Issuu

CARING ASSOCIATE Handbook Resources to support your health, happiness, and future.

CONTENTS Welcome & Company Values Welcome ................................................................................................ 3 Our Mission & Vision Statement .............................................. 4 Commitment to Diversity ............................................................ 5 Culture Vision ...................................................................................... 5 Culture Code ........................................................................................ 5 Definition of a Caring Associate .............................................. 6 Communication ................................................................................ 6 Your Employment Benefits ................................................................................................... 7 At-Will Employment Statement ............................................. 9

Standards of Conduct Professionalism & Workplace Behavior .................................. 26 Workplace Violence Prevention .................................................. 27 Dress Code (General) .......................................................................... 28 Company Issued Apparel Policy ................................................. 29 Visitors in the Workplace ................................................................. 29 Solicitation, Distribution & Use of Bulletin Boards ........... 29 Cell Phone Policy .................................................................................. 30 Head Phone Policy .............................................................................. 30 Weapon-Free Workplace Policy ................................................... 31 Time Away From Work & Leaves of Absence

Employee Relations Policy ......................................................... 9 Personnel File Policy ....................................................................... 9 Equal Employment Opportunity Statement ................ 10

Paid Holidays ........................................................................................... 32 Paid Leave Time (PLT) ......................................................................... 33 PLT Cash-Out Option .......................................................................... 35

Harassment & Sexual Harassment Policy ......................... 11 Americans with Disabilities Act ............................................. 16

MA Paid Family & Medical Leave (PFML) ................................ 36 Family & Medical Leave Act (FMLA) ........................................... 37

Pregnant Workers Fairness Act .............................................. 17 Lactation Accommodation Policy (PUMP Act) ............ 18 Background Check Policy ..........................................................18

Massachusetts Earned Sick Time Law ..................................... 38 Bereavement Leave ............................................................................. 39 Jury Duty .................................................................................................... 39

Massachusetts Equal Pay Act (MEPA) ................................ 19 Child Labor Law .............................................................................. 20 COBRA Benefits ............................................................................... 21

Military Leave .......................................................................................... 40 Parental Leave ........................................................................................ 40 Emergency Response Leave .......................................................... 40

General Attendance

Small Necessities Leave .................................................................... 41 Victim Leave ............................................................................................. 41

Work Week ......................................................................................... 22 Timekeeping Policy ...................................................................... 22

Voting ........................................................................................................... 41 Unpaid Time Off & Leaves of Absence ..................................... 42

Day of Rest ......................................................................................... 22 Attendance & Punctuality ........................................................ 23 Meals & Other Breaks ................................................................... 23

Health, Safety & Workplace Environment Work-Related Injury & Incident Reporting ........................... 43

Closings & Emergencies ............................................................. 23 Compensation & Payroll Pay Period ......................................................................................... 24 Overtime .............................................................................................. 24 Reporting Pay – Massachusetts ............................................. 24 Pay Transparency Policy ............................................................ 24 Direct Deposit .................................................................................. 25 Employment Taxes & Voluntary Deductions ................ 25

Workers’ Compensation Policy .................................................... 43 Smoke-Free Workplace & Environment ................................ 44 Drug-Free Workplace Policy .......................................................... 44 Technology, Data & Confidentiality Use of Company Assets & Technology ..................................... 45 Email Etiquette ...................................................................................... 46 Artificial Intelligence Use Policy .................................................. 47 Transportation & Driving Company Car Policy ........................................................................... 48 Driver Eligibility ..................................................................................... 49 Insurance Requirements ................................................................. 49 Distracted Driving ................................................................................ 49

WELCOME At Coghlin Companies (“Coghlin” or “the Company”), we believe every Caring Associate plays an important role in our success. The talent, dedication, and passion of our people are what make our company strong, and we are excited to welcome you to our team and our “home away from home.” We are committed to fostering a culture built on collaboration, respect, integrity, and continuous improvement. We strive to treat others the way we would like to be treated, communicate openly and honestly, and work together to make a positive impact on one another, our customers, and our communities. This handbook is designed to help you become familiar with Coghlin Companies and provide information about our benefits, programs, and employment policies. We encourage you to read it carefully and use it as a resource throughout your journey with us. It outlines many of your responsibilities as a Caring Associate, as well as the opportunities, resources, and support available to help you succeed. Our goal is to provide an environment where Associates can learn, grow, and thrive, both personally and professionally. We are grateful you have chosen to join us, and we look forward to all we will accomplish together. Sincerely,

Cheryl Gallant Executive Vice President, Human Resources

WELCOME OUR MISSION & VISION STATEMENT WHAT WE DO - Total Turnkey Time to Market Services™ Coghlin Companies provides world-class Time to Market Services™ (TTMS) and is an expert in the commercialization of mid-to-large scale capital equipment and FDA-compliant medical devices. We are passionately focused on accelerating our clients' Time to Market and reducing their product costs by leveraging our modular design approach and global supply chain relationships. Our TTMS model includes engineering, product development, manufacturing, global fulfillment, product refurbishment, and other aftermarket services. WHO WE DO IT FOR - Innovation Companies in Alignment with Our Golden Rules™ Coghlin Companies provides these services to a diverse group of global equipment innovators across industries, including medical, life sciences, robotics, additive manufacturing, 3D printing, advanced energy, food service, security, semiconductor, LED, industrial automation, and AI. WHY WE DO IT - Our Purpose and Passion Leveraging decades of experience and our proprietary Commercialization Reimagined™ value proposition, we deliver a powerful, positive impact on our clients' success in commercializing and scaling their products, with confidence and in a more cost-effective, compliant, and timely manner than competitors. Our client engagements support innovative technologies that disrupt and displace the status quo, reinvigorating industries that have been stagnant for decades. WE ARE HELPING CHANGE THE WORLD through the successful commercialization of advanced innovation, one product launch and customer experience at a time. BENEFITS OF SUCCESSFUL EXECUTION With each personalized client engagement and commercialization success, we continuously improve, and our reputation becomes integrated with the innovative and powerful brands we collaborate with, increasing our referability and driving more opportunities to CCI. With increased opportunity, we become more refined in client selection and enhanced pricing strategies, only engaging in programs that provide the highest assurance of sustained growth, profitability, and success. With the successful execution of this Mission/Vision, we create career advancement opportunities for Caring Associates, strengthen our "WORK HARD, PLAY HARD" culture, attract new experienced talent, become more financially independent, make capital investments that drive further efficiency and innovation, retain additional earnings to ensure strength through varying economic climates, and continue to give back to the community through deeper investment of our time, talent and treasure.

WELCOME COMMITMENT TO DIVERSITY Coghlin is committed to fostering a diverse, equitable, and inclusive workplace. We value – and our Caring Associates benefit from having – the perspectives of people with different backgrounds and experiences. Coghlin promotes diversity, equity, and inclusion through recruiting, retention, and the implementation of internal policies and practices to ensure that each individual has an equal opportunity to succeed, regardless of their background and identity.

CULTURE VISION To drive the most positive, fun, energetic, accountable, engaged, and empowered culture imaginable. We will apply our collective marketing, technical and communication talents in a compliant and efficient manner to successfully exceed client expectations and commercialize life-saving and life-changing medical devices and capital equipment products for the most innovative companies in the world. We will ALWAYS prioritize kindness, collaboration and transparency and promote Caring Associate growth, development and advancement to enable the highest probability of retention, exceptional Associate and client experiences, and organization-wide referability. “Customers will never love a company until the employees love it first.” - Simon Sinek

CULTURE CODE BE KIND

BE EFFICIENT

BE PREPARED

BE HELPFUL

BE ON TIME

BE HONEST

BE A TEAM PLAYER

SAY IT STRAIGHT

SAY PLEASE AND THANK YOU

WORK HARD

PLAY HARD

WORK SMART

SUGGEST IMPROVEMENTS

DO IT RIGHT THE FRIST TIME

DON’T GUESS ... JUST ASK!

ALWAYS DO YOUR BEST

GO THE EXTRA MILE

KEEP IT REAL

ESCALATE WHEN NECESSARY

COMPLIMENT ONE ANOTHER

JUST BE YOU

WELCOME DEFINITION OF A CARING ASSOCIATE At Coghlin Companies, we call our people “Caring Associates!” The definition of a Caring Associate is as follows: Comes to work on time every day Adheres to all company procedures and policies Escalates whenever they are uncertain and never guesses Is respectful of their workplace and their fellow Caring Associates Makes suggestions to leadership when they see opportunities for improvement Focuses on creating exceptional customer experiences each day Does “whatever it takes” to preserve the legacy and integrity of the Coghlin Companies’ brand

COMMUNICATION The Company is committed to providing the best possible working conditions for its Associates. Part of this commitment is encouraging an open and transparent atmosphere in which any problem, complaint, suggestion, or question receives a timely response from Company supervisors/managers. The Company strives to ensure treatment consistent with all policies in this handbook. Supervisors/managers and Associates are expected to treat each other with mutual respect. You are encouraged to offer positive and constructive feedback.

