2012 Policy Manual SAMPLE

Sample

Policy Manual Revised and Effective as of February 2012

Brought to you by:

Table of Contents No.

Policy

Effective Date: Revision Date:

Section 1: Terms of Employment 101

Nature of Employment ................................... 7/1/2005

102 Non-Disclosure................................................ 7/1/2005 103

Introductory Period ......................................... 7/1/2005 10/17/2008

104 Termination...................................................... 7/1/2005 105

Insurance Licensing........................................ 7/1/2008 1/07/2009

106

Conflicts of Interest......................................... 7/1/2005 5/27/2009

107 Performance Evaluation.................................. 7/1/2005 5/27/2009 108

Drug and Alcohol Use..................................... 7/1/2005 7/15/2008

Section 2: Federal Rights 201 Equal Employment Opportunity...................... 7/1/2005 10/17/2008 202

Immigration Law Compliance.......................... 7/1/2005

203 HIPAA ............................................................. 7/1/2005 204 ERISA ............................................................. 7/1/2005 205

Disability Accommodation .............................. 7/1/2005

206 Military Leave.................................................. 7/1/2005 207

Sexual and Other Unlawful Harassment ........ 7/1/2005 10/1/2011

Section 3: Rules and Conduct 301 Employee Work Rules...................................... 7/1/2005 302

Business Ethics and Conduct......................... 7/1/2005

303 Progressive Discipline..................................... 7/1/2005 304 Personal Appearance...................................... 7/1/2005 305 Attendance and Punctuality............................ 7/1/2005 5/27/2009 306 Personal Property............................................ 7/1/2005 307

Travel & Business Expense............................. 7/1/2005 5/27/2009

308 Gifts................................................................. 7/1/2005 309 Overtime.......................................................... 7/1/2005 310 Personal Automobile Use................................ 7/1/2005 5/27/2009 311 Problem Resolution......................................... 7/1/2005 312

Return of Property........................................... 7/1/2005 10/17/2008

313 Personnel Data Changes................................ 7/1/2005 10/17/2008 2

No.

Policy

Effective Date: Revision Date:

Section 4: Safety and Security 401 Safety............................................................... 7/1/2005 402

First Aid........................................................... 7/1/2005

403 Security............................................................ 7/1/2005 9/01/2008 404

Workplace Monitoring..................................... 7/1/2005

Section 5: Computing and Telecommunications 501

Computer and Email Usage............................ 7/1/2005

502

Internet Usage................................................. 7/1/2005

503 Telephones...................................................... 7/1/2005 10/17/2008 Section 6: Benefits 601 Benefits........................................................... 7/1/2005 10/17/2008 602 Holidays........................................................... 1/1/2006 1/03/2011 603 Paid Time Off (PTO)........................................ 1/1/2006 5/27/2009 604

Non-FMLA Leave of Absence......................... 8/1/2005 1/26/2009

605

Family and Medical Leave............................... 2/1/2009 1/26/2009

606

Bereavement Leave......................................... 7/1/2005 10/01/2008

607

Jury Duty......................................................... 7/1/2005 10/17/2008

608

Section 125 Plan............................................. 7/1/2005 10/17/2008

609

Workers’ Compensation Insurance................. 7/1/2005

610

Benefits Continuation (COBRA)...................... 7/1/2005

611 Additional Benefits.......................................... 7/1/2005 10/17/2008 612

Higher Education Bonus Incentive.................. 5/1/2010

This employee handbook will give you important information about working at Wepor Proug. The policies in the handbook explain many of the benefits of working here.

The handbook also explains what we expect of you and tells about many of our rules.

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INTRODUCTORY STATEMENT This employee handbook is intended to acquaint employees of Wepor Proug with the policies and expectations of the company in addition to providing information regarding working conditions, employee benefits, and policies affecting employment.

Please read, understand, and comply with the policies and provisions in this manual as it describes many responsibilities as an employee. The main objective of Wepor Proug is to provide a healthy work environment that is conducive to both personal and professional growth.

Employment with Wepor Proug is voluntary. As there is no specified length of employment, the Company or employees of the Company may terminate the relationship at will with or without cause, at any time, so long as there is no violation of applicable federal or state laws.

This employee handbook cannot cover every situation or answer every question about the policies and benefits at Wepor Proug. Please consult a Company Officer, regarding questions not answered in this manual. Wepor Proug reserves the right to revise, supplement, or rescind any policies or portions of the manual, as it deems appropriate, in its sole and absolute discretion. The only exception to any changes is the employment-at-will policy, which permits either the employee or the Company to end or modify the relationship for any reason at any time (See Policy 101 Nature of Employment). Any revised information may super-cede, modify or eliminate existing policies. This manual is neither a contract of employment nor a legal document.

