this paragraph when one of the following occurs:
a) The injury or illness makes him or her medically unfit to perform the duties of his or her office,
grade, rank or rating.
b) It causes the service member to have a VA Service Disability Rating is at 50% or greater.
c) It is a mental or physical condition substantially impairs their ability to obtain gainful employment
d) The VA enrolls the associate in the Department of Veteran Affairs Program of Comprehensive
Assistance for Family Caregivers.
Eligible associates are entitled to a total of 26 weeks of unpaid Military Caregiver Leave during a single 12-month period.
This single 12-month period begins on the first day an eligible associate takes Military Caregiver Leave (as long as it is
within 5 years of the covered service member’s active duty) and ends 12 months after that date. Military Caregiver
Leave applies on a per-covered service member, per-injury basis, so that an associate may be eligible to take more
than one 26 week period of Military Caregiver Leave, but no more than 26 weeks of leave may be taken during any one
12-month period.
An eligible associate is entitled to a combined total of 26 workweeks of leave for all FMLA qualifying reasons during the
single 12-month period described above. For example, if an associate takes 10 weeks of FMLA leave due to his/her own
serious health condition, the associate may take only 16 weeks of Military Caregiver Leave during that same 12 month
period.
Definitions
• A "serious health condition" as referred to above means an illness, injury, impairment, or physical or
mental condition that involves:
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1. in-patient care (i.e., an overnight stay) in a hospital or other medical care facility (including
any period of incapacity or any subsequent treatment in connection with such in-patient
care);
2. a period of incapacity of more than three (3) consecutive full calendar days, and any
subsequent treatment or period of incapacity relating to the same condition that also
involves (i) treatment two (2) or more times by a health care provider or under the
supervision of a health care provider within 30 days of the start of the incapacity, or (ii)
treatment by a health care provider on at least one (1) occasion within seven (7) days of the
start of the incapacity which results in a regimen of continuing treatment under the
supervision of a health care provider;
3. any period of incapacity or treatment due to pregnancy, or for prenatal care;
4. any period of incapacity or treatment due to a chronic serious health condition requiring
periodic visits of at least twice a year for treatment by a health care provider;
5. a period of incapacity or treatment which is permanent or long-term due to a condition for

which treatment may not be effective, during which the associate (or family member) must
be under the continuing supervision of, but need not be receiving active treatment by, a
health care provider; or
6. any period of absence to receive multiple treatments by a health care provider or under
the supervision of a health care provider, either for restorative surgery after an accident or
other injury, or for a condition that will likely result in a period of incapacity of more than
three (3) consecutive calendar days in the absence of medical intervention or treatment.
• A "qualifying exigency" referenced above under "Active Duty Leave" refers to the following
circumstances:
1. Short-notice deployment: to address issues arising when the notification of a call or order to
active duty is seven (7) days or less;
2. Military events and related activities: to attend official military events or family assistance
programs or briefings;
3. Childcare and school activities: for qualifying childcare and school related reasons for a
child, legal ward or stepchild of a covered military member;
4. Care of the covered military member’s parent if the parent is incapable of self-care;
5. Financial and legal arrangements: to make or update financial or legal affairs to address the
absence of a covered military member;
6. Counseling: to attend counseling provided by someone other than a health care provider
for oneself, for the covered military member, or child, legal ward, or stepchild of the covered
military member;
7. Rest and recuperation: to spend up to fifteen (15) calendar days for each period in which a
covered military member is on a short-term rest leave during a period of deployment; or
8. Post-deployment activities: to attend official ceremonies or programs sponsored by the

military for up to 90 days after a covered military member's active duty terminates or to
address issues arising from the death of a covered military member while on active duty.
When Spouses Work Together

If both spouses are employed by Highgate Hotels and are eligible for leave under this policy, they are eligible for a
combined total of 12 weeks of leave within the applicable 12-month period when the leave is due to the birth or
placement of a child or to care for a parent who has a serious health condition, or a combined total of 26 weeks within
the applicable 12-month period when the leave is due to the birth or placement of a child or to care for a parent who
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has a serious health condition and for Military Caregiver Leave. (However, in no event shall the spouses take more than
a combined total of 12 weeks of leave within the applicable 12-month period for the birth or placement of a child or to
care for a parent who has a serious health condition).
Notice of Need for FMLA Leave

An associate who wants to take FMLA must follow normal call-in policies and notify the person an associate would
normally notify for an absence. Failure to adhere to normal company call-in procedures can result in discipline, as with
any other type of leave.
If FMLA applies or believed to possibly apply, the associate will be required, thereafter, to contact Human Resources to
complete a request for leave. The associate will be required to fill out prescribed forms requesting leave.
To avoid a delay in FMLA protection, the associate must give notice as soon as possible and practicable under the
circumstances of enough facts to advise the person receiving the call that FMLA may apply. Associates are always
required to give notice as soon as practicable and possible, but, except for instances of active duty leave, an associate
is not required to provide more than thirty (30) days advance notice.
If an associate fails to give the required notice with no reasonable excuse, FMLA coverage may be delayed for a period
of time. This can result in discipline for absences taken prior to FMLA coverage commencing.
Associates should make every reasonable effort to schedule foreseeable medical treatments so as not to disrupt the
ongoing operations of the Company.
Substitution of Paid Leave for Unpaid FMLA Leave

Associates must concurrently exhaust any short-term disability benefits, workers compensation benefits, accrued
vacation time, personal days, or any other form of applicable paid leave for FMLA leave. All substituted paid leave that
is being concurrently exhausted will be counted against an eligible associate's FMLA leave entitlement.
Intermittent FMLA Leave

Intermittent or reduced schedule leave is leave at varying times for the same qualifying condition. Intermittent leave or
reduced schedule leave may be available if the need for leave is due to an associate's serious health condition or an
associate's immediate family member's serious health condition and when the need for intermittent or reduced schedule
leave is certified by a health care provider. Intermittent or reduced schedule leave is not available for the birth or
placement of a child for adoption or foster care, unless the Company agrees. Military Caregiver Leave may be taken
intermittently or on a reduced leave schedule when medically necessary. Active Duty Leave may also be taken on an
intermittent or reduced leave schedule.
Associates who take foreseeable intermittent or reduced schedule leave must attempt to schedule their intermittent or
reduced schedule leaves so as not to disrupt the operations of Highgate Hotels and in some instances, Highgate Hotels
may require associates taking foreseeable intermittent or reduced schedule leaves to transfer temporarily to an
alternative position for which the associate is qualified and which better accommodates the associate's leave schedule.
Pay and shifts would not be affected by a change to an alternate position. Time worked in the alternate position would
not count towards the associate’s FMLA leave entitlement.
Associates taking unforeseeable intermittent leaves must follow the Company's standard call-in procedures absent
unusual circumstances.
Documentation Supporting FMLA Leave

An associate requesting leave for a serious health condition must provide a completed FMLA Certification of Health
Care Provider Form supporting the need for the leave. A request for reasonable documentation of family relationship
verifying the legitimacy of a request for FMLA Leave may also be required.
The associate will have fifteen (15) days in which to return a completed Certification form following Highgate Hotels’
request for the certification. If the associate fails to provide timely certification after being required to do so, covered
leave may be delayed moving forward until the certification form is finally submitted. Absences counted against the
associate for a late certification will not be reversed absent exceptional circumstances. If an associate never returns the
completed form, the FMLA will be denied and the absences will be unprotected. If the Certification form is incomplete
or insufficient, an associate will be given written notification of the information needed and will be given a period of
seven (7) days to provide the necessary information.
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In some circumstances, a second opinion, at the expense of the Company, related to the health condition may be
required. If the original certification and the second opinion differ, a third opinion, at the expense of the Company, may
be required. The opinion of the third health care provider, which the Company and the associate jointly select, will be
the final and binding decision.
A request for Active Duty Leave must be supported by the Certification of Qualifying Exigency for Military Family Leave
form as well as appropriate documentation, including the covered military member's active duty orders.
A request for Military Caregiver Leave must be supported by the Certification for Serious Injury or Illness of Covered
Service member form or Certification for Serious Injury or Illness of a Veteran for Military Caregiver Leave form as well as
any necessary supporting documentation.
Once the company has received a complete and sufficient certification form from the associate, the Company will
advise the associate whether he or she has been approved or denied FMLA and, if possible, will advise how much FMLA
will be used.
Recertification
In the following circumstances, the Company may, in its sole discretion, require recertification of the qualifying reason for
FMLA: (1) where the associate needs more leave than the original certification justified; (2) where circumstances and
facts cast doubt on the associate’s need for FMLA; or (3) when the need for FMLA extends beyond 6 calendar months.
In these situations, the associate will have fifteen (15) days in which to provide a completed Recertification form.
Restoration to Position and Benefits

Healthcare benefits will be maintained while an associate is on FMLA, subject to the payment of premiums explained in
this paragraph. For all other benefits, they will be maintained similarly to others on similar forms of leave (paid/unpaid).
Associates on paid FMLA (because they are concurrently exhausting a paid leave benefit) will continue to have their
premium payments deducted from their paycheck as if they were on non-FMLA paid leave. Associates on an unpaid
FMLA leave (for which no paid leave is substituted or after all paid leave has been exhausted) will need to maintain the
benefits they accrued prior to commencement of the leave by making premium payments. If the payment is not
received on the due date or thereafter, the company will provide the associate written notice of non-payment and
provide 15 days to make the payment. If the payment is not made within the 15 day window, and at least 30 days have
passed from the due date, then coverage under the benefit plan will lapse, retroactively to the original due date.
Associates are permitted to return to whatever position they would have held had they not taken FMLA leave.
Generally, this means associates returning from FMLA leave within 12 weeks will be returned to the job position that they
held when they went on leave, or a substantially similar one. If the associate would have lost their position even if they
had not taken the leave, then there exists no reinstatement right. For example, if the associate’s position is eliminated
because of a reduction in force, then no reinstatement right exists.
If an eligible associate fails to pay his or her portion of the required premium payments for benefit coverage, and the
Company elects to make the associate’s portion of premium payments to keep benefit coverage in effect during a
period of paid or unpaid FMLA leave for medical and dental benefits, and/or a period of unpaid FMLA leave for other
benefits, the Company may recover the amount of the premium payment from the associate regardless of whether the
associate returns to work. The Company may recover its own share of the premiums paid for maintaining an associate's
medical and dental benefit coverage during any period of unpaid FMLA leave if the associate fails to return from leave
after entitlement has expired, provided the associate failure to return to work for a reason other than the continuation,
recurrence, or onset of a serious health condition was unrelated to the qualifying reason the associate took FMLA leave.
Return to Work
Associates on FMLA leave must periodically inform the Human Resources Department of their status and intent to return
to work while on FMLA leave. Associates returning from FMLA leave must be able to assume all of the essential functions
of their jobs upon return. The Company will provide time for the associate to learn of any changes or new technology
implementations. As a condition to restoring an associate whose leave was based on the associate's own serious health
condition, the associate must provide certification from the associate's health care provider stating that the associate is
able to resume work. This return to work statement is required for all serious health conditions unless the associate has
previously provided one for that condition within the past year. If safety issues exist, the Company may require a return
to work statement every thirty days.
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Failure to Return From Leave
Unless required otherwise by law an associate granted a leave of absence under these provisions who fails to return to
work upon expiration of the leave will no longer have protected absences. Further absences would count against the
attendance policy. Employers are prohibited from discriminating against or interfering with an associate’s rights under
the FMLA.
Key Associates
An associate who qualifies as a "key associate" may be denied restoration of employment after a period of FMLA leave if holding
the associate’s position would cause the company grievous economy injury.
Reasonable Accommodation Medical Leave

The Company complies with the reasonable accommodation obligations under the ADAAA and will engage in the
interactive process to discuss an unpaid leave of absence as a reasonable accommodation with associates who are
unable to perform the essential functions of their job due to a physical or mental disability. Leave under this policy is at
the discretion of management and will be considered in accordance with the reasonable accommodation obligations
of the ADAAA. A reasonable accommodation leave of absence may be provided to associates who are unable to
perform the essential functions of their job due to physical or mental disability and are not eligible for FMLA. Similarly,
leave under this policy may be granted as a reasonable accommodation for associates who have exhausted FMLA but
are unable to return to work due to a disability that prohibits them from performing the essential functions of their job.
Leaves of absence under this policy will be handled on a case-by-case basis in accordance with the ADAAA. The
duration of any leave of absence under this policy will vary depending on the particular circumstances of each
associate’s need and whether additional leave is reasonable under the circumstances and/or would create an undue
hardship for the Company.
Before commencing a reasonable accommodation medical leave of absence taken because of the medical condition of an
associate, the associate must submit a certification completed by a health care provider to Human Resources. An associate may
be required to submit a recertification to support a continuing personal leave for medical reasons every 30 days. An associate
returning from a medical leave taken because of the associate’s own disability must submit a medical certification from a health
care provider stating that the associate is fit to return to work and can perform the essential functions of the job with or without
reasonable accommodation.
Interaction with State Leave Laws

Certain states require employers to provide greater or different job-protected leave. When applicable, the Company
complies with all such leave laws. When leave provided under one of these laws is covered under the federal FMLA, it
also shall count toward the associate's federal FMLA entitlement and as FMLA Leave under this Policy. These leave laws
vary by state, and the associate should contact Human Resources if you have questions about them.
Outside Activity During Disability

A number of approved benefits and leaves of absence are provided to associates who are unable to perform the
essential functions of their job. Such leave includes FMLA, disability leave, and workers’ compensation disability leave.
Since you must be disabled or temporarily incapacitated from your job to claim these benefits, the Company specifically
prohibits an associate who is on any of these forms of leave from participating in any activity that would be precluded
by their medical restrictions. This includes working for any secondary employer while on a leave of absence if the work
to be performed would violate your medical restrictions. Violation of this policy may lead to disciplinary action up to and
including immediate termination of employment.
Nursing Mothers Leave

The Company will provide a reasonable amount of break time to accommodate female associate’s need to express
breast milk for the associate’s infant child up until 12 months of age. If possible, the break time should be taken
concurrent with other break periods already provided. If the associate needs longer than a scheduled break to
express milk, the remainder of the break will be unpaid. The Company will also make reasonable efforts to provide
the associate with the use of a room or other location in close proximity to the associate’s work area for the associate
to express milk in private. Associate should notify her Manager or Human Resources, if she is requesting time to
express breast milk under this policy.
Uniformed Services Leave

This policy grants Uniformed Services Leave when an associate, voluntarily or involuntarily, serves in the United States
uniformed services in accordance with the Uniformed Services Employment and Reemployment Rights Act (USERRA).
Advance notice of uniformed service is required, unless military necessity prevents such notice or it is otherwise
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impossible or unreasonable. Highgate Hotels complies with USSERRA and all applicable state military leave laws. Please
see a Human Resources Representative for additional information regarding military leave.
Other Legally Protected Absences

In addition to the leaves described herein, Highgate Hotels complies with all applicable state laws relating to various
forms of protected absences. Depending on the particular state in which you are employed, associates may be legally
entitled to time off under various state laws. For additional information and to determine if you qualify for additional
leaves of absence, please contact your Manager or Human Resources.
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NEW JERSEY ADDENDUM (For New Jersey Associates Only)
STATE LAW ADDENDA

The following state law addenda supplement the policies contained in the Associate Playbook. Should there be any
conflict between a policy in the Associate Playbook and the state law addenda, the state law addenda shall be
controlling. These state law addenda are only applicable to associates working in the relevant states. These state law
addenda are not a contract of employment and do not alter the at-will employment relationship. This state law
addenda is not all inclusive there are other state and local laws that may be applicable to your employment. Please
contact your manager or refer to the employment posters at your location for additional information on state and local
laws applicable to your employment.
NEW JERSEY ADDENDUM – For New Jersey Associates Only

Associates working in New Jersey may be eligible for family leave under the New Jersey Family Leave Act (NJFLA), as
described below. This policy is only a summary of Associates’ rights under the NJFLA. If there are any differences
between the NJFLA and the summary below, the NJFLA will govern.
Eligibility for NJFLA
To be eligible for NJFLA leave, an associate must: (1) have been employed by the Company in New Jersey for at least 12
months, (2) have worked for the Company for at least 1000 hours in the 12 months preceding the date the leave is
requested to begin, and (3) work for an employer with at least 30 Associates.
Please contact the Human Resources Department to determine whether you are eligible for NJFLA leave.
Leave Entitlement
An eligible associate is generally entitled to 12 workweeks of unpaid leave in a 24-month period (a rolling 24 month
period measured backward from the date the leave is requested to begin) for the following reasons: 1) to care for a
family member with a serious health condition (“caregiver leave”); or 2) to care for a newborn child or a child placed
with the Associate through adoption or foster care (“bonding leave”) or 3) to provide care or treatment of a child
during a state of emergency if their school or place of care is closed by order of a public official due to an epidemic
of a communicable disease or other public health emergency (“epidemic related school closure leave”).
NJFLA bonding leave must be commenced (not completed) within 12 months of the child’s birth, adoption, or foster care
placement.
If an associate requests leave for a reason that is covered by both the NJFLA and another leave law (such as the FMLA
or the SAFE Act) the leave will count simultaneously against the associate’s entitlement under each respective law.
The terms “’family member,” “child” and “serious health condition” have specific definitions under the NJFLA. Please
contact your Supervisor or Human Resources for more information.
Substitution of Accrued Paid Leave
NJFLA leaves of absence are generally granted without pay. However, associates may be eligible for compensation
while absent on NJFLA leave in certain circumstances:
Associates may elect to use available paid time off while on NJFLA leave.
Associates may be eligible to receive Family Leave Insurance (wage replacement) benefits from the State of New Jersey
while on NJFLA leave. Please see section below entitled “Compensation from the State – FLI Benefits” for a complete
discussion of Family Leave Insurance Benefits.
Even if not requested by an associate, the Company may require associates to use available paid time off while on
NJFLA leave. However, associates will not be required to use available PTO in lieu of Family Leave Insurance (FLI)
benefits. If an associate applies and qualifies for FLI benefits from the State, the associate may elect to receive FLI
benefits before being required to use his/her available accrued PTO. If an associate’s leave continues after the
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associate has exhausted his/her FLI benefits, then the associate will required to use all available accrued PTO. After
exhaustion of all available accrued PTO, the leave will be unpaid.
PTO time and time while FLI benefits are received will run concurrently with NJFLA leave.
Intermittent/Reduced Schedule Leave
Associates may take NJFLA bonding leave on a continuous, intermittent, or reduced work schedule basis.
Associates may take NJFLA caregiver leave on a continuous basis or, when certified as medically necessary by a health
care provider, on an intermittent or reduced work schedule basis.
NJFLA leave taken on an intermittent basis or a reduced schedule basis must be completed in a 12 consecutive month
period.
Requesting and Scheduling Leave
Bonding Leave
When an associate takes bonding leave on a continuous basis, the associate must give the Company 30 days’ advance notice
when the need for leave is foreseeable, and if not, as much notice as possible.
When an associate takes bonding leave on an intermittent or reduced leave schedule basis, the associate must give the
Company 15 days’ advance notice when the need for leave is foreseeable, and if not, as much notice as possible. The
associate should make a reasonable effort to schedule the leave so as not to unduly disrupt the operations of the
Company and, if possible, provide the Company, prior to the first day of intermittent leave, with a regular schedule of
the days or days of the week on which the intermittent leave will be taken.
Caregiver Leave
When an associate takes caregiver leave on a continuous basis, the associate must give the Company 30 days’
advance notice if possible, and if not, as much notice as possible.
When an associate takes caregiver leave on an intermittent or reduced leave schedule basis, the associate must give
the Company 15 days’ advance notice if possible, and if not, as much notice as possible. The associate should make a
reasonable effort to schedule the leave so as not to unduly disrupt the operations of the Company and, if possible,
provide the Company, prior to the first day of intermittent leave, with a regular schedule of the days or days of the week
on which the intermittent leave will be taken.
Even in the absence of a request for family leave, the Company will designate leave taken for reasons that qualify as
family leave as approved NJFLA leave and charge the leave taken against the associate’s NJFLA leave entitlement.
Epidemic Related School Closure Leave
When an associate takes epidemic-related school closure leave on a continuous basis, the associate must give the
Company as much notice as possible.
When an associate takes epidemic related school closure leave on an intermittent basis, the associate must give 1) prior
notice to the Company as soon as practicable and 2) make a reasonable effort to schedule the intermittent leave so as
not to unduly disrupt the operations of the Company and, if possible, provide the Company before leave is taken with a
regular schedule of the day(s) when intermittent leave will be taken.
Even in the absence of a request for family leave, the Company will designate leave taken for reasons that qualify as
family leave as approved NJFLA leave and charge the leave taken against the associate’s NJFLA leave entitlement.
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Required Certifications
At the time an associate requests family leave, he/she will be requested to submit an appropriate Certification (in some
cases the Company’s Certification request may be made after the associate’s leave request is made, such as in the
case of unforeseen leave). Blank Certification forms are available from the Human Resources Department.
An associate must return the required Certification to the Supervisor or Human Resources Department within 15 days
after the associate requests leave, unless it is not practicable under the circumstances to do so. In such cases, the
associate must return the completed Certification as soon as possible and practical. If an associate fails to provide timely
Certification after being requested to do so, the associate’s leave request may be denied until the Certification is
provided.
If the Certification submitted by the associate is incomplete or insufficient, the associate will be given written notification
of the information needed and will have seven (7) days after receiving such written notice to provide the necessary
information, unless it is not practicable under the circumstances to do so. If an associate fails to cure the deficiencies
after being requested to do so, the associate’s leave request may be denied.
In cases where the Company does not agree with the assessment of the associate’s family member’s health care provider, the
Company may require a second opinion at the Company’s expense by another health care provider. In the case of a conflict
between the first two opinions, the Company may require, and must pay for, a third opinion by a health care provider jointly
designated by the Company and the associate. The third opinion will be binding.
In cases where the associate requests epidemic-related school closure leave, the Company may request a
certification issued by the associate’s child’s school or place of care setting forth the date of and reason for the
closure.
Job/Benefits Protection
An eligible associate who takes leave is entitled, upon return from leave, to be reinstated to his or her previous position of
employment, or to an equivalent position with equal pay, benefits and other terms and conditions of employment. There
are certain exceptions to this requirement, including in the case of layoffs that occur during leave affecting the
Associate’s position and in the case of “Key Associates.”
Associates must notify the Company of their intention to return to work at least two weeks prior their return to work date.
An associate who desires to return to work earlier than scheduled must give the Company at least two (2) days prior
notice of his/her intent.
An associate who takes family leave is not entitled to the accrual of additional benefits or seniority that would have
occurred during the period of leave. However, associates are entitled to accrue hours of service (service credit) during
periods of paid leave.
Compensation from the State – FLI Benefits
A New Jersey associate who takes bonding or caregiver leave may be eligible for Family Leave Insurance (FLI) benefits
from the State. FLI benefits are intended to compensate associates for wage loss experienced while taking these types
of family leave. Associates who apply and qualify for FLI benefits will be eligible to receive 85% of their average weekly
wage (up to a maximum set by the State) for a maximum of 12 weeks when leave is taken on a continuous basis or in
intermittent weekly increments (or 56 days when leave is taken in intermittent daily increments) per 12-month period.
The following additional eligibility terms apply to FLI benefits:
• Associates may receive FLI benefits for bonding leave taken on a continuous basis or an intermittent basis.
Associates may receive FLI benefits for caregiver leave taken on a continuous basis or, when certified as
medically necessary, on an intermittent basis.
• Associates must give the Company at least 30 days’ notice prior to commencing bonding leave on a
continuous basis, unless the commencement time of the leave is unforeseeable. Associates intending to take
such leave on an intermittent basis must give the Company at least 15 days prior notice, unless an unforeseen
emergency precludes prior notice.
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• Associates must give the Company notice in a reasonable and practicable manner prior to commencing
caregiver leave on a continuous basis, unless an unforeseen emergency precludes prior notice. Associates
intending to take such leave on an intermittent basis must give the Company at least 15 days prior notice,
unless an unforeseen emergency precludes prior notice.
• Associates apply for FLI benefits from the State by submitting a claim form to the State, which are available
from the Human Resources Department.
• Eligibility for FLI benefits is determined by the State, not the Company.
Associates who take bonding or caregiver leave under the NJFLA are permitted to, but not required to, apply for FLI
benefits from the State. If an associate elects not to apply for FLI benefits when taking bonding or caregiver leave, the
Company’s normal rules regarding the substitution of paid leave will apply.
An associate may be eligible for FLI benefits from the State even if he/she is not eligible for family leave under the NJFLA.
The Company may require certification from a health care provider supporting the need for FLI.
A separate notice describing associates’ rights to FLI benefits is available from the Human Resources Department.
Domestic Violence/Sexual Assault Victim Leave Policy
Under the New Jersey Security and Financial Empowerment Act (SAFE Act), an eligible associate who (1) is a victim of an
incident of domestic violence or sexual assault or (2) whose family member is a victim of such an incident, is entitled to
unpaid leave for various medical and legal purposes, as explained below. This policy is only a summary of associates’
rights under the SAFE Act. If there are any differences between the Act and the summary below, the Act will govern.
Eligibility for Leave
To be eligible for leave, an associate must: (1) have been employed by the company for at least 12 months, (2) must
have worked at least 1,000 hours during the 12-month period immediately preceding the leave, and (3) work for an
employer with at least 25 Associates.
Please contact the Supervisor or Human Resources Department to determine whether you are eligible for SAFE leave.
Reasons for Leave
An eligible associate may take leave for purposes of:
• Seeking medical attention for, or recovering from, physical or psychological injuries caused by domestic or
sexual violence to the associate or the associate’s family member;
• Obtaining services from a victim services organization for the associate or the Associate’s family member;
• Obtaining psychological or other counseling for the associate or the associate’s family member;
• Participating in safety planning, temporarily or permanently relocating, or taking other actions to increase the
safety of the associate or the associate’s family member from future domestic or sexual violence or to ensure
economic security;
• Seeking legal assistance or remedies to ensure the health and safety of the associate or the associate’s family
member, including preparing for, or participating in, any civil or criminal legal proceeding related to or derived
from domestic or sexual violence; or
• Attending, participating in, or preparing for a criminal or civil court proceeding relating to an incident of
domestic or sexual violence of which the associate or the associate’s family member was a victim.
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Amount of Leave
Under the SAFE Act, an eligible associate is entitled to 20 days of unpaid leave during the 12-month period following an
incident of domestic violence or sexual assault for any of the reasons stated above. An eligible associate is also entitled
to 20 days of unpaid leave for any subsequent incidents of domestic violence or sexual assault, but no more than 20
days of leave may be taken during any 12-month period. Leave may be taken intermittently in intervals of no less than a
day.
Substitution of Paid Leave/Coordination with Other Leave Laws
SAFE leaves of absence are generally granted without pay. However, associates may be eligible for compensation while
absent on SAFE leave in certain circumstances:
Associates may elect to use available accrued paid time off while on SAFE leave.
An associate who is disabled as a result of an incident of domestic violence or sexual assault may be eligible for
Temporary Disability Insurance (wage replacement) benefits from the State of New Jersey while on SAFE leave. Please
contact the Supervisor or Human Resources Department for more information.
Associates who are not disabled but otherwise eligible for SAFE leave may be eligible to receive Family Leave Insurance
(wage replacement) benefits from the State of New Jersey while on SAFE leave. Please see section above in the New
Jersey Family Leave Act (“NJFLA”) Policy entitled “Compensation from the State – FLI Benefits” for a complete discussion
of Family Leave Insurance Benefits.
Even if not requested by an associate, the Company may require associates to use available accrued paid time off
while on SAFE leave. However, associates will not be required to use available paid time off in lieu of Family Leave
Insurance (FLI) benefits. If an associate applies and qualifies for FLI benefits from the State, the associate may elect to
receive FLI benefits before being required to use his/her available paid time off. If an associate’s leave continues after
the associate has exhausted his/her FLI benefits, then the associate will required to use all available paid time off.
After exhaustion of all available paid time off, the leave will be unpaid.
If an associate requests leave for a reason that is covered by both the SAFE Act and the NJFLA, the leave will count
simultaneously against the associate’s entitlement under each respective law.
PTO time and time while FLI benefits are received will run concurrently with SAFE leave.
Requesting and Scheduling Leave
If the need for leave under this policy is foreseeable, an associate must provide the Company with advance written
notice of the need for leave. The notice must be provided to the Store Manager on duty or Human Resources
Department as far in advance as is reasonable and practical under the circumstances, unless an emergency or other
unforeseen circumstances precludes prior notice.
Required Documentation
An associate must submit documentation in support of his/her leave request. Any one of the following forms of
documentation will be deemed sufficient:
• A domestic violence restraining order or other documentation of equitable relief issued by a court of
competent jurisdiction;
• A letter or other written documentation from the county or municipal prosecutor documenting the domestic
violence or sexually violent offense;
• Documentation of the conviction of a person for the domestic violence or sexually violent offense;
• Medical documentation of the domestic violence or sexually violent offense;
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• Certification from a certified Domestic Violence Specialist or the director of a designated domestic violence
agency or Rape Crisis Center, that the associate or Associate’s family member is a victim of domestic violence
or a sexually violent offense; or
• Other documentation or certification of the domestic violence or sexually violent offense provided by a social
worker, member of the clergy, shelter worker, or other professional who has assisted the associate or the
associate’s family member.
Confidentiality
The Company will maintain the confidentiality of any documentation provided by an associate in support of his/her
leave request, and any information regarding a leave taken under this policy and, if applicable, the associate’s failure to
return to work, unless disclosure is voluntarily authorized in writing by the associate or is required by a federal or state law,
rule, or regulation.
Associates are advised that any information they submit to the Company regarding their SAFE Act leave should be
directed to Human Resources.
Discrimination and Retaliation Prohibited
Discharging, harassing, or otherwise discriminating or retaliating against any associate for exercising his/her rights under
the NJ SAFE Act is strictly prohibited. An associate who believes he/she has been subjected to any such improper
conduct should contact the Human Resources Department immediately.
Conscientious Associate Protection Act “Whistleblower Act”
It is unlawful in New Jersey for an employer to take retaliatory action against any Associate who discloses, threatens to
disclose, objects to, or provides information to a governmental body about, any activity that the associate reasonably
believes is unlawful, fraudulent, criminal, or incompatible with a clear mandate of public policy. Associates who are
aware of any such activity, or who believe they have been subjected to retaliation for disclosing, threating to disclose
objecting to, or providing any information about any such activity, should immediately report the matter to the
designated Company contact,
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CALIFORNIA ADDENDUM (For California Associates Only)
CALIFORNIA ADDENDUM – For California Associates Only
To our California associates: please note that wherever California law provides for or offers greater protections to our
associates, California law will govern. One or more of these policies may not be applicable to associates subject to a
Collective Bargaining Agreement.
EEOC Protected Status