YOUR EMPLOYMENT BENEFITS * Health Insurance The Company makes group health benefits available to all full-time Associates and their family members. Associates are eligible for benefits on the first day of the month following their hire date. Health benefits are paid in part by the Company. The remainder of the cost is the Associate’s responsibility. Associates can receive details about company health benefits, contribution rates, and eligibility by contacting Human Resources. * Dental Insurance The Company makes group dental benefits available to all full-time Associates and their family members. Associates are eligible for benefits on the first day of the month following their hire date. Dental benefits are voluntary and are the responsibility of the Associate. Associates can receive details about company dental benefits, contribution rates, and eligibility by contacting Human Resources. * Vision Insurance The Company makes group dental benefits available to all full-time Associates and their family members. Associates are eligible for benefits on the first day of the month following their hire date. Vision benefits are voluntary and are the responsibility of the Associate. Associates can receive details about company vision benefits, contribution rates, and eligibility by contacting Human Resources. * Flexible Spending Account (FSA) The Company offers flexible spending benefits to all full-time Associates and their family members. Associates are eligible for benefits on the first day of the month following their hire date. FSA benefits are voluntary and are the responsibility of the Associate. Associates can receive details about the FSA plan by contacting Human Resources. * Short-Term Disability Insurance The Company offers short-term disability benefits available to all full-time Associates. Associates are eligible for benefits on the first day of the month following their hire date. Short-term disability benefits are voluntary and are the responsibility of the Associate. Associates can receive details about the company's short-term disability, contribution rates, and eligibility by contacting Human Resources. * The company reserves the right to amend, modify, or discontinue this plan at any time. Associates with questions about the plan should contact Human Resources.

YOUR EMPLOYMENT BENEFITS * Pet Insurance The Company offers pet insurance to all full-time Associates. Associates are eligible for benefits on the first day of the month following their hire date. Pet Insurance benefits are voluntary and are the responsibility of the Associate. Associates can receive details about company pet insurance benefits, contribution rates, and eligibility by contacting Human Resources. * Group Life Insurance The Company provides basic life insurance and an accidental death, disability & dismemberment (AD&D) plan administered by an insurance carrier to help support your family in the event of your death or serious injury. The Company pays the entire cost of your coverage. * Long-Term Disability The Company provides long-term disability (LTD) coverage to eligible Associates as additional income protection for long periods of disability. * 401(k) Retirement Savings Plan The Company offers a 401(k) Retirement Savings Plan to eligible Associates to help support long‑term retirement savings. Participation in the plan is voluntary and subject to the terms and conditions of the plan document and applicable law. Eligible Associates may contribute a portion of their compensation to the plan through payroll deductions, subject to IRS limits. The Company may make matching or other contributions at its discretion, in accordance with the plan provisions. Vesting rules apply. Associates will receive detailed information about eligibility, enrollment, contributions, investments, and distributions through the plan’s Summary Plan Description (SPD) and related materials. In the event of any inconsistency between this handbook and the official plan documents, the plan documents will govern. * The Company reserves the right to amend, modify, or discontinue the 401(k) plan at any time, subject to applicable law. Associates with questions about the plan should contact Human Resources.

YOUR EMPLOYMENT AT-WILL EMPLOYMENT STATEMENT While we hope to have a long and productive relationship with you, your employment with the Company is voluntary and is subject to termination by you or the Company at-will, with or without cause, and with or without notice, at any time. None of the information provided in our policies signifies a contractual agreement or should be interpreted to conflict with, eliminate, or modify in any way your employment-at-will status with the Company.

EMPLOYEE RELATIONS POLICY We firmly believe that by communicating with each other directly, we can continue to resolve any difficulties that may arise and develop a mutually beneficial relationship. If you have an issue, concern, or question, you are encouraged to use the following process: Speak with your immediate supervisor/manager about the matter. If your supervisor/manager is unavailable or you believe it would be inappropriate to contact that person, you may present the issue to the Human Resources Department or any other member of management. Your supervisor/manager will address the problem during the discussion or, when necessary, after consulting with appropriate management. You may present the issue to the Human Resources Department if it remains unresolved. The Human Resource Department will counsel and advise you, visit your supervisor/manager, and, if necessary, direct the issue to Senior Management for further action. Not every issue can be resolved to everyone’s total satisfaction, but only through understanding and discussion of mutual problems can Associates and management develop confidence in each other.

PERSONNEL FILE POLICY Associates have the right to access their personnel records upon written request. If requested, Human Resources will provide a paper copy within five business days of the written notification. For additional information about this policy, please contact Human Resources.

YOUR EMPLOYMENT EQUAL EMPLOYMENT OPPORTUNITY (EEO) The employment policy of the Company is to provide equal opportunity to all persons. The Company, therefore, has committed to equal employment opportunity through a positive and continuing Affirmative Action Program. No Associate or applicant for employment will be discriminated against because of race, color, religion, gender, sexual preference, national origin, age, or otherwise qualified disabled or veteran status. To implement these policies, the Company will continue to: Recruit, hire, train, and promote persons in all job classifications without regard to race, color, religion, gender, sexual preference, national origin, age, or otherwise qualified disabled or veteran status. Base decisions on employment to further the principle of equal employment opportunity. Ensure promotion decisions are in accordance with the principles of equal employment opportunity by imposing only valid requirements for promotional opportunities. Ensure that all actions (including, but not limited to compensation, benefits, transfers, layoffs, return from layoffs, company- sponsored training, educational, social and recreational programs) are administered without regard to race, color, religion, gender, sexual preference, national origin, age, otherwise qualified disabled, or veteran status. Cheryl Gallant has been designated EEO Officer and is responsible for compliance with state and federal equal employment opportunity laws, which include equal employment practices, monitoring, and internal reporting. Associates believing they have not been treated in accordance with this policy are encouraged to contact Cheryl Gallant at 508-929-4675. Equal employment opportunity is not only the law, but it is a principle of the Company. Your cooperation is expected to achieve this goal.

YOUR EMPLOYMENT SEXUAL HARASSMENT POLICY The Company is committed to maintaining an environment free from sexual discrimination and unlawful harassment as well as adhering to applicable federal and state laws. Sexual harassment in the workplace is unlawful and unacceptable at the Company. Making unwelcome sexual advances, requests for sexual favors, and verbal or physical conduct of a sexual nature a condition of employment or continued employment; making submission and/or rejection of such conduct the basis for any employment decision(s) affecting Associate(s); and creating an intimidating, hostile or offensive working environment by such conduct, all constitute sexual harassment. The Company recognizes that each sexual harassment concern must and will be treated seriously and with the utmost confidentiality. Given the nature of this type of discrimination, the Company recognizes that false accusations can have serious effects on innocent men and women. We trust that all Associates will continue to act responsibly to establish a pleasant working environment free of discrimination. Sexual harassment of Associates in any form is a major offense and may result in serious disciplinary action, from counseling to immediate discharge. This policy applies to all Associates, vendors, contractors, customers, and visitors. Any supervisor/manager who becomes aware, directly or indirectly, of possible sexual or other unlawful harassment should promptly advise Human Resources or any member of management who will handle the matter in a timely and confidential manner. It is important to note that while this policy sets forth the Company’s goals of promoting a workplace that is free of sexual harassment, the policy is not designed or intended to limit the Company’s authority to discipline or take remedial action for workplace conduct that is deemed unacceptable, regardless of whether that conduct satisfies the definition of sexual harassment.