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SECTION 1: Terms of Employment 101 Nature of Employment Effective Date: 7/1/2005 Revision Date: All individuals that become employees of Wepor Proug are on a voluntary basis; therefore, all employment is at will. “At will” means that employees are free to resign at any time, with or without cause. Likewise, “at will” means that Wepor Proug may terminate employment at any time, with or without cause or advance notice, as long as there is no violation of applicable federal or state laws.

The policies in this handbook are not a contract and should not be construed to constitute contractual obligations of any kind between Wepor Proug and any employee. The provisions in the handbook have been developed at the discretion of management, except for the policy of employment-at-will, and may be amended or cancelled at any time.

These provisions replace all other existing policies and practices and may not be changed or added to without the express written approval of a Company Officer of Wepor Proug.

102 Non-Disclosure & Confidentially Effective Date: 7/1/2005 Revision Date: It is of the utmost importance of Wepor Proug to protect all confidential business information and trade secrets. Upon accepting employment, employees are asked to sign an Employment Agreement, which provides that all employees will not disclose or use confidential information during or after employment. If access is given to confidential information employees may be asked to sign a non-disclosure agreement as a condition of employment. Employment with Wepor Proug assumes an obligation to maintain confidentiality both during and post- employment.

Additionally, clients and suppliers entrust the Company with important and, at times, confidential information. The nature of this relationship requires that employees adhere to Wepor Proug’s Non-Disclosure and Confidentiality policies discussed herein. In safeguarding the information received, Wepor Proug earns the respect and trust of our valued clients and suppliers.

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If a question posed by an outside party to the company and/or department raises a concern as to its appropriateness, employees should not feel pressured to answer.

Rather, as politely as possible, refer the request to a Company Officer.

No one is permitted to remove or make copies of any Wepor Proug records, reports, or documents without prior management approval. Should employees improperly use or disclose trade secrets and/or confidential business information, such behavior will be subject to possible legal action in addition to disciplinary action, up to and including termination of employment. This policy applies to all incidents, even if no direct benefit results from the disclosure.

103 Introductory Periods Effective Date: 7/1/2005 Revision Date: 10/17/2008 The introductory period is intended to give new employees the opportunity to demonstrate their ability to achieve a satisfactory level of performance and to determine whether the new position meets expectations of both the company and the new employee. The Company uses this period to evaluate employee capabilities, work habits, and overall performance. Either the employee or Wepor Proug may end the employment relationship at will at any time during or after the introductory period, with or without cause or advance notice.

All new and rehired employees work on an introductory basis for the first 90 calendar days after date of hire. Any significant absence will automatically extend an introductory period by the length of the absence. If Wepor Proug determines that the designated introductory period does not allow sufficient time to thoroughly evaluate the employee’s performance; the introductory period may be extended for a specified period. Upon satisfactory completion of the introductory period, employees enter the “regular” employment classification.

During the introductory period, new employees are eligible for those benefits that are required by law, such as workers’ compensation insurance and Social Security.

Employees may also be eligible for other company provided benefits, subject to the terms and conditions of each benefits program; i.e., medical, dental, and/or retirement benefits. Employees should read the information for each specific benefits program for the details on eligibility requirements (See Section 6).

104 Termination Effective Date: 7/1/2005 Revision Date:

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Termination of employment is an inevitable part of personnel activity within any organization, and many of the reasons for termination are routine. Below are

some examples of the most common circumstances under which employment is terminated: • Resignation - voluntary employment termination initiated by an employee.

•

Discharge - involuntary employment termination initiated by the organization.

•

Layoff - involuntary employment termination initiated by the organization for non-disciplinary reasons.

•

Retirement - voluntary employment termination initiated by the employee meeting age, length of service, and any other criteria for retirement from the organization.

Wepor Proug will generally schedule exit interviews at the time of employment termination. The exit interview will afford an opportunity to discuss such issues as employee benefits, conversion privileges, repayment of outstanding Company debts, or return of property. Suggestions, complaints, and questions can also be voiced at this time.

Since employment with Wepor Proug is based on mutual consent, both the employee and employer have the right to terminate employment at will, with or without cause, at any time. Employee benefits will be affected by employment termination in the following manner:

•

All accrued, vested benefits due and payable at termination will be paid.

Some benefits may be continued at the employee’s expense if the employee so chooses. The employee will be notified in writing of the benefits that may be continued and of the terms, conditions, and limitations of such continuance (See Policy 609 Benefits Continuation).

105 Insurance Licensing Effective Date: 7/1/2008 Revision Date: 1/7/2009 Wepor Proug requires all producers, producers in training, and service staff, including but not limited to: account executives, account managers, assistant account managers, service assistants, senior account managers, and junior account managers to be licensed in Kansas and Missouri.

Wepor Proug will cover the cost of up to the first three initial tests. If the employee fails to become licensed after the third test, further testing expense will be at the employees’ expense, and disciplinary action may be taken up to and including termination.

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E&O insurance coverage is required for all producers and service staff. Wepor Proug will pay for the first year for all producers. Renewal is at the producer’s expense, subject to each Producer’s employment agreement with Wepor Proug. Service staff E&O coverage will be covered by Wepor Proug.