It is the policy of the Company to provide employment opportunities without regard to race, color, age, sex, sexual
orientation, familial status, religious creed, national origin, ancestry, medical condition, marital status and registered
domestic partner status, citizenship status, protected hair style or texture, military and veteran status, disability, protected
medical condition, genetic information or any other status protected by law. Harassment and/or discrimination based
on “sex” includes harassment and/or discrimination based upon gender, gender identity (including gender identity and
gender expression), pregnancy (including childbirth or related medical conditions, and breastfeeding), and gender
stereotyping. Discrimination based on any of these protected classifications is unlawful and is a violation of company
policy. The Company makes all employment decisions without regard to these protected statuses and does not tolerate
harassment or discrimination.
Harassment Training
The harassment prevention policy and complaint procedures contained in the main handbook are applicable to
California associates. The Company’s harassment prevention policy in California will be enforced in accordance with
the California Fair Employment and Housing Act (“FEHA”). The FEHA prohibits harassment and discrimination in
employment because of race, color, religion, sex, gender (including gender identity and gender expression), sexual
orientation, marital status, registered domestic partner status, military status, veteran status, national origin (including
language use restrictions and possession of a driver’s license issued under section 12801.9 of the California Vehicle
Code), protected hair style or texture, ancestry, citizenship status, mental and physical disability, protected medical
condition, genetic information, political activity, age, pregnancy (including childbirth or related medical conditions,
and breastfeeding), denial of medical and family care leave or pregnancy disability leave, and/or retaliation for
reporting any violations of this policy, or any other category protected by applicable law.
Sexual harassment may be a single incident or a series of harassing acts. Inappropriate conduct that is sexually
harassing in nature can involve individuals of the same or opposite sex, a supervisor (or manager) and subordinate, co-
workers, an associate, or a non-associate (third party) such as a customer, contractor, vendor, or supplier.
Sexual harassment also includes harassment based on gender (including gender identity and gender preference),
pregnancy, childbirth, or related medical conditions, transgender and sexual orientation (meaning one’s
heterosexuality, homosexuality, or bisexuality), and sex stereotyping. Sexual harassment does not need to be motivated
by sexual desire to be unlawful or to violate this policy.
“Gender expression” means a person’s gender-related appearance or behavior, whether or not stereotypically
associated with the person’s sex at birth. “Gender identity” means a person’s identification as male, female, a gender
different from the person’s sex at birth, or transgender. “Sex stereotype” means an assumption bout a person’s
appearance or behavior, or about an individual’s ability or inability to perform certain kinds of work based on a myth,
social expectation, or generalization about the individual’s sex.
Moreover, the company will comply with all applicable laws regarding pay equity between men and women. Any pay
discrepancies in pay for substantially similar work will be based on bona fide business factors other than sex.
Furthermore, nothing in the Company’s policies should be construed to prohibit associates from discussing their own
wages.
The company’s policy prohibiting unlawful harassment and discrimination applies to all associates of the company,
including supervisors and managers. The company prohibits managers, supervisors and associates from harassing or
discriminating against co-workers as well as the company’s customers, vendors, suppliers, independent contractors and
others doing business with the Company. In addition, the Company prohibits its customers, vendors, suppliers,
independent contractors and others doing business with the Company from harassing our associates.
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Associates who feel that they have been harassed or discriminated against in violation of this policy must immediately
report any violation using the reporting mechanisms set forth in the main policy or to the Human Resources Department
so that investigation of the complaint can be undertaken. Violation of this policy will subject an associate to disciplinary
action, up to and including immediate termination. Additionally, under California law, associates may be held
personally liable for harassing conduct that violates the California Fair Employment and Housing Act. The Company will
not retaliate against any associate for lodging a complaint or participating in an investigation. If you feel that you are
being retaliated against you should immediately contact the Human Resources, or any other manager. In addition, if
you observe retaliation by another associate, supervisor, manager or non-associate please report the incident
immediately to the Human Resources.
Additionally, state agencies, including the California Department of Fair Employment and Housing, may have authority
to issue accusations against employers, conduct formal hearings, and award affirmative relief. State and federal law
also prohibit retaliation against associates because they have filed a complaint with the EEOC or DFEH, participated in
an investigation, proceeding, or hearing with either agency, or opposed any unlawful discriminatory practice. If you
think you have been harassed or that you have been retaliated against for resisting or complaining, you may file a
complaint with the appropriate agency. The nearest office can be found by visiting the agency websites at
www.eeoc.gov and www.dfeh.ca.gov.
In accordance with California Code § 12590.1, associates and supervisors will be provided sexual harassment training
and education every two years. Newly hired supervisors or associates promoted into a supervisory position will receive
training within six months of assuming supervisory responsibilities.
California Family Rights Act
The California Family Rights Act (CFRA) provides many of the same leave benefits and protections to California
associates that the federal Family and Medical Leave Act (FMLA) does. However, associates may be eligible for an
unpaid CFRA leave not otherwise provided through FMLA and/or any other qualified leave that may run concurrently
with CFRA. In circumstances where an associate’s leave is covered under both the FMLA and the CFRA, the leaves will
run concurrently.
To be eligible for CFRA, an associate must be employed with the Company for at least twelve (12) months and have
performed at least 1250 hours of service with the Company during the previous twelve months prior to the
commencement of leave. Full-time associates may take CFRA of up to 12 work weeks in a 12-month period measured
backward from the date leave is requested. Part-time associates may take leave on a proportional basis. Associates
may take CFRA leave on an intermittent basis instead of all at one time.
Reasons for Leave Under CFRA
Eligible associates may request an unpaid CFRA leave of absence in circumstances that include:
(1) birth of a child of the associate, to bond with a new child, or due to the placement of a child with an associate
in connection with the adoption of a foster care of the child by the associate;
(2) to care for an immediate family member (associate’s spouse, registered domestic partner, child, registered
domestic partner’s child, sibling, parent, grandparent or grandchild) with a serious health condition;
(3) for the associate’s own serious health condition that makes the associate unable to perform the function of the
associate’s position, except for leave taken for disability on account of pregnancy, childbirth, or related medical
conditions;
(4) to handle certain qualifying exigencies arising out of the fact that the associate’s spouse, domestic partner,
child, or parent is on duty under a call or order to active duty in the Uniformed Services (up to 12 weeks).
Associates are entitled to take CFRA leave in addition to any leave entitlement they might have under California
Pregnancy Disability Leave. Associates must take leave for the birth or fostering or adoption of a child within one year
of the event.
Definitions for purposes of this policy
“Child,” means a biological, adopted or foster child; a stepchild; a legal ward; a child of a domestic partner; or a
person to whom the associate stands in loco parentis. "Child," for purposes of Qualifying Exigency Leave and Military
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Caregiver Leave, means a biological, adopted or foster child; stepchild; legal ward; or a child for whom the person
stood in loco parentis, and who is of any age.
“Designated person” means any individual related by blood or whose association with the associate is the equivalent
of a family relationship. The associate may identify the designated person at the time the associate requests the leave
to care for the person. Associates may designate one designated person per 12-month period for family care and
medical leave.
“Domestic partner” has the same meaning as defined in Section 297 of the Family Code.
“Grandchild” means a child of the associate’s child.
“Grandparent” means a parent of the associate’s parent.
“Parent,” for purposes of this policy, means a biological, adoptive, step or foster parent, a legal guardian, or any other
individual who stood in loco parentis to the person when the person was a child. Parent does not include a parent-in-
law.
“Parent-in-law” means the parent of a spouse or domestic partner.
“Sibling” means a person related to another person by blood, adoption, or affinity through a common legal or
biological parent.
“Spouse” means a husband or wife. Husband or wife refers to the other person with whom an individual entered into
marriage as defined or recognized under federal or state law in the state in which the marriage was entered into or, in
the case of a marriage entered into outside of any state, if the marriage is valid in the place where entered into and
could have been entered into in at least one state. This definition includes an individual in a same-sex or common law
marriage that either (1) was entered into in a state that recognizes such marriages; or (2) if entered into outside of any
state, is valid in the place where entered into and could have been entered into in at least one state.
“Serious health condition” means an illness, injury, impairment or physical or mental condition that involves either:
(1) Inpatient care (including, but not limited to, substance abuse treatment) in a hospital, hospice or residential
medical care facility, including any period of incapacity (that is, inability to work, attend school or perform other regular
daily activities) or any subsequent treatment in connection with this inpatient care; or
(2) Continuing treatment (including, but not limited to, substance abuse treatment) by a health care provider that
includes one or more of the following:
a. A period of incapacity (that is, inability to work, attend school or perform other regular daily activities due to a
serious health condition, its treatment or the recovery that it requires) of more than three consecutive calendar days,
and any subsequent treatment or period of incapacity relating to the same condition, that also involves treatment two
or more times via an in-person visit to a health care provider, or at least one visit to a health care provider that results in
a regimen of continuing treatment under the supervision of the health care provider.
b.. Any period of incapacity or treatment for incapacity due to a chronic serious health condition that requires
periodic visits to a health care provider, continues over an extended period of time and may cause episodic
incapacity.
c. A period of incapacity that is permanent or long-term due to a condition for which treatment may not be
effective, such as Alzheimer's, a severe stroke and the terminal stages of a disease.
d. Any period of absence to receive multiple treatments (including any period of recovery) by a health care
provider either for (a) restorative surgery after an accident or other injury; or (b) a condition that would likely result in a
period of incapacity of more than three consecutive calendar days in the absence of medical intervention or
treatment.
Serious health condition for purposes of this policy does not include any period of incapacity due to pregnancy,
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childbirth, or related medical conditions, which are covered under the company’s pregnancy disability leave policy.
“Qualifying Exigency Leave” includes leave related to a covered active duty or call to covered active duty of an
associate’s spouse, domestic partner, child, parent (defined to include a parent-in-law for purposes of Qualifying
Exigency Leave) in the Armed Forces of the United States, for the following purposes:
(a) Activities undertaken within seven calendar days from the date that a spouse, domestic partner, child, or parent
has been notified of an impending call or order to covered active duty in the Armed Forces of the United States
to address any issue that arises from the call or order.
(b) Attendance in either or both of the following:
(1) An official ceremony, program, or event sponsored by the military that is related to the covered active duty
or call to covered active duty of the spouse, domestic partner, child, or parent.
(2) A family support or assistance program and informational briefing sponsored or promoted by the military,
military service organizations, or the American Red Cross that is related to the covered active duty or call to
covered active duty of the spouse, domestic partner, child, or parent.
(c) Any of the following activities related to the biological, adopted, or foster child, stepchild, legal ward, or child for
whom the spouse, domestic partner, child, or parent in the Armed Forces of the United States stands in loco
parentis, who is either not more than 18 years of age or, if equal to or more than 18 years of age, is incapable of
self-care because of a disability at the time that the paid leave is to commence:
(1) Arranging for alternative childcare for the child when the covered active duty or call to covered active
duty of the spouse, domestic partner, child, or parent in the Armed Forces of the United States necessitates
a change in the existing childcare arrangement.
(2) Providing childcare for the child on an urgent, immediate need basis when the need to provide this care arises from
the covered active duty or call to covered active duty of the spouse, domestic partner, child, or parent in the Armed
Forces of the United States.
(3) Enrolling or transferring the child to a new school or day care facility when enrollment or transfer is necessitated by
the covered active duty or call to covered active duty of the spouse, domestic partner, child, or parent in the Armed
Forces of the United States
(4) Attending meetings with staff at the child’s school or day care facility, including, but not limited to, meetings with
school officials regarding disciplinary measures, parent-teacher conferences, or meetings with school counselors, when
these meetings are necessary due to circumstances arising from the covered active duty or call to covered active duty
of the spouse, domestic partner, child, or parent in the Armed Forces of the United States.
(d) To make financial and legal arrangements for either or both of the following purposes:
(1) Making or updating financial or legal arrangements to address the absence of the spouse, domestic
partner, child, or parent in the Armed Forces of the United States while on covered active duty or call to
covered active duty, including, but not limited to, preparing and executing financial and healthcare
powers of attorney, transferring bank account signature authority, enrolling in the Defense Enrollment
Eligibility Reporting System (DEERS), obtaining military identification cards, or preparing or updating a will or
living trust.
(2) Acting as the representative of the spouse, domestic partner, child, or parent in the Armed Forces of the
United States before a federal, state, or local agency for purposes of obtaining, arranging, or appealing
military service benefits while the spouse, domestic partner, child, or parent in the Armed Forces of the
United States is on covered active duty or call to covered active duty, and for a period of ninety days
following the termination of the covered active duty.
(e) Attending counseling provided by someone other than a health care provider, for oneself, for the spouse,
domestic partner, child, or parent in the Armed Forces of the United States, or for the biological, adopted, or
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foster child, a stepchild, or a legal ward of the spouse, domestic partner, child, or parent in the Armed Forces of
the United States, or a child for whom this person stands in loco parentis, who is either not more than 18 years of
age, or equal to or more than 18 years of age and incapable of self-care because of a disability at the time that
paid family leave is to commence, provided that the need for counseling arises from the covered active duty or
call to covered active duty of the spouse, domestic partner, child, or parent in the Armed Forces of the United
States.
(f) Accompanying a spouse, domestic partner, child, or parent in the Armed Forces of the United States while that
individual is on short-term, temporary, rest and recuperation leave during the period of deployment in a foreign
country, provided that any leave taken for this purpose is for not more than 15 calendar days beginning on the
date of commencement for the rest and recuperation leave.
(g) Attending arrival ceremonies, reintegration briefings and events, and any other official ceremony or program
sponsored by the military for a period of 90 days following the termination of the covered active duty of the
spouse, domestic partner, child, or parent in the Armed Forces of the United States.
(h) Addressing issues that arise from the death of the spouse, domestic partner, child, or parent in the Armed Forces
of the United States while on covered active duty status, including meeting and recovering the body of the
spouse, domestic partner, child, or parent in the Armed Forces of the United States, making funeral
arrangements, and attending funeral services.
(i) Any of the following activities related to the parent of the spouse, domestic partner, child, or parent in the Armed
Forces of the United States while the parent of the spouse, domestic partner, child, or parent in the armed forces
during covered active duty is incapable of self-care by requiring active assistance or supervision over daily self-
care in three or more of the activities of daily living or instrument activities of daily living:
(A) Arranging for alternative care for the parent of the spouse, domestic partner, child, or parent in the Armed Forces of
the United States when the covered active duty or call to covered active duty of the spouse, domestic partner, child,
or parent in the Armed Forces of the United States necessitates a change in the existing care arrangement for the
parent.
(B) Providing care for the parent who is incapable of self-care on an urgent, immediate need basis when the need to
provide this care arises from the covered active duty or call to covered active duty of the spouse, domestic partner,
child, or parent in the Armed Forces of the United States.
(C) Admitting or transferring the parent to a care facility when admission or transfer is necessitated by the covered
active duty or call to covered active duty of the spouse, domestic partner, child, or parent in the Armed Forces of the
United States.
(D) Attending meetings with staff at the parent’s care facility, including, but not limited to, meetings with hospice or
social service providers of the parent of the spouse, domestic partner, child, or parent in the Armed Forces of the United
States when these meetings are necessary due to circumstances arising from the covered active duty or call to
covered active duty of the spouse, domestic partner, child, or parent in the Armed Forces of the United States.
For purposes of this subdivision, “activities of daily living” include adaptive activities, such as caring appropriately for
one’s grooming and hygiene, bathing, dressing, and eating. Instrumental activities of daily living include, but are not
limited to, cooking, cleaning, shopping, taking public transportation, paying bills, maintaining a residence, using
telephones and directories, and using a post office.
(j) Any other activities to address other events that arise out of the covered active duty or call to covered active
duty of the spouse, domestic partner, child, or parent in the Armed Forces of the United States, provided that the
employer and associate agree that this leave shall qualify as an exigency, and agree to both the timing and
duration of this leave.
“Covered Active Duty” means (1) in the case of a member of a regular component of the Armed Forces, duty during
the deployment of the member with the Armed Forces to a foreign country; and (2) in the case of a member of a
reserve component of the Armed Forces, duty during the deployment of the member with the Armed Forces to a
foreign country under a call or order to active duty (or notification of an impending call or order to active duty) in
support of a contingency operation as defined by applicable law.
“Covered Servicemember” means (1) a member of the Armed Forces, including a member of a reserve component of
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the Armed Forces, who is undergoing medical treatment, recuperation or therapy; is otherwise in outpatient status; or is
otherwise on the temporary disability retired list, for a serious injury or illness incurred or aggravated in the line of duty
while on active duty that may render the individual medically unfit to perform his or her military duties; or (2) a person
who, during the five years prior to the treatment necessitating the leave, served in the active military, Naval or Air
Service, and who was discharged or released under conditions other than dishonorable (a "veteran" as defined by the
Department of Veteran Affairs), and who has a qualifying injury or illness incurred or aggravated in the line of duty while
on active duty that manifested itself before or after the member became a veteran. For purposes of determining the
five-year period for covered veteran status, the period between October 28, 2009, and March 8, 2013, is excluded.
“Serious injury or illness” in the case of a current member of the Armed Forces, National Guard or Reserves is an injury or
illness incurred by a covered servicemember in the line of duty on active duty (or that preexisted the member's active
duty and was aggravated by service in the line of duty on active duty) in the Armed Forces that may render him or her
medically unfit to perform the duties of his or her office, grade, rank or rating. In the case of a covered veteran, "serious
injury or illness" means an injury or illness that was incurred in the line of duty on active duty (or existed before the
beginning of the member's active duty and was aggravated by service in line of duty on active duty) and that
manifested itself before or after the member became a veteran.
Requesting Leave
An associate who requests leave for the serious health condition of the associate’s child, parent, grandparent,
grandchild, sibling, spouse or domestic partner, must provide written certification to the extent permitted by law to the
Company from the health care provider of the individual requiring care, which states:
(1) the date on which the serious health condition commenced;

(2) the probable duration of the condition;
(3) an estimate of the amount of time that the health care provider believes the associate needs to care for the
individual requiring the care; and
(4) that the serious health condition warrants the participation of the associate to provide care during the period of
treatment or supervision of the individual requiring care.
An associate who requests leave for his or her own serious health condition must provide written certification to the
extent permitted by law to the Company from his or her health care provider which states:
(1) the date on which the serious health condition commenced;

(2) the probable duration of the condition;
(3) that the associate is unable to perform the function of the associate’s position (including a statement of the
essential functions the associate is unable to perform) or must be absent from work for medical treatment.
Leave Details
Eligible associates may be granted up to a total of twelve (12) work weeks of CFRA leave during any rolling twelve (12)
month period measured backward from when leave is requested. In any situation, the length of leave granted will be
only for that period of time reasonably necessary to attend to the CFRA situation and will not exceed twelve (12) work
weeks. In the case in which the Company employs both parents who are eligible for leave under this policy, each
parent may take a leave not to exceed twelve (12) work weeks for the birth, adoption or foster care of their child within
a twelve (12) month period.
An associate returning from an approved CFRA leave of absence that does not exceed the maximum eligible length of
such leave will be reinstated to his or her original or equivalent position with no loss in seniority or benefits that accrued
prior to the leave of absence. If, however, due to business reasons, the original or equivalent position ceased to exist
during the leave period, and, had the associate not taken the leave, the associate would not otherwise have been
employed at the time reinstatement is requested, the associate will not be reinstated at the end of his or her leave
period.
During an approved leave under the CFRA, California’s Pregnancy Disability Leave law (and, if applicable under the
FMLA), the Company shall continue to provide medical coverage to the associate under its group health plan at the
level and under the same conditions that coverage would have been provided by the Company if the associate had
been continuously employed. The associate will remain personally responsible for paying the associate’s portion of the
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insurance premium during this time, including the associate’s portion of dependent coverage, if any. An associate’s
failure to pay premiums in a timely manner may result in a COBRA notice. If the associate fails to return to work for at
least thirty (30) days following the expiration of leave under this policy, the associate may be required to reimburse the
Company for the group health insurance premiums paid for by the Company on behalf of the associate, unless the
associate’s failure to return is caused by the continuation, recurrence, or onset of a serious health condition that entitles
the associate to leave under this policy or circumstances beyond the associate’s control.
During leave pursuant to this policy, the associate shall retain associate status with the Company and the leave shall
not constitute a break in service. An associate returning from leave shall return with no less service time credit than the
associate had when the leave commenced. Except, as specifically provided under this policy, an associate shall not
accrue service time or benefits during the period when they are on leave. Service time and benefits may accrue
during the portion of the leave, if any, that the associate is paid (including payment of the Company accrued vacation
or sick time), in accordance with the Company’s policies governing paid leaves.
Any associate who desires to take a CFRA leave must submit a written request to the Company, specifying the date on
which the leave will commence and the estimated duration of the leave. If the associate’s need for leave is
foreseeable, the associate must provide the Company with reasonable advance notice of the need for the leave – i.e.,
at least thirty (30) days’ notice. If the need for the leave is due to planned medical treatment or supervision, the
associate must use all reasonable efforts to schedule the treatment or supervision to avoid disruption to the operations
of the Company.
Any requests for extensions of a CFRA should be received at least five (5) workings days before the date on which the
associate was originally scheduled to return to work and must include the revised anticipated date(s) and duration of
the additional CFRA leave.
An associate may elect to use any accrued vacation time during the leave until such time all benefits are exhausted. If
the CFRA leave is for the associate’s own serious health condition, the use of accrued sick and/or vacation time during
the leave is required. The leave shall then be considered unpaid and no vacation/sick time will accrue. The use of
such accrued benefits shall not extend the period of the approved leave of absence. Associates receiving disability
pay, or Paid Family Leave from the State of California, are not required to use their vacation time or paid sick time while
receiving disability/PFL benefits but may do so to supplement their income.
As a condition of the associate returning from a leave taken because of the associate’s own serious health condition,
the Company may require medical certification and/or recertification from his or her health care provider that the
associate is able to resume work with or without reasonable accommodation. Associates who do not return to work at
the end of their authorized leave and who do not obtain an approved extension of the CFRA leave, and/or do not
request an extension of leave under another leave statute such as an accommodation under the Americans with
Disabilities Act or the Fair Employment and Housing Act, will be treated as having voluntarily resigned.
To the extent permitted by law, leave taken pursuant to the CFRA policy shall run concurrently with any other leave for
which the associate is eligible. One example of this would be a leave that is subject to both the FMLA and the CFRA.
Leave taken pursuant to this policy shall be counted against the associate’s rolling twelve (12) month calculation for
CFRA entitlements under the CFRA and any applicable State or local laws.
Work-related injuries or illnesses will be coordinated with CFRA, FMLA, and Workers’ Compensation according to Plan
provisions, and any other benefits provided to the associate in an effort to minimize the impact of the leave. Workers’
Compensation benefits will be coordinated in such a manner that associates may receive no more than regular
earnings from all sources.
Please remember, throughout the duration of the leave, the availability of benefits, the opportunity for reinstatement,
and other privileges associated with this leave are limited to the requirements of applicable state and federal law. No
express or implied contractual rights should be inferred from this policy.
All questions regarding CFRA leave should be addressed to Human Resources.
Bereavement Leave
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In accordance with the California Family Rights Act, associates who have worked for Company for at least 30 days before the
leave begins are eligible for up to five days of leave for the death of a family member. The first three days of leave will be with paid
leave consistent with Company policy. The additional two days of leave will be unpaid.
For purposes of this provision, “family member” means a spouse, child, parent, sibling, grandparent, grandchild, domestic partner, or
parent-in-law.
Associates may be required to provide documentation of the death of the family member within 30 days of the first day of leave.
Documentation may include a death certificate, a published obituary, or written verification of death, burial, or memorial services
from a mortuary, funeral home, burial society, crematorium, religious institution, or governmental agency.
Civil Air Patrol Leave