YOUR EMPLOYMENT SEXUAL HARASSMENT POLICY Sexual harassment does not refer to purely voluntary social activities. It refers to behavior that is not welcomed by the Associate, which is personally offensive to him or her, and which undermines morale and/or interferes with the ability of the Associate to work effectively. While it is not possible to list all of the circumstances that may constitute sexual harassment, depending upon the totality of the facts, including the severity of the conduct and its pervasiveness, the following is a list of situations that could constitute sexual harassment: Verbal abuse of a sexual nature Use of sexually degrading words Jokes or language of a sexual nature Conversation or gossip with sexual overtones Obscene or suggestive gestures or sounds Sexually-oriented teasing Verbal comments of a sexual nature about an individual's appearance or sexual terms used to describe an individual Inquiries into one's sexual experiences Discussion of one's sexual activities Comments, jokes, or threats directed at a person because of his/her sexual preference Unwelcome and repeated invitations (for lunch, dinner, drinks, dates, sexual relations) Demand for sexual favors accompanied by an implied or overt threat concerning an individual’s employment status or promises of preferential treatment Physical contact such as touching, hugging, kissing, stroking, fondling, patting, pinching, or repeated brushing up against one's body Deliberate bumping, cornering, mauling, and grabbing Assaults, molestations, or coerced sexual acts Posting or distributing sexually suggestive objects, pictures, cartoons, or other materials Sexually-oriented letters or notes Sending offensive or discriminatory messages or materials through the use of electronic communications (e.g., electronic mail, including the Internet, voice mail, and facsimile) that contain overt sexual language, sexual implications or innuendo, or comments that offensively address someone's sexual orientation Staring at parts of a person's body Sexually suggestive gestures, leering Condoning sexual harassment

YOUR EMPLOYMENT SEXUAL HARASSMENT POLICY Sexual harassment is not limited to prohibited behavior by a male Associate toward a female Associate. Sexual harassment can occur in a variety of circumstances. Here are some things to remember: A man as well as a woman may be the victim of sexual harassment, and a woman as well as a man may be the harasser The harasser does not have to be the victim's supervisor The victim does not have to be of the opposite sex from the harasser The victim does not have to be the person at whom the unwelcome sexual conduct is directed. The victim may be someone who is affected by the harassing conduct, even when it is directed toward another person. If the conduct creates an intimidating, hostile, or offensive working environment for the coworker or interferes with the coworker's work performance Each Associate of the Company is personally responsible for: Ensuring that his/her conduct does not sexually harass any other Associate or person with whom the Associate comes in contact on the job, such as an outside vendor Cooperating in any investigation of alleged sexual harassment by providing any information he/she possesses concerning the matter being investigated Actively participating in efforts to prevent and eliminate sexual harassment and to maintain a working environment free from such discrimination Ensuring that an Associate who files a sexual harassment claim or cooperates in an investigation may do so without fear of retaliation or reprisal The Company does not tolerate sexual harassment. It is, therefore, against the policy of the Company for any individual, male or female, to harass another individual sexually, that is, by making unwelcome sexual advances, requests for sexual favors, or other uninvited verbal or physical conduct of a sexual nature when: Submission to such conduct is made either implicitly or explicitly a term or condition of an Associate's employment Submission to, or rejection of, such conduct by an individual is made the basis for employment decisions affecting the Associate A hostile or intimidating work environment is created for the Associate Such conduct has the purpose or effect of interfering with an individual's work performance

YOUR EMPLOYMENT SEXUAL HARASSMENT POLICY It is also against the policy of the Company for an individual to sexually harass any person with whom the Associate comes in contact on the job or to engage in any harassment or inappropriate or unprofessional conduct in the workplace. Retaliation against an individual for filing a complaint of sexual harassment or against any individual for cooperating in an investigation of a sexual harassment complaint is against the law. Any individual violating this policy will be subject to appropriate discipline, including possible discharge. Any Associate who believes that he or she has been the subject of sexual harassment should report the alleged charge immediately to Mary Tower, Director, Human Resources, 27 Otis Street, Westborough, MA 01581, at 508-929-4609 or Cheryl Gallant, EVP, Human Resources, 27 Otis Street, Westborough, MA 01581 at 508- 929-4675. The person conducting the investigation will meet with the alleged harasser to review and discuss the complaint. The alleged harasser will have the opportunity to refute the allegations. It is unlawful to retaliate against an Associate who files a complaint of sexual harassment or for cooperating in an investigation of a complaint of sexual harassment. The individual should be aware that the longer the period between the occurrence of the event giving rise to the complaint and the filing, the more difficult it will be for the person conducting the investigation to investigate what occurred. The individual will be requested to write out his or her complaint to document the charge. If an Associate prefers to discuss a possible sexual harassment problem with his or her supervisor, the Associate may always do so, but Associates do not have to go through the regular chain of supervision when reporting sexual harassment and may go directly to Human Resources. Upon receiving the complaint, the person conducting the investigation will promptly have a preliminary investigation made into the matter. If, after the completion of this preliminary investigation, it is determined that there is reasonable cause for finding a violation of this policy, the Company will notify the complainant and the charged Associate of the finding. The charged Associate will be requested to respond to the complaint. Additional investigation will be made to the extent appropriate in each case. This process will be confidential to the extent consistent with an effective investigation, subject to the business needs of the Company.

YOUR EMPLOYMENT SEXUAL HARASSMENT POLICY The Company will conduct a prompt investigation as confidentially as possible under the circumstances. Associates who raise concerns and make reports in good faith can do so without fear of reprisal; at the same time, Associates have an obligation to cooperate with the Company in enforcing this policy and investigating and remedying complaints. Any Associate who becomes aware of possible sexual harassment or other illegal discrimination against others should promptly advise Human Resources or any other appropriate member of management. After the response of the charged individual has been made, and any further investigation that may be warranted has been carried out, the Company will make a final decision. Anyone found to have engaged in such wrongful behavior will be subject to appropriate discipline, which may include termination. Specific state and federal agencies have been empowered to enforce employment discrimination legislation. Anyone who feels he or she has been a victim of sexual harassment may contact either agency directly. The state discrimination enforcement agency is the Massachusetts Commission Against Discrimination, One Ashburton Place – Room 601, Boston, MA 02108, (617) 727-3990. The federal discrimination enforcement agency is the Equal Employment Opportunity Commission, One Congress Street, 10th Floor, Room 1001, Boston, MA 02114, (617) 565-3200. The Harassment Policy is distributed to all newly hired Associates and is distributed to all Associates annually.

YOUR EMPLOYMENT AMERICANS WITH DISABILITIES ACT Qualified individuals with disabilities may make requests for reasonable accommodation to Human Resources. Upon receipt of an accommodation request, a representative from Human Resources will meet with the requesting individual to discuss and identify the precise limitations resulting from the disability and the potential accommodation that the Company might make to help overcome those limitations. Human Resources, in conjunction with the appropriate management representatives identified as needing to know (e.g., the individual's supervisor), will determine the feasibility of the requested accommodation, considering various factors, including, but not limited to, the nature and cost of the accommodation, the availability of tax credits and deductions, outside funding, the Company’s overall financial resources and organization, and the accommodation's impact on the operation of the facility, including its impact on the ability of other Associates to perform their duties and on the Company’s ability to conduct business. Human Resources will inform the Associate of the Company’s decision on the accommodation request or on how to make the accommodation. If you require an accommodation for a sincerely held religious practice, please contact a representative from Human Resources. The Company will work with you to help assess whether your request can be reasonably accommodated, taking into account the Company’s business needs, resources, your job description, and the other relevant factors. If the request imposes an undue hardship on the Company, the request for accommodation may not be able to be provided.

YOUR EMPLOYMENT AMERICANS WITH DISABILITIES ACT The Company is committed to complying with the Americans with Disabilities Act of 1990 and its related Section 504 of the Rehabilitation Act of 1973. The Company recognizes that some individuals with disabilities may require accommodations at work. The Company complies with the Americans with Disabilities Act (ADA) and applicable state and local laws providing for nondiscrimination in employment against qualified individuals with disabilities. The Company also provides reasonable accommodation for such individuals in accordance with these laws. It is the Company’s policy to, without limitation: Ensure that qualified individuals with disabilities are treated in a nondiscriminatory manner in the preemployment process and that Associates with disabilities are treated in a nondiscriminatory manner in all terms, conditions, and privileges of employment. Keep all medical-related information confidential in accordance with the requirements of the ADA and retain such information in separate confidential files. Provide applicants and Associates with disabilities with reasonable accommodation, except where such an accommodation would create an undue hardship on the Company. Notify individuals with disabilities that the Company provides reasonable accommodation to qualified individuals with disabilities, by including this policy in the Associate handbook and by posting the Equal Employment Opportunity Commission's poster on not discriminating against individuals with disabilities and other protected groups conspicuously in the break room at the Company’s Westborough headquarters.

PREGNANT WORKERS FAIRNESS ACT The Pregnant Workers Fairness Act provides reasonable accommodations to female Associates due to pregnancy or conditions related to pregnancy. Specifically, the act grants Associates a “reasonable accommodation” for an Associate’s pregnancy or condition related to pregnancy, unless doing so would impose an undue hardship on the company. For details on the Pregnant Workers Fairness Act, please contact Human Resources.

YOUR EMPLOYMENT LACTATION ACCOMMODATION POLICY (PUMP ACT) Our company provides reasonable accommodations for Associates who need to express breast milk during the workday. Associates are entitled to reasonable break time and a private space that is not a bathroom, shielded from view, and free from intrusion, for up to one year after childbirth. The designated space will include a chair, a clean surface, access to electricity, and nearby access to water and refrigeration for milk storage. Associates may request schedule flexibility or additional breaks as needed. These accommodations will be provided unless doing so would cause undue hardship to the company. Associates should notify Human Resources to arrange accommodations.