106 Conflicts of Interest Effective Date: 7/1/2005 Revision Date: Employees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which Wepor Proug wishes the business to operate. The purpose of these guidelines is to provide a general direction so that employees can seek further clarification on issues related to the subject of acceptable standards of operation.

Contact a Company Officer for more information or questions about conflicts of interest.

An actual or potential conflict of interest occurs when an employee is in a position to influence a decision that may result in a personal gain for that employee or for a relative as a result of Wepor Proug’s business dealings. For the purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the employee is similar to that of persons who are related by blood or marriage.

One case in which personal gain may result is when an employee or relative has a significant ownership in a firm with which Wepor Proug does business. Another case is when an employee or relative receives any kickback, bribe, substantial gift, or special consideration as a result of any transaction or business dealing involving Wepor Proug.

No “presumption of guilt” is created by the mere existence of a relationship with outside firms. However, if employees have any influence on transactions involving purchases, contracts, or leases, it is imperative that they disclose to an officer of Wepor Proug the existence of any actual or potential conflict of interest as soon as possible. Safeguards can then be established to protect all parties.

Outside Employment Employees may hold outside jobs as long as they meet the performance standards of their job with Wepor Proug. All employees will be judged by the same performance standards and will be subject to Wepor Proug’ scheduling demands, regardless of any existing outside work requirements.

If Wepor Proug determines that an employee’s outside work interferes with job performance, the employee may be asked to terminate the outside employment if he or she wishes to remain with Wepor Proug. Outside employment that constitutes 8

a conflict of interest is prohibited. Employees may not receive any income or material gain from individuals outside Wepor Proug for materials produced or services rendered while performing their jobs. Employees should use special and extraordinary care in abiding by this provision.

107 Performance Appraisals Effective Date: 7/1/2005 Revision Date: It is the policy of Wepor Proug to encourage the growth and development of employees by periodical review of their progress through formal and informal appraisals. Supervisors and employees are strongly encouraged to guide, counsel, and evaluate their personnel in a manner that will result in increased effectiveness and greater job satisfaction to the employee.

A formal written performance appraisal will be conducted annually to include goal setting and performance evaluation. Additional performance appraisals may be conducted to provide both supervisors and employees the opportunity to discuss job tasks, identify and correct weaknesses, encourage and recognize strengths, and discuss positive, purposeful approaches for meeting goals.

108 Drug and Alcohol Use Effective Date: 7/1/2005 Revision Date: 7/15/2008 Wepor Proug is committed to being a drug-free, healthful, and safe workplace.

Employees are required to come to work in a mental and physical condition that will allow adequate performance of work-related functions.

Wepor Proug employees may not use, possess, distribute, sell, or be under the influence of alcohol or illegal drugs while on Wepor Proug premises or while conducting any business-related activity away from Wepor Proug grounds.

Employees may use legally prescribed drugs on the job only if they do not impair ability to perform the essential job functions without fear of endangerment. As a drug-free workplace, Wepor Proug employees involved in an accident may be required to take a drug test.

Violation of this policy may lead to disciplinary action, up to and including immediate termination of employment in addition to possible legal ramifications. Wepor Proug may also require participation in a substance abuse rehabilitation or treatment program.

Questions and/or issues regarding this policy should be directed to a Company Officer without fear of reprisal.

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Company Events While attending company sponsored events or activities (Wepor Proug Events), Wepor Proug employees and their guests must abide by all applicable local, state and federal laws with regard to consumption of alcohol. In the United States, anyone under the age of 21 is prohibited from drinking alcohol.

If you choose to drink, please drink responsibly and realize that Wepor Proug is not liable for your actions. Driving with a blood alcohol concentration (“BAC�) of or in excess of .08% is illegal in the states of Missouri and Kansas. Your blood alcohol level may be affected by your age, gender, and physical condition, amount of food consumed and any drugs or medication that may be in your system. Also, even your emotional state may impact the amount of alcohol you may safely consume without impairing your physical and mental abilities.

As already stated all employees are responsible for their choices and behavior regarding alcohol. Employees who plan to drink must provide a designated driver or another form of transportation.

SECTION 2: Federal Rights

201 Equal Employment Opportunity Effective Date: 7/1/2005 Revision Date: 10/17/2008

In order to provide equal employment and advancement opportunities to all individuals, employment decisions at Wepor Proug are based on merit, qualifications, and abilities. Wepor Proug does not discriminate on the basis of race, color, citizenship status, religion, creed, gender, sexual orientation, national origin, ancestry, age, physical or mental disability, marital status, veteran status, political affiliations, or any other characteristic protected by law.

Wepor Proug will make reasonable accommodations for qualified individuals with known disabilities unless doing so would result in an undue hardship. This policy governs all aspects of employment, including selection, job assignment, compensation, discipline, termination, and access to benefits and training.