To the extent required by law, Highgate Hotels provides leave to qualifying civilian volunteers in the California wing of the
Civil Air Patrol. Associates who volunteer as part of the California Wing of the civilian auxiliary of the United States Air
Force (known as “Civil Air Patrol”) may be entitled to 10 or more days of unpaid leave per calendar year to respond to
certain emergency situations when responding to an emergency operational mission of the Civil Air Patrol. To be eligible
for such leave, an associate must have been employed for at least a 90-day period immediately preceding the
commencement of leave.
Lactation Break
Highgate Hotels will provide a reasonable amount of break time to accommodate a female associate’s need to express
breast milk for the associate's infant child. If possible, the break time should be taken concurrently with other break
periods already provided. If this time does not run concurrently with normally scheduled rest periods, associates should
clock out for this time and such time will be unpaid. Highgate Hotels will also make a reasonable effort to provide the
associate with the use of a room, or other location in close proximity to the associate's work area for the associate to
express milk in private.
Associates should notify their immediate supervisor if they are requesting time to express breast milk under this policy.
Highgate Hotels does, however, reserve the right to deny an associate’s request for a lactation break if the additional
break time will seriously disrupt operations.
Lactation Space Requirements. Highgate Hotels will provide associates with the use of a room or location, other than a
bathroom, in close proximity to the work area, to express milk in private. This location may be the place where the
associate normally works if it meets all other requirements. The location must also:
• be shielded from view and free from intrusion while the associate is expressing milk;
• be safe, clean, and free from hazardous materials;
• contain a surface on which to place a breast pump and personal items;
• contain a place to sit; and
• have access to electricity or alternative devices, such as extension cords or charging stations, needed
to operate an electric or battery-powered breast pump.
Also Highgate Hotels will provide access to a sink with running water and a refrigerator (or other cooling device, if a refrigerator is
not possible) suitable for storing milk, in close proximity to the employee’s workplace. If a multipurpose room is used for lactation and
other purposes, lactation use must take precedence over the other uses for the time it is in use for lactation purposes.
Highgate Hotels may make a temporary location available for lactation purposes if all of the following conditions are
met:
• Highgate Hotels is unable to provide a permanent lactation location due to space, operational, or
financial limitations;
• The temporary location is not a bathroom and is in close proximity to the associate’s work area;
• The temporary lactation location is shielded from view and free from intrusion while an associate
expresses milk; and
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• The temporary location otherwise meets the state law requirements for lactation accommodation.
Leave for Victims of Domestic Violence & Sexual Assault

To the extent required by law, associates who are victims of domestic violence or of sexual assault may receive unpaid
leave to: 1) obtain services from a domestic violence shelter or rape crisis center; 2) seek medical attention for injuries
caused by domestic violence or sexual assault; 3) obtain psychological counseling for the domestic violence or sexual
assault; or 4) take action, such as relocation, to protect against future domestic violence or sexual assault.
To take this leave, the associate must provide Highgate Hotels with advance notice of this leave. If advance notice is
not possible, the associate must provide Highgate Hotels with the following certification upon returning back to work: 1)
a police report showing that the associate was a victim of domestic violence or sexual assault; or 2) a court order
protecting the associate from the perpetrator or other evidence from the court or prosecuting attorney that the
associate appeared in court; or 3) documentation from a medical professional, domestic violence or sexual assault
victim advocate, health care provider, or counselor showing that the associate’s absence was due to treatment for
injuries from domestic violence or sexual assault.
The associate may choose to use any accrued personal time off, if available, for an absence described above.
Leave for Victims of Felony Crimes

To the extent required by law, associates who are victims of certain, specified felony crimes, or who are immediate
family members of a victim, a registered domestic partner of a victim, or the child of a registered domestic partner of a
victim, may receive unpaid time off from work to attend judicial proceedings related to that crime. To take this leave,
the associate must provide Highgate Hotels in advance with a copy of the notice of the proceeding. If advanced
notice is not possible, the associate must provide Highgate Hotels with appropriate documentation evidencing the
associate’s attendance at the judicial proceeding upon returning back to work.
Military Spouse Leave
Purpose
To provide a leave of absence for an associate who is the spouse (or registered domestic partner) of a qualified member of the
United States Armed Forces, National Guard or Reserves in accordance with applicable law.
Eligibility
To be eligible for a Military Spouse Leave, an associate must be (1) regularly scheduled to work, an average of twenty (20) hours per
week and (2) the spouse (or registered domestic partner) of a “qualified member” of the United States Armed Forces, National
Guard or Reserves, who is on leave from deployment during a “period of military conflict.”
Duration of Leave
Eligible associates may take up to ten (10) days unpaid leave. Associates may utilize accrued vacation during the
leave.
Procedure for Requesting Military Spouse/Registered Domestic Partner Leave

An eligible associate must (i) notify his or her supervisor in writing of the intent to take a Military Spouse Leave within two business
days of being notified that his or her spouse (or registered domestic partner) will be on leave from deployment and (ii) provide his or
her supervisor with written documentation certifying that the associate’s spouse (or registered domestic partner) will be on leave
from deployment during the period the associate is requesting leave.
Any request to extend the leave beyond ten days must be approved by the associate’s supervisor and will be treated as
a request for planned vacation and must be approved by the associate’s supervisor. Approval of requests for any
request to extend the leave beyond ten days will be subject to Highgate Hotels’ ability to provide alternative coverage
and/or its operational needs.
Definitions
Qualified Member – means (i) a member of the United States Armed Forces who has been deployed during a period of
military conflict to an area designated as a combat theater or combat zone by the President of the United States or (ii) a
member of the National Guard or Reserves who has been deployed anywhere during a “period of military conflict.”
Period of Military Conflict – means either a period of war declared by the United States Congress or a period of
deployment for which a member of a reserve component of the military is ordered to active duty.
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Miscellaneous
This policy is intended to comply with and will be interpreted in accordance with California Military & Veterans Code §395.10 and all
applicable regulations. To the extent this policy may conflict with such laws and regulations, those laws and regulations will control.
Organ and Bone Marrow Donation Leave

Highgate Hotels shall grant to an associate the following paid leaves of absence to assist with organ or bone marrow
donation:
A leave of absence not exceeding 30 days to an associate who is an organ donor in any one-year period, for the
purpose of donating his or her organ to another person.
A leave of absence not exceeding five days to an associate who is a bone marrow donor in any one-year period, for
the purpose of donating his or her bone marrow to another person.
a. In order to receive a leave of absence pursuant to this policy an associate shall provide written
verification to (human resources) that he or she is an organ or bone marrow donor and that there is a medical
necessity for the donation of the organ or bone marrow.
b. Any period of time during which an associate is required to be absent from his or her position by
reason of being an organ or bone marrow donor will not be considered a break in his or her continuous service
for the purpose of his or her right to salary adjustments, PTO, annual leave, or seniority. During any period that
an associate takes leave under this policy, Highgate Hotels will maintain and pay for coverage under any
group health plan, for the full duration of the leave.
c. Highgate Hotels may require as a condition of an associate's initial receipt of bone marrow or
organ donation leave that the associate take up to five days of earned but unused sick or vacation leave for
bone marrow donation and up to two weeks of earned but unused sick or vacation leave for organ donation.
d. Notwithstanding existing law, bone marrow and organ donation leave shall not be taken
concurrently with any leave taken pursuant to the federal Family and Medical Leave Act or the California
Family Rights Act.
e. Leave provided for pursuant to this section may be taken in one or more periods.
f. Upon expiration of a leave authorized by this policy, Highgate Hotels will restore the associate to the
position held by him or her when the leave began or to a position with equivalent seniority status, associate
benefits, pay, and other terms and conditions of employment. Highgate Hotels may decline to restore an
associate as required in this section because of conditions unrelated to the exercise of rights under this part by
the associate.
Pregnancy Disability Leave Of Absence

Pregnancy disability leave (“PDL”) is available for female associates with disabilities related to childbirth. “Disabled” as
used in this section includes, but is not limited to, severe morning sickness, prenatal or postnatal care, bed rest,
gestational diabetes, pregnancy-induced hypertension, preeclampsia, postpartum depression, childbirth, loss or end of
pregnancy, and/or recovery from childbirth or loss or end of pregnancy. Only your healthcare provider (as defined by
California law) may determine whether you are disabled.
An associate may take up to four months of leave per pregnancy regardless of length of service with the Company. The
four-month leave period is equivalent to the number of hours an associate would regularly work in 17-1/3 weeks. For
instance, a full-time associate who works 40 hours per week is entitled to 693 hours of leave. Associates who work more or
less than that are entitled to a pro rata or proportional amount of leave. Associates who are eligible and take such leave
will, on return from leave, have their same or similar position in accordance with state law. An associate may be
transferred to a less strenuous or hazardous position upon request, if such transfer is medically advisable.
A woman can take PDL at any time that her healthcare provider designates her as disabled by pregnancy, childbirth, or
related medical conditions. She can take leave at any time she is disabled during or after the pregnancy. She need not
take all of her leave at once. The pregnant associate can take PDL intermittently, as in the case of morning sickness early
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in the pregnancy, followed months later by the birth of the child.
Except in cases of emergency, you must provide the Company with advance notice that you require a leave or other
accommodation related to your pregnancy. If the need for leave is foreseeable, you must provide notice at least 30
days before the leave is to begin. If 30 days’ advance notice is not possible due to a lack of knowledge of when the
leave, reasonable accommodation, or transfer will begin, a change in circumstances, a medical emergency, or other
good cause, you must notify the Company as soon as possible. The Company will respond to your request as soon as
possible, and in any event, not later than 10 calendar days after receiving the request.
You are required to obtain a certification from your health care provider of your pregnancy disability or the medical
advisability of a transfer. The certification should include: (1) the date on which you became disabled due to
pregnancy or the date of the medical advisability of a transfer; (2) the probable duration of the period(s) of disability or
the period(s) for the advisability of a transfer; and, (3) a statement that, due to the disability, you are either unable to
work at all or to perform any one or more of the essential functions of your position without undue risk to yourself or to
other persons, or a statement that, due to your pregnancy, a transfer to a less strenuous or hazardous position or duties is
medically advisable. Failure to obtain the required certification may result in the delay or denial of your request for
leave.
PDL leave is unpaid by the Company. However, at your option, you may use any accrued vacation time or other
accrued paid time off as part of your PDL before taking the remainder of your leave on an unpaid basis. We require,
however, that you use any available sick leave during your PDL. The use of any paid leave will not extend the duration
of your PDL.
We encourage you to contact the Employment Development Department regarding your eligibility for state disability
benefits insurance during your leave.
When a pregnancy disability leave ends, the associate will be reinstated to the same position, unless either the job
ceased to exist because of legitimate business reasons or the means of preserving the job would substantially undermine
the ability of the Company to operate safely and/or efficiently. In most instances, if the same position is not available,
the associate will be offered a comparable position in terms of pay, benefits, job content, and promotional
opportunities.
State Mandated Insurance Benefit Programs
State Disability Insurance

By state law, we are required to deduct a certain amount from your pay to provide State Disability Insurance (S.D.I.).
S.D.I. benefits are payable when you cannot work because of illness or injury unrelated to your employment. For
information concerning these benefits, contact the Employment Development Department of the State of California,
which administers the S.D.I. program.
Family Temporary Disability Insurance

In addition, we are also required to withhold a certain percentage of your wages pursuant to the Family Temporary
Disability Insurance Act ("FTDI") in order to fund the Paid Family Care Leave Program. FTDI is another disability benefits
program that is administered by California’s Employment Development Department which allows eligible associates to
receive compensation for lost wages, for up to six (6) weeks in a twelve-month period, if you take time off work to
provide care for a seriously ill child, spouse, parent, or domestic partner or to bond with a new child.
Despite its name, the FTDI is not a "leave" program; it does not provide you with any entitlement to leave and it does not
protect your job while you are out on leave. In addition, you will be required to use up to two (2) weeks of accrued
vacation prior to receiving FTDI benefits. Note that you may not be eligible for FTDI benefits if you are receiving State
Disability Insurance, Unemployment Compensation Insurance or Workers’ Compensation benefits.
Time off for Literacy Assistance

Under state law, an associate who discloses a problem with literacy and who requests assistance in enrolling in an adult
literacy education program will receive assistance from their employer, as long as this will not cause undue hardship to
the employer. An employer’s duty to accommodate may include providing the associate with locations of local literacy
education programs or arranging for the literacy education provider to visit the job site. Employers are not required to
pay the associate for absences from work because of the associate’s participation in an adult literacy program.
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Unpaid Family School Partnership Leave

Highgate Hotels encourages its associates to be involved in the education of their children. Parents, guardians and
grandparents with custody of school age children (K-12) are eligible for up to forty (40) hours of unpaid leave each
school year to participate in school-related activities of their children, provided the following criteria are met.
The associate must personally notify his/her supervisor as soon as the associate learns of the need for the planned
absence. Associates will be denied time off if they do not provide their supervisors with adequate notice. Highgate
Hotels may require verification of the school-related activity. Associates are requested to schedule individually
scheduled activities, such as parent/teacher conferences, during non-work hours. Associates who request leave for
unauthorized purposes will be subject to discipline, up to and including termination.
Volunteer Civil Service Leave

To the extent required by law, Highgate Hotels gives time off to associates to perform emergency duty or to train as
volunteer firefighters, reserve peace officers or as emergency rescue personnel.
An associate who is a volunteer firefighter, reserve peace officer or volunteers as emergency rescue personnel will be
granted leave of absence not to exceed a total of fourteen (14) days in any calendar year for the purpose of engaging
in training for firefighting, law enforcement or working as emergency rescue personnel. If you need time off for training
on account of activities that fall under this policy, you should notify your supervisor as soon as possible so that
arrangements to accommodate your absence may be made.
Time off to serve or train as a volunteer firefighter, reserve peace officer or as emergency rescue personnel is unpaid;
however, you may choose to use accrued, but unused vacation during this time off. Remember, you should notify your
supervisor as far in advance as possible and please keep in mind that Highgate Hotels may request a copy of your call-
to-duty orders, training certificates or other verification that you were called to duty to serve or train. No action will be
taken against any associate in any manner for requesting or taking any time off as provided for under this policy.
Time off to serve in the Civil Air Patrol is unpaid; however, you may choose to use accrued, but unused vacation during
this time off. Remember, you should notify your supervisor as far in advance as possible and please keep in mind that
Highgate Hotels may request a copy of your certification from the Civil Air Patrol or other verification that you were
called to duty to serve. If the requisite certification is requested by the employer but the associate does not provide it,
the leave may be denied. If proper certification is provided, no action will be taken against any associate in any
manner for requesting or taking any time off as provided for under this policy.
Vacation
For associates working in California, the accrual cap is 1.5 times the annual vacation accrual.
Meal Periods
Except for certain exempt associates, all associates who work five (5) or more hours in a day are required to take a thirty
(30) minute duty-free meal period. An associate who works over ten (10) hours in a day is required to take a second
thirty (30) minute duty-free meal period unless the associate elects to waive the second meal period as provided for
below. When an associate works for a work period of more than five hours, a meal period must start no later than the
end of the associate’s fifth hour of work (in other words, before the start of the associate’s sixth hour of work). Associates
are completely relieved of their job responsibilities during their meal periods. For this reason, unless there is a valid written
agreement for an on-duty meal period, associates must clock in and out for their meal periods or record the beginning
and ending time of the meal period on their timesheet every day. Associates may be required to sign a certification
providing, among other things, that they have taken all of their daily meal periods during the pertinent pay period.
Associates may leave the hotel during meal breaks but must timely return from break.
Waiver of Meal Period. Associates may waive, if the Company agrees, their meal periods under the following
circumstances. If an associate will complete their work day in six (6) hours, the associate may waive their meal period.
Associates who work over ten (10) hours in a day may waive their second meal period only if they take their first meal
period and they do not work more than twelve (12) hours that day. Anytime an associate elects to waive a meal period
they must submit a written request and receive prior written authorization from their supervisor. Associates may not
waive meal periods to shorten their work day or to accumulate meal periods for any other purpose. Associates must sign
a written meal period waiver.
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No Company manager or supervisor is authorized to instruct an associate to forego a meal or rest period. Associates should
immediately report a managers’ or supervisor’s instruction to skip a meal period to Human Resources.
On Duty Meal Period. In limited situations, certain designated associates may be required to work an on-duty meal
period due to the nature of the associate’s duties. Unless your supervisor directs you to take an on-duty meal period due
to the nature of your job duties and you agree to an on-duty meal period in writing, you will not be permitted to take an
on-duty meal period.
Rest Periods
The Company provides all full-time non-managerial and other non-exempt associates with the opportunity to take a ten
minute rest period for every four (4) hours worked (or a major fraction thereof), which should be taken so far as
practicable in the middle of each work period. The Company generally will not authorize a rest period for associates
whose total daily work time is less than three and one-half (3 ½) hours. Associates are expected to schedule their rest
periods at their own discretion under these guidelines unless instructed otherwise by a supervisor. Rest periods may not
be combined with meal periods. Associates may leave the hotel during rest breaks but must timely return from break.
Rest periods are counted as hours worked, and thus, associates are not required to record their rest periods on their
timesheets or time cards. Rest periods may not be waived to shorten your workday or be accumulated for any other
purpose. Associates may be required to sign a certification providing, among other things, that they have taken all of
their rest periods during the pertinent pay period. Associates may leave the premises during their rest breaks but must
return timely from breaks or be subject to disciplinary action.
The following chart shows the number of rest breaks for which non-exempt associates are entitled to depending on the
number of hours worked in a given workday.
Hours Worked Number of Rest Breaks
0 – 3.5 0
3.5 – 6.0 1
6.0 – 10.0 2
10.0 – 14.0 3
14.0 – 18.0 4
Overtime Pay
The nature of our business sometimes requires associates to work overtime. Your supervisor will notify you when you are
required to work overtime. We expect and appreciate your cooperation. We will try to provide you with advance
notice of any overtime that will be required of you.
If you are a California non-exempt/hourly associate, you will be paid overtime as follows:
• One-and-a-half times your regular rate of pay for any hours worked over eight hours per workday or 40 hours
per workweek(the workday beings at 12:01 am and ends at midnight);
• One-and-a-half times your regular rate of pay for any hours worked during the first eight hours on the seventh
consecutive day in the same workweek;
• Double your regular rate of pay for any hours worked over 12 hours per workday or for any hours worked over
eight hours on the seventh day of the workweek.
There may be exceptions to these standards where allowed by law.
Please remember you are not permitted to work overtime unless it has been authorized in advance by your supervisor.
The Company pays all overtime wages required by law, and supervisors are expressly forbidden from instructing or
encouraging associates to work overtime off the clock. Associates should immediately report to Human Resources any
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instruction or suggestion by a supervisor that an associate work off the clock.
Reporting Time Pay

If you report to work as scheduled or at the Company’s request, but are not put to work because of an unanticipated
closure, the Company will pay you for at least half of the hours that you were scheduled for or usually worked, but never
less than two hours pay and never more than four hours pay.
Reporting time pay will not be owed or paid under the following circumstances:
• When a closure is caused by threats to associates or company property or when recommended by a civil
authority, such as the police;
• When public utilities fail, such as water, gas, electricity, or sewer; or
• When work is interrupted by an act of God or other causes not within the company’s control.
Final Pay
Highgate Hotels pays terminating terminated associates for the time worked through the date of termination. If an
associate is discharged by Highgate Hotels, the associate will be paid all compensation due immediately at the time of
discharge. If an associate quits, his/her wages are due and payable not later than 72 hours thereafter. Final pay is
issued on the next regularly scheduled pay date or as otherwise required by state law. Taxes and other legal
withholdings will be taken from your final pay.
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COLORADO ADDENDUM (For Colorado Associates Only)
COLORADO ADDENDUM – For Colorado Associates Only
To our Colorado associates: please note that wherever Colorado law provides for or offers greater protections to our
associates, Colorado law will govern. Please contact Human Resources with questions about any policies in this
Addendum.
Public Health Emergency Leave (“PHEL”)
In addition to paid sick and safe time, all employers in Colorado are required to provide employees with additional paid
sick leave during a public health emergency (for the reasons discussed below under “Reasons for Leave”). Specifically, on
the date a public emergency is declared, all employers must supplement each employee’s accrued PSST as necessary to
ensure that an associate can take the following amounts of PHEL:
• For employees who normally work 40 or more hours a week: at least 80 hours of PHEL; or
• For employees who normally work fewer than 40 hours in a week: the greater of (a) the amount of time
the associate is scheduled to work in a 14-day period or (b) the amount of time the associate actually
works during an average 14-day period.
Employers may count an employee’s unused, accrued PSST toward the supplemental PHEL required. Employees are
entitled to PHEL one time during the entirety of a public health emergency (even if it is amended, extended, etc.).
Employees may use PHEL under the Act until 4 weeks after the official termination or suspension of the public health
emergency. Employers may not require documentation for taking PHEL.
Qualifying Reasons for Leave
Eligible employees may use the one-time allotment of PHEL for the following reasons:
• an employee’s need to self-isolate (or to care for a family member who is self-isolating) because the associate
or family member is diagnosed with, or experiencing symptoms of, the communicable disease that caused the
public health emergency;
• to seek or obtain (or to care for a family member who needs) medical diagnosis, care, or treatment if
experiencing symptoms of a communicable disease that is the cause of the public health emergency;
• to seek (for the or a family member) preventive care concerning a communicable disease that is the cause
of the public health emergency;
• if it has been determined by a local, state, or federal public official or health authority having jurisdiction, or by
the associate’s or family member’s employer, that the presence of the associate, or the associate’s family
member needing care, on the job or in the community would jeopardize the health of others because of
exposure to the communicable illness or because the associate or family member is exhibiting symptoms of the
illness (regardless of diagnosis);
• to care for a child or other family member when the child care provider is unavailable due to a public health
emergency, or if the child’s or family member’s school or place of care has been closed due to a public health
emergency—including if the school or place of care is physically closed but providing instruction remotely; or
• if an associate is unable to work because the associate has a health condition that may increase susceptibility
to, or risk of, a communicable disease that is the cause of the public health emergency
Unused PHEL is not paid out at termination.
Verification
If an associate uses PSST for 4 or more consecutive work days, an employer may require “reasonable documentation”
that the PSST is for an authorized purpose. Employers may not require disclosure of details relating to domestic violence,
sexual assault, or stalking, or the details of an associate’s or family member’s health information, as a condition of
providing PSST. Employers may not require documentation for an associate’s use of the one-time allotment of PHEL.
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Overtime
Overtime Rate: non-exempt associates will be paid time and one-half of the regular rate of pay for any work in excess of:
1) Forty (40) hours per workweek;
2) Twelve (12) hours per workday, or
3) Twelve (12) consecutive hours without regard to the starting and ending time of the workday (excluding
duty free meal periods), whichever calculation results in the greater payment of wages.
Colorado Overtime and Minimum Pay Standards Order
The Company incorporates Colorado Overtime and Minimum Pay Standards Order (“COMPS”) into the Colorado State
Addendum. Please see written notice below. By signing the Associate Handbook, associates are also acknowledging
receipt of this written notice under Colorado COMPS Order #36 Poster.
Please reach out to Human Resources with any questions.
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Colorado Healthy Families and Workplace Act

Please be advised that the Company intends to ensure that all eligible associates who work in Colorado will receive and be permitted
to use paid sick and safe time (“PSST”) in accordance with the Colorado Healthy Families and Workplaces Act (“HFWA”), up to the
maximum annual accrual and usage amount of 48 hours. Additionally, during the course of a public health emergency, associates
who wish to use personal protection equipment (“PPE”) in addition to PPE provided by the Company, if any, are permitted to do so if
the additional PPE provides more protection than the Company’s provided equipment, is recommended by a government health
agency, and does not result in an inability to perform a work task.
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56
CONNECTICUT ADDENDUM (For Connecticut Associates Only)
CONNECTICUT ADDENDUM – For Connecticut Associates Only