BACKGROUND CHECK POLICY The Company conducts background checks as part of its commitment to maintaining a safe, secure, and trustworthy workplace. Background checks may be required for candidates applying for employment, current Associates being considered for promotion or transfer, and in other circumstances permitted by law. Background checks are conducted in accordance with applicable federal, state, and local laws and may include, where appropriate, criminal history and other job‑related inquiries. All background check results are reviewed on an individualized basis and do not automatically disqualify an individual from employment. Employment with the Company may be contingent upon the successful completion of a background check. Refusal to authorize a required background check or providing false or misleading information may result in withdrawal of an offer or disciplinary action, up to and including termination of employment. All background check information is treated as confidential and is used solely for employment‑related purposes consistent with applicable law. Associates with questions regarding this policy should contact Human Resources.

YOUR EMPLOYMENT MASSACHUSETTS EQUAL PAY ACT (MEPA) This law ensures that employers do not discriminate based on gender in the payment of wages, or pay any person in their employment a salary or wage rate less than the rates paid to their employees of a different gender for comparable work. The law defines “comparable work” as work that requires substantially similar skill, effort, and responsibility, and is performed under similar working conditions. The new law does permit differences in pay for comparable work only when based upon: A system that rewards seniority A system which measures earnings by quantity or quality of production, sales, or revenue The geographic location in which a job is performed Education, training, or experience to the extent such factors are reasonably related to the particular job in question; or travel, if the travel is a regular and necessary condition of the particular job Other key points covered under the new law: Wages, under this law, mean all forms of remuneration, including benefits Employers may not prohibit employees from disclosing or discussing their wages Employers may not seek the salary or wage history of any prospective employee before making an offer of employment that includes compensation, and may not require that a prospective employee’s wage or salary history meet certain criteria Employers may not retaliate against any employee who exercises his or her rights under the law For more information about this law, please contact Human Resources.

YOUR EMPLOYMENT CHILD LABOR LAW Coghlin Companies is committed to upholding the highest standards of ethical conduct, including compliance with all Federal and Massachusetts laws and regulations related to child labor. This policy outlines our stance on prohibiting the use of child labor in any form within our organization. Our company strictly prohibits the use of child labor in any form. We adhere to all Federal and Massachusetts laws and regulations regarding child labor. We believe that children should be protected from exploitation and allowed to pursue their education and personal development without the burden of work at a young age.

Definition of Child Labor For this policy, child labor is defined as any work performed by individuals under the age of 18. We do hire students who are 17 years old when they are referred as a student and obtain a permit to work in Massachusetts. Youth must obtain a work permit by completing an employment permit application and presenting it to the superintendent of schools for the municipality in which the minor lives or attends school.

Prohibited Practices We strictly prohibit the use of child labor in any aspect of our operations, including but not limited to production, manufacturing, and supply chain activities. This prohibition extends to all Associates, contractors, and labor suppliers working on behalf of our company.

Age Verification Before hiring any new employee, we require proof of age to ensure compliance with child labor laws. This verification process may include requesting official documents such as birth certificates or government-issued identification cards.

Monitoring and Compliance Our HR team is responsible for monitoring compliance with this policy and controls all aspects of the hiring process to ensure compliance.

YOUR EMPLOYMENT COBRA BENEFITS The Company complies with the federal law, Consolidated Omnibus Budget Reconciliation Act of 1985, otherwise known as COBRA. Covered Associates and their dependents who lose insurance coverage for any of the following reasons are eligible to continue their coverage through COBRA: Termination of the covered Associate’s employment Reduction in the covered Associate’s working hours Divorce or legal separation Death of the Associate Eligibility for Medicare Loss of dependent child status under the insurance plan All administrative rules and processes, as well as changes in plan benefits and premiums, apply to those on continuation coverage. In the event of divorce or legal separation, or the loss of dependent child status under the plan, a covered Associate or dependent must notify Human Resources within 60 days to maintain the right to continue coverage. At that time, Human Resources will provide enrollment materials to the Associate or covered dependent within 14 days of that notification. The covered Associate or dependent has 60 days to elect continuation of coverage from either the date that coverage would ordinarily have ended under the plan by reason of a qualifying event or the date of notification, whichever comes later. Election of continuation of coverage is established by completing and returning enrollment materials to Human Resources.

GENERAL ATTENDANCE WORK WEEK The Company’s work week is Monday through Sunday. Daily work schedules vary throughout our organization. Supervisors/managers will advise Associates of their work schedules. Staffing needs and operational demands may necessitate variations in start and end times, as well as in the total hours scheduled each day and each week. Consult your supervisor/manager for clarification on work schedule.

TIMEKEEPING POLICY Accurately recording time worked is the responsibility of every hourly-paid Associate. Federal and state laws require the Company to keep accurate records of time worked and paid leave benefits used to calculate Associate pay and benefits. Time worked is all the time actually spent on the job performing assigned duties. It is the responsibility of all hourly-paid Associates to consistently use the Company’s time and attendance system to record and report accurate time. All hourly paid Associates are required to clock in four (4) times each day - at the beginning and end of every workday as well as out and in for their lunch break. All Associates must arrive at work on time for their scheduled shift, clocking in only when ready to work. Overtime work must always be approved before it is performed. Altering, falsifying, tampering with time records, or recording time may result in disciplinary action, up to and including termination of employment. The Company takes all reasonable steps to ensure that you receive the correct amount of pay in each paycheck and that you are paid promptly on the scheduled payday. In the unlikely event that there is an error in the amount of pay, you should promptly bring the discrepancy to the attention of your supervisor/manager so that corrections can be made as quickly as possible.

DAY OF REST The Massachusetts Day of Rest Law requires that non-exempt Associates be entitled to one day of rest in seven days. This provision safeguards workers’ health and well-being by preventing continuous work without a break. To qualify, an Associate must work in a nonexempt role and typically work more than six consecutive days.

GENERAL ATTENDANCE ATTENDANCE AND PUNCTUALITY You are expected to report to work on time for your assigned work schedule. Absenteeism and tardiness place a burden on other co-workers and on the Company. In rare instances when you cannot avoid being late to work or are unable to work as scheduled, you should notify your supervisor/manager as soon as possible in advance of the anticipated tardiness or absence. In the rare circumstances when your supervisor/manager is unavailable, you must speak with another member of Management. Failure to report to work without calling your immediate supervisor/manager for three (3) consecutive days is considered voluntary resignation from the Company. Poor attendance and excessive tardiness will lead to disciplinary action, up to and including termination of employment. If you become ill at work or must leave the office for some other reason before the end of the workday, you must inform your supervisor/manager of the situation. In the event of severe weather, we customarily remain open for business during regularly scheduled working hours. You are expected to report for work in severe weather if it is possible to do so safely. In the event we do close due to weather, your supervisor/manager will contact you. Please keep your work group and supervisor/manager informed on how to reach you on such occasions. (See also Office Closings/Storms/Emergencies.)

MEALS AND OTHER BREAKS All full-time Associates are provided with one (1) unpaid meal period each workday. Meal periods vary from 30 minutes to one (1) hour. Supervisors/managers will schedule meal periods to accommodate operating requirements with the objective of scheduling meal breaks towards the middle of one’s shift. Associates will be relieved of all active responsibilities and restrictions during meal periods and will not be compensated for that time. Break periods for Associates are designated by supervisors/managers and consist of two (2) 10minute periods. Both time periods are compensated. No other break periods are authorized, and Associates are not permitted to leave the property during these paid break periods.

OFFICE CLOSINGS, STORMS AND EMERGENCIES At times, emergencies such as severe weather or power failure may disrupt Company operations. These extreme circumstances may require the closing of the work facility. You should provide contact information to your supervisor/manager, who may contact you with a closing notification or instructions to report for work at an alternate location. If the office is open, but you determine that coming to work during severe weather will be dangerous to your well-being, you must call your supervisor/manager. You will be expected to use paid leave time (PLT) for your absence.

COMPENSATION & PAYROLL PAY PERIOD Associates are paid biweekly, every other Friday. Each biweekly paycheck includes pay for the previous work week and the current work week, which is calculated as “40 hours paid in advance.” If you are an hourly-paid Associate and you work overtime during the week that you are paid 40 hours in advance, the overtime hours will be paid in the next pay period.

OVERTIME Hourly-paid Associates are eligible for overtime for all hours worked in excess of 40 in any work week. All worked overtime designated by your supervisor/manager is approved overtime. If an Associate works overtime without approval, the overtime will be paid, however, the Associate may be subject to disciplinary action. Overtime is paid at the rate of one-and-one-half times (1-½) your regular hourly rate of pay. PLT is not considered hours worked for the purpose of calculating overtime.

REPORTING PAY – MASSACHUSETTS If a non-exempt Associate is scheduled to work, arrives on time as expected, and is not given the anticipated hours of work, they will receive compensation for three (3) hours at their base pay rate.