Any employees with questions or concerns about any type of discrimination in the workplace are encouraged to bring these issues to the attention of their immediate supervisor, or a Company Officer. Any third party (client, vendor, or member of general public) with a complaint of discrimination will be directed to report their concerns to a Company Officer. Both employees and third parties can raise concerns and make reports without fear of reprisal. All incidents of prohibited discrimination that are reported will be investigated. Anyone found to be engaging in any type of unlawful discrimination will be subject to disciplinary action, up to and including termination of employment.

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202 Immigration Law Compliance Effective Date: 7/1/2005 Revision Date: Wepor Proug is committed to employing only those individuals who are United States citizens or who are legal aliens authorized to work in the United States. We do not illegally discriminate because of a person’s citizenship or national origin.

We comply with the Immigration Reform and Control Act of 1986, which requires every new employee at Wepor Proug to complete the Employment Eligibility Verification Form I-9 and show documents that prove identity and employment eligibility.

If employees of Wepor Proug are rehired, another Form I-9 must be completed if one of the following criteria is met: • the previous I-9 with Wepor Proug is more than three years old • the original I-9 is not accurate anymore, • the original I-9 is no longer available Should questions arise that have not been addressed within this manual, or if further information on the immigration laws is requested, employees may contact a Company Officer without fear of reprisal.

203 HIPAA Effective Date: 7/1/2005 Revision Date: The Health Insurance Portability and Accountability Act of 1996 (HIPAA) was signed into law on August 21, 1996 to limit exclusions for preexisting conditions; prohibit discrimination against employees and dependents based on their health status; guarantee renew-ability and availability of health coverage to certain employers and individuals; and protect many workers who lose health coverage by providing better access to individual health insurance. Since insurance carriers typically handle HIPPA rules and regulations, please see the Plan Administrator for more details.

HIPAA Special Enrollment (Federal Register Section 54.9801-6T) The special enrollment rights apply without regard to the dates on which an individual would otherwise be able to enroll under the plan. Special Enrollment periods apply to the following: • Employee • Employee Spouses • Employee Child(ren) • Employee Dependent(s)

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Under these rules, a group health plan is required to provide a special enrollment period for these individuals should they request enrollment within 30 days after a special enrollment event has occurred.

HIPAA Special Enrollment for Declining Enrollment If a written statement provided by the employee indicates that the reason for declining enrollment in Wepor Proug’s plan is coverage under another group health plan or health insurance coverage, then special enrollment right may apply to that employee and their dependents (including spouse) in the event of a loss of coverage or eligibility.

HIPAA Annual Open Enrollment Wepor Proug’s plan may offer an Annual Open Enrollment giving employees that had previously declined enrollment the opportunity to enroll in the group health plan.

In order to obtain enrollment forms and additional information about Wepor Proug’s benefit plans please contact the Plan Administrator and/or a Company Officer.

204 ERISA Effective Date: 7/1/2005 Revision Date: As a participant of Wepor Proug’s plan, employees are entitled to certain rights and protections under the Employee Retirement Income Security Act of 1974 (ERISA).

ERISA provides that all plan members shall be entitled to

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• •

Receive information about the group health plan and benefits.

•

Obtain copies of all plan documents and other plan information, including insurance contracts and collective bargaining agreements, and copies of the latest annual report, and updated summary plan description, by writing to the plan administrator. The plan administrator may make a reasonable charge for copies.

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Receive a summary annual report of the plan’s financial activities. The plan administrator is required by law to furnish each participant with a copy of this summary annual report.

Examine, without charge at the plan administrator’s office and other specified worksites, all plan documents — including pertinent insurance contracts, trust agreements, collective bargaining agreements, annual reports, and other documents filed with the Internal Revenue Service or the U.S. Department of Labor. Document examination is also available at the Public Disclosure Room of the Pension and Welfare Benefit Administration.

In addition to creating rights for plan members, ERISA imposes duties upon those individuals who are responsible for the operation of the employee benefit plan.

Individuals operating the plan, called “fiduciaries” of the plan, have a duty to do so

prudently and in the interest of employees, other plan members, and beneficiaries.

No one, including Wepor Proug, may terminate employees, or otherwise discriminate, to prevent any one from obtaining a welfare benefit or exercising individual rights under ERISA. If claims for a welfare benefit are denied in whole or in part, employees must receive a written explanation of the reason for denial. All employees have a right to have the plan reviewed and the claim reconsidered.

Should employees have additional questions about Wepor Proug’s plan, contact the Plan Administrator. If employees have additional questions regarding this statement or about individual rights under ERISA, contact the nearest Area Office of the U.S. Labor-Management Services Administration, Department of Labor.

205 Disability Accommodations Effective Date: 7/1/2005 Revision Date: Americans with Disabilities Act (ADA) Wepor Proug is committed to complying fully with the Americans with Disabilities Act (ADA) and ensuring equal opportunity in employment for qualified persons with disabilities. As such, all employment practices and activities are conducted on a non-discriminatory basis.