CONNECTICUT FAMILY AND MEDICAL LEAVE ACT
Effective January 1, 2022, under Connecticut’s Family and Medical Leave Act, Eligible Associates may receive up to twelve weeks of
leave in a twelve-month period for (1) the birth of a child of the associate; (2) the placement of a child with the associate in
connection with the adoption or foster care of the child; (3) to care for a Family Member with a serious health condition; (4) a serious
health condition of the associate; (5) to serve as an organ or bone marrow donor; (6) a qualifying exigency related to the associate’s
spouse, son, daughter or parent being on active duty or having been notified of an impending call or order to active duty in the
armed forces; and (7) for reasons related to family violence (but subject to a twelve day limitation). Associates who have earned
wages of $2,325 in the highest-earning quarter of the first four of the five most recently completed quarters (the "base period") and are
currently employed, or were employed within the last twelve weeks, are eligible for paid family leave administered by the Connecticut
Paid Leave Authority.
"Eligible Associate" means an associate who has been employed for at least three months immediately preceding his or her request for
leave. A Family Member means a son, daughter, parent, parent-in-law, grandparent, grandparent-in-law, sibling, spouse of the
associate, or an individual related to the associate by blood or affinity, and whose close association the associate shows to be the
equivalent of those family relationship.
Except in the case of leave taken because of the birth or placement of a child with the associate in connection with adoption or
foster care, unless otherwise agreed by the Company, an Eligible Associates may be eligible to take leave on an intermittent basis for
a serious health condition of an Eligible Associate or covered family member. Eligible Associates may be entitled to two additional
weeks for pregnancy-related health conditions resulting in incapacitation. An associate may be required to use concurrently utilize
accrued paid vacation/personal leave as part of such family/medical leave; provided that Eligible Associates may choose to retain
up to two weeks of accrued paid vacation/personal leave, if available, and the total compensation received by the associate
cannot exceed the associate's regular rate of compensation. For those associates who qualify for leave under the federal Family
Medical Leave Act, leave pursuant to this policy will run concurrently with leave to which the associate may be entitled under the
federal Family Medical Leave Act.
If the leave is foreseeable for the birth or placement of a child due to adoption or foster care, the associate must provide at least 30
days advance notice before the leave is to begin, unless the date of birth or placement requires leave to begin in less than 30 days, in
which case the associate should provide as much notice as is practicable. If the leave is for a serious health condition, the associate
must provide 30 days advance notice, unless the date of the treatment requires leave to begin in less than 30 days, in which case the
associate must provide as much notice as is practicable. For a serious health condition of a covered family member, the associate
must provide certification stating (1) the date on which the serious health condition began; (2) the probable duration; (3) appropriate
medical facts within the health care provider’s knowledge regarding the condition; and where applicable, (4) information regarding
the need for intermittent leave. For the associate’s own serious health condition, the associate must provide certification stating (1) the
date on which the serious health condition began; (2) the probable duration; (3) appropriate medical facts within the health care
provider’s knowledge regarding the condition; and where applicable, (4) information regarding the need for intermittent leave.
Associates who take leave under the law are entitled to be restored to their original positions or, if the original position is not available,
to an equivalent position with equivalent benefits, pay, and terms and conditions of employment. The law prohibits retaliation for
Eligible Associates requesting or using paid leave under state law. While associates are encouraged to report claims internally, if an
associate believes that he or she has been subjected to retaliation, he or she may file a formal complaint with the Connecticut
Department of Labor.
Associates will apply to the Company for time away from work, by contacting Human Resources Paid leave will be administered by
the Connecticut Paid Leave Authority. To receive income replacement while on leave, you must contact the Connecticut Paid Leave
Authority at https://ctpaidleave.org/. In some situations, it will be necessary for the associate, the Company and the Connecticut Paid
Leave Authority to communicate in order to establish the reason for the leave or to verify the duration and frequency of the leave.
POLICY AGAINST UNLAWFUL SEXUAL HARASSMENT
Sexual harassment is illegal and prohibited by Connecticut and federal law in the workplace, pursuant to § 46a-60(a)(8) of the
Connecticut General Statutes and Title VII of the Civil Rights Act of 1964, 42 U.S.C. § 2000e et seq.
While associates are encouraged to report claims internally, if an associate believes that they have been subjected to sexual
harassment, the associate may file a formal complaint with the Connecticut Commission on Human Rights and Opportunities (the
“Commission”) at 860-541-3400, CT Toll Free 1-800-477-5737, or online at www.ct.gov/CHRO.
Individuals who engage in acts of sexual harassment may be subject to civil penalties in the form of a cease and desist orders, back
pay, compensatory damages, hiring, promotion or reinstatement, emotional distress, as well as attorney’s fees, costs, pre- and post-
judgment interest and punitive damages (if the case is tried in court). Individuals may also be subject to additional criminal penalties
stemming from acts of sexual harassment.
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CONNECTICUT ADDENDUM (For Connecticut Associates Only)
Connecticut law requires that a written complaint be filed with the Commission within 300 days of the date the alleged harassment for
events occurring.
ELECTRONIC MONITORING
Associates should recognize that their work activities and communications may be subject to electronic monitoring. “Electronic
monitoring” is defined as “the collection of information on an employer’s premises concerning associates’ activities or
communications by any means other than direct observation, including the use of a computer, telephone, wire, radio, camera,
electromagnetic, photoelectronic or photo-optical systems, but not including the collection of information for security purposes in
common areas of the employer’s premises which are held out for use by the public, or which is prohibited under state or federal law.”
Associates may be subject to electronic monitoring or recording (including sound, voice or video devices) while on the Company’s
premises, except that associates will not be subject to any such monitoring or recording in areas designed for the health or personal
comfort of the associates or for safeguarding of their possessions, such as rest rooms, locker rooms or lounges.
Associates should understand that their activities involving Company computer equipment and computer and/or electronic
documents, data and communications, including e-mail and internet usage, are subject to being monitored, recorded and reviewed.
Associates should be aware that the fact that a document, data or communication has been “deleted” by the associate does not
mean that the item cannot be monitored or retrieved and reviewed.
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DISTRICT OF COLUMBIA ADDENDUM (For D.C. Associates Only)
DISTRICT OF COLUMBIA ADDENDUM – For D.C. Associates Only

DC UNIVERSAL PAID LEAVE
Eligible associates may qualify for paid leave benefits under the DC Universal Paid Leave Act (UPLA).
Eligibility. To be eligible for UPLA leave benefits, an individual must be employed by the Company at the time when he or she applies
for UPLA benefits. Additionally, the associate either (a) must spend more than 50% of his or her working time in the District of Columbia,
or (b) must be based in the District, regularly spend a substantial amount of his or her work time in the District, and not spend more
than 50% of his or her work time in another jurisdiction. UPLA benefits will not be paid to any person who is receiving unemployment
benefits or long-term disability payments.
Types and Amounts of Leave. Eligible associates may apply for UPLA leave benefits for any of the following three qualifying reasons:
1. Parental leave. Eligible associates may qualify for up to 8 weeks of paid parental leave within a 52-workweek period for
events associated with the birth of a child, the placement of a child for adoption or foster care, or the placement of a child
for whom the associate legally assumes and discharges parental responsibility.
2. Family leave. Eligible associates may qualify for up to 6 weeks of paid family leave within a 52-workweek period to care for a
family member with a serious health condition.
3. Medical leave. Eligible associates may qualify for up to 2 weeks of paid leave within a 52-workweek period to care for his or
her own serious health condition.
Associates may only receive UPLA leave benefits for a maximum of 8 weeks per year, regardless of the type of leave taken. UPLA
leave may be taken on a continuous or intermittent basis.
To the fullest extent permitted by law, UPLA leave shall run concurrently with leave taken under the federal Family Medical Leave Act,
the DC Family Medical Leave Act, and the DC Accrued Sick and Safe Leave Act.
Notice to Employer. If an associate’s need for UPLA leave is foreseeable, he or she must provide written notice to the Company at
least 10 days before taking leave. The written notice must include the qualifying reason for the absence (within the parameters of the
Health Insurance Portability and Accountability Act of 1996 (HIPPA)) and the expected duration of the paid leave.
If an associate’s need for UPLA leave is unforeseeable, he or she must notify the Company orally or in writing before the start of the
work shift for which the paid leave is being used. In the case of an emergency that prevents an eligible associate from giving notice
to the Company before the start of the work shift for which the associate intends to take leave, the associate (or individual acting on
behalf of the associate) must notify the Company orally or in writing within 48 hours of the emergency occurring.
Applying for Leave. The DC Department of Employment Services, Office of Paid Family Leave (OPFL) is solely responsible for
administering the paid leave benefits available under the UPLA. To apply, eligible associates may go online at
https://dcpaidfamilyleave.dc.gov/how-to-apply-for-benefits/ and submit an application with the OPFL following the occurrence of a
qualifying event. The OPFL determines whether an eligible associate qualifies for parental leave, family leave, or medical leave. In
addition, OPFL determines the amount of paid leave benefits an eligible associate will receive based on a set formula, not to exceed
$1,000 per week.
Discrimination and Retaliation Prohibited. The Company will not discriminate or retaliate against any individual who exercises his or her
rights under the UPLA. An individual who in good faith believes that he or she has been subjected to discrimination or retaliation in
violation of the UPLA has the right to file a complaint with the DC Office of Human Rights.
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HAWAII ADDENDUM (For Hawaii Associates Only)
HAWAII ADDENDUM – For Hawaii Associates Only
Equal Opportunity Employment
It is the policy of Highgate Hotels to provide equal employment opportunity regardless of race, color, age, religion, sex,
gender, national origin, ancestry, disability, pregnancy, genetic information, uniformed services, veteran status, sexual
orientation, gender identity and expression race, sex, reproductive health decision, sexual orientation, marital status,
arrest and court record, domestic or sexual violence victim status, breastfeeding, assignment of income for child support,
credit history or any other legally protected classification. This policy of nondiscrimination prevails throughout all aspects
of the employment relationship, including but not limited to recruitment, selection, placement, transfer, promotion,
layoff/recall, termination, training, working conditions, discipline, discharge, benefits and compensation.
Hawaii Family and Medical Leave
Under the Hawaii Family Leave Law (HFLL), associates may be eligible for a period of job-protected unpaid leave for
certain family and medical reasons as described below. The Company has posted a notice of HFLL eligibility in its Hawaii
facilities and has provided written information about an associate’s HFLL rights and responsibilities at the time of hire. The
information in those posters and provided at the time of hire are incorporated into this policy by reference.
General Eligibility
To be eligible for HFLL leave, associates must have worked at least six consecutive months regardless of the number of
hours worked during the six-month period.
Types and Duration of HFLL Leave
An associate may be eligible for up to four (4) weeks of family leave during a 12-month period (measured backwards
from the date an associate uses HFLL leave) for:
• the birth or adoption of a child or

• to care for the associate’s child, grandchild, spouse or reciprocal beneficiary, sibling, or a parent with a serious
health condition.
“Reciprocal beneficiary” means an adult who is in a valid reciprocal beneficiary relationship with another adult defined
as follows:
• each of the parties be at least eighteen years old;

• neither of the parties be married , a party to another reciprocal beneficiary relationship , or a partner in a civil
union;
• the parties be legally prohibited from marrying one another;
• consent of either party to the reciprocal beneficiary relationship has not been obtained by force, duress, or
fraud; and
• each of the parties sign a declaration of reciprocal beneficiary relationship in compliance with Hawaii law.
A “child” under this Policy may be of any age and can be a biological, adopted, or foster child, a stepchild, or a legal
ward of the associate.
A “parent” includes a biological, foster, or adoptive parent, a parent-in-law, a stepparent, a legal guardian, a biological
or adoptive grandparent, or a grandparent-in-law.
HFLL leave need not start immediately upon the birth or adoption of a child or the beginning of a serious health
condition. However, leave under this Policy for the birth of a child must be taken within 12 months after the child's birth.
Associates can take HFLL leave for the adoption of a child when a court or authorized agency places the child with
them or allows them to retain custody of the child before the adoption decree is issued. Unused family leave does not
carry over to the next calendar year.
Spouses Working Together
Spouses who both work for Highgate Hotels can use their HFLL leave at the same time and without regard to the
availability of other family members.
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Intermittent Leave
Intermittent leave is available under the HFLL, including for the birth or adoption of a child. In order to accommodate a
request for intermittent leave, Highgate Hotels may in some instances modify an associate’s existing, regular job duties or
temporarily transfer an associate to an available alternative position for which he/she is qualified. Associates must agree
to any modifications to job duties or temporary transfers to an alternative position. Pay or benefits will not be affected.
Substitution of Paid Leave for Unpaid Leave
Associates may choose to concurrently exhaust any accrued and available insurance benefit, workers' compensation
benefit, unemployment compensation due to illness or disability, temporary disability insurance benefit, vacation time,
personal days, or up to 10 days of accrued and available sick leave for all or some of the four (4) week HFLL leave.
For purposes of the HFLL Policy, sick leave means accrued and available increments of compensated leave that
associates can use:
• when they are physically or mentally unable to perform their duties due to an illness, injury, or medical condition;
• to obtain a professional diagnosis or treatment for their medical condition; or
• for other personal medical reasons, such as pregnancy or a physical examination.
Except for the above, HFLL leave is unpaid. Unused HFLL leave does not carry over from one 12-month period to the
next.
Notice of Need for HFLL Leave
If the need for HFLL leave is foreseeable, associates must give at least 30 days advance notice in writing. If this notice is
not possible or practicable, associates must give verbal notice within two (2) workdays of the start of the leave and a
written notice as soon as practicable.
If the need for HFLL leave is unforeseeable, associates must give verbal notice within two (2) workdays of the start of the
leave or as soon as practicable. Written notice confirming the need for HFLL leave must be provided as soon as
practicable. If associates fail to provide notice as required without a reasonable excuse, Highgate Hotels may delay
HFLL leave until proper notice is provided as permitted by law.
The notice of need for HFLL leave must include the general reason for the leave request (if known) and the anticipated
start date and duration of this leave (if known). Highgate Hotels may request additional information to determine
whether a certification to support a need for HFLL leave is necessary.
Documentation Supporting the Need for Leave
Highgate Hotels requires the following types of written certification to verify an associate’s need for HFLL leave:
• A statement issued by a health-care provider or family court for the birth of a child.
• A statement issued by a recognized adoption agency, the attorney handling the adoption, or the person officially
designated by the birth parent to select and approve the adoptive family for the placement of a child with them for
adoption. Associates can also provide the adoption petition filed with the court.
• A statement issued by the patient's health-care provider to care for a child, spouse, reciprocal beneficiary, sibling, or
parent with a serious health condition. The document must state:
• the patient's name and relationship to the associate;

• the health-care provider's name, title, type of practice or field of specialization, location, and
signature;
• the patient's condition qualifies as a serious health condition for HFLL leave purposes;
• the associate is needed to participate in the patient's care;
• the patient's condition requires hospitalization or the health-care provider's continuing treatment or
supervision;
• an estimate as to when the serious health condition began and how long the associate will need to
care for the patient; and
• whether the associate will need to take intermittent family leave.
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• Reasonable documentation or statement of the relationship to confirm family relationships.

Reasonable documentation include but are not limited to a court document or a birth,
marriage, or reciprocal beneficiary certificate.
If the certification is incomplete, the associate will have the opportunity to provide the necessary information.
If the need for HFLL leave is foreseeable, associates may be required to provide certification before the leave starts. If
the need for HFLL leave is unforeseeable, associates may be required to provide certification within two (2) workdays
after leave starts. If an associate needs to take HFLL leave in more than one 12-month period due to the chronic,
continuous nature of the family member's serious health condition, the Company may require that the associate provide
certification for each period. Certification may also be required for any extensions of an approved HFLL leave when the
original request for leave is under the four-week maximum and the extension request is made within the 12-month
period.
Generally, associates are required to pay for any required certifications.
Recertification
Highgate Hotels may require recertification at the Company’s expense during any 12-month period, but no more than
once every 30 days for the following reasons:
• circumstances described by the previous certification have changed significantly (e.g. the duration of the
illness, the nature of the illness, and complications); or
• the Company has received information that casts doubt on an associate’s stated reason for the absence.
Pay and Benefits
HFLL leave can consist of unpaid or paid leave or a combination of both. The Company and associate may mutually
agree to retroactively apply accrued and available paid leave to cover unpaid HFLL leave after an associate returns to
work.
Return to Work
Associates are permitted to return to whatever position they would have held had they not taken HFLL leave. Generally,
this means associates returning from HFLL leave, or who provide at least two days advance notice of an earlier return to
work date, will be promptly returned to the job position that they held when they went on leave, or an equivalent one.
If the associate would have lost their position even if they had not taken HFLL leave, then there exists no reinstatement
right. For example, if the associate’s position is eliminated because of a reduction in force, then no reinstatement right
exists.
Associates retain any benefits accrued before the start of HFLL leave, except for any paid leave substituted for unpaid
HFLL leave and any accrued leave benefits that did not carry over from one year to the next. Associates who take HFLL
leave are entitled to pay and benefit changes as if they had not taken HFLL leave, unless these changes are contingent
on seniority or accrual pursuant to policy or contract.
This HFLL Policy does not grant or deny associates the accrual of seniority or benefits during a period of HFLL leave or any
right, benefit, or position that they would have been entitled to if they had not taken HFLL leave.
Temporary Disability Insurance
The Company provides temporary disability insurance (TDI) benefits to eligible associates who experience a covered
disability. Depending on an eligible associate’s average weekly wage, the weekly TDI benefit is generally calculated as
58 percent of the associate’s average weekly wage up to the annually established maximum, which is subject to
change each year. An eligible associate’s maximum total benefit for a claim is 26 times the weekly benefit. For
associates who qualify for TDI benefits, a portion of the premiums is deducted from wages subject to legal requirements.
For more information about your eligibility for TDI benefits, please contact Human Resources.
Pregnancy Disability Accommodation and Leave
Highgate Hotels will make reasonable accommodations for female associates affected by pregnancy, childbirth, or
related medical conditions. The Company will also provide unpaid leave for a reasonable period if a disability results
from an associate’s pregnancy, childbirth or related medical condition.
"Reasonable period of time" as used in this Policy shall be determined by the associate’s physician taking into consideration the
associate’s physical condition and the job requirements. The Company may require a medical certification of the estimated
amount of pregnancy disability leave needed and the estimated beginning and ending dates of the leave.
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Prior to returning to work from pregnancy disability leave, associates must provide a medical certificate from the
associate’s physician approving her return to work. Upon return, associates will be reinstated to their former positions or a
comparable one, without loss of accumulated service credits and privileges.
Leave for Bone Marrow, Peripheral Blood Stem Cell, and Organ Donation
Associates with at least one (1) year of employment may take up to seven (7) days of leave per calendar year to
donate bone marrow or peripheral blood stem cells or take up to 30 days per calendar year to serve as an organ donor.
Associates may be required to provide written verification that the associate will serve as a donor and the medical
necessity of the donation. Group health insurance coverage will continue during the duration of the leave. At the end
of the leave, associates may return to their former position or an equivalent one. This leave does not run concurrently
with FMLA leave of Hawaii Family Leave.
National Guard Leave
Associates may take a leave of absence to perform services in the National Guard without loss of seniority. At the end of
the leave, the Company will return associates to their former or a like position unless the Company’s circumstances have
changed such that reinstatement is no longer possible or reasonable. If an associate can no longer perform the job
duties of the former position, the associate may return to a position for which he/she is qualified and which is as similar to
the previous position as possible.
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ILLINOIS ADDENDUM (For Illinois Associates Only)
ILLINOIS ADDENDUM – For Illinois Associates Only

To our Illinois associates: please note that wherever Illinois law provides for or offers greater protections to our associates,
Illinois law will govern. One or more of these policies may not be applicable to associates subject to a Collective Bargaining
Agreement.
Harassment in Illinois (Including Chicago)
The Company hopes that any incident of sexual harassment can be resolved through the internal Reporting Procedure
outlined in the handbook. However, in Illinois, associates have the right to file formal charges with the Illinois Department
of Human Rights (IDHR) and/or the United States Equal Employment Opportunity Commission (EEOC). A charge with
IDHR must be filed within 300 days of the incident of sexual harassment. A charge with EEOC must be filed within 300
days of the incident.
The State of Illinois also has created a Sexual Harassment Helpline: 1-877-236-7703 which is administered by the Illinois
Department of Human Rights (IDHR).
ADMINISTRATIVE CONTACTS
Illinois Department of Human Rights (IDHR)

Chicago: 312-814-6200 or 800-662-3942
Chicago TTY: 866-740-3953
Springfield: 217-785-5100
Springfield TTY: 866-740-3953
Illinois Human Rights Commission (IHRC)

Chicago: 312-814-6269
United States Equal Employment Opportunity Commission (EEOC)

Chicago: 800-669-4000
Chicago Commission on Human Relations

740 N. Sedgwick, 4th Floor
Chicago, IL 60654
312-744-411
cchr@cityofchicago.org
Associates working in Chicago, Illinois are also reminded that sexual harassment and retaliation are illegal in the City of Chicago.
The Human Rights Ordinance defines sexual harassment as any (i) unwelcome sexual advances or unwelcome conduct of a sexual
nature or (ii) requests for sexual favors or conduct of a sexual nature when submission to such conduct is either explicitly or implicitly
a term or condition of an individual’s employment or such conduct has the effect of creating a hostile or offensive work
environment.
Associates may report sexual harassment using the reporting avenues set forth in the harassment policy in the main handbook. The
Company prohibits sexual harassment and will not retaliate against anyone that brings a complaint of sexual harassment or
participates in an investigation of sexual harassment. All associates will be provided annual sexual harassment training in
accordance with applicable law.
Pregnancy Accommodations in Illinois
A. Eligibility:
This policy applies to all applicants or associates of the Company in the State of Illinois, and controls where it may
conflict with the Company’s other policies.
B. General Provisions:
The Company complies with employment laws applicable to mothers and expectant mothers, including the
Family Medical Leave Act, Pregnancy Discrimination Act, Americans with Disabilities Act and Illinois Human Rights
Act. In Illinois, it is the Company’s policy to make reasonable accommodations for pregnancy, childbirth and
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medical and common conditions related to pregnancy and childbirth if requested by an applicant or associate,
and agreed upon.
C. Procedure for Requesting Accommodations:

1. Illinois applicants or associates that require accommodation(s) for pregnancy, childbirth, or medical or
common conditions related to pregnancy or childbirth shall make the request to her immediate supervisor
or Human Resources, which will work with them to determine any effective reasonable accommodation(s).
An accommodation(s) may not be reasonable where it poses an undue hardship on the Company.
2. The associate may be required to provide documentation from her physician to support the need for the
reasonable accommodation(s). Documentation may include the medical justification for the requested
accommodation(s), a description of the reasonable accommodation(s) that is medically advisable, the
date the reasonable accommodation(s) became medically advisable, and the probable duration of the
reasonable accommodation(s).
3. Associates have the right to reject any unsolicited accommodation offered by the Company. Additionally,
associates have the right to continue working during a pregnancy if a reasonable accommodation is
available which would allow the associate to continue to perform her job.
D. Enforcement:
The Company prohibits discrimination, harassment, and retaliation against applicants and associates for
requesting and/or using accommodation(s). If an applicant or associate experiences such prohibited conduct,
they must file a complaint with the Company as set forth in the Company’s policies. Associates have the right to
file a charge with the Illinois Department of Human Rights within 300 days of the conduct and/or the United States
Equal Employment Opportunity Commission within 300 days of the conduct.
Illinois Department of Human Rights U.S. Equal Employment Opportunity Commission

Chicago: 312-814-6200 or Chicago: 800-669-4000
800-662-3942 Chicago TTY: 800-869-8001
Illinois Breastfeeding/Lactation
The Illinois Nursing Mothers in the Workplace Act provides paid break time to nursing mothers to express milk as needed
during work hours.
During at least the first year after her child is born, a nursing mother may take lactation breaks whenever she needs, for a
“reasonable” time. Employers must provide a private location in close proximity to the associate’s work space, other than
a bathroom stall, for this purpose.
The break time may run concurrently with other breaks already provided to the associate. The associate’s compensation
may not be reduced for the time used for expressing milk or nursing a baby.
Meal Breaks
Non-exempt associates will be provided meal breaks in accordance with Illinois law. Associates should contact their supervisor for
more information. A 20-minute meal break is required for associates working 7.5 continuous hours or more. The meal break must
begin no later than 5 hours after the start of the work period. In most properties, associates will be provided a 30 minute meal break.
Effective January 1, 2023, associates that work more than 7.5 consecutive hours are entitled to an additional 20-minute meal break
for every additional 4.5 continuous hours worked.
BEREAVEMENT LEAVE
The Illinois Family Bereavement Leave Act (“FBLA”) requires covered employers to provide unpaid bereavement time following the
death of a child. Effective January 1, 2023, the law is expanded to cover additional family members. “Covered family member”
means an associate’s child, stepchild, spouse, domestic partner, sibling, parent, mother-in-law, father-in-law, grandchild,
grandparent, or stepparent.
Employers that have more than 50 employees are covered. To be eligible for leave, an associate must have worked at least 12
months for the Company 1,250 hours during the prior 12-month period (i.e., an associate eligible under the federal FMLA).
Associates are entitled to a maximum of 2 work weeks, or 10 work days, of unpaid bereavement time following the death of a child
or covered family member as defined under FBLA. Associates may be entitled to up to 6 weeks of unpaid bereavement time in the
event of the death of more than one child or covered family member during a 12-month period.
Bereavement leave may not be taken in addition to unpaid leave permitted under the federal FMLA and may not exceed unpaid
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leave time allowed under the FMLA. An associate may elect to substitute part or all of any paid or unpaid leave (including sick
leave, personal leave, or other similar leave) to which the employee is entitled pursuant to any applicable law or benefits program.
Any paid and unpaid leave will run concurrent.
Associates must provide employers with 48 hours of notice before the leave, unless not reasonable and practicable. Employers may
not require that the associate identify which category of event the leave pertains to as a condition of exercising rights under the
FBLA.
Victim’s Economic Security and Safety Act (VESSA)