PAY TRANSPARENCY POLICY We believe in fairness and openness when it comes to pay. In compliance with Massachusetts law, we provide pay range information for all job postings—whether internal or external—for positions based in Massachusetts. This includes promotions, transfers, and new roles. If you are applying for a job, being promoted, or moving to a new position, you have the right to know the pay range for that role. You can also request the pay range for your current position at any time. Retaliation for asking about pay ranges is strictly prohibited. Our goal is to ensure transparency and equity across all positions. If you have questions about pay ranges or this policy, please contact Human Resources.

COMPENSATION & PAYROLL DIRECT DEPOSIT The Company requires all Associates to have their paycheck electronically transferred directly to their savings or checking account(s) through the information provided. If you do not have a savings or checking account, you can elect to have your pay transferred to a pay card. A pay card works much like a debit card – your pay is transferred onto your pay card through direct deposit. Please see the Human Resources Department for more information about direct deposit.

EMPLOYMENT TAXES & VOLUNTARY DEDUCTIONS As an Associate of the Company, you are responsible for paying federal, state, and local taxes. This includes federal and state income taxes, Social Security, and Medicare taxes. These taxes will be automatically withdrawn from each of your paychecks at a rate that is determined by the number of deductions you claim. You are also eligible to receive benefit coverage as described later in this Handbook. Should you choose to enroll in any of the offered benefits programs, you will be required to pay a portion of the premium cost (no cost for company-paid Life/AD&D/LTD). Your total annual contribution cost for the coverage you select will be divided by 24 pay periods in the Plan Year to determine the amount that will be deducted (on a pre-tax basis) from each of your paychecks. You have the option of waiving all pre-tax benefits. Should you choose to waive these benefits, you will not have another opportunity to elect them until the next Open Enrollment Period. The only exception to this is a qualifying event for an applicable benefit. Some common qualifying events include changes in employment status, divorce, and marriage. The employment taxes and voluntary deductions described above will continue to be deducted from your paycheck until changes are made to the number of deductions you claim, or until you change your benefit elections.

STANDARDS OF CONDUCT PROFESSIONALISM & WORKPLACE BEHAVIOR Professionalism is key to our success. We expect all Associates to treat each other with respect and courtesy. Harassment, discrimination, or any form of bullying will not be tolerated and will result in disciplinary action. To ensure orderly operations and provide the best possible work environment, the Company expects Associates to follow standards of conduct that will protect the interests and safety of all Associates and the Company. Failure to follow Company rules during working hours, on-site or off-site, may result in disciplinary action, up to and including immediate suspension or termination of employment. The following illustrative and non-exhaustive list contains a few examples of conduct that will not be tolerated: Theft, inappropriate removal, or unauthorized possession of Company property Falsification of timekeeping records Possession, distribution, sale, transfer, or use of alcohol or illegal drugs in the workplace, while on duty, including nonpaid break periods, or while operating Company-owned vehicles or equipment Fighting or threatening violence in the workplace Boisterous or disruptive activity in the workplace Negligence or improper use of company-owned or customer-owned property Driving Company vehicles or equipment (i.e., forklifts) without authorization or without proper licensing qualifications Insubordination or other disrespectful conduct Violation of safety or health rules Smoking in prohibited areas Sexual or other unlawful or unwelcome harassment Possession of dangerous or unauthorized materials, such as explosives, fireworks, or firearms, in the workplace or on the job site Excessive tardiness, absenteeism, or any absence without notice Failure to follow the supervisor/manager’s instructions Unauthorized use of telephones, mail system, computers, or other employer-owned equipment Unauthorized disclosure of confidential information Sleeping or dozing during working hours Additional conduct and work rules may apply to certain Company businesses. Please consult your supervisor/manager with questions about conduct and work rules in your work area.

STANDARDS OF CONDUCT WORKPLACE VIOLENCE It is the Company’s policy to provide a workplace that is safe and free from all threatening and intimidating conduct. Therefore, the Company will not tolerate violence or threats of violence in any form in the workplace, at work-related functions, or outside of work if it affects the workplace. This policy applies to Company Associates, clients, customers, guests, vendors, and persons doing business with the Company. It is a violation of this policy for any individual to engage in any conduct, verbal or physical, that intimidates, endangers, or creates the perception of intent to harm persons or property. Examples include but are not limited to: Physical assaults or threats of physical assault, whether made in person or by other means (i.e., in writing, by phone, fax, or email) Verbal conduct that is intimidating and has the purpose or effect of threatening the health or safety of a co-worker Any other conduct or acts that management believes represent an imminent or potential danger to workplace safety or security Anyone with questions or complaints about workplace behaviors that fall under this policy may discuss them with a supervisor/manager or a Human Resources representative. The Company will promptly and thoroughly investigate any reported occurrences or threats of violence. Violations of this policy will result in disciplinary action, up to and including immediate termination of Associates. Where such actions involve non-Associates, the Company will take appropriate action in the circumstances. Where appropriate and/or necessary, the Company will also take whatever legal actions are available and necessary to stop the conduct and protect Company Associates and property.

STANDARDS OF CONDUCT DRESS CODE (GENERAL) The Company believes that your pride in both yourself and the company is reflected in your appearance and in the image you create. We believe that our business image is important and therefore request that our Associates maintain standards of dress and appearance appropriate to both the organization as a whole and their individual positions and responsibilities. Dress, grooming, personal cleanliness, and professional behavior standards contribute to the professional image we strive to present to our customers and visitors. Therefore, while performing duties for the Company, Associates are expected to dress appropriately for the business environment and behave professionally at all times to best represent our business. Guidelines: Our formal dress guidelines include a more relaxed dress or “Business Appropriate” dress, which we believe is in the best interest of our Associates and our customers. Associates may dress according to the requirements of their position; however, our belief regarding business-appropriate dress is that business is always first. This means that Associates should keep their day’s schedule in mind. We recognize that different levels of dress may be appropriate for different occasions. As a general rule, when meeting with clients, prospects, or outside visitors, traditional business attire should always be worn except where it does not make good business sense. All Associates should select their business attire for meetings and contacts outside the office based on the type of function they will attend. Also, on occasion, there may be a specific business reason to require that all Associates dress in traditional business attire. In such an instance, this will be communicated to Associates in advance, and they will be required to dress accordingly. Our business appearance and image are important to us. However, we respect individual preference and choice in dress and appearance. We are confident that Associates will use their best judgment in following our dress and attire guidelines. We ask that, at all times, Associates ensure their appearance is well-groomed and clean, and that their clothing is appropriate, neat, clean, and well-fitting. While relaxed business attire is acceptable within the stated guidelines, we want to be sure our environment does not jeopardize professionalism and productivity. If an Associate is unclear about dress and appearance guidelines, you are encouraged to consult with Human Resources. Continued or frequent departures from these guidelines will not be permitted, and Associates who appear for work inappropriately dressed or groomed repeatedly will be subject to disciplinary action.

STANDARDS OF CONDUCT COMPANY‑ISSUED APPAREL POLICY Associates in designated positions are required to wear company‑issued shirts while working. These shirts help promote professional appearance, support safety and identification, and represent the Company to customers, suppliers, and visitors. Company‑issued shirts must be worn during scheduled work hours and maintained in a clean and presentable condition. Associates are responsible for the proper care of issued apparel. Failure to wear required company‑issued apparel may result in corrective action, up to and including discipline, unless an accommodation has been approved by Human Resources.

VISITORS IN THE WORKPLACE Visitors must be accompanied by an Associate. If it is necessary for you to receive visits from a relative or friend, these visits should be kept brief and restricted from disrupting the workflow during business hours. The routine or extended presence of friends or family at our workplace is not permitted. Special care should be taken to allow children on-site. If it is necessary for children to visit the workplace, they must at all times be in the company of and under the supervision of an adult. As noted above, these visits should be brief and infrequent.

SOLICITATION, DISTRIBUTION & USE OF BULLETIN BOARDS The Company recognizes that Associates may have interests in events and organizations outside the workplace. However, you may not solicit or distribute literature concerning these activities during working time. In addition, the posting of written solicitations on company bulletin boards or through e-mail systems is restricted. Company bulletin boards display important information, and Associates should consult them for work-related policies, including federal and state laws. If you have a message of interest to the workplace, you may submit it to the Human Resources Department for approval. All approved messages will be posted by the Human Resources Department.

STANDARDS OF CONDUCT CELL PHONE POLICY We realize the importance of personal cell phones in society, and we have so much activity in our lives that we depend on timely cell phone communication via text, email, and apps. That being said, we kindly want to remind everybody that personal cell phones should only be used during normally scheduled company breaks and meal periods, as well as for unavoidable emergencies, while adhering to the following requirements: Cell phones should NEVER be used while operating any type of machinery or heavy equipment, or driving company vehicles Personal cell phones should never be used to photograph or record any confidential company information or to download any personal content using the company's Wi-Fi network Personal cell phones should remain on silent or vibrate mode during normal working hours to ensure minimal disruption to productivity and workflow Personal cell phones should not be used on the production floor, warehouse, or office areas during shift times for talking, viewing, texting, reading, or any other interactive purposes Personal cell phones MAY be used for passive listening of music or sound ONLY when allowed per the headphone policy guidelines Failure to comply can lead to disciplinary action up to and including termination.