Hiring procedures have been reviewed and provide persons with disabilities meaningful employment opportunities. Pre-employment inquiries are made only regarding an applicant’s ability to perform the duties of the position.

In cases where a disability affects the employee’s performance of job functions, reasonable accommodation is available. All employment decisions are based on the merits of the situation in accordance with defined criteria, not the disability of the individual.

Qualified individuals with disabilities are entitled to equal pay and other forms of compensation (or changes in compensation) as well as in job assignments, classifications, organizational structures, position descriptions, lines of progression and seniority lists. Leave of all types will be available to all employees on an equal basis.

Wepor Proug is also committed to not discriminating against any qualified employees or applicants because they are related to or associated with a person with a disability. Wepor Proug will follow any state or local law that provides individuals with disabilities greater protection than the ADA. This policy is neither exhaustive nor exclusive. Wepor Proug is committed to taking all other actions necessary to ensure equal employment opportunity for persons with disabilities in accordance with the ADA and all other applicable federal, state, and 13

local laws. If an employee feels that they have been unlawfully discriminated against, immediately inform a Company Officer. Please be assured that complaints will be thoroughly investigated and retaliatory action will not be taken.

Life-Threatening Illnesses Employees with life-threatening illnesses, such as cancer, heart disease, and AIDS, often wish to continue their normal pursuits, including work, to the extent allowed by their condition. Wepor Proug fully supports these endeavors as long as employees are able to meet acceptable performance standards. As in the case of other disabilities, Wepor Proug will make reasonable accommodations in accordance with all legal requirements, to allow qualified employees with life-threatening illnesses to perform the essential functions of their jobs.

Medical information on individual employees is treated confidentially. Wepor Proug will take reasonable precautions to protect such information from inappropriate disclosure. Managers and other employees have a responsibility to respect and maintain the confidentiality of employee medical information. Anyone inappropriately disclosing such information is subject to disciplinary action, up to and including termination of employment.

Employees with questions or concerns about life-threatening illnesses are encouraged to contact a Company Officer for information and referral to appropriate services and resources. If an employee feels that they have been unlawfully discriminated against, immediately inform a Company Officer. Please be assured that complaints will be thoroughly investigated and retaliatory action will not be taken.

206 Military Leave Effective Date: 7/1/2005 Revision Date: Wepor Proug will grant a military leave of absence to employees serving in the U.S. Uniformed Services in accordance with the Uniformed Services Employment and Reemployment Rights Act (USERRA). Employees must give supervisor advance notice of upcoming military service, unless military necessity prevents advance notice or it is otherwise impossible or unreasonable.

Employees will not be paid for military leave. However, employees may use any available accrued paid time off, such as vacation or sick leave, to help pay for the leave.

The availability of continuation of health insurance benefits is made available through USERRA. Benefit continuation is based upon the length of the leave and subject to the terms, conditions and limitations of the applicable plans for which employees are otherwise eligible.

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If on military leave for up to 30 days, employees must return to work on the first regularly scheduled work period after the end of service (allowing for reasonable travel time). If on military leave for more than 30 days, employees must apply for reinstatement in accordance with USERRA and applicable state laws.

When returning from military leave (depending on the length of military service in accordance with USERRA), employees will be placed either in the original position that would have been attained if there had been continuous employment, or in a comparable position. For the purpose of determining benefits that are based on length of service, all employees will be treated as though there was no lapse of employment.

If employees have questions about military leave, contact a Company Officer for more information.

207 Sexual and Other Unlawful Harassment Effective Date: 7/1/2005 Revision Date: 10/17/2008 It is the policy of this Company that all employees shall have the right to work in an environment free from any form of unlawful discrimination or harassment. All personnel are reminded that each employee, client, vendor, and member of the general public is at all times to be treated courteously and in a manner so that he or she is free from harassment or interference based on factors such as race, color, sex, gender, religion, age, national origin, disability, pregnancy status, veteran status, sexual orientation, or any other protected status. A violation of this policy will result in disciplinary action, up to and including termination.

Sexual Harassment is a form of harassment constituted as discrimination and is prohibited by state and federal laws. The position of this company is that sexual harassment will not be tolerated. It is a violation of company policy for any supervisor or employee, male or female to engage in sexual harassment as defined below. Such conduct will result in disciplinary action up to and including termination.

The Equal Employment Opportunity Commission (EEOC) defines sexual harassment as follows: Quid Pro Quo - Unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature constitute quid pro quo when (1) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment and, or (2) submission or rejection of such conduct by an individual is used as the basis for employment decisions affecting an individual.

Hostile Environment - Is one which unwelcome sexual advances, requests for sexual favors and verbal or other conduct of a physical nature occur and when such 15

conduct has the purpose or effect of unreasonably interfering with an individuals work performance or creating an intimidating, hostile, or offensive work environment.