Leave of Absence Policy
POLICY OVERVIEW
Under the Illinois Victims’ Economic Security and Safety Act of 2003 (“VESSA”), each eligible associate in Illinois is entitled
to 12 weeks of unpaid leave during any 12-month period. If this leave also qualifies as leave under the Family and
Medical Leave Act (“FMLA”) then this VESSA leave runs concurrently (meaning, at the same time) with leave under
FMLA. Therefore, each time an associate takes leave under either the FMLA or VESSA for an FMLA qualifying reason, the
remaining leave entitlement is any balance of the 12 weeks that has not been used during the immediately preceding
12-month period. An associate may take VESSA leave if the associate or a family or household member (includes spouse,
parent, son, daughter, other person related by blood or by present or prior marriage, other person who shares a
relationship through a son or daughter, and persons jointly residing in the same household) was a victim of a sexual
assault, stalking, domestic violence, or any other crime of violence and requires the leave for one or more of the
following reasons:
a. to seek medical attention for, or recovery from, physical or psychological injuries caused by domestic or sexual
violence or any other crime of violence to the associate or the associate’s family or household member;
b. to obtain services from a victim services organization for the associate or the associate’s family or household
member;
c. to obtain psychological or other counseling for the associate or the associate’s family or household member;
d. to participate in safety planning, temporarily or permanently relocating, or to take other action to increase the
associate’s safety; or
e. to seek legal assistance or remedies to ensure health and safety of the associate or associate’s family or
household member, including preparing for or participating in any civil or criminal legal proceeding related to
or derived from the domestic or sexual violence or other crime of violence.
An associate’s health insurance coverage, including family coverage, will be continued during the leave, provided that
the associate was covered under such policy prior to the leave and provided that the associate continues to pay his or
her portion of the premiums, if applicable. An associate is not guaranteed that he or she will be returned to his or her
exact position; however, an associate will be returned to the same or an equivalent position with equivalent
employment benefits, pay, and other terms and conditions of employment unless the position was eliminated for
legitimate business reasons. Associates will not forfeit benefits they have already earned, such as paid time off pay, but
will not accrue additional employment benefits during any period of leave. An associate may use any paid time off that
has accrued.
ELIGIBILITY
For purposes of VESSA, an associate is eligible if he or she is employed by the Company on either a full-time or part-time
basis in the state of Illinois.
Notice and Certifications
If an associate wishes to take a leave because he or she or a family member was a victim of domestic or sexual
Violence or any other crime of violence, the associate must provide the Company with at least 48 hours advance notice
of the associate’s intention to take the leave, unless providing such notice is not practicable. When an unscheduled
absence occurs, the Company will not take any action if the associate, within a reasonable time after the leave
commences, notifies the Company as soon as practicable. In addition, the Company may require the associate to
submit a certification that that the associate or a member of the associate’s family or household was a victim of
domestic or sexual violence and that the leave is for one of the eligible purposes under VESSA. If requested, certification
is a sworn statement from the associate and a copy of: (i) documentation from an associate, agent, or volunteer of a
victim services organization; an attorney; a member of the clergy; or a member or other professional from whom the
associate or the associate’s family or household member has sought assistance to address the effects of the violence; (ii)
a police or court order; or (iii) other corroborating evidence.
TIMING OF LEAVE
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An associate may take a leave consecutively, intermittently or on a reduced schedule basis when the leave is taken
because he or she or a household member is seeking assistance due to domestic or sexual violence. When leave is
taken intermittently or on a reduced schedule basis, the total amount of the leave will not be reduced. An associate
may be required to transfer temporarily to a position that has equivalent pay and benefits and that better
accommodates recurring periods of leave.
Intermittent or reduced schedule leave for medical reasons will not be permitted unless the associate, in the case of
foreseeable treatment, makes a reasonable effort to schedule the treatment so as not to disrupt unduly the Company’s
operations and he or she provides thirty days’ notice, or as much notice as the required treatment permits. In addition,
an associate must provide the Company with a doctor’s certification that sets forth the medical necessity of the
intermittent or reduced schedule leave and the duration of such leave.
RETURNING FROM LEAVE
If an associate fails to return after VESSA leave for reasons within the control of the associate, the Company is entitled to
recover the cost of any premium that was paid for maintaining health coverage for the associate. If an associate fails to
return to work after a VESSA leave due to: (i) the continuation, reoccurrence, or onset of domestic or sexual violence or
other crime of violence that qualified for VESSA leave; or (ii) other circumstances beyond the control of the associate,
the Company is not entitled to recover the cost of any premiums paid and the Company may require the associate to
provide certification of the reason for his or her inability to return to work. If the Company requests such certification, it
shall include a sworn statement from the associate and documentation from an associate, agent, or volunteer of a
victim services organization; an attorney; a member of the clergy; or a medical or other professional from whom the
associate has sought assistance in addressing domestic or sexual violence and the effects of that violence; a police or
court record; or other corroborating evidence. COBRA continuation rights will commence at the time the associate’s
health coverage terminates for failure to return to work.
NON-DISCRIMINATION UNDER VESSA
The Company will not fail to hire, refuse to hire, discharge, constructively discharge or harass, retaliate against or
otherwise discriminate against any individual in any form or manner, because:
1. The individual:
a. is or is perceived to be a victim of domestic or sexual violence or other crime of violence;
b. attended, participated in, prepared for, or requested leave to attend, participate in, or prepare for a criminal
or civil court proceeding relating to an incident of domestic or sexual violence or other crime of violence of
which the individual or a family or household member of the individual was a victim, or requested or took
VESSA leave;
c. requested an accommodation in the workplace in response to actual or threatened domestic or sexual
violence or other crime of violence, regardless of whether the request was granted; or
d. exercised any rights provided for under VESSA or this policy, or opposed any practice made unlawful by VESSA
(including filing charges or proceedings under VESSA, providing information in connection with any proceeding
under VESSA, or testifying, or is about to testify, in any proceeding under VESSA); or
2. The workplace is disrupted or threatened by the action of a person whom the individual states has committed or
threatened to commit domestic or sexual violence or other crime of violence against the individual or the individual’s family or
household member.
REQUESTS FOR ACCOMMODATION (VESSA)
The Company will provide reasonable accommodations to the known limitations resulting from circumstances relating to
an associate being a victim of domestic or sexual abuse or an associate’s family or household member being a victim of
domestic or sexual abuse so long as the individual is an otherwise qualified individual as defined in Section 30(b)(2) of
VESSA, and who is (a) an applicant or associate of the Company; and (b) a victim of domestic or sexual abuse or other
crime of violence, or with a family or household member who is a victim of domestic or sexual abuse or other crime of
violence (provided the associate is not the perpetrator). The Company is not required to provide such accommodations if
it would impose an undue hardship on the Company’s operations.
ACKNOWLEDGMENT OF BIOMETIC INFORMATION COLLECTION AND STORAGE POLICY AND CONSENT FORM
Highgate Hotels, L.P., its parent or affiliated companies, vendors and customers (collectively, the “Company”) have adopted a Biometric
Information Policy to address how the Company will collect, use, store, disclose and destroy biometric information under all applicable
laws.
As a Company employee in a position where the use of biometric information is required, you understand that your fingerprint, voiceprint,
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hand, face, retina or iris may be scanned with biometric equipment (“Equipment”) to create an encrypted mathematical representation
of it (“Biographic Identifier”). The data may be stored and used for timekeeping, door entry/access, security or similar purposes. If, for
example, the Company scans your hand to create a Biometric Identifier, you will scan your finger each time you access the Equipment.
This scan is then compared to the Biometric Identifier created by the initial scan to confirm your identity.
The Company will require its vendors, contractors and lessors, where appropriate and necessary, to comply with its Biometric Information
Policy. In some cases, the vendors, contractors and lessors may have similar policies.
The Company will use a reasonable standard of care in the storage, transmission and disclosure of my Biometric Identifier, as it does in
the storing of other confidential employee information. You understand that your Biometric Identifier will be stored and used by the
Company during the time of your employment and for an additional period of time thereafter in accordance with applicable law and
the Company’s Policy after which it will be destroyed. You understand that the Company will not retain your biometric identifier for
longer than what is permitted by law following your last interaction with the Company.
By signing the Playbook Acknowledgment, you acknowledge and understand that the Company’s use of your Biometric Identifier is
limited to lawful purposes and that the Company does not sell, lease, trade or otherwise profit from its use or collection of your Biometric
Identifier. The Company will not disclose your Biometric Identifier unless:
• The disclosure completes a financial transaction requested and authorized by me or my legally authorized
representative;
• The disclosure is required by state or federal law or by municipal ordinance;
• The disclosure is required pursuant to a valid warrant or subpoena issued by a court or agency of competent
jurisdiction; or
• I otherwise consent to the disclosure.
Accordingly, I acknowledge that I have read this policy and do consent to the Company’s collection, use, storage
and destruction of my Biometric Identifier as set forth above. I so consent by signing the Playbook Acknowledgment.
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MASSACHUSETTS ADDENDUM (For Massachusetts Associates Only)
MASSACHUSETTS ADDENDUM – For Massachusetts Associates Only
Sexual Harassment Policy
It is the policy of the Company to provide and maintain a workplace that is free of sexual harassment. Sexual
harassment in the workplace is both a violation of Company policy and it is unlawful. This policy applies to all associate s
of Company, regardless of their position.
Prohibited sexual harassment includes sexual advances, requests for sexual favors and other verbal or physical conduct
of a sexual nature that has the purpose or effect of unreasonably interfering with an associate’s work performance by
creating an intimidating, hostile, humiliating or sexually offensive working environment. In addition, no manager or
supervisor, male or female, may sexually harass any associate by making submission to or rejection of sexual advances,
requests for sexual favors or other verbal or physical conduct of a sexual nature either explicitly or implicitly a term or
condition of employment or a basis for employment decisions. An associate who engages in sexual harassment is
subject to disciplinary action, up to and including termination of employment.
Determinations of whether particular language or conduct is subject to disciplinary action under this policy are made on
an individual basis, in light of all of the circumstances. The following, however, are some examples of conduct that may
be considered sexual harassment, depending on the circumstances, and are prohibited by Company policy:
• Comments to, or about, any associate or his/her appearance that are sexually graphic or
would otherwise tend to be degrading.
• Unwelcome physical contact of a sexual nature.
• Unwelcome jokes or other remarks with sexual content that is graphic or may otherwise be
offensive to others.
• Display of objects, posters or pictures of a sexual nature.
• A repetition of any words or conduct of a sexual nature after the person addressed has
indicated that such words or conduct is unwelcome.
• Questions regarding sexual conduct.
• Unwelcome touching, leering, whistling, brushing against the body, or suggestive or obscene
gestures.
• Threats, either explicitly or implicitly, that an individual’s refusal to submit to sexual advances or
sexual conduct will adversely affect his or her employment, evaluation, wages, advancement,
assigned duties, benefits, or any other material aspect of employment.
Complaint Procedure
If an associate believes that she or he has been subjected to sexual or other harassment prohibited by this policy,
whether by a supervisor, a co-worker or any other person with whom the associate comes in contact in connection with
his/her work for the Company, the associate should report the incident immediately to the human resources manager,
the associate’s, supervisor, or another management representative, who can be reached at 877-782-6256. An associate
may choose instead to contact his/her department head or another manager with whom the associate feels
comfortable. Any claim may be made orally or in writing.
The Company will handle all complaints of sexual harassment in as confidential and prompt a manner as possible,
though recognizing that complete confidentiality is not always possible. Following its investigation and review of the
circumstances surrounding each complaint, the Company will take remedial action to it determines are appropriate to
end any conduct in violation of this policy, including disciplining any associate s it determines engaged in harassing
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conduct (which may range from warnings, suspensions and demotions to termination of employment), and offer
assistance to any associate s it deems to have been subjected to harassment.
Retaliation Prohibited
The Company will not permit retaliation of any kind against anyone who complains in good faith about harassment or
participates in good faith in an investigation of a harassment complaint. Such retaliation is both unlawful and a violation
of Company policy, and any individual found to have engaged in retaliation will be subject to disciplinary action, up to
and including termination of employment.
Responsible Agencies
The following agencies are charged with investigating claims of unlawful discrimination, harassment and retaliation:
Massachusetts Commission Against Discrimination:
One Ashburton Place

Sixth Floor, Room 601
Boston, MA 02108
Phone: 617-994-6000
436 Dwight Street

Second Floor, Room 220
Springfield, MA 01103
(413) 739-2145
Worcester City Hall

455 Main Street, Room 100
Worcester, MA 01608
(508) 799-8010
Equal Employment Opportunity Commission:

John F. Kennedy Federal Building
475 Government Center
Boston, MA 02203
(800) 669-4000
MEAL BREAKS
Non-exempt associate are entitled to a 30 minute meal break under Massachusetts law for every 6 hours worked in a work day.
Associates should see their supervisor for specific details on the timing of meal breaks.
MASSACHUSETTS PARENTAL LEAVE

Massachusetts associates who are not eligible for Family or Medical Leave under the FMLA may be eligible for a leave of
absence for childbirth, adoption, or for the placement of a child pursuant to a court order under the Parental Leave Act.
The Company also complies with the Massachusetts PFML law.
Eligible associates are full-time female and male associates who have been employed for at least three (3) months.
Associates are eligible for up to eight (8) weeks of unpaid leave for (a) giving birth, (b) caring for a newly placed child
under the age of 18 or under the age of 23 if the child is mentally or physically disabled, or (c) for an intended or actual
adoption.
The Parental Leave Act also provides that if any two associates of the same employer are the parents to the same child,
those associates are only entitled to one aggregate period of eight weeks of leave between them.
The associate who takes leave is generally entitled to be restored to his or her previous or similar position with the same
status, pay, and seniority as when the leave period began. These protections apply only to leaves of up to eight weeks.
According to the MPLA, the law does not require that an associate be reinstated to a position when associates in similar
positions with similar lengths of service and status have been laid off due to economic or other operating conditions. In
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these circumstances, the associate on leave is to be afforded the same preferential treatment in consideration for
another position as he or she would have had at the time that his or her leave period began.
Leave under MPLA is unpaid, though associates may use applicable accrued paid time off while on leave. Where an
associate qualifies for leave under the MPLA and the federal FMLA as described in the main playbook, leave under both
statutes will run concurrently.
To obtain a Leave of Absence Medical Certification Form, contact the Human Resources Department pursuant to the
notification procedures under the federal FMLA provision in the main playbook.
PREGNANT WORKERS
Associates have the right to be free from discrimination in relation to pregnancy or a condition related to the associate’s
pregnancy including, but not limited to, lactation or the need to express milk for a nursing child, including the right to
reasonable accommodations for conditions related to pregnancy. Employers may not treat associates less favorably
than other associates based on pregnancy or pregnancy-related conditions, and may not refuse to hire or deny an
employment opportunity to an associate because of the associate’s request for or use of a reasonable accommodation
for pregnancy or a pregnancy-related condition.
To request an accommodation for your pregnancy or a pregnancy-related condition, please contact Benefits
Administrator. Upon this request, we will engage in an interactive process to work with you to determine a reasonable
accommodation to enable you to perform the essential functions of your job. We will accommodate pregnancy and
pregnancy-related conditions unless doing so would post an undue hardship to the company.
An employer cannot require an associate affected by pregnancy or a pregnancy-related condition to accept an

accommodation, if that accommodation is unnecessary to enable the associate to perform the essential functions of
the job. An employer cannot require an associate to take a leave if another reasonable accommodation may be
provided for the known conditions related to the associate’s pregnancy, without undue hardship to the company.
We may require that medical documentation about the need for a reasonable accommodation be provided, however,
we will not require medical documentation about the need for an accommodation for pregnancy or pregnancy-
related conditions if the accommodation requested is for: (i) more frequent restroom, food or water breaks; (ii) seating;
(iii) limits on lifting no more than 20 pounds; and (iv) private, non-bathroom space for expressing breast milk.
MASSACHUSETTS SMALL NECESSITIES LEAVE
Massachusetts associates may take a total of up to 24 hours of Small Necessities Leave (“SNL”) during any twelve-month
period (measured backwards from the effective date of the leave) to allow them to participate in certain family
obligations. In order to be eligible, an associate must (i) have worked for the Company for at least twelve months and
(ii) have worked 1,250 hours or more in the preceding twelve-month period. An eligible associate may take SNL to: (1)
participate in school activities directly related to the educational advancement of his/her child; (2) accompany his/her
child to routine medical or dental appointments; or (3) to accompany an elderly relative (defined by Massachusetts law
as an individual related by blood or marriage who is at least 60 years of age) to routine medical or dental appointments,
or for other professional services related to the elderly relative’s care.
SNL is unpaid, except to the extent that an associate has accrued but unused sick time or vacation time available, in
which case such time shall be applied to the leave. SNL may be taken all at once, intermittently (in increments of an
hour or greater), or through a reduced work schedule. An associate’s absence from work for SNL shall be no greater
than that necessary to accomplish the relevant task necessitating the leave.
An associate seeking SNL must provide at least seven days’ notice before taking SNL, if the need for leave is foreseeable;
if the need for leave is not foreseeable, then the associate must provide as much notice as is practicable. The
Company, in its discretion, may require from the associate certification of the need for any SNL.
MASSACHUSETTS PAID FAMILY AND MEDICAL LEAVE
The Family and Employment Security Trust Fund provides eligible associates in Massachusetts with paid leave for the following
reasons:
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• To bond with a child during the first 12 months after a child's birth or placement with the team member for adoption or
foster care.
• Any qualifying exigency arising from the fact that a family member is on active duty or has been notified of an impending
call or order to active duty in the Armed Forces.
• To care for a family member who is a covered servicemember.
• The associate's own serious health condition.
• To care for a family member’s serious health condition.
Associates may use up to:

• 12 weeks of paid family leave in a benefit year
• 26 weeks of paid family leave in a benefit year if the associate uses leave to care for a family member who is a covered
service member
• 20 weeks of medical leave in a benefit year
• 26 weeks of combined family and medical leave in a benefit year
An associate’s benefit year begins the Sunday immediately before the first day that the associate begins to take job-protected
medical or family leave and runs for 52 weeks.
An associate may take family leave for any of the following family members:
• Spouse
• Domestic partner
• Child
• Parent or parent of a spouse or domestic partner
• A person who stood in place of the associate’s parent when the associate was a minor
• Grandchild
• Grandparent
• Sibling
A serious health condition is an illness, injury, impairment, or physical or mental condition that involves either:
• Inpatient care in a hospital, hospice, or residential medical facility.
• Continuing treatment by a health care provider.
Leaves may be taken intermittently or on a reduced schedule:

• To care for a family servicemember if intermittent or reduced schedule leave is medically necessary.
• Because of any qualifying exigency of a family member on active duty or called to active duty.
• If an arrangement is made with the Company, to bond with a new child or after placement with the associate for
adoption or foster care.
When your leave is foreseeable, you must provide the Company with at least 30 days' notice of your anticipated starting date,
length of leave, and expected return date. If you are unable to provide 30 days' notice for reasons beyond your control, you must
provide notice as soon as is practicable.
When taking leave, you must file a benefit claim with Department of Family and Medical Leave and provide the certification
required by the Department. Claims filed more than 90 days after the start of leave may result in reduced benefits.
The Company will restore eligible associates who take family or medical leave to their previous position or to an equivalent position,
with the same status, pay, employment benefits, length of service credit, and seniority. However, if similarly situated associates have
been laid off because of economic conditions or other operating changes affecting employment during your leave, you may not
be eligible for reinstatement to your prior position.
The Company will not interfere with or deny an associate's exercise of any right provided by the Massachusetts Paid Family and
Medical Leave Act. The Company will not take any adverse action against an associate because the associate opposes practices
which the associate believes to be in violation of this law or supports the exercise of rights of another associate under this law,
including filing an action, instituting a proceeding, providing information in connection with an inquiry or proceeding, or testifying or
intending to testify in any inquiry or proceeding.
Leave under this policy will run concurrently with other leaves, including but not limited to the federal Family and Medical Leave Act
and the Massachusetts Parental Leave Act.
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NEW YORK ADDENDUM (for New York Associates Only)
NEW YORK ADDENDUM – for New York Associates Only

To our New York associates: please note that wherever New York law provides for or offers greater protections to our
associates, New York law will govern. Please contact Human Resources with questions about any policies in this
Addendum.
Paid Family Leave
The New York Paid Family Leave Law provides eligible associates with paid family leave (PFL) in order to bond with a new
child (including absences required to meet adoption and foster care obligations), care for a family member with a serious
health condition, or care for a military member who has been called into active military service, as described in greater
detail below.
Associate Eligibility
Generally, associates who are regularly scheduled to work 20 or more hours per week will become eligible to take PFL after
the associate has worked 26 consecutive weeks for the Company. Associates who are regularly scheduled to work less
than 20 hours per week will become eligible to take PFL after 175 days are worked for the Company.
Waiver of Benefits
Associates may opt to file a waiver of PFL benefits if their regular employment schedule is (1) 20 hours or more per week
but the associate will not work 26 consecutive weeks; or (2) less than 20 hours per week and the associate will not work 175
days in a 52 consecutive week period. Associates who file a waiver will not have payroll deductions taken to cover PFL
benefits.
Within 8 weeks of any change in the regular work schedule of such an associate that requires the associate to continue
working for 26 consecutive weeks or 175 days in a 52 consecutive week period, any waiver under this provision will be
deemed revoked, and the affected associate must begin making contributions to the cost of PFL benefits, including any
retroactive amounts due from date of hire, as soon as notified of such by the Company.
Types of PFL
• Leave to Care for a Family Member with a Serious Health Condition
Eligible associates are permitted to take PFL to provide care for a recipient with a serious health condition so long
as:
1. The associate is Providing Care for a recipient who is a Family Member with a Serious Health Condition,
which includes, but is not limited to, illness, injury, impairment, or physical or mental condition that involve
inpatient care in a hospital, hospice, or residential health care facility or Continuing Treatment or
Continuing Supervision by a Health Care Provider; and
2. The associate is in close and continuing proximity to the care recipient. This means present at the same
location as the family member during the majority of the employment period from which leave has
been taken. Travel for the purpose of securing medication or arranging care for the family member, or
for other reasons determined to be reasonably related to providing care, is permitted.
For purposes of this policy:

− Providing Care may include necessary physical care, emotional support, visitation, assistance in
treatment, transportation, arranging for a change in care, assistance with essential daily living
matters and personal attendant services.
− Family Member includes spouses, domestic partners, children, parents, parents-in-law,
grandparents, and grandchildren.
− Serious Health Condition means an illness, injury, impairment, or physical or mental condition that
involves: inpatient care in a hospital, hospice, or residential health care facility; or Continuing
Treatment or Continuing Supervision by a Health Care Provider.
Continuing Treatment or Continuing Supervision by a Health Care Provider may mean one or more of the
following:
1. A period of more than three consecutive, full days during which a family member is unable to work,
attend school, perform regular daily activities, or is otherwise incapacitated due to illness, injury,
impairment, or physical or mental conditions, and any subsequent treatment or period of incapacity
relating to the same condition, that also involves:
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− Treatment two or more times by a health care provider; or

− Treatment on at least one occasion by a health care provider, which results in a regimen of
continuing treatment under the supervision of the health care provider.
2. Any period during which a family member is unable to work, attend school, perform regular daily
activities, or is otherwise incapacitated due to a chronic serious health condition. A chronic serious
health condition is one which:
− Requires periodic visits for treatment by a health care provider;
− Continues over an extended period of time (including recurring episodes of a single underlying
condition); and
− May cause episodic rather than a continuing period of incapacity. Examples of such episodic
incapacity include but are not limited to asthma, diabetes, and epilepsy
3. A long-term or permanent period during which a family member is unable to work, attend school,
perform regular daily activities, or is otherwise incapacitated due to an illness, injury, impairment, or
physical or mental condition for which treatment may not be effective. The family member must be
under the continuing supervision of, but need not be receiving active treatment by, a health care
provider. Examples include, but are not limited to, Alzheimer’s, a severe stroke, or the terminal stages of
a disease.
4. A period during which a family member is unable to work, attend school, perform regular daily activities,
or is otherwise incapacitated because he or she is receiving treatment (including any period of recovery
therefrom) by a health care provider for:
− Restorative surgery after an accident or other injury; or
− A condition that would likely result in a period of incapacity of more than three consecutive full
days in the absence of medical intervention or treatment. Examples include, but are not limited to,
cancer (e.g., chemotherapy and radiation), severe arthritis (physical therapy), or kidney disease
(dialysis).
Treatment includes, but is not limited to, examinations to determine if a serious health condition exists and
evaluations of the condition (e.g., therapy requiring special equipment to resolve or alleviate the health
condition). Treatment does not include routine examinations.
• Bonding Leave and Adoption or Foster Care Obligations

Eligible associates are permitted to take PFL to bond with their newborn child for the first year of the child’s
life, with a recently adopted child for the first year of the adoption, or with a child recently placed into foster
care with them for the first year of the placement (even if the child was born, adopted, or placed prior to
January 1, 2018). Eligible associates may also take family leave before the actual placement or adoption of
a child if an absence from work is required for the placement for adoption or foster care to proceed. This
includes, but is not limited to, leave due to counseling sessions, court appearances, or travel to another
country to complete an adoption. Eligible associates’ entitlement to PFL under this section expires at the end
of the consecutive 52 week period beginning on the date of the birth or placement.
• Military Caregiver Leave

Eligible associates are permitted to take PFL for purposes identified under the federal Family and Medical
Leave Act (“FMLA”) when their spouse, domestic partner, child, or parent of the associate is on active duty
or has been notified of an impending call or order to active duty in the armed forces of the United States.
PFL may not be used for an associate’s own qualifying military event.
Requesting Leave
As described below, eligible associates have certain obligations and responsibilities both before and during PFL. Eligible
associates must comply with the following obligations in connection with any PFL.
Timing to Provide Notice of the Need for PFL
• Foreseeable Leave
For foreseeable events, an associate must provide at least 30 days advance notice before PFL is to begin.
“Foreseeable” events generally include an expected birth, placement for adoption or foster care; planned
medical treatment for a serious health condition of a family member; the planned medical treatment for a serious
injury or illness of a covered service member; or other known military exigency. When the need for PFL is
foreseeable and an associate fails to give 30 days’ advance notice, the associate’s claim may be partially
denied for a period of up to 30 days from the date notice is provided.
• Unforeseeable Leave
If 30 days advance notice is not practicable for reasons such as a lack of knowledge of approximately when
leave will be required to begin, a change in circumstances, or a medical emergency, notice must be given as
soon as practicable under the facts and circumstances of the qualifying event. The associate shall advise the
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Company as soon as practicable if dates of scheduled leave change or are extended, or were initially unknown.
When an associate becomes aware of a qualifying event less than 30 days in advance, it should be practicable
for the associate to provide notice of the need for leave either the same day or the next business day. An
associate must request payment for a previously unspecified day of family leave within thirty days of the leave.
• Intermittent Leave
Associates taking intermittent PFL must advise the Company of the schedule for intermittent PFL and provide
notice as soon as is practicable before each day of intermittent PFL.
Content of Notice of the Need for PFL