HEADPHONE POLICY The use of earbuds is allowed in certain Coghlin Companies facilities, but not in all locations. The approval to use earbuds will be determined by building, and managers will let you know what the policy is for your specific location. When approved by a manager or supervisor, earbud use is limited to one earbud to ensure safe working conditions and productive communication. Earbud use is completely prohibited while driving company-owned vehicles, operating any equipment, or in areas where heavy equipment, such as forklifts and material handlers are operating.

STANDARDS OF CONDUCT WEAPON-FREE WORKPLACE POLICY To ensure that the Company maintains a workplace safe and free of violence for all Associates, the company prohibits the possession or use of dangerous weapons* on company property. A license to carry the weapon does not supersede company policy. Associates are responsible for ensuring that any item they possess is not prohibited by this policy. If you require such an item, please request it from your supervisor or manager. For those Associates who require sharp objects (box cutters, letter openers, etc.) to perform their tasks, the Company will provide such tools as are necessary. Such tools are to be left on the premises upon the Associates’ departure at the end of each day. *Dangerous weapons include firearms, explosives, knives, and other weapons that might be considered dangerous or that could cause harm.

TIME AWAY FROM WORK PAID HOLIDAYS The Company grants paid time off to all eligible Associates for the holidays listed below: New Year's Day (January 1st) Presidents’ Day (3rd Monday in February) Patriot’s Day (3rd Monday in April) Memorial Day (last Monday in May) Independence Day (July 4th) Labor Day (1st Monday in September) Columbus Day (2nd Monday in October) Thanksgiving (4th Thursday in November) The Friday after Thanksgiving (in observance of Veterans’ Day) Christmas (December 25th) Holiday pay is calculated based on the Associate's straight time pay rate (as of the date of the holiday) times the number of hours they would otherwise have worked on that day. Holiday hours are counted toward hours worked (PLT is not). If you are not scheduled to work on a holiday, you will not receive holiday pay. If a recognized holiday falls during an eligible Associate's paid leave time absence, holiday pay will be provided instead of the PLT benefit that would otherwise have applied. If eligible hourly Associates are requested to work on a recognized holiday, they will receive holiday pay plus pay for hours worked on the holiday. You must either work or use a paid leave day, the working day before and after a holiday, in order to qualify for a paid holiday.

TIME AWAY FROM WORK PAID LEAVE TIME (PLT) Time off with pay is available to eligible associates for vacation, illness, and personal pursuits. The amount of paid leave time (PLT), you receive each pay period increases with the length of your employment as shown in the following schedule. Years of Service

Accrued Each Pay Period

Accrued Annually

Up to 1 Year

3.08 Hours

10 Days

After 1 Year

4.62 Hours

15 Days

After 8 Years

6.16 Hours

20 Days

After 15 Years

7.69 Hours

25 Days

After 20 Years

8.30 Hours

27 Days

After 25 Years

9.23 Hours

30 Days

After 30 Years

10.76 Hours

35 Days

You are eligible to begin earning PLT from your date of hire. You earn PLT each pay period that you are actively working. You may begin using PLT as soon as it is earned. Associates may utilize accrued PLT for current and future time-off requests. The PLT policy allows an associate to include 16 hours of PLT not yet accrued (-16) as part of the accrual calculation. Except for instances when PLT is used for sick leave purposes as discussed below, to utilize PLT, you must request and receive advance approval from your supervisor/manager; One (1) week for a one (1) or two (2) day leave; Four (4) weeks’ notice for a one (1) week leave. Non-sickrelated leave requests will be reviewed based on a number of factors, including business needs and staffing requirements. PLT is paid at your base pay rate at the time of use. You may accrue up to 30 days of PLT. No additional paid leave will accrue until the accumulated PLT is less than the maximum 30 days (240 Hours). Please note: On January 1st of each year, your accrued PLT will carry over into the next calendar year.

TIME AWAY FROM WORK PAID LEAVE TIME (PLT) Upon termination of employment, you will be paid for all accrued unused PLT. If you are unable to report to work due to illness or injury or that of a family member, you must notify your direct supervisor/manager before the scheduled start of your workday. The direct supervisor/manager must also be contacted on each additional day of absence due to sick leave. If an associate is absent due to having called in sick from work the day before or the day after a scheduled holiday, the associate may not receive holiday pay. If an associate needs to be absent, to be late, or to leave work early due to illness, the associate must give advance notice to the supervisor, except in an emergency. If the PLT day is being used for illness and the use is foreseeable such as a scheduled medical appointment, the associate must provide as much notice as is practicable but not less than seven days’ advance notice, unless the associate learns of the need to use earned sick time within a shorter period. If the absence is not foreseeable, the associate must provide notice to his or her supervisor as soon as practicable. If an associate is going to be absent on multiple days, the associate must provide notice of the expected duration of the leave or, if unknown, provide notice of continuing absence daily, unless the circumstances make such notice unreasonable. Associates may be asked to certify in writing that they were sick and whether they would like to use any available sick leave prior to the pay period. Associates are generally required to submit a doctor’s note or other documentation to support the use of sick time if the absence: exceeds twenty-four (24) consecutively scheduled work hours or three (3) consecutive days on which the associate is scheduled to work; occurs within two (2) weeks prior to an associate’s final scheduled day of work; or occurs after four (4) unforeseeable and undocumented absences within a three (3) month period. Required documentation must be submitted within seven (7) days of the absence. Additional time to produce such documentation will be provided when the associate can demonstrate that additional time is needed to produce the required documentation.

TIME AWAY FROM WORK PLT CASH-OUT OPTION Associates may carry over accrued Paid Leave Time (PLT) from year to year, subject to the maximum accrual limit set forth in this policy. In January of each calendar year, associates who meet the following minimum accrued PLT balances may elect to receive a cash payment for up to five (5) days (40 hours) of accrued PLT: Hourly Associates: Must have an accrued PLT balance greater than fifteen (15) days (120 hours). Salaried Associates: Must have an accrued PLT balance of at least twenty-five (25) days (200 hours). Approved cash-out requests will be paid by the end of January following the associate's election. Participation in the PLT cash-out program is voluntary and subject to Company approval and administrative requirements. This cash-out opportunity is available only once per calendar year during the designated annual election period in January. Associates who elect to cash out eligible PLT balances may do so only during this annual window. Requests for PLT cash-outs submitted at any other time during the year will not be approved or accepted. The Company reserves the right to modify, suspend, or discontinue the PLT cash-out program at any time, with or without notice.

TIME AWAY FROM WORK PAID FAMILY AND MEDICAL LEAVE (PFML) Paid Family and Medical Leave (PFML) is a program designed to help people in Massachusetts take paid time off from work for family or medical reasons. Massachusetts’s PFML is funded through employer and employee contributions, and is different from the federal Family and Medical Leave Act. Qualifying reasons allowed for leave are: Caring for your own serious health condition. This must be certified by a health care provider. This may include illness, injury, childbirth, or serious health conditions related to pregnancy. Caring for a family member with a serious health condition. This must be certified by a health care provider. This may include illness, injury, or pregnancy/childbirth. Bonding with your child during the first 12 months after birth, adoption, or placement Caring for a family member who is a covered service member with a serious health condition that was received or aggravated while they were deployed on active duty Managing affairs while a family member is deployed or about to be deployed on active duty If you are eligible, you can take up to 26 weeks of combined PFML per benefit year. Up to 20 weeks of paid medical leave to manage your own serious health condition Up to 12 weeks of paid family leave to care for a family member or to bond with a child Up to 26 weeks of paid family leave to care for a family member who is a covered service member with a serious health condition that was received or aggravated while they were deployed on active duty You can take more than one kind of leave in a benefit year, but the maximum amount of paid leave you can take in a benefit year is 26 weeks. Your benefit year is unique to you and is based on when you take time off through any leave program. Your benefit year starts the Sunday before your first day of leave and lasts for 52 consecutive weeks. The benefit year determines your benefit rate, which will stay the same for the entire benefit year, even if you file multiple applications or take different types of leaves. Your benefit rate will only change when you start a new benefit year. If you need to take paid leave, the first thing you need to do is inform Human Resources. Human Resources will guide you through the entire process. The Human Resources Team provides this notice to new hires and annually posts the PFML poster in each facility.