Some examples of sexual harassment include but are not limited to:

• • •

Unwanted sexual advances

•

Visual conduct such as leering, making sexual gestures, or displaying sexually suggestive objects, pictures, cartoons, or posters

•

Verbal conduct such as making derogatory comments, epithets, slurs, sexually explicit jokes or comments about an employee’s body or dress

• •

Verbal sexual advances or propositions

•

Physical conduct such as touching, assault or impeding or blocking movement and Retaliation for reporting harassment or threatening to report harassment

Offering employment benefits in exchange for sexual favors Making threatening reprisals after a negative response to sexual advances

Verbal abuse of a sexual nature, graphic verbal commentary about an individuals body, sexually degrading words to describe an individual or suggestive or obscene letters, notes or invitations

207 Sexual and Other Unlawful Harassment (Continued) Any employee who believes he/she has experienced or has witnessed harassing conduct by anyone, including a supervisor, co-worker or by persons doing business with or for this company should tell the offender that such conduct is unwelcome and unacceptable. If the offensive behavior does not stop, or if the employee is uncomfortable confronting the offender, the employee must immediately report such conduct to their supervisor or to one of the Company Compliance Officers listed below: Rhonda McNeece Daniel Laskero Female Representative Male Representative This company prohibits retaliation against any employee who complains of harassment or who participates in an investigation. All aspects of the complainthandling procedure will be handled discreetly. However, it may be necessary to include others on a need to know basis.

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Any third party (client, vendor, or member of general public) with a complaint of harassment will be directed to follow the same reporting procedure as outlined above. All incidents of prohibited harassment that are reported will be investigated.

The Compliance officers listed above will immediately undertake or direct an effective, thorough, and objective investigation of the harassment allegations.

The investigation will be completed as soon as practicable and a determination regarding the reported harassment will be made and communicated to the employee or third party who complained and to the accused harasser. If a complaint of prohibited harassment is substantiated, appropriate corrective action, up to and including discharge, will be taken. Appropriate action will also be taken to correct the effects of the harassment and to deter any future harassment.

By signing below, employees acknowledge that they have read the above harassment policy and will comply with all of its provisions.

Employee Signature _________________________________________________ Date _______________________________________________________________

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SECTION 3: Rules and Conduct 301 Employee Work Rules Effective Date: 7/1/2005 Revision Date: Wepor Proug expects all employees to follow certain work rules and conduct oneself in ways that protect the interests and safety of all employees.

While it is impossible to list every action that is unacceptable conduct, the following lists some examples of behavior to avoid. Employees who break work rules such as these may be subject to disciplinary action, up to and including termination of employment:

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• • • •

Theft or inappropriate removal or possession of property

• • •

Fighting or threatening violence in the workplace

• • • • •

Insubordination or other disrespectful conduct

• • •

Excessive absenteeism or any absence without notice

• • •

Unauthorized disclosure of business “secrets” or confidential information

Falsification of timekeeping records Working under the influence of alcohol or illegal drugs Possession, distribution, sale, transfer, or use of alcohol or illegal drugs in the workplace, while on duty, or while operating employer-owned vehicles or equipment

Boisterous or disruptive activity in the workplace Negligence or improper conduct leading to damage of employer-owned or client-owned property

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 or firearms, in the workplace

Unauthorized absence from work station during the workday Unauthorized use of telephones, mail system, or other employer-owned equipment

Violation of personnel policies Unsatisfactory performance or conduct

Employment with Wepor Proug is voluntary and at will. As such, employees may terminate employment at any time, with or without cause or advance notice. Likewise, Wepor Proug may terminate employment at any time, with or without cause or advance notice.

302 Business Ethics and Conduct Effective Date: 7/1/2005 Revision Date: The successful business operation and reputation of Wepor Proug is built upon the principles of impartial dealing and ethical conduct of our employees. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as regard for the highest standards of conduct and integrity.

The continued success of Wepor Proug is dependent upon our clients’ trust and we are dedicated to preserving that trust. Employees owe a duty to Wepor Proug, its clients, and shareholders to act in a way that will merit the continued trust and confidence of the public.

Wepor Proug will comply with all applicable laws and regulations and expects its directors, officers, and employees to conduct business in accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest, or unethical conduct.

In general, the use of good judgment based on high ethical principles will serve as a guide with respect to lines of acceptable conduct. If a situation arises in which it is difficult to determine the proper course of action, the matter should be discussed openly with an immediate supervisor and, if necessary, with a Company Officer for advice and consultation.

Compliance with this policy of business ethics and conduct is the responsibility of every Wepor Proug employee. Disregarding or failing to comply with this standard of business ethics and conduct could lead to disciplinary action, up to and including possible termination of employment.

303 Progressive Discipline Effective Date: 7/1/2005 Revision Date: The purpose of this policy is to state Wepor Proug’s position on administering equitable and consistent discipline for unsatisfactory conduct in the workplace. The best disciplinary measure is the one that does not have to be enforced and comes from good leadership and impartial supervision at all employment levels.