Eligible associates must provide notice to the Company sufficient to make the Company aware of the qualifying event
and the anticipated timing and duration of the leave. The associate shall identify the type of PFL when providing such
notice to the Company.
Associate Documentation
Eligible associates will need to file a Request for Paid Family Leave form and documentation in support of their PFL request
to Human Resources unless otherwise notified. A claim form may be obtained from Human Resources or the New York
State Paid Family Leave website.
To justify an associate’s request for PFL, an associate will be required to present a certification from the health care provider
treating the associate’s family member or, if the leave is following birth of a child, the health care provider treating the
mother of the child. For adoption and foster care, different types of documentation will be needed. If taking PFL for a
qualifying military event, associates will need to present copies of Duty Papers or other supporting documentation. Further
details regarding what documentation is required to support a request for PFL are available from the PFL insurance carrier.
No benefits shall be paid by the carrier until the completed Request for Paid Family Leave, together with any necessary
certifications or proof of claim documentation, has been submitted to the carrier.
PFL Duration and Pay Generally
The maximum PFL benefit is based on the New York State Average Weekly Wage (NYSAWW). The maximum benefit will
increase on January 1, 2023 to $1,131.08. Associates may take the maximum benefit length in any given 52-week period.
The 52-week clock begins to run on the first day the associate takes PFL. Associates may not receive both disability benefits
and family leave benefits for the same period.
Duration of Intermittent Leave

Associates taking PFL in daily increments will be eligible for the maximum period of paid family leave calculated based on
the average number of days worked per week with a maximum of 60 days per year for associates working at least 5 days
per week.
When an associate requests PFL in daily increments, rather than as a weekly benefit, the daily benefit will be calculated
based on the associate’s average weekly wage divided by the average number of days the associate worked per week.
In arriving at the average number of days the associate worked per week for the purpose of determining the associate’s
wage for one day, the Company will average the number of days the associate worked per week over the last 8 weeks
the associate worked.
FMLA and PFL

In situations in which an associate is eligible for both PFL and FMLA leave, FMLA leave will run concurrently with PFL. When
the total hours taken for FMLA in less than full day increments reaches the number of hours in an associate’s usual work
day, the Company will deduct one day of PFL benefits from the associate’s annual available PFL benefit.
Use of Accruals
Associates are permitted to charge all or part of their PFL time to unused accruals or other paid time off and receive their
full salary while on PFL, as opposed to the partial salary provided under the PFL. Associates whose PFL has also been
designated as FMLA leave will be required to exhaust their unused vacation in connection with the portion of their PFL
leave that runs concurrently with their FMLA leave.
Health Insurance During PFL

Healthcare benefits will be maintained while an associate is on PFL, provided that the associate continues to make any
normal contributions to the cost of the health insurance premiums while on leave and is not more than 30 days late in
payment of such premium.
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Reinstatement to Position and Benefits

An associate who has received PFL benefits generally has the right to return to the same or equivalent position at the
conclusion of his or her leave, with equivalent pay, benefits, and other employment terms.
No Discrimination or Retaliation
The Company will not retaliate or discriminate against an associate for exercising rights under the New York State Paid
Family Leave Law. An associate who feels that he or she has been discriminated against or retaliated against due to an
assertion of PFL rights should contact Human Resources.
Sexual Harassment Prevention Policy
The Company is committed to a discrimination-free work environment, which includes maintaining a workplace free from
all types of harassment, including sexual harassment. This policy supplements the Company’s Non-Harassment and Non-
Retaliation policy.
Sexual harassment is offensive, a violation of our policies, and a form of associate misconduct. Associates of every level,
including managers and supervisors, who engage in sexual harassment, or who allow such behavior to continue, will be
disciplined for such misconduct, in accordance with this policy.
Scope
This policy, as well as New York State law, applies to all associates, applicants for employment, interns (paid or unpaid),
non-associates, and persons conducting business with the Company, regardless of immigration status (“Covered
Individuals”). A non-associate is someone who is (or who is employed by) a contractor, subcontractor, vendor, consultant,
intern (paid or unpaid), or anyone providing services in the workplace. Notwithstanding the application of this policy to
such individuals, nothing herein creates an employment relationship.
Unlawful sexual harassment is not limited to the physical workplace itself. It can occur, for example, while Covered
Individuals are traveling for business or at employer-sponsored events or parties. Calls, texts, emails, and social media usage
by Covered Individuals can constitute unlawful workplace harassment, even if they occur away from the workplace, on
personal devices, or outside of work hours.
All associates must review this policy and commit to maintaining a work environment free from sexual harassment. In
addition, all associates must complete annual sexual harassment training. An associate’s failure to comply with this policy
and/or failure to complete annual training may result in appropriate remedial and/or disciplinary action, up to and
including termination of employment.
What Is “Sexual Harassment”?

Sexual harassment is a form of sex discrimination and is unlawful under federal, state, and local laws. Sexual harassment
includes harassment on the basis of sex, sexual orientation, self-identified or perceived sex, gender expression, gender
identity, and/or the status of being transgender.
Sexual harassment includes unwelcome conduct that is either of a sexual nature or directed at an individual because of
that individual’s sex when:
• Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or
creating an intimidating, hostile or offensive work environment, even if the reporting individual is not the intended
target of the sexual harassment;
• Such conduct is made either explicitly or implicitly a term or condition of employment; or
• Submission to or rejection of such conduct is used as the basis for employment decisions affecting an individual’s
employment.
A sexually harassing hostile work environment includes, but is not limited to, words, signs, jokes, pranks, intimidation, or
physical violence that is of a sexual nature or directed at an individual because of that individual’s sex. Sexual harassment
also consists of any unwanted verbal or physical advances, sexually explicit derogatory statements, or sexually
discriminatory remarks made by someone that are offensive or objectionable to the recipient, that cause the recipient
discomfort or humiliation, and/or that interfere with the recipient’s job performance.
Sexual harassment also occurs when a person in authority tries to trade job benefits for sexual favors. This can include hiring,
promotion, continued employment, or any other terms, conditions, or privileges of employment. This is also called “quid
pro quo” harassment.
Sexual harassment can occur by males against females, by females against males, or by or between individuals of the
same or opposite sex or gender. It is important to know that sexual harassment can occur between any individuals,
regardless of their sex or gender.
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A harasser can be a superior, a subordinate, a coworker, or anyone in the workplace, including an independent
contractor, contract worker, vendor, client, customer, or visitor.
Sexual harassment may be a single incident or a series of harassing acts. Any harassing conduct, even a single incident,
may be addressed under this policy.
Examples of Sexual Harassment

The following describes some of the acts that may be unlawful sexual harassment and that are strictly prohibited:
• Verbal statements, such as:
o Making lewd or sexual comments about an individual’s appearance, body, or style of dress; or
o Making sexist remarks or derogatory comments based on gender.
• Physical acts of a sexual nature, such as:
o Touching, pinching, patting, kissing, hugging, grabbing, brushing against another person’s body, or poking
another person’s body; or
o Rape, sexual battery, or molestation, or any attempt to commit these acts.
• Unwanted sexual advances or propositions, such as:
o Requests for sexual favors accompanied by implied or overt threats concerning the target’s job
performance evaluation, a promotion, or other job benefits or detriments; or
o Subtle or obvious pressure for unwelcome sexual activities.
• Sexually oriented gestures, noises, remarks, jokes, or comments about a person’s sexuality or sexual experience
that create a hostile work environment.
• Sex stereotyping, which may occur when conduct or personality traits are considered inappropriate because
they may not conform to ideas or perceptions about how individuals of a particular sex should act or look.
• Sexual or discriminatory displays or publications anywhere in the workplace, such as:
o Displaying pictures, posters, calendars, graffiti, objects, promotional material, reading materials, or other
materials that are sexually demeaning or pornographic; or
o Sexual displays on workplace computers or cell phones and sharing such displays while in the workplace.
• Hostile actions taken against an individual because of that individual’s sex, sexual orientation, gender identity, or
the status of being transgender, such as:
o Interfering with, destroying, or damaging a person’s workstation, tools, or equipment, or otherwise interfering
with the individual’s ability to perform the job;
o Sabotaging an individual’s work; or
o Bullying, yelling, or name-calling because of sex, sexual orientation, gender identity, and/or the status of
being transgender.
The legal definition of sexual harassment under federal, state, and local law is broad and, in addition to the above
examples, other sexually oriented conduct, whether or not it is intended, that is unwelcome and has the effect of creating
a work place environment that is hostile, offensive, intimidating, or humiliating may also constitute sexual harassment.
Supervisory Responsibilities
All supervisors and managers who receive a complaint or information about suspected sexual harassment, observe what
may be sexually harassing behavior, or for any reason suspect that sexual harassment is occurring are required to report
such suspected sexual harassment to their manager or Human Resources Representative.
A supervisor’s or manager’s failure to report such conduct may result in disciplinary action, up to and including termination
of employment. Supervisors and managers may also be subject to disciplinary action if they engage in, or in any way
condone, sexually harassing conduct. Supervisors and managers will also be subject to discipline, up to and including
termination of employment, for engaging in retaliation.
The Company strictly prohibits retaliation against anyone who reports, in good faith, an incident of sexual harassment,
provides information about suspected sexual harassment, or otherwise assists or participates in any investigation of a sexual
harassment complaint. Any Covered Individual who believes that he or she has been subject to retaliation should
immediately report such conduct to a manager or human resources staff member. Specific reporting contact options and
information is provided below.
No Covered Individual will be subject to adverse action because he or she reports, in good faith, an incident of sexual
harassment, provides information, or otherwise assists in any investigation of a sexual harassment complaint.
Any associate who retaliates against anyone involved in a sexual harassment investigation will be subject to disciplinary
action, up to and including termination of employment.
What is Retaliation?
Retaliation is unlawful under federal, state and applicable local law, as well as our policies. The Company prohibits any
adverse employment action or any action that is likely to deter a person from engaging in protected activity. Protected
activity occurs when an individual has, in good faith:
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• Made a complaint of sexual harassment, either internally or with any anti-discrimination agency;
• Testified or assisted in a proceeding involving sexual harassment under any federal, state or local anti-
discrimination law;
• Opposed sexual harassment by making a verbal or informal complaint to management, or by simply informing
a supervisor or manager of harassment;
• Reported that another associate has been sexually harassed; or
• Encouraged a fellow associate to report harassment.
Even if the alleged harassment does not turn out to rise to the level of a violation of law, the individual is protected from
retaliation if the person had a good faith belief that the practices were unlawful. However, this anti-retaliation provision
does not protect persons making intentionally false charges.
Reporting Sexual Harassment

Preventing sexual harassment is everyone’s responsibility. The Company cannot prevent or remedy sexual harassment
unless it knows about it. Any Covered Individual who has been subjected to behavior that may constitute sexual
harassment, or anyone who witnesses or becomes aware of potential instances of sexual harassment, should report such
behavior to a manager or Human Resources representative.
Reports of sexual harassment may be made verbally or in writing. A form for submission of a complaint is available from
your manager. All Covered Individuals are encouraged to use this Complaint Form. Covered Individuals who report sexual
harassment on behalf of others are encouraged to use the Complaint Form and note that it is on another person’s behalf.
If a complaint is verbal, the individual making the complaint is encouraged to complete the Complaint Form in writing. If
he or she refuses, the person receiving the complaint should prepare a Complaint Form based on the verbal reporting.
Any Covered Individual who engages in sexual harassment or retaliation will be subject to remedial and/or disciplinary
action, up to and including termination of employment or a business relationship, or other appropriate remedy.
Investigation of Sexual Harassment

All complaints or information (whether submitted verbally or in writing) about sexual harassment will be investigated. An
investigation of any complaint, information, or knowledge of suspected sexual harassment will be prompt and thorough,
and the Company will strive to complete its investigation in a timely manner. Information will be shared on a need-to-know
basis only; however, others named or who may have information about the complaint will be notified and will have an
opportunity to supply relevant information. The investigation will be conducted in a way that is impartial and fair to all
participants.
All Covered Individuals are required to cooperate in an investigation of suspected sexual harassment. Covered Individuals
who participate in any investigation will not be retaliated against.
While the process may vary from case to case, investigations will generally be completed in accordance with the following
steps:
• Upon receipt of a complaint, Human Resources will conduct an immediate review of the allegations, and may
take any interim actions as deemed appropriate.
• Human Resources will request and review all relevant documents, including all electronic communications, and
will take appropriate steps to preserve all documents, e-mails, and/or phone records relevant to the investigation.
• Human Resources will interview all relevant parties involved, including any relevant witnesses.
• Human Resources will create written documentation of the investigation, which may contain the following:
o A list of all documents reviewed, along with a detailed summary of relevant documents;
o A list of names of those interviewed, along with a detailed summary of their statements;
o A timeline of events;
o A summary of prior relevant incidents, reported or unreported; and
o The basis for the decision and final resolution of the complaint, together with any corrective action(s).
• Human Resources will take appropriate steps to keep written documentation and associated documents in the
Company’s secure and confidential files.
Upon completion of the investigation, a determination will be made as to whether the conduct at issue violates the policy,
and/or the nature of the disciplinary action or other corrective measures, if any, to be imposed. Human Resources will
notify the reporting individual and the individual(s) about whom the complaint was made, and any corrective actions will
be implemented promptly.
Legal Protections and External Remedies
All Covered Individuals have a legal right to a workplace free from sexual harassment, and in addition to the internal
process at the Company, Covered Individuals may also enforce this right by filing a complaint with a government agency
or by pursuing available remedies in court under federal, state, or applicable local antidiscrimination laws. There is no cost
to file with these governmental agencies.
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Each of the agencies listed below can conduct impartial investigations, facilitate conciliation, and if the agency finds that
there is probable cause or reasonable grounds to believe sexual harassment occurred, it may take the case to court or
hearing and/or award relief, which varies but may include requiring the Company to take action to stop the harassment,
or redress the damage caused, including payment of monetary damages, attorney’s fees and civil fines. Courts may also
award remedies if a violation of law is found.
Complaints with the New York State Division of Human Rights, United States Equal Employment Opportunity Commission,
and the New York City Commission on Human Rights are subject to applicable statute of limitations. In addition, a
complainant also has the right to hire a private attorney, and to pursue a private legal action in federal or state court in
accordance with the applicable procedural requirements and within the applicable statute of limitations. Complaining
internally to the Company does not extend your time to file with an agency or in court. The contact information for each
of these agencies is set forth below.
New York State Division of Human Rights United States Equal Employment Opportunity Commission
One Fordham Plaza, Fourth Floor, (EEOC)
Bronx, New York 10458 The EEOC has district, area, and field offices where
(888) 392-3644 or (718) 741-8400 complaints can be filed.
www.dhr.ny.gov or 1-800-669-4000 (TTY: 1-800-669-6820)
www.dhr.ny.gov/complaint E-mail: info@eeoc.gov
www.eeoc.gov
New York City Commission on Human Rights The Local Police Department
Law Enforcement Bureau of the NYC Commission
on Human Rights If harassment involves unwanted
40 Rector Street, 10th Floor physical touching or coerced sexual
New York, New York 10006 act, the conduct may constitute a
311 or (212) 306-7450 crime. Contact your local police.
www.nyc.gov/html/cchr/html/home/home.shtml
PROHIBITION OF DISCRIMINATION BASED ON REPRODUCTIVE

HEALTH DECISION MAKING
The Company prohibits harassment, discrimination, or retaliation against an associate with respect to compensation,
terms, conditions, or privileges of employment because of or on the basis of the associate's or dependent's reproductive
health decision making, including, but not limited to, a decision to use or access a particular drug, device or medical
service. The Company prohibits any practice when it subjects an individual to inferior terms, conditions or privileges of
employment because of the associate’s or associate’s dependent’s reproductive health decisions. The Company
prohibits anyone from requiring that an associate to sign a waiver or other document which purports to deny an
associate the right to make their own reproductive health care decisions, including use of a particular drug, device, or
medical service. The Company will not access an associate's personal information regarding the associate's or the
associate's dependent's reproductive health decision making, including but not limited to, the decision to use or access
a particular drug, device or medical service without the associate's prior informed affirmative written consent.
Complaint and Reporting Procedure

Associates must immediately report any violation or suspected violation of this policy to their manager and Human
Resources. All supervisors and managers are required to report any such information or complaints to Human Resources.
An associate may bring a civil action in court. If a violation of an associate’s reproductive health rights has been found,
the court has the power to award damages and other available relief.
The Company, as well as applicable state law, strictly prohibits discrimination and retaliation against anyone who, in
good faith, reports or provides information about suspected violation of this policy. For purposes of this policy, retaliation
or retaliatory personnel action means discharging, suspending, demoting, or otherwise penalizing an associate for: (a)
making or threatening to make, a complaint to an employer, co-worker, or to a public body, that rights related to
reproductive health decisions have been violated; (b) causing to be instituted any proceeding under or related to this
section; or (c) providing information to, or testifying before, any public body conducting an investigation, hearing, or
inquiry into any such violation of a law, rule, or regulation by such employer.
Anyone who is found to have violated this policy will be will be subject to disciplinary action, up to and including
termination of employment.
MEAL BREAKS
An associate who works a shift of more than 6 hours which extends over the noon meal period (11 a.m. to 2
p.m.) is entitled to a 30 minute meal period to be taken between 11 a.m. and 2 p.m. If an associate starts his or
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her shift before 11 a.m. and continues after 7 p.m., the associate is entitled to both the 30 minute noon meal
period and an additional 20 minute break between 5 p.m. and 7 p.m. The 30 minute meal period will be unpaid
and associate will be required to record the starting and ending time of the 30 minute break.
An associate who works a shift of more than 6 hours starting between the hours of 1:00 p.m. and 6:00 a.m. is
entitled to a meal period of at least 45 minutes in the middle of his or her shift. The 45 minute meal period will be
unpaid and associates will be required to record the starting and ending time of the 45 minute meal break
ELECTRONIC MONITORING
In accordance with New York law, we are notifying all employees that all Company electronic resources and
information, including e-mail messages, internet searches, and files, that are created, sent, or retrieved over the
Company’s technical resources are the property of the Company, and should not be considered private or
confidential. Associates have no right to privacy as to any information or file transmitted or stored through the
Company’s computer, voice mail, cell phone, e-mail, text messages, or telephone systems. Any electronically
stored information that you create, send to, or receive from others may be retrieved and reviewed when doing
so serves the legitimate business interests and obligations of the Company. The Company reserves the right to
monitor your use of its technical resources at any time. All information including text and images may be
disclosed to law enforcement or to other third parties without prior consent of the sender or the receiver.
By signing this handbook, you acknowledge and consent to such electronic monitoring of any and all
telephone conversations or transmissions, electronic mail or transmissions, or internet access or usage by an
associate by any electronic device or system, including but not limited to the use of a computer, telephone,
wire, radio or electromagnetic, photoelectronic or photo-optical systems at any and all times and by any lawful
means.
New York City, New York Associates Only
Accommodating Associates in the Workplace
The Company complies with New York City law as it relates to the reasonable accommodation process for associates
needing reasonable accommodations for a covered disability, religious belief, pregnancy, childbirth or related medical
condition, or as a victim of domestic violence, sex offenses and stalking. New York City’s law is broader than the
American with Disabilities Act and the Company complies with the reasonable accommodation obligations applicable
to associates in New York City.
The Company will engage in the interactive process and will have a cooperative dialogue with respect to
accommodations requested. The interactive process may be in writing or orally depending on the particular situation.
The “cooperative dialogue” constitutes a good faith discussion between the associate and Company concerning the
associate’s accommodation needs; potential accommodation that may address the associate’s need for an
accommodation; and any undue hardships or other difficulties that the potential accommodation may pose on the
Company. At the conclusion of the interactive process, the Company will provide an associate a determination in
writing on the request for reasonable accommodation that will indicate the accommodation requests that have either
been granted or denied.
No associate will be subject to retaliation for requesting or obtaining a reasonable accommodation under this policy.
Lactation Accommodation Policy
In accordance with the New York City Human Rights Law, the Company provides reasonable accommodations for
associates' pregnancy, childbirth, or other related medical conditions, including accommodations for lactation. Before
an associate returns from parental leave, the Company will seek to discuss with the associate whether the associate
needs a reasonable accommodation to express breast milk at work.
The Company will not tolerated discrimination or harassment against any associate based on the request for or usage of
lactation accommodations. Any discrimination, harassment, or other violations of this policy can be reported to the
Company’s Human Resources Department.
Use of Lactation Room

• The dedicated lactation room[s] is/are located at [insert location].
• The lactation room is: clean; is free from intrusion and shielded from view of others; contains at least one
electrical outlet, a surface to place a pump and other personal items, and a chair; is near running water (i.e.,
for washing hands and/or cleaning breast pump parts); and can be locked from the inside.
• When more than one associate needs to use the designated lactation room, the Company will discuss various
options with all associates who use the lactation room to determine what arrangement addresses each
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associate's needs such that each associate has access to the lactation room amenities. Options may include:
finding an alternative clean space free from intrusion; sharing the space among multiple users; or creating a
schedule for use. Any accommodation will ensure each associate is afforded a reasonable amount of time to
pump.
• The Company will provide a reasonable amount of time for an associate to express breast milk and will not
unreasonably limit the amount of time or the frequency that an associate expresses breast milk. The Company
will speak with the associate to determine a schedule of breaks that reasonably accommodates the pumping
needs of the associate.
Lactation Accommodation Request Process

• Before an associate returns from parental leave, the Company will resend this policy to the associate in writing
(electronically or by mail) and request information from the associate regarding the need for a reasonable
accommodation to express breast milk at work.
• Associates may also independently request a lactation accommodation by contacting Human Resources.
• Management will respond to a request for a lactation accommodation as quickly as possible. Under no
circumstances will this amount of time exceed five (5) business days.
• The Company recognizes that associates' lactation accommodation needs may change over time. Associates
may request changes to their existing lactation accommodation at any point.
Undue Hardship
• If the Company believes that the lactation accommodation requested poses an undue hardship on the
business, the Company will discuss reasonable alternatives with the associate to accommodate the associate's
needs, initiating a cooperative dialogue as quickly as possible, but absolutely no later than five (5) business
days from the date of the request. The conversation between the Company and the associate will be in good
faith, may occur orally or in writing, and will conclude with a final written determination of the accommodation
granted or denied.
• During the time it takes to respond to a request and/or engage in a cooperative dialogue to determine the
accommodation, the Company will provide a temporary accommodation to the associate so that the
associate can pump in a manner that meets the associate's immediate needs unless doing so poses an undue
hardship.
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OREGON ADDENDUM (for Oregon Associates Only)
OREGON ADDENDUM—For Oregon Associates Only
To our Oregon associates: please note that wherever Oregon law provides for or offers greater protections to our
associates, Oregon law will govern. Please contact a member of the Human Resources Department if you have any
questions about any policies in this Addendum.
ANTI-DISCRIMINATION AND HARASSMENT
This policy supplements the company’s EEO and anti-harassment policies contained in the main handbook. The company
prohibits discrimination and harassment. This policy outlines the complaint procedure available to bring complaints to the
company’s attention.
The Company provides a work environment free from unlawful discrimination or harassment on the basis of race, color,
religion, sex, sexual orientation, national origin, marital status, age, expunged juvenile record, performance of duty in a
uniformed service or physical or mental disability, or any other characteristic protected by local law, regulation, or
ordinance.
It is our policy that all associates, customers, clients, contractors, and visitors to the work site are entitled to a respectful
and productive work environment free from behavior, action, or language that constitutes workplace harassment or
discrimination. The “workplace” includes when associates are on company premises, at a company-sponsored off site
event, traveling on behalf of the company, or conducting company business, regardless of location.
The policy prohibits any conduct at work that a reasonable person in the individual’s circumstances would consider
unwelcome, intimidating, hostile, threatening, violent, abusive, or offensive. It also prohibits employment actions,
including hiring, promotion, termination, and compensation decisions, to be taken based on a protected characteristic.
This policy also prohibits any form of retaliatory action toward an associate for filing a complaint of discrimination or
harassment, or for participation in an investigation of a compliant.
Workplace harassment can be based on national origin, age, sex, race, disability, religion, sexual orientation, gender
identity, or gender expression. It may also encompass other forms of unwelcome, hostile, intimidating, threatening,
humiliating, or violent behavior that is not necessarily illegal, but still prohibited by this policy.
Sexual harassment is a form of workplace harassment and includes, but is not limited to, the following types of conduct:
● Unwelcome sexual advances, requests for sexual favors, or other conduct of a sexual nature when such
conduct is directed toward an individual because of that individual's sex and submission to such conduct is
made either explicitly or implicitly a term or condition of employment; or submission to or rejection of such
conduct is used as the basis for employment decisions affecting that individual.
● Unwelcome verbal or physical conduct that is sufficiently severe or pervasive to have the purpose or effect of
unreasonably interfering with work performance or creating a hostile, intimidating or offensive working
environment.
Sexual Assault
Unwanted conduct of a sexual nature that is inflicted upon a person or compelled through the use of physical force,
manipulation, threat, or intimidation.
Prohibited Conduct
This policy prohibits conduct based on an individual’s protected class status. Although by no means all-inclusive, the
following examples represent prohibited behavior:
● Physical harassment, including but not limited to unwelcome physical contact such as touching, impeding or
blocking movement, or any physical interference with work;
● Verbal harassment, including but not limited to disparaging or disrespectful comments, jokes, slurs, innuendoes,
teasing, and other sexual talk such as jokes, personal inquiries, persistent unwanted courting and derogatory
insults;
● Nonverbal harassment, including but not limited to suggestive or insulting sounds, obscene gestures, leering or
whistling;
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● Visual harassment, including but not limited to displays of explicit or offensive calendars, circulation of
derogatory content, posters, pictures, drawings or cartoons that reflect disparagingly upon a class of persons or
a particular person; or
● Sexual harassment, as described above, including but not limited to unwelcome sexual advances, requests for
favors in exchange for conduct of a sexual nature, submission to unwelcome conduct of a sexual nature in
exchange for a term of employment, or other conduct of a sexual nature.
Penalties
We will not tolerate discriminatory conduct, harassment, or sexual assault. Any individual found to have engaged in such
conduct may face disciplinary action up to, and including, dismissal. The company may also subject managers and
supervisors who fail to report known harassment—or fail to take prompt, appropriate corrective action—to disciplinary
action, including potential dismissal.
Retaliation Protections
The Company prohibits retaliation against any associate for filing a complaint regarding conduct in violation of this
policy. The Company will not tolerate retaliation against any associate for raising a good faith concern, for providing
information related to a concern, or for otherwise cooperating in an investigation of a reported violation of this policy.
Any associate who retaliates against anyone involved in an investigation is subject to disciplinary action, up to and
including dismissal.
Reporting Procedure
Any associate aware of or experiencing discrimination, harassment or sexual assault in the workplace must report that
information immediately to a company designee. Specifically, an associate may make the report verbally or in writing to
the associate’s immediate supervisor or higher management, if the associate prefers. As an alternative, an associate
may report the harassment to the company’s human resource office. Associates may report to any of the persons listed
above, regardless of any particular chain of command. All associates are encouraged to document any incidents
involving discrimination, harassment, and sexual assault as soon as possible.
Nondisclosure or Nondisparagement Agreements