TIME AWAY FROM WORK FAMILY MEDICAL LEAVE ACT (FMLA) As an Associate of the Company, you may be eligible to take unpaid family and medical leave under the federal law, the Family and Medical Leave Act (FMLA). To be eligible for FMLA leave, you must be employed by the Company for at least 12 months. In the 12 months immediately preceding the beginning of the leave, you must also have worked at least 1,250 hours to qualify for federal FMLA. Eligible Associates may take up to a total of 12 weeks (480 hours) of FMLA leave within a rolling 12-month period, measured backward from the date an Associate uses any FMLA leave, for any combination of the following reasons: The birth of an Associate’s newborn child or the placement of a child with the Associate for adoption or foster care To care for the Associate’s spouse, child, or parent with a serious health condition The Associate has a serious health condition that makes him or her unable to perform the functions of their job A qualifying exigency that arises because the Associate’s spouse, child or parent is a covered military member on covered active duty (or has been notified of an impending call or order to covered active duty) where leave is taken to care for a covered service member who is undergoing medical treatment, recuperation or therapy, is in outpatient status or is otherwise on the temporary disability retired list for a serious injury or illness, a spouse, child, parent or next of kin may take up to 26 weeks of unpaid FMLA leave during a single 12-month period. Spouses working for the same employer are together entitled to a combined total of 12 weeks of FMLA leave for the birth of a child, placement for adoption or foster care, or to care for a parent with a serious health condition. For military caregiver leave, spouses are jointly entitled to a combined total of 26 weeks of FMLA leave for caring for a covered service member with a serious injury or illness.

TIME AWAY FROM WORK FAMILY MEDICAL LEAVE ACT (FMLA) Associates seeking to use FMLA leave are required to provide to Human Resources: Thirty (30) days' advanced notice of the need to take FMLA leave when the need is foreseeable, otherwise as soon as is practicable. Medical certification supporting the need for leave due to a serious health condition affecting the Associate or an immediate family member in accordance with the form provided by the Company; Second or third medical opinions and periodic recertifications (at the Company’s expense) if requested by the Company. Periodic reports during FMLA leave regarding the Associate’s status and intent to return to work as requested by department heads. When leave is needed under the category of care for an immediate family member or the Associate’s own illness, and is for planned medical treatment, the Associate must try to schedule treatment so as not to unduly disrupt the Company’s operation. For additional information regarding FMLA, please contact Human Resources.

MASSACHUSETTS SICK LEAVE COMPLIANCE Our PLT policy satisfies all requirements under the Massachusetts Earned Sick Time law. Associates accrue and may use paid leave for any purpose permitted by law, including their own illness or injury, medical appointments, caring for a family member, or reasons related to domestic violence or certain family health circumstances. Associates should provide notice when possible; documentation may be requested for absences exceeding 24 consecutive work hours. Unused leave may be carried over as required by law, but no more than 40 hours may be used for sick time purposes in a calendar year.

TIME AWAY FROM WORK BEREAVEMENT LEAVE Associates requiring time off due to the death of an immediate family member should notify their supervisor/manager immediately. The Company defines “immediate family” as the Associate’s spouse, parent, child, sibling, or grandparent, the Associate’s spouse’s parent, child, or sibling, grandparent, or any relative residing in the Associate’s household. Up to three (3) days of paid bereavement leave will be provided to full-time Associates. Bereavement pay is calculated based on the base pay rate at the time of absence and will not include any special forms of compensation, such as incentives, commissions, bonuses, or shift differentials. Bereavement time is not counted as hours worked for purposes of computing overtime. You may, with your supervisor/manager’s approval, use any available PLT for additional time off as necessary. Please review each circumstance with your supervisor/manager.

JURY DUTY The Company encourages Associates to fulfill their civic responsibilities by serving jury duty when required. Associates who have completed a minimum of ninety (90) calendar days of service may use, if necessary, up to two (2) weeks of paid jury duty leave over any three (3) year period. You must present the jury duty summons to your supervisor/manager as soon as possible so that your supervisor/manager may decide to accommodate your absence. You are expected to report for work whenever the court schedule permits. Jury duty pay will be calculated on the Associate's base pay rate times the number of hours the Associate would otherwise have worked on the day of absence for jury service. If you are required to serve jury duty beyond the period of paid jury duty leave, you may use any available PLT benefits, or you may request an unpaid jury duty leave of absence.

TIME AWAY FROM WORK MILITARY LEAVE The Company provides Associates who perform service in the uniformed military with unpaid leave in compliance with federal and state laws. Associates should notify their supervisor/manager as soon as they become aware of a military service obligation. No Associate will be required to use PLT for military duty, but Associates who do elect to schedule their PLT to coincide with military duty will receive their full regular PLT pay in addition to any pay from the military. Questions regarding the Company’s military leave policy should be directed to Human Resources.

PARENTAL LEAVE Any full-time Associate who completes three (3) consecutive months of full-time employment is eligible for up to eight (8) weeks of unpaid parental leave for the following: Leave to give birth or care for their newborn child Adopt a child under 18 years of age Adopt a child under 23 years of age if the child is mentally or physically disabled If you return after the leave entitlement, you will be reinstated to your previous position or to a substantially similar position, provided that your job still exists and you would have continued to be employed in that job had you not taken leave.

EMERGENCY RESPONSE LEAVE Associates who serve as volunteer firefighters or emergency medical technicians may take time off from work to respond to emergencies that occurred prior to the time Associates are scheduled to report to work. Associates should notify their supervisors if they are volunteer firefighters or emergency medical technicians and may occasionally need time off work to respond to emergencies. Associates must use available PLT for Emergency Responder Leave.

TIME AWAY FROM WORK SMALL NECESSITIES LEAVE The Small Necessities Leave allows Associates who qualify under the federal Family and Medical Leave Act to take off up to 24 hours of PLT in a 12-month period for: Your child's school activities, such as parent-teacher conferences Your child's medical appointments Your elderly relative's medical appointments or appointments for other professional services related to the elder's care, such as interviews at nursing or group homes

VICTIM LEAVE An Associate can take up to 15 days of leave in any 12-month period to deal with abusive behavior or domestic violence perpetuated against them or a family member. Associates using this leave will have confidentiality protection, and Human Resources will work with them directly on this leave. Associates must use available PLT for this leave.

VOTING On Election Days, Associates are encouraged to vote, but they are expected to do so either before or after work. If there are extenuating circumstances, arrangements can be made with the supervisor/manager for unpaid time off to vote. Please consult with the Human Resources Department if you have any questions about these policies.

TIME AWAY FROM WORK UNPAID TIME OFF & LEAVES OF ABSENCE Unpaid personal leaves of absence are considered on a case-by-case basis for Associates who need time away from work that exceeds their available PLT. Such leaves generally will be considered only for full-time Associates who have completed at least (1) year of continuous employment. If you are considering an unpaid personal leave of absence, please discuss your circumstances with your supervisor/manager. You will be required to initiate your request in writing for requests that result in more than two (2 days/ (-16) unpaid hours. Written requests will be forwarded to the Senior Executive in your division for review and final approval. You must use all your earned, but unused, PLT as part of the leave. The remainder of your leave will be unpaid. You will not earn PLT during any period in which you are on unpaid leave. Although the Company will make an effort to reinstate you at the end of your leave to the same job, or a job that is similar in responsibilities and seniority, reinstatement is not guaranteed except to the extent required by federal and/or state law.

HEALTH AND SAFETY WORK-RELATED INJURY & INCIDENT REPORTING POLICY The Company is committed to establishing and maintaining a comfortable and safe working environment for all Associates. Safety is everyone’s responsibility. All work-related injuries and illnesses should be reported immediately to Human Resources, even if you are not sure whether they are truly work-related. Even small, seemingly insignificant injuries left untreated can result in serious conditions. Human Resources and your supervisor will work with you to complete an Incident Report. When injuries are reported immediately, they will be investigated quickly, and corrective action will be taken to prevent similar injuries in the future.

WORKERS’ COMPENSATION POLICY The Company provides workers’ compensation, a type of accident and injury insurance, that compensates an Associate for lost time, medical expenses, and loss of life or dismemberment from an injury arising out of or in the course of work. Associates must report any accident or injury immediately to their supervisor/manager and Human Resources so that the necessary paperwork can be completed in a timely manner. Associates returning to work after an injury or illness for which they were receiving workers’ compensation must provide proof of rehabilitation or treatment from a licensed physician and verification that they can perform all job-related tasks. In the event that the Associate cannot complete some of the tasks as ordered by the physician, the company will, if possible, modify the Associate’s job load. Once a physician has verified that the Associate can resume all job-related tasks, he or she will no longer receive workers’ compensation benefits.

HEALTH AND SAFETY SMOKE-FREE WORKPLACE & ENVIRONMENT The Company is a smoke-free environment. Smoking of traditional or e-cigarettes, cigars, pipes, etc., is not permitted at any time in Company work areas or vehicles, or in client work areas or vehicles. Smoking is allowed outside of the building in designated locations, and smokers should be considerate of colleagues, customers, and members of the public. Help to maintain a clean environment by depositing cigarettes in appropriate containers. Associates who smoke must observe the same guidelines as non-smokers for the frequency and length of break periods. Smoking is prohibited throughout the workplace, in Company vehicles, or on any loading docks.