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Wepor Proug’s own best interest lies in ensuring impartial treatment of all employees and in making certain that disciplinary actions are prompt, uniform, and impartial.

The major purpose of any disciplinary action is to correct the problem, prevent recurrence, and prepare the employee for satisfactory service in the future.

Although employment with the Company is based on mutual consent and both the employee and employer have the right to terminate employment at will, with or without cause or advance notice, Wepor Proug may use a progressive discipline at its discretion.

Disciplinary action may call for any of four steps -- verbal warning, written warning, suspension with or without pay, or termination of employment -- depending on the severity of the problem and the number of occurrences. There may be circumstances when one or more steps are bypassed.

Progressive discipline means that, with respect to most disciplinary problems, these steps will normally be followed: a first offense may call for a verbal warning; a next offense may be followed by a written warning; another offense may lead to a suspension; and, still another offense may then lead to termination of employment.

The Company recognizes that there are certain types of employee problems that are serious enough to justify either a suspension, or, in extreme situations, termination of employment, without going through the usual progressive discipline steps.

By using progressive discipline, we hope that most employee problems can be corrected at an early stage, benefiting both the employee and Wepor Proug.

304 Personal Appearance Effective Date: 7/1/2005 Revision Date: 2/1/2010 During business hours or when representing Wepor Proug, each employee is expected to dress professionally, regardless of if one’s job involves dealing with clients or visitors in person. It is management’s intent that work attire should complement an environment that reflects an efficient, orderly, and professionally operated organization. This policy is intended to define appropriate “business attire” during normal business operations and “casual business attire” on Fridays.

Business attire is to be worn Monday through Thursday, and on Fridays when meeting with clients. There may be times when a client is coming in to the office on a Friday, in which case professional attire will take precedence over business casual.

Appropriate business attire for employees include the following:

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Men: • Blazers, suits, or sport coats • Dress slacks • Ties • Dress shirts with buttons and collars • Dress shoes Women: • Dresses • Skirts • Dress slacks • Blouses • Dress shoes • Sweaters • Cardigans • Nylons or stockings *Please note that all attire must be of an appropriate and acceptable length.

(Ultimate discretion is up to management.)

There will be certain appointed days when a more relaxed dress code will be proper.

For example, employees participating in the Denim Dollars Program may wear jeans on Fridays as deemed appropriate (see Policy 611 Additional Benefits - Charitable Donations). Wepor Proug may, at its discretion, establish a more stringent dress code, as it deems appropriate; client or third party perception shall play an integral part of such discretion.

The key point to sustaining an appropriate business casual attire program is the use of common sense and good judgment, and applying a dress practice that Wepor Proug deems conductive to our business environment. If you question the appropriateness of the attire, it probably isn’t appropriate. Unacceptable business casual attire includes, but is not limited to, the following:

• • • • • • • • • • • •

Plain or pocket T-shirts T-shirts with logos Athletic wear Sweatshirts Thongs/flip-flops of any kind Tennis shoes Tank tops, tube tops, halter tops with spaghetti straps Midriff length tops Provocative attire Off-the-shoulder tops Workout clothes or shoes Hats of any kind (including baseball caps, fedoras, etc.)

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Department leads and supervisors are responsible for monitoring and enforcing this policy. If an employee’s personal appearance is inappropriate, they may be asked to leave work and return properly dressed and groomed. In such an event, the employee will not be compensated for the time away from work. Anyone unclear about correct clothing standards should consult a Company Officer.

Where necessary, Wepor Proug may make a reasonable accommodation to this policy for a person with a disability.

Wepor Proug reserves the right to rescind and/or amend this, and all company policies, at any time.

305 Attendance and Punctuality Effective Date: 7/1/2005 Revision Date: 1/21/2009 In order to maintain a safe and productive work environment, Wepor Proug expects employees to be reliable and punctual in reporting to work as scheduled.

Absenteeism and tardiness place a burden on other employees and on the Company.

Poor attendance and excessive tardiness are disruptive; either may lead to disciplinary action, up to and including termination. If employees have advance notice of their need to be absent, employees should request time off directly from their Supervisor, while also notifying the Controller. In the rare instance when employees cannot avoid being late to work or are unable to work as scheduled, notification should be given to the front desk Receptionist and immediate Supervisor as soon as possible in advance of the anticipated tardiness or absence.

Absence for three (3) consecutive days without notifying a direct Supervisor, Business Manager, or Company Officer will be considered a voluntary resignation.

If absent because of an illness for more than three (3) days, the direct Supervisor, Controller, or Company Officer may request that a form is submitted by a doctor stating the employee is unable to resume normal work duties. The employee will be advised of their rights under the Family and Medical Leave Act (FMLA) and directed on how to request FMLA Leave for approval (see Policy 605 Family and Medical Leave).