Under this policy, a nondisclosure agreement is any agreement by which one or more parties agree not to discuss or
disclose information regarding any complaint of work-related harassment, discrimination, or sexual assault.
A nondisparagement agreement is any agreement by which one or more parties agree not to discredit or make
negative or disparaging written or oral statements about any other party or the company.
A no-rehire provision is an agreement that prohibits an associate from seeking reemployment with the company and
allows a company to not rehire that individual in the future.
The company will not require an associate to enter into any agreement if the purpose or effect of the agreement
prevents the associate from disclosing or discussing conduct constituting discrimination, harassment, or sexual assault.
An associate claiming to be aggrieved by discrimination, harassment, or sexual assault may, however, voluntarily request
to enter into a settlement, separation, or severance agreement which contains a nondisclosure, nondisparagement, or
no-rehire provision and will have at least seven (7) days to revoke any such agreement.
Time Limitations
Nothing in this policy precludes any person from filing a formal complaint with the Bureau of Labor and Industries’ Civil
Rights Division or the Equal Employment Opportunity Commission. Note that Oregon state law requires that any legal
action taken on alleged discriminatory conduct (specifically that prohibited by ORS 659A.030, 659A.082 or 659A.112)
commence no later than five years after the occurrence of the violation. Other applicable laws may have a shorter time
limitation on filing.
MEAL AND REST BREAKS
It is the policy of the Company to provide meal and rest breaks during the course of each workday.
REST BREAKS
Nonexempt associates (those covered by the minimum wage and overtime requirements of the Fair Labor Standards
Act and/or Oregon law) must take a rest break of ten (10) minutes for every segment of working time that is more than
two (2) hours and less than or equal to four (4) hours. For example, an associate who works two (2) four-hour periods in
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one day is entitled to two paid 10-minute rest periods, one during each four-hour period. An associate who works a shift
longer than ten (10) hours is entitled to a third rest period. Associates are expected to be punctual in starting and
ending their breaks and may be disciplined for tardiness. Time spent on rest breaks will be compensated as working
time.
Associates may not waive rest breaks. If an associate believes that they are not receiving their rest breaks, they are
required to notify Human Resources.
MEAL BREAKS
Nonexempt associates scheduled to work six or more hours during any work period must take a 30-minute uninterrupted
meal break. If the work period is at least six hours but less than seven hours, the meal period is to be taken after the
second hour worked and before the commencement of the fifth hour worked. If the work period is more than seven
hours, the meal period is to be taken after the third hour worked and before the commencement of the sixth hour
worked. Nonexempt associates required to work 14 hours or more in any work period will be allowed a second 30-minute
meal break.
Associates are entitled, encouraged, afforded and expected to take all meal periods provided under the Meal Period
policy. The Company completely relieves associates of all work duties and does not exercise control over associates’
activities during their uninterrupted, duty-free meal period. Associates are free to leave the workplace during the meal
period and are free to spend their meal period time as they choose (consistent with any other Company policies that
may apply during off-duty time). Associates may not waive or take a shorter meal period. Nonexempt associates must
sign out and back in for all meal breaks. Associates will be subject to discipline if tardy returning from a break.
Meal breaks are unpaid and generally will not be compensated as working time unless, due to exceptional or
unforeseen circumstances, the associate does not receive a full 30-minute meal break or is required to perform work
during their break. If an associate believes that they are not receiving their full 30-minute meal breaks, they are required
to notify Human Resources.
PREGNANCY AND LACTATION ACCOMMODATIONS
PREGNANCY ACCOMMODATIONS
Provided that the Company has at least six associates, the Company will provide reasonable accommodations to
Oregon associates for known limitations related to pregnancy, childbirth, or related medical conditions (including, but
not limited to lactation), unless doing so would impose an undue hardship. The Company will not deny employment
opportunity because of pregnancy accommodations, retaliate against associates for making accommodation requests,
or force pregnant associates to take leave time or accept accommodations if there is no known limitation due to
pregnancy. Possible pregnancy-related accommodations under this policy could include acquisition or modification of
equipment or devices, longer or more frequent break periods, assistance with manual labor, or modification to work
schedules or job assignments. Associates are encouraged to contact Human Resources for additional information
regarding the availability of pregnancy accommodations.
LACTATION ACCOMMODATIONS
The Company will provide reasonable lactation breaks to accommodate Oregon associates who need to express milk
for the associate’s child during the workday, unless undue hardship to the Company’s operations would result. The
Company will provide the associate with a reasonable lactation break to express milk each time the associate has need
to express milk until the child is 18 months of age. If feasible, the associate shall attempt to take lactation breaks at the
same time as her normal rest or meal break(s). Lactation breaks are unpaid, expect to the extent they overlap with a
paid rest or meal break. With approval of a supervisor, if an associate takes unpaid lactation breaks, she may, but will
not be required to, start work early or finish work later in order to make up the amount of time used during unpaid
lactation breaks. When possible, the associate should provide reasonable notice to the Company that she intends to
express milk upon returning to work after the child’s birth (however, failure to provide such notice will not be grounds for
disciplinary action). The Company will make reasonable efforts to provide a location, other than a public restroom or
toilet stall, in close proximity to the associate’s work area for the associate to express milk in private. Associates with
questions about lactation accommodations should contact Human Resources.
OREGON FAMILY LEAVE ACT
Associate Eligibility
Provided that the Company has employed 25 or more associates in Oregon in the current or previous year, an associate
may qualify for leave under the Oregon Family Leave Act (“OFLA”) if the associate works in Oregon and: (1) has worked
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for the Company for at least 180 days; and (2) has worked at least an average of 25 hours per week during the 180-day
period before the start of the requested leave. The second requirement does not apply if an associate is requesting OFLA
leave for parental leave purposes.
Oregon also has implemented paid Family Leave through the state starting January 1, 2023. The 25 employee limit does
not apply to the paid leave law. The paid leave program will be administered through the state from payroll
deductions paid 60% by employer and 40% by employee. The annual contribution cap is set at 1% total wages up to
$132,900. Employees will be eligible to request paid benefits starting September 1, 2022. More information on the paid
benefit can be found at https://paidleave.oregon.gov/Pages/default.aspx. Employees with questions should contact
Human Resources.
Eligibility after Separation and Reemployment or Temporary Cessation of Work
Effective January 1, 2022, Oregon associates reemployed by the Company after a separation from employment, or
returning to work at the Company after a temporary cessation of scheduled work hours, within 180 days will be eligible
for OFLA Leave as follows:
• Associates reemployed or returning within 180 days who were eligible for OFLA Leave (based on regular eligibility
criteria above) at the time of their separation or the beginning of their temporary cessation of work, will be
eligible to take OFLA Leave immediately upon their reemployment or return to work.
• Associates reemployed or returning within 180 days who were not eligible for OFLA Leave (based on regular
eligibility criteria above) at the time of their separation or the beginning of their temporary cessation of work, will
receive credit for the amount of time that they worked for the Company prior to the break in service for purposes
of OFLA eligibility.
• Any OFLA Leave taken by the reemployed/returning associate within any one-year period will continue to count
towards the associate’s OFLA Leave entitlement.
• Associates reemployed or returning to work after a separation or temporary cessation of scheduled hours for
more than 180 days must reestablish eligibility for OFLA Leave and will not receive credit for prior service.
Eligibility during Periods of Public Emergency
Effective January 1, 2022, during a period covered by a public health emergency, all Oregon associates are eligible for
OFLA Leave if the Company has employed them for at least 30 days immediately before the leave begins and they
have worked an average of at least 25 hours per week during the 30 days immediately before the leave begins. For
purposes of this policy, “public health emergency” means a public health emergency declared under ORS 433.441, or
an emergency declared under ORS 401.165 if related to a public health emergency as defined in ORS 433.442.
Permissible Purposes of OFLA Leave
An eligible associate may generally take unpaid OFLA leave for any of the following reasons:
1. For the associate’s own “serious health condition”;
2. For the associate’s own disability due to pregnancy, child birth, or related medical condition (“pregnancy
disability leave”) or absence for prenatal care.
3. To care for a family member (spouse; same-gender domestic partner; biological, adoptive foster, or step-
parent or child; grandparent or grandchild; parent-in-law; parent of same-gender domestic partner; person
with whom the associate was or is in a relationship of in loco parentis; or the biological, adopted, foster, or step-
child of the associate or the associate’s same-gender domestic partner) with a “serious health condition”;
4. To care for an associate’s sick child (including a biological, adopted, foster, or stepchild of the associate or the
associate’s same-gender domestic partner or a child with whom the associate is or was in a relationship of in
loco parentis) suffering from an illness, injury, or medical condition that requires home care but is not a serious
health condition or whose school or childcare provider has been closed in conjunction with a statewide public health
emergency declared by a public health official (“sick child leave”), provided the child is under the age of 18, or over the
age of 18 and substantially limited by a physical or mental impairment;
5. To care for (or be with) an associate’s child (including a biological, adopted, foster, or stepchild of the
associate or the associate’s same-gender domestic partner) after birth, adoption, or foster care placement
(“parental leave”), provided the child is under the age of 18, or over the age of 18 and substantially limited by
a physical or mental impairment and the leave is completed within twelve (12) months after the birth or
placement; and
6. Bereavement (see Oregon Bereavement Leave).
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For purposes of Sick Child Leave during a statewide public health emergency declared by a public health official, “Child Care
Provider” means a place of care or person who cares for a child. A person who cares for a child includes, but is not limited to,
individuals paid to provide childcare (for example, nannies, au pairs, and babysitters) or individuals who provide child care at no cost
and without a license on a regular basis (for example, grandparents, aunts, uncles, or neighbors). A “place of care” is a physical
location in which care is provided for a child, including, but not limited to, day care facilities, preschools, before and after school care
programs, schools, homes, summer camps, summer enrichment programs, and respite care programs. The physical location does not
have to be solely dedicated to such care. “Closure” for the purpose of this type of Sick Child Leave means a closure that is ongoing,
intermittent, or recurring and restricts physical access to the child’s school or childcare provider.
Duration of Leave
An eligible associate is ordinarily entitled to up to 12 weeks of OFLA leave during a 12-month period. The 12-month period
in which the leave occurs will be calculated on a “rolling” 12-month period measured backward from the date an
associate uses any OFLA leave.
An eligible associate may be entitled to take additional OFLA leave under the following conditions. First, a female
associate may use an additional 12 weeks of OFLA leave as “pregnancy disability leave” for pregnancy- or childbirth-
related illnesses, injuries or conditions that disable her from performing any available job duties offered by the Company,
even if she has already taken 12-weeks of OFLA for any permissible purpose, including an extension of pregnancy
disability leave. Second, a parent who has already used 12 full weeks of OFLA leave as “parental leave” may take up to
an additional 12 weeks of OFLA leave as “sick child leave” within the same 12 months.
OFLA leave may be taken consecutively, or may be taken intermittently during nonconsecutive periods with the
approval of the Company.
When two or more family members are employed by the Company and are eligible for OFLA leave, they may not take
concurrent OFLA leave unless: one associate needs to care for another associate who is a family member and is
suffering from a serious health condition; one associate needs to care for a child who has a serious health condition
while another associate who is a family member is also suffering from a serious health condition; or the associates are
taking OFLA leave related to the death of a family member.
Requesting OFLA Leave
Associates must provide the Company with at least 30 days’ written notice in advance of their OFLA leave, unless the
leave is taken for an emergency. In an emergency, associates must give verbal notice within 24 hours of starting a leave
and provide written notice within three days after the associate returns to work. Verbal notice can be given by another
person on behalf of the associate.
Associates taking OFLA leave for the associate’s own serious medical condition, the serious medical condition of a family
member, or sick child leave, must provide to Human Resources medical certification supporting the need for the leave.
The notice and medical certification need to provide a specific medical diagnoses, but must provide sufficient
information for the Company to determine whether the leave qualifies for OFLA and, if so, what type of OFLA leave.
Associates will have 15 days to return the requested medical certification. If the medical certification is incomplete or
certification, the associate will be notified an allowed seven (7) days to provide the necessary certification information.
Recertification may also be required where an associate needs more leave than the original certification justified or
where circumstances and facts cast double on an associates need for OFLA leave. If an associate fails to provide the
required notice or certification, OFLA coverage may be delayed or the leave may not be considered protected under
OFLA, and the associate may be subject to disciplinary action under the Company’s normal attendance policies.
Notwithstanding the foregoing, associates will not be required to provide medical certification for sick child leave taken
under OFLA unless they have already taken more than three days of sick child leave under OFLA during the leave year,
in which case the Company will reimburse them for the out-of-pocket costs associated with obtaining medical
verification for sick child leave. The Company also will not require associates to provide medical verification for Sick
Child Leave due to the closure of the child’s school or child care provider in conjunction with a statewide public health
emergency declared by a public health official; however, it may require verification of the need for such leave,
including: (a) the name of the child being cared for; (b) the name of the school or child care provider that has closed
or become unavailable; (c) a statement from the associate that no other family member of the child is willing and able
to care for the child; and (d) for the care of a child older than 14, a statement that special circumstances exist requiring
the associate to provide care to the child during daylight hours.
Associates on OFLA leave must periodically notify Human Resources of their status and intent to return to work and
estimated return date.
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Pay While on OFLA Leave
OFLA leave is unpaid, but associates may use accrued paid sick leave.
Relation to FMLA Leave
OFLA leave runs concurrently with FMLA leave if the associate is eligible under both laws at the time the leave is taken
and, to that extent, the terms and conditions in the Company’s FMLA Leave Policy are incorporated into this policy by
reference. There are a few situations, however, such as sick child leave and leave to care for a parent-in-law,
grandparent, or grandchild with a serious health condition, in which OFLA provides for leave and FMLA does not.
Conversely, some FMLA circumstances do not necessarily qualify for leave under OFLA. Please contact the Human
Resources Department for further information.
When associates are eligible for and use OFLA leave, any paid sick time used for purposes that qualify under OFLA will
also be designated as OFLA leave. Associates will not continue to accrue paid sick time while on OFLA leave.
A worker’s compensation injury is not considered an OFLA-qualifying event and leave taken because of an on-the-job
disabling injury will not reduce the amount of OFLA leave that an associate may take during the OFLA leave year, unless
the associate refuses a genuine offer for light duty or modified work, in which case OFLA leave automatically begins
upon the associate’s refusal and will run concurrently with workers’ compensation leave.
Continuation of Benefits During OFLA Leave
The insurance benefits of associates who participate in the Company’s group health insurance or other insurance plans
will continue during their OFLA leave, and the Company will continue to pay its share of their insurance premiums for the
duration of the OFLA leave. However, associates will be responsible for continuing to make any normal associate
contributions for their own share of the cost of insurance premiums during an OFLA leave. Please contact Human
Resources for additional information.
Return to Work
Eligible associates are entitled to be restored to their former position if that position still exists following an approved OFLA
leave. If the job no longer exists, the Company will restore associates returning from OFLA leave to an equivalent job with
the same compensation, benefits, and other terms and conditions of employment. If an equivalent job is not available
at the former jobsite, associates may be placed in an equivalent job at an alternative location within twenty
(20) miles of the former jobsite.
If the reason for which an associate took, OFLA leave was the associate’s own serious health condition, the associate
may be required to provide certification from a healthcare provider that the associate is released to return to work,
either with or without restrictions.
Unless otherwise required by law, an associate who fails to return to work upon expiration of an approved OFLA leave will
no longer have job reinstatement protections or protected absences under OFLA.
Non-Interference and Non-Retaliation
The Company will not interfere with any associates’ OFLA rights and will not retaliate or discriminate against any
associate because they associate has asked about or taken OFLA leave, opposed any practice made unlawful by
OFLA, or is involved in any proceeding under or related to OFLA.
Associates who have any questions or would like any additional information regarding their eligibility or rights under OFLA
should contact Human Resources.
OREGON MILITARY FAMILY LEAVE ACT
An associate is eligible for up to 14 days per deployment of unpaid leave under the Oregon Military Family Leave Act
(“OMFLA”) if: (1) the associate works at least an average of 20 hours per week; (2) the associate’s spouse or registered
domestic partner is a member of the United States Armed Forces, National Guard, or military reserve forces; and (3) the
spouse or domestic partner has been notified of an impending call or order to active duty or the spouse is on leave from
deployment. OMFLA leave is unpaid. However, an associate who takes OMFLA leave may choose to substitute any
accrued paid time off, in the order of the associate’s choice, to which the associate is entitled for all or any part of the
OMFLA leave.
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Associates who wish to request this leave must provide the Human Resources Department with a written request for such
leave within 5 business days of receiving official notice of an impending call to active duty or that the military spouse or
domestic partner will be on leave from deployment. The Company may require the associate to provide a copy of the
service members’ written orders to verify the need for OMFLA leave. OMFLA leave taken will be included in the total
amount of leave under the OFLA and, where applicable, the FMLA.
An associate who takes OMFLA leave is entitled to be restored to a position of employment and to the continuation of
benefits just like an associate taking OFLA Leave. The Company will not interfere with an associate’s OMFLA rights and
will not retaliate against an associate who asks about or takes OMFLA Leave, opposes any practice made unlawful by
the OMFLA, or is involved in any proceeding under or related to OMFLA. Associates who have any questions or would
like any additional information regarding their eligibility or rights under OMFLA should contact Human Resources.
OREGON BEREAVEMENT LEAVE
Associates who are eligible for OFLA leave (see above), may take up to two weeks per death of unpaid OFLA
bereavement leave to: (1) attend the funeral of a family member; (2) make arrangements necessitated by the death of
the family member; or (3) grieve the death of the family member. If an associate suffers the death of multiple family
members in a 12-month-period, the associate is limited to a maximum of 12-weeks of leave. OFLA bereavement leave
taken will be included in the total amount of leave under the OFLA. If spouses or domestic partners both work for the
Company, they may take OFLA Bereavement Leave concurrently. Associates may use accrued sick leave to receive
pay for covered absences under OFLA bereavement leave.
OFLA bereavement leave must be taken within 60 days after the associate receives notice of the family member’s
death. Oral notice of the need for OFLA bereavement leave must be given to the Human Resources Department within
24 hours of the beginning of the leave, and written notice must be given no later than three days after the associate
returns to work from the leave. Associates are encouraged to give written notice of the need for OFLA bereavement
leave as soon as possible.
LEAVE FOR BONE MARROW DONATIONS
Associates who work an average of 20 hours or more per week may use up to 40 hours of their accrued paid leave per
year to donate bone marrow. The total length of any combined leaves to donate bone marrow may be determined by
an associate but may not exceed the amount of already accrued paid leave or forty (40) work hours, whichever is less,
unless other agreed to by the Company.
The Company will not retaliate against an associate for requesting or using accrued leave to donate bone marrow. The
Company may require medical certification for associates requesting this leave. If there is a medical determination that
the associate does not qualify as a bone marrow donor, any paid leave used by the associate before that medical
determination is not affected.
WITNESS DUTY LEAVE
Associates will be granted a reasonable amount of time off to participate in certain legal proceedings, testify in a civil
proceeding or criminal trial, or to appear in juvenile court with their child (including a child for which the associate is the
legal guardian). Time off for witness duty leave will be unpaid. However, an associate may (but is not required to) elect
to use available accrued paid sick leave or vacation (in the order of the associate’s choosing) for witness duty.
Associates must submit a copy of the notification to their supervisor as soon as possible after receipt. If witness duty does
not take the entire day, the associate is expected to return to work.
EMERGENCY PERSONNEL/ORGANIZED MILITIA SERVICE LEAVE
The Company provides leave to qualifying volunteer firefighters, members of rural fire protection districts, firefighters
employed to perform services under the Emergency Conflagration Act, search and rescue volunteers, and members of
any state’s organized militia, such as the Oregon National Guard or Oregon State Defense Force, to perform active state
service. This leave of absence is unpaid; however, an associate will be required to use all available accrued vacation or
other paid time off during any leave period approved under this section. Associates who qualify for and use this leave
will be reinstated to their previous positions without loss of seniority, accrued unused leave, or other benefits.
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VETERANS DAY LEAVE
The Company will allow qualifying veterans who provide at least 21 calendar days’ notice and proof of veteran status to
take leave for the federal Veterans Day holiday. This leave is unpaid, but the associate may (but is not required to) elect
to use available accrued paid sick leave or vacation for Veterans Day leave. Within 14 days after an associate has
submitted a request for Veterans Day Leave, the Company will notify the associate whether the time off will be paid or
unpaid. Failure to provide the required notice and/or documentation may result in denial of the leave. The Company
also may deny a leave request under this section if it determines that such leave would cause significant economic or
operational disruption or undue hardship. If the Company denies a qualifying associate’s request to take Veterans Day
off work due to undue hardship, the Company will allow the associate to choose, with the Company’s approval, a single
day off within the year after Veterans Day on which to honor the associate’s service.
VICTIMS OF DOMESTIC VIOLENCE AND SEXUAL ASSAULT (LEAVE AND SAFETY ACCOMMODATIONS)
To the extent required by law, the Company will provide reasonable leave and/or reasonable safety accommodations
at work to an associate who is a victim, or who is the parent or legal guardian of a minor child or dependent who is a
victim, of domestic violence, harassment, sexual assault, or stalking. An associate who is a victim, or who is the parent or
legal guardian of a minor child or dependent who is a victim, of domestic violence, harassment, sexual assault, or
stalking is eligible for these protections regardless of how long the associate has been employed or how many hours per
week the associate works.
An associate who is a victim, or who is the parent or legal guardian of a minor child or dependent who is a victim, of
domestic violence, stalking, harassment, or sexual assault may receive unpaid leave to: (1) seek legal or law
enforcement assistance or remedies to ensure the health and safety of the associate or the associate’s minor child or
dependent, including preparing for and participating in protective order proceedings or other civil or criminal legal
proceedings related to domestic violence, harassment, sexual assault, or stalking; (2) seek medical treatment for or to
recover from injuries caused by domestic violence, harassment, sexual assault, or stalking of the eligible associate or the
associate’s minor child or dependent; (3) obtain, or to assist a minor child or dependent in obtaining, counseling from a
licensed mental health professional related to an experience of domestic violence, harassment, sexual assault, or
stalking; (4) obtain services from a victim services provider for the eligible associate or the associate’s minor child or
dependent; or (5) relocate or take steps to secure an existing home to ensure the health and safety of the eligible
associate or the associate’s minor child or dependent.
To take this leave, the associate must provide the Company with advance notice of this leave, unless giving advance
notice is not practicable. This leave is unpaid, but the associate may (but is not required to) elect to use available
accrued paid sick time or vacation (in the order of the associate’s choosing) for this type of leave. There is no specific
limit to the amount of leave an associate may take for this purpose, but the Company may limit the amount of leave an
associate takes for this purpose if the associate’s leave creates an undue hardship to the Company. The Company will
not deny an eligible associate’s request for reasonable leave or discharge, threaten to discharge, intimidate or coerce
an associate because of leave for these reasons.
An associate who is a victim, or who is the parent or legal guardian of a minor child or dependent who is a victim, of
domestic violence, harassment, sexual assault, or stalking may also be eligible for reasonable safety accommodations at
work. Reasonable safety accommodations could include things such as transfer, reassignment, modified schedule,
unpaid leave, changed work telephone number, changed work station, installed lock, change in office policy, or any
other adjustment to a job structure, workplace facility, or work requirement in response to actual or threatened domestic
violence, sexual assault, or stalking, provided that such accommodation would not pose an undue hardship on the
Company.
Prior to providing leave or a safety accommodation under this policy, the Company may require the associate to
provide certification that the associate is a victim of domestic violence, harassment, sexual assault, or stalking and/or of
the need for the safety accommodation, such as: a document from law enforcement or the courts; a police report or
restraining order; a letter or other document from an attorney, counselor, domestic violence or sexual assault victim
service provider, health care professional, or clergy member. The associate must provide the certification within a
reasonable time after the Company’s request. All records and information kept by the Company regarding an
associate’s request for a safety accommodation, including the fact that the associate is a victim of domestic violence,
harassment, sexual assault, or stalking, will be maintained as confidential and will not be released without the express
permission of the associate, unless otherwise required by law.
Discharging, harassing, or otherwise discriminating or retaliating against any associate for exercising rights pursuant to this
policy is strictly prohibited. Associates who believe they have been subjected to any such improper conduct should
contact Human Resources immediately.
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CRIME VICTIMS’ LEAVE
Provided the Company has six or more associates in the state of Oregon, the Company will provide reasonable leave
from work for an associate to attend criminal proceedings if the associate or the associate’s immediate family member
(spouse, domestic partner, father, mother, sibling, child, stepchild or grandparent) is the victim of a crime constituting a
“person felony” under Oregon law that causes the associate or family member financial, social, psychological or
physical harm. To be eligible for this leave, the associate must have worked an average of more than twenty-five (25)
hours per week for at least 180 days immediately before the date of the leave. The associate must provide reasonable
notice of intention to take the leave, as well as copies of any notices of scheduled criminal proceedings that an
associate receives from a law enforcement agency. This leave is unpaid, but the associate may (but is not required to)
elect to use available accrued paid sick leave or vacation (in the order of an associate’s choosing) for this type of
leave. The Company will not deny an eligible associate’s request for reasonable leave or discharge, threaten to
discharge, intimidate or coerce an associate because of leave taken to attend a criminal proceeding.
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WASHINGTON ADDENDUM (for Washington Associates Only)
WASHINGTON ADDENDUM—For Washington Associates Only
To our Washington associates: please note that wherever Washington law provides for or offers greater protections to our
associates, Washington law will govern. Please contact a member of the Human Resources Department if you have any
questions about any policies in this Addendum.
MEAL PERIODS AND REST BREAKS