DRUG-FREE WORKPLACE POLICY We recognize alcohol and drug abuse as a potential health, safety, and security problem. It is expected that all Associates will assist in maintaining a work environment free from the effects of alcohol, drugs, or other intoxicating substances. Compliance with this Drug-free Workplace Policy is made a condition of employment. Associates are prohibited from the following when reporting for work, while on the job, on Company or customer premises, or in the surrounding areas, or in any vehicle used for Company business: The unlawful use, possession, transportation, manufacture, sale, dispensation, or other distribution of an illegal or controlled substance or drug paraphernalia The unauthorized use, possession, transportation, manufacture, sale, dispensation, or other distribution of alcohol Being under the influence of alcohol or having a detectable amount of an illegal or controlled substance in the blood or urine (“controlled substance” means a drug or other substance as defined in applicable federal laws on drug abuse prevention). Any Associate who violates these prohibitions will be subject to disciplinary action, up to and including termination. Please note that the recent decriminalization of recreational marijuana use does not in any way change or alter the Company’s policy prohibiting Associates from possessing, using, or coming to/being at work under the influence of marijuana.

TECHNOLOGY USE OF COMPANY ASSETS AND TECHNOLOGY Computers and all information technology equipment and information system resources are the property of Coghlin Companies, Inc. or one of its subsidiaries, Columbia Electrical Contractors, Inc. d/b/a Columbia Tech, or Cogmedix, Inc., and are provided only for authorized use by its Associates. Associates must use Coghlin Companies information system resources in compliance with applicable confidentiality, privacy, cybersecurity, and company policies for company use only. You are responsible for maintaining the privacy of your authentication information and any data you access and/or use in the course of your work. You may not share your authentication information under any circumstances and may not share data outside of the scope of your authority. Use of the Coghlin Companies information system resources outside the scope of your authority or in a manner contrary to policies is subject to discipline up to and including termination of employment. If you violate state or federal law when using Coghlin Companies information system resources, you may be subject to criminal investigation and prosecution or civil monetary penalties. Associates who possess personal identifying information (PII) of another individual as part of their job, e.g., financial account number, social security number, driver’s license number, or state-issued identification number, may only possess this information for the shortest amount of time needed to complete the task for which they possess the information. For more information regarding the company’s policy on PII, please refer to the Use of Company Assets and Technology. The Company is committed to accomplishing its business objectives in a secure and timely manner. Each Associate must assist in achieving this goal while safeguarding corporate information assets. The basic regulations for using the Company computer systems are as follows: Computers, Internet, and email are for business use only The Company may access any information created, transmitted, or stored on its information systems Copying or downloading software of any kind is prohibited without prior permission Any email of an offensive, pornographic, or otherwise inappropriate nature is prohibited violations may result in disciplinary action Company proprietary information must be protected

TECHNOLOGY USE OF COMPANY ASSETS AND TECHNOLOGY Associates who possess personal financial information of another individual as part of their job, e.g., credit card information, Social Security Number, bank account information, etc., may only possess this information for the shortest amount of time needed to complete the task for which they possess the information. Additionally, Associates must affirmatively take steps to protect the personal financial information of another that they possess from unauthorized disclosures. For more information regarding the company’s policy on the protection of personal financial data, please refer to the Company’s Written Information Security Plan (WISP) that each Associate receives. If you would like a copy of the Company’s WISP, please refer to the Company Resources folder.

EMAIL ETIQUETTE When sending emails to multiple users, it is important to follow these best practices: Subject Line: Use a clear, professional subject line to show your recipient what the email will cover. Body of Email: Use the body of your email to communicate your message clearly and effectively. Keep emails brief, focused, and easy to read by including only relevant information and key details. If additional discussion is needed, offer to follow up or encourage the recipient to reach out with any questions or concerns. Reply All: Be mindful when using “Reply All” and include only those who need to receive the information being shared. Limiting unnecessary replies helps respect others’ time and keeps inboxes organized. When sending emails to large groups or distribution lists, use the “BCC” field when appropriate to protect recipient information and reduce unnecessary email traffic. Before responding, consider who truly needs to be included in the conversation. If you have questions about these email procedures, please feel free to contact Human Resources.

TECHNOLOGY ARTIFICIAL INTELLIGENCE USE POLICY Coghlin Companies is committed to the lawful and ethical use of artificial intelligence (AI) in its operations, products, and services. This policy applies to all Associates, contractors, and representatives. AI should be used to improve business efficiency and support organizational goals, never to compromise Coghlin’s values or introduce undue risk. All AI use must comply with global legal standards and company guidelines. Associates may use embedded AI tools in approved software (e.g., grammar checks in Microsoft Word) without additional approval. However, any new AI system requires prior approval from the Information Technology and Cybersecurity department. AI-generated content must be reviewed by subject matter experts for accuracy and alignment with Coghlin’s brand. Non-public company data, trade secrets, or sensitive personal information must never be entered into open AI systems. Associates are strictly prohibited from entering any personal data—whether their own or anyone else’s—into any AI system or tool. Coghlin expects ethical and transparent AI use. Associates must disclose AI assistance when required, avoid bias, and ensure content is appropriate and business-related. High-risk uses— such as screening job candidates or handling personal data—require extra caution and compliance with legal and ethical standards. All Associates are required to comply fully with the Company’s Artificial Intelligence (AI) Policy and adhere to all guidelines, responsibilities, and restrictions outlined within it.

If you would like a copy of the Company’s AI policy, please refer to the Company Resources folder.

TRANSPORTATION & DRIVING COMPANY CAR POLICY The Company provides vehicles for business use and provides reimbursement for business use of personal vehicles according to the following guidelines. The Company retains the right to amend or terminate this Policy at any time. Associates may not drive any business vehicles without prior approval. Before being approved to operate a company vehicle, an Associate’s driving records will be reviewed, with the consent of the Associate, and the existence of a valid driver’s license will be verified. Associates approved to drive on company business are required to inform Human Resources of any changes that may affect their legal or physical ability to drive or their continued insurability. Associates holding jobs that require regular business driving as an essential job function must, as a condition of employment, be able to meet the driver approval standards of this Policy at all times. For all other jobs, driving is considered only an incidental function of the position. Associates who drive a vehicle on company business must, in addition to meeting the approval requirements above, exercise due diligence to drive safely and maintain the security of the vehicle and its contents. Associates are also responsible for any driving infractions or fines resulting from their driving. Associates who use their personal vehicles for approved business purposes will receive a mileage allowance. This allowance is to compensate for the cost of gasoline, oil, depreciation, and insurance. Associates who operate personal vehicles for Company business must obtain auto liability coverage for bodily injury and property damage with a special endorsement for business use, when necessary, as determined by their personal insurance agent. Associates must report any theft or malicious damage involving a company vehicle, regardless of the extent of the damage. Such reports must be made as soon as possible, but no later than 48 hours after the incident. While reporting incidents to law enforcement, Associates should make no voluntary statements other than in response to questions from investigating officers. Associates are not permitted, under any circumstances, to operate a company vehicle or a personal vehicle for company business when any physical or mental impairment causes the Associate to be unable to drive safely. Additionally, Associates shall not operate any company vehicle at any time, or operate any personal vehicle for company business while using or consuming alcohol, illegal drugs, or prescription medications that may affect their ability to drive. These prohibitions include circumstances in which the Associate is temporarily unable to operate a vehicle safely or legally because of impairment, illness, medication, or intoxication.

TRANSPORTATION & DRIVING DRIVER ELIGIBILITY Drivers must possess a valid driver's license for the type of vehicle to be operated, and keep the license(s) with them at all times while driving.

INSURANCE REQUIREMENTS Associates who use their personal vehicles for company business are required to carry adequate limits of liability, with a suggested minimum of $100,000 for property damage and $100,000/$300,000 for bodily injury. A copy of the declaration page of your personal automobile insurance policy must be provided to the Company annually at your renewal date. Basic Vehicle Operation Guidelines: Always use seat belts Drive defensively, always anticipate what other drivers might do wrong, and plan your escape route Never move through traffic aggressively Respect speed limits and traffic signs Follow all traffic signals Always lock the vehicle and apply the parking brake when getting out, even if it remains in sight During long trips, take breaks every four hours and never drive more than 10 hours during a 24-hour period Avoid driving in dangerous conditions, including drowsiness and inclement weather

DISTRACTED DRIVING The Company is committed to Associate safety and, for this reason, firmly prohibits all behavior that distracts Associates while operating a company vehicle. Associates may use hands-free equipment to make or answer calls while driving without violating this policy. However, safety must always be your first priority. You are expected to keep these calls brief. If, because of weather, traffic conditions, or any other reason, you are unable to concentrate fully on the road, you must either end the conversation or pull over and safely park your vehicle before resuming your call.