The following meal and rest break requirements apply to Washington associates other than executive, administrative, or professionally
exempt associates.
MEAL PERIODS
Associates who work more than 5 hours in a shift are permitted to take a 30-minute duty free meal period, which shall start no less than
2 hours nor more than 5 hours from the beginning of the shift. Associates shall not be required to work more than 5 consecutive hours
without a meal period. This means that, depending on when the first meal period is taken and the total hours worked in a shift, an
associate may be entitled to take an additional 30-minute meal period.
Example: Associate is scheduled for an 8-hour shift from 9:00 a.m. to 5:00 p.m. Associate takes a meal period from 11:00 to 11:30 a.m.
No later than 4:30 p.m., the associate must be provided the opportunity to take a second meal period because the associate will work
more than 5 hours after the first meal period. If the associate takes the first meal period at 11:30 or later, no second meal period is
required.
Meal Period Timing

• A meal period may not be taken before 2 hours of work is completed.
• No associate shall be required to work more than 5 consecutive hours without a meal period.
• A meal period should be scheduled for shifts in excess of 5 hours. The meal period should be scheduled as close to the
middle of the scheduled work shift as possible, and before the 5th hour of work (i.e., the meal period should start no more
than 4 hours and 59 minutes into the shift).
• Second meal periods, if applicable, should be scheduled no later than 5 hours after the end of the first meal period.
• Associates working three or more hours longer than a normal work day (the shift the associate is regularly scheduled to work)
shall be allowed at least one 30-minute meal period prior to or during the additional work period.
Meal Period Procedure

• Meal periods are unpaid and at least 30 consecutive minutes long. However, unless waived in accordance with this policy
(see below), associates will be paid for their meal period if any of the following rare or unexpected circumstances occur: (1)
they are required or allowed to remain on duty or perform any work tasks during the meal period or return to work early; or (2)
they are required to remain on premises in order to be “on call” and are obligated to respond and/or return to work if called
during their meal period. If an associate’s meal period is interrupted, in addition to the meal period being paid, the meal
period will be continued until the associate receives 30 minutes of meal period time.
• Associates must clock in and out for all meal periods.
• Associates are free to leave the premises during meal periods.
Meal Period Waiver

Associates may voluntarily waive their meal periods by signing a Meal Period Waiver Form. Associates who waive meal periods may
choose to later revoke their waiver by providing a written revocation.
REST BREAKS
• Rest breaks are paid and are ten (10) minutes in duration.
• Rest breaks should ideally be taken as near as possible to the middle of the shift or work period.
• Rest breaks are to be allowed for every four hours worked. No associate shall be required to work more than three
consecutive hours without a break.
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• Restroom breaks are not considered rest breaks.
• Rest breaks and meal periods cannot be combined.
• Rest breaks cannot be waived.
Scheduled rest breaks are not required where the nature of the work allows associates to take intermittent rest breaks equivalent to
ten minutes for each four hours worked.
COMPLAINT PROCEDURE
If anyone or anything interferes with an associate’s ability to take rest breaks or meal periods as outlined in this policy, the associate
must immediately notify the associate’s supervisor or manager or Human Resources. No associate will be retaliated against for raising
a concern regarding meal periods and/or rest breaks. Failure to comply with this policy may result in disciplinary action up to and
including termination.
PREGNANCY ACCOMMODATIONS
In accordance with the Washington Healthy Starts Act, the Company will provide pregnant associates with the following pregnancy
accommodations upon request, without need for written certification from a healthcare provider: limiting lifting to 17 pounds; offering
more frequent, longer, or flexible restroom breaks as needed; modifying a no-food-or-drink policy; and making seating available or
allowing a pregnant associate to sit more frequently. In addition, unless undue hardship on the operation of the business would result,
or the associate’s continued employment, despite accommodation, would pose a direct threat to the safety of the associate or
others, the Company will provide additional reasonable pregnancy accommodations upon provision of written certification of a
healthcare provider, as determined based on a case-by-case analysis. The Company will not discriminate or retaliate against
associates who request, decline, or use an accommodation under this policy. In addition, the Company will not require an associate
to take leave if another reasonable accommodation can be provided for the associate’s pregnancy. Please contact Human
Resources for more information or to request a pregnancy accommodation.
LACTATION BREAKS
The Company will provide reasonable break time for an associate to express breast milk in the workplace for 2 years after the child's
birth each time the associate has need to express the milk, and will provide a private location, other than a bathroom, if such a
location exists at the place of business or worksite, which may be used by the associate to express breast milk. If the business location
does not have a space for the associate to express milk, the Company will work with the associate to identify a convenient location
and work schedule to accommodate the associate’s needs to express breast milk. Lactation breaks are unpaid; except to the extent
they overlap with paid rest breaks.
PREGNANCY DISABILITY LEAVE
The Company provides associates who are disabled by pregnancy, childbirth or related medical conditions with accommodation,
including potential leaves of absence, pursuant to the Washington Law Against Discrimination. Pregnancy disability leave is for the
period of disability only, and not for childrearing after the disability ends. Leave will be allowed for the entire period of pregnancy-
related or childbirth-related disability and will be provided under the same terms and conditions as leave for other temporary
disabilities. The Company may require that a licensed healthcare provider certify the actual period of disability. Leave provided under
this policy will be in addition to leave available, if applicable, under the Washington Family and Medical Leave Act. Please contact
Human Resources for more information.
WASHINGTON PAID FAMILY AND MEDICAL LEAVE ACT

Washington state’s Paid Family and Medical Leave is a mandatory statewide insurance program that provides most Washington
associates with paid time off to give or receive care.
If an associate qualifies, this program will allow an associate to take up to 12 weeks, as needed, for family or medical leave if you:
• Welcome a child into your family (through birth, adoption or foster placement)*
• Experience a serious illness or injury
• Need to care for a seriously ill or injured relative or family member
• Are grieving during the seven (7) days following the death of a newborn or newly placed child
• Need time to prepare for a family member’s pre- and post-deployment activities, as well as time for childcare issues related to
a family member’s military deployment. For specifics on military-connected paid leave, visit
www.dol.gov/whd/regs/compliance/whdfs28mc.pdf
• Bereavement leave during 7 days following death of a newborn child or child newly placed for adoption
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If an associate experiences multiple events in a year, the associate might be eligible to receive up to 16 weeks, and up to 18 weeks of
paid leave if the associate experiences a serious health condition during pregnancy that results in incapacity. Some of the events for
which an associate may qualify for wage replacement benefits are subject to a seven (7) consecutive day waiting period.
*The 6 weeks after a child’s birth is the postnatal period; any PFML taken during that period will be designated as medical leave, unless
the associate chooses to use family leave. Certification of a serious health condition is not required for paid leave taken in the postnatal
period.
Payment of premiums
The program is funded by premiums paid by both associates and employers. It will be administered by the Employment Security
Department (ESD).
Premium collection amount for 2022, the premium is 0.6 percent of gross wages and this amount may change from year to year as
determined by ESD. Associates pay a portion of the premiums and the Company pays the remainder of the premiums. The Company
withholds the associate portion of premiums from associates’ paycheck as required and submits them to ESD on a quarterly basis.
Taking leave
Associates who have worked 820 hours in the qualifying period may be able to apply to take paid medical leave or paid family leave,
even if all of those hours have not been worked with the Company.
If an associate qualifies for leave, the associate may also qualify for partial wage replacement. That means the associate may receive
a portion of your average weekly pay. The benefit is generally up to 90 percent of your weekly wage, with a current minimum of $100
per week and a maximum of $1,327 per week. If you qualify for partial wage replacement benefits, you will be paid by ESD rather than
the Company during your leave.
Leave under this Paid Family and Medical Leave Policy may run concurrently with other available unpaid or paid leaves. Associates
must contact Human Resources to discuss this and other forms of leave for which they may be eligible.
Job Protections
If the Company has 50 or more associates, then associates who return from leave under this policy will be restored to a same or
equivalent job if they have work for the Company for at least 12 months, and have worked 1,250 hours in the 12 months before taking
leave. During any period of leave taken under this policy, you may retain your health insurance by continuing to pay your portion of the
cost of your health insurance premiums.
The Company prohibits discrimination and retaliation against associates who have requested or taken paid leave. Associates should
report any concerns regarding discrimination or retaliation directly to Human Resources.
WASHINGTON FAMILY CARE ACT
Washington associates may use their choice of any accrued paid leave benefits available to them, such as Paid Leave, PTO, holiday,
and some short-term disability plans for family care purposes, including (1) to care for a minor child of with a health condition that
requires treatment or supervision, including preventative care, or for an adult child who cannot care for themselves because of a
disability, or (2) to care for a child, spouse, registered domestic partner, parent, parent-in-law, or grandparent of the associate who
has a serious health condition or an emergency health condition, including temporarily disability because of pregnancy or childbirth.
Please contact Human Resources for additional information regarding eligibility and verification requirements.
VICTIMS OF DOMESTIC VIOLENCE, SEXUAL ASSAULT, OR STALKING
Associates who (or associates whose family members) are victims of domestic violence, stalking, or sexual assault may receive
reasonable safety accommodations at work and/or reasonable unpaid leave to seek, or assist a family member in seeking, legal or
law enforcement assistance, medical treatment, counseling, obtaining services from a shelter or a victim’s advocate program, or for
safety planning or relocation. “Family members” include a child (including a biological, adopted, foster, or step child, legal ward or
child for whom the associate stands in loco parentis, or in the place of a parent), spouse, registered domestic partner, parent, parent-
in-law, grandparent, or a person the associate is dating.
To take this leave, the associate must provide the Company with advance notice of this leave. If advanced notice is not possible, the
associate (or someone on the associate’s behalf) must provide the Company with notice by no later than the end of the first day that
the associate takes such leave. The associate may choose to use any accrued personal time off or paid sick leave, if available, for an
absence described above. The leave must be reasonable in duration, which will be determined by management and the affected
associate, based upon the circumstances.
The Company will also work with victims of domestic violence to provide reasonable accommodations to ensure an associate’s safety
at work.
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The following certifications may be required upon returning back to work, or before provision of a reasonable safety accommodation
at work: (1) a police report showing that the associate was a victim of domestic violence, sexual assault, or stalking; (2) a court order
protecting the associate from the perpetrator or other evidence from the court or prosecuting attorney that the associate appeared
in court; or (3) documentation from a medical professional, domestic violence, sexual assault, or stalking victim advocate, health care
provider, or counselor showing that the associate’s absence was due to treatment for injuries from domestic violence or sexual assault;
(4) an associate’s written statement that the associate or the associate’s family member is a victim of domestic violence, sexual
assault, or stalking, and that the leave was taken for one of the purposes described above. Associates will not be required to provide
additional information beyond this required verification, or information that would compromise the safety of the associate or the
associate’s family member. Except as otherwise required or permitted by law, the Company will maintain the confidentiality of all
information associates provide under this policy, including the fact that the associate or a family member is a victim or that the
associate has requested leave or safety accommodations for these purposes.
Discharging, harassing, or otherwise discriminating or retaliating against any associate for exercising rights pursuant to this policy is
strictly prohibited. Associates who believe they have been subjected to any such improper conduct should contact Human Resources
immediately.
MILITARY FAMILY LEAVE
Associates who work an average of 20 hours or more per week whose spouse or registered domestic partner is deployed or on leave
from active deployment in the state military, US Armed Forces, the National Guard, or the reserves may take up to 15 days of unpaid
leave per deployment while the military service member is on leave from deployment, or before and up to deployment, during a
period of military conflict. Associates may split their 15 days of leave between different periods of time (i.e., pre-deployment or while
the servicemember is on leave during deployment), however, the total number of days of leave cannot exceed 15 days per
deployment. Associates must provide Human Resources with notice of the associate’s intent to take leave within five business days of
receiving official notice that the associate’s spouse or registered domestic partner will be on a leave or will be called or ordered to
duty. This leave is unpaid. However associates may use any available paid time off for the absence. Please contact Human
Resources for additional information regarding eligibility and verification requirements.
LEAVE FOR EMERGENCY SERVICES PERSONNEL
Provided the Company had 20 or more full time equivalent associates in the previous year, the Company will not discipline or
terminate a volunteer firefighter or reserve officer because of leave taken related to an alarm of fire or an emergency call, or a civil air
patrol member because of leave taken related to an emergency service operation that prevents them from showing up to work or
showing up on time. "Alarm of fire or emergency call" means responding to, working at, or returning from a fire alarm or an
emergency call, but not participating in training or other nonemergency activities. To be eligible, a volunteer firefighter must not be
paid and must be on the alarm or emergency call and ordered to remain on the scene by the commanding authority. "Emergency
service operation" means the following operations of the civil air patrol: (i) Search and rescue missions designated by the air force
rescue coordination center; (ii) Disaster relief, when requested by the federal emergency management agency or the department of
homeland security; (iii) Humanitarian services, when requested by the federal emergency management agency or the department of
homeland security; (iv) United States air force support designated by the first air force; and (v) Counterdrug missions.
Leave under this section is unpaid. However, associates may choose to use accrued paid time off benefits. Associates must provide
notice as soon as possible, and may be required to provide documentation to show qualifying reason for the leave. The Company
may request verification that the associate was called to duty to serve. If the requisite certification is requested by the Company but
the associate does not provide it, the leave may be denied. If proper certification is provided, no action will be taken against any
associate in any manner for requesting or taking any time off as provided for under this policy. Please contact Human Resources for
additional information regarding eligibility and verification requirements.
ACKNOWLEDGMENT OF BIOMETIC INFORMATION COLLECTION AND STORAGE POLICY AND CONSENT FORM
Highgate Hotels, L.P., its parent or affiliated companies, vendors and customers (collectively, the “Company”) have adopted a Biometric
Information Policy to address how the Company will collect, use, store, disclose and destroy biometric information under all applicable
laws.
As a Company employee in a position where the use of biometric information is required, you understand that your fingerprint, voiceprint,
hand, face, retina or iris may be scanned with biometric equipment (“Equipment”) to create an encrypted mathematical representation
of it (“Biographic Identifier”). The data may be stored and used for timekeeping, door entry/access, security or similar purposes. If, for
example, the Company scans your hand to create a Biometric Identifier, you will scan your finger each time you access the Equipment.
This scan is then compared to the Biometric Identifier created by the initial scan to confirm your identity.
The Company will require its vendors, contractors and lessors, where appropriate and necessary, to comply with its Biometric Information
Policy. In some cases, the vendors, contractors and lessors may have similar policies.
The Company will use a reasonable standard of care in the storage, transmission and disclosure of my Biometric Identifier, as it does in
the storing of other confidential employee information. You understand that your Biometric Identifier will be stored and used by the
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Company during the time of your employment and for an additional period of time thereafter in accordance with applicable law and
the Company’s Policy after which it will be destroyed. You understand that the Company will not retain your biometric identifier for
longer than what is permitted by law following your last interaction with the Company.
By signing the Playbook Acknowledgment, you acknowledge and understand that the Company’s use of your Biometric Identifier is
limited to lawful purposes and that the Company does not sell, lease, trade or otherwise profit from its use or collection of your Biometric
Identifier. The Company will not disclose your Biometric Identifier unless:
• The disclosure completes a financial transaction requested and authorized by me or my legally authorized
representative;
• The disclosure is required by state or federal law or by municipal ordinance;
• The disclosure is required pursuant to a valid warrant or subpoena issued by a court or agency of competent
jurisdiction; or
• I otherwise consent to the disclosure.
Accordingly, I acknowledge that I have read this policy and do consent to the Company’s collection, use, storage and destruction of
my Biometric Identifier as set forth above. I so consent by signing the Playbook Acknowledgment
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STATE AND CITY PREGNANCY ACCOMMODATION ADDENDUM
Connecticut Associates
The Company will make a reasonable effort to transfer a pregnant associate to any suitable temporary position which
may be available in any case in which an associate gives written notice of her pregnancy to the Company and the
Company or the pregnant associate reasonably believes that continued employment in the position held by the
pregnant associate may cause injury to the associate or fetus.
Any pregnant associate dissatisfied with a transfer under this policy may appeal the transfer in accordance with the
Connecticut Fair Employment Practices Act. Conn. Gen. Stat. § 46a-51 et seq.
Delaware Associates
NOTICE OF RIGHTS FOR PREGNANT ASSOCIATES IN DELAWARE
Delaware law provides that Delaware associates have the right to be free from discrimination in relation to pregnancy,
childbirth, and related conditions including lactation, pursuant to Chapter 7, Title 19 of the Delaware Code § 711. The
Company will:
• reasonably accommodate an associate’s medical needs related to pregnancy, childbirth or related

conditions including lactation (including the acquisition of equipment for sitting, more frequent or longer
breaks, periodic rest, assistance with manual labor, job restructuring, light duty assignments, modified work
schedules, time off to recover from childbirth, or break time and appropriate facilities for expressing breast
milk); and
• temporarily transfer pregnant Associates to a less strenuous or hazardous position (where one is available)
or duties if medically needed because of an associate’s pregnancy.
Delaware law prohibits making unnecessary changes to a pregnant associate’s job functions or requiring a pregnant
associate to take paid or unpaid leave when a reasonable accommodation would permit an associate to continue
working. Please note the Company is not required to provide pregnant Associates with workplace accommodations if
the requested accommodations pose an undue hardship.
This notice is a summary of Associates’ rights and obligations under the Delaware Code. For more information about
rights for pregnant Associates, contact Human Resources or the Delaware Department of Labor at (302) 761-8200 or
(302) 422-1134.
District of Columbia Associates
The Company’s policy is to reasonably accommodate any associate whose ability to perform the functions of her job
are limited by pregnancy, childbirth, a related medical condition, or breastfeeding.
A “reasonable accommodation” means an accommodation that does not cause undue hardship in the operation of
the Company’s business that the Company can make for an associate whose ability to perform the functions of her job
are affected by pregnancy, childbirth, a related medical condition, or breastfeeding. A reasonable accommodation
may include (a) more frequent or longer breaks; (b) time off to recover from childbirth; (c) the acquisition or modification
of equipment or seating; (d) the temporary transfer to a less strenuous or hazardous position or other job restructuring
such as providing light duty or a modified work schedule; (e) having the associate refrain from heavy lifting; (f) relocating
the associate’s work area; or (g) providing private non-bathroom space for expressing breast milk.
“Undue hardship” means any action that requires significant difficulty in the operation of the Company’s business or
significant expense on the behalf of the Company when considered in relation to factors such as the size of the
Company, its financial resources, and the nature and structure of its operation.
96
An associate requiring an accommodation related to pregnancy, childbirth, a related medical condition, or

breastfeeding should contact her designated human resources representative. Upon the Company’s receipt of such a
request or its awareness of the need for such an accommodation, the Company will engage in good faith in a timely
and interactive process with the associate to determine a reasonable accommodation.
The Company may require an associate to provide a certification from the associate’s health care provider concerning
the medical advisability of a reasonable accommodation to the same extent a certification is required for other
temporary disabilities. Any such certification must include: (a) the date the reasonable accommodation became or will
become medically advisable; (b) an explanatory statement as to the medical condition and the advisability of
providing the reasonable accommodation in light of the condition; and (c) the probable duration that the reasonable
accommodation will need to be provided.
The Company will not (a) refuse to make reasonable accommodations to the known limitations of an associate related
to pregnancy, childbirth, related medical conditions, or breastfeeding, unless the accommodation would impose an
undue hardship; (b) take an adverse action against an associate who requests or uses a reasonable accommodation;
(c) deny employment opportunities to an associate or a job applicant based on the need to make reasonable
accommodations to known limitations related to pregnancy, childbirth, related medical conditions, or breastfeeding; (d)
require an associate affected by pregnancy, childbirth, related medical conditions, or breastfeeding to accept an
accommodation the associate chooses not to accept if the associate does not have a known limitation related to
pregnancy, childbirth, related medical conditions, or breastfeeding, or if the accommodation is not necessary for the
associate to perform her duties; or (e) require an associate to take leave if a reasonable accommodation other than
leave can be provided.
Maryland Associates
If an associate has a disability caused or contributed to by pregnancy or childbirth and the associate requests a
reasonable accommodation, the Company will explore with the associate providing the requested reasonable
accommodation. Please note that the Company has no obligation to provide a requested reasonable
accommodation if it would impose an undue hardship on the Company. If you have a disability caused or contributed
to by pregnancy or childbirth and you request a transfer to a less strenuous or less hazardous position, we will provide you
with a transfer for the duration of your pregnancy to the same extent that we provide such transfers to Associates with
other temporary disabilities. Associates with disabilities caused or contributed to by pregnancy or childbirth, like
associates with other disabilities, must provide certification from a health care provider regarding the medical
advisability of any requested accommodation. If you have any questions regarding this policy, please contact your
designated Human Resources representative.
Providence, Rhode Island Associates
The Company’s policy is to provide reasonable accommodations to associates who are pregnant and those with
conditions related to pregnancy and childbirth, unless such accommodation would create an undue hardship for the
Company. Such a reasonable accommodation may include (a) more frequent or longer breaks, (b) time off to recover
from childbirth, (c) acquisition or modification of equipment, (d) seating, (e) temporary transfer to a less strenuous or
hazardous position, (f) job restructuring, (g) light duty, (h) break time and private non-bathroom space for expressing
breast milk, (i) assistance with manual labor, or (j) modified work schedules.
An associate requiring an accommodation related to pregnancy or a condition related to pregnancy or childbirth

should contact her designated human resources representative. Upon the Company’s receipt of such a request or its
awareness of the need for such an accommodation, the Company will engage in good faith in a timely and interactive
process with the associate to determine a reasonable accommodation.
The Company may require an associate to provide a certification from the associate’s health care provider concerning
the medical advisability of a reasonable accommodation to the same extent a certification is required for other
temporary disabilities. Any such certification must include: (a) the date the reasonable accommodation became or will
become medically advisable; (b) an explanatory statement as to the medical condition and the advisability of
providing the reasonable accommodation in light of the condition; and (c) the probable duration that the reasonable
accommodation will need to be provided.
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Virginia Associates
PREGNANCY, CHILDBIRTH, OR RELATED MEDICAL CONDITIONS
State law prohibits unlawful discrimination based on pregnancy, childbirth, or any related medical conditions. Associates
have a right to request a reasonable accommodation for known limitations related to pregnancy, childbirth, or related
medical conditions. Requests for an accommodation may be made through management or the Human Resources
Department. Upon request for an accommodation, the company will engage in an interactive process with you to
determine if a reasonable accommodation is available that would not cause an undue hardship.
98
ACKNOWLEDGEMENT OF ASSOCIATE PLAYBOOK
• I hereby acknowledge receiving a copy of the Highgate Hotels Associate Playbook.

• I understand that I am responsible for familiarizing myself with the information contained in this Playbook and
any later revisions.
• I also understand that Highgate Hotels may occasionally change the policies, procedures and practices
outlined in this Playbook.
• I will make myself aware of any changes, whether or not republished in the Associate Playbook.
• I understand that if covered by a Collective Bargaining Agreement, many of the guidelines outlined in this
Playbook may be superseded by the applicable Collective Bargaining Agreement.
• I understand that neither the statements in this Playbook nor this Acknowledgment constitute a contractual
obligation, express or implied, on the part of the Company, pertaining to any portion of this Playbook or any
aspect of my employment. Information is provided in this Playbook to give me a general overview of the
Company’s expectations of its associates and to provide information and guidelines, policies, programs and
procedures of Highgate Hotels.
• I understand that in identified locations outside of CBA agreements, my employment relationship with
Highgate Hotels is on an “at-will” basis, meaning I or the Company may terminate my employment at any
time, for any reason, with or without cause. I understand that nothing in this associate playbook alters my “at-
will” employment status with the Company.
• As part of this at-will policy, I understand that the Company expressly reserves its authority to manage and
control its business enterprise and to exercise its sole discretion to determine all issues pertaining to my
employment, including but not limited to, job assignment, promotion, demotion, transfer, work force size and
discipline.
• I understand the violation of any of the policies, procedures or programs included in this playbook may
constitute good cause for disciplinary measures by the Company management against me that could
include the permanent separation of employment.
• I further acknowledge that I have read and consent to the Company’s collection, use, storage, and
destruction of my Biometric Identifier as forth in the Biometric Information Policy.
I have read the foregoing and have had an opportunity to ask any questions I may have. I further understand that if I have any
questions about the interpretation or application of any policies contained in the Playbook, I should direct these questions to the
Human Resources Department.
Print Name:
Associate Signature: _________
Today’s Date:
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ASSOCIATE PLAYBOOK

Effective Date: January 2023

EQUAL OPPORTUNITY EMPLOYMENT

Accommodating Associates with Disabilities

Non-Harassment and Non-Retaliation of Associates

Responsibility for Enforcement

Procedure for Reporting Harassment or Retaliation

Please notify your Human Resources representative promptly of changes.

Lost and Found & Guest Property

• Turning off lights in unused rooms and offices

Promotions and Transfers

Minimum Age Requirements

Meal Time and Breaks

Associate Referral Program

Guest Courtesy and Privacy

Associate Entrance and Exit

Company Property & Company Issued Items

Giving and Receiving Gifts and Entertainment

• To influence a business decision

Separation from the Company

Open Door Policy

Use of Communications Devices

Use of Personal Electronic Devices

Use of Cell Phones/Other Electronic Devices While Driving

Business Ethics and Associate Integrity

Concealed Weapons Policy

Know and follow the rules

Post only appropriate and respectful content

For more information

Highgate Hotels Standards of Conduct

17) I agree not to violate the Company’s non-solicitation policy.

Biometric Information Policy

Highgate’s policy and procedure is as follows:

Definition of Biometric Data

Highgate’s Collection of Biometric Data

Data Storage, Transmission, and Protection

SAFETY AND ACCIDENTS

Safety and Accidents

Hazardous Material Handling

• Physical violence, threats of physical violence, or harassment towards associates or guests

HEALTH AND WELFARE BENEFITS

Health and Welfare

Associate Assistance Program

Associate Discount Room Nights

Family and Medical Leave (FMLA)

Types and Duration of FMLA Leave

• Military Caregiver Leave

3. any period of incapacity or treatment due to pregnancy, or for prenatal care;

5. a period of incapacity or treatment which is permanent or long-term due to a condition for

8. Post-deployment activities: to attend official ceremonies or programs sponsored by the

When Spouses Work Together

Notice of Need for FMLA Leave

Substitution of Paid Leave for Unpaid FMLA Leave

Intermittent FMLA Leave

Documentation Supporting FMLA Leave

Restoration to Position and Benefits

Reasonable Accommodation Medical Leave

Interaction with State Leave Laws

Outside Activity During Disability

Nursing Mothers Leave

Uniformed Services Leave

Other Legally Protected Absences

STATE LAW ADDENDA