A consistent pattern of questionable absences can be considered excessive, and may be cause for concern. In addition, excessive lateness or leaving early without alerting a direct Supervisor, Business Manager, or Company Officer will be considered a “lateness pattern� and may carry the same weight as an absence. It is understandable that, from time to time, emergencies, illnesses, or pressing personal business may arise that cannot be scheduled outside work hours. Paid time off (PTO days) has been provided for this purpose.

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306 Personal Property Effective Date: 7/1/2005 Revision Date: Wepor Proug cannot be responsible for losses of personal property that is lost, damaged or stolen. If bringing personal or company property/items/belongings into the office, employees are individually responsible for keeping track of them.

Those bringing personal property into the workplace must understand that it will not be covered under the Company’s insurance. Additionally, because of limitations on personal homeowners’ policies with business property away from the home premises, it may not be covered under homeowner’s coverage either.

Wepor Proug prohibits any items on the premises or worksite that are sexually suggestive, offensive, or demeaning to specific individuals or groups, along with firearms or other weapons. Employees should understand that all personal property brought onto the employer’s premises may be inspected for purposes of enforcing the organization’s policies and to protect against theft.

307 Travel & Business Expenses Effective Date: 7/1/2005 Revision Date: 1/7/2009 Non-Commissioned Employees It is the practice of Wepor Proug to reimburse non-commissioned employees for payment of travel fares and normal daily expenses in association with business conduct. This policy shall apply to local and out-of-town expenses.

Reimbursement of approved travel expenses include, but are not limited to the following categories: meals, lodging, and other expenses as long as they are necessary to meet the objectives of the trip. Reimbursement for mileage incurred during business travel will be reimbursed. Travel reimbursement for mileage in excess of 250 miles, will require advance approval from a direct supervisor. Please see the Controller for the current rate. You are expected to keep expenses within reasonable limits.

When a business trip is over, submit your completed travel expense report within 30 days. Travel expenses submitted in excess of 90 days will require a direct Supervisor signature prior to reimbursement. With your expense report, you must also submit receipts for every expense item. Please see your Supervisor if you require additional assistance regarding business travel, expense reports, or any other travel issues.

If you are involved in an accident while on business travel, immediately report the accident to your supervisor. If you use a vehicle owned, leased, or rented by Wepor 23

Proug, you may not use that vehicle for personal reasons unless you received advance approval.

It is a very serious matter if you record false or misleading information on your expense report. You may not request reimbursement for expenses that you did not have or that were not business-related. Employees who do not follow this business travel policy could be subject to disciplinary action, up to and including termination of employment.

Commissioned Employees It is not the practice of Wepor Proug to reimburse commissioned employees for payment of travel fares and normal daily expenses in association with business conduct. This practice is subject to each commissioned employee’s employment agreement.

308 Gifts Effective Date: 7/1/2005 Revision Date: Gifts may be subject to taxation; as a result, advance approval from management is required before an employee may accept or solicit a gift of any kind from a client, supplier or vendor representative.

309 Overtime Effective Date: 7/1/2005 Revision Date: When operating requirements or other needs cannot be met during regular working hours, employees will be given the opportunity to volunteer for overtime work assignments. All overtime work must receive the Supervisor’s prior authorization.

Overtime assignments will be distributed as equitably and practical as possible to all employees qualified to perform the required work.

Overtime compensation is paid to all non-exempt employees in accordance with federal and state wage and hour restrictions. Overtime pay is based on actual hours worked. Time off for holidays, on sick leave, vacation leave, or any leave of absence will not be considered hours worked for purposes of performing overtime calculations.

Holiday Policies “Non-exempt” employees, those employees who are eligible for overtime pay in accordance with the Fair Labor Standards Act, who work on a company holiday are considered to have worked overtime on that day and will be paid overtime for hours worked, regardless of the number of hours worked during that same work week.

Again, all overtime must be approved in advance by an immediate Supervisor.

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310 Personal Automobile Effective Date: 7/1/2005 Revision Date: 1/7/2008 Non-Commissioned Employees It is the practice of Wepor Proug to reimburse non-commissioned employees for mileage incurred in a personal automobile that is in association with business conduct. The Company will issue reimbursements based upon actual miles driven multiplied by the rate established by Wepor Proug. Please see the Controller for the current rate. This is expected to completely compensate for gasoline mileage, wear and tear, and insurance costs associated with the business use of the vehicle. Travel reimbursement for mileage in excess of 250 miles, will require advance approval from a direct Supervisor.

Commissioned Employees It is not the practice of Wepor Proug to reimburse commissioned employees for payment of travel fares and normal daily expenses in association with business conduct, subject to each commissioned employee’s employment agreement.

All Employees Wepor Proug is not responsible for any damage incurred to personal automobiles while on Company business.

311 Problem Resolution Effective Date: 7/1/2005 Revision Date: Wepor Proug is committed to providing the best possible working conditions for its employees. Part of this commitment is to encourage an open and frank atmosphere in which any problem, complaint, suggestion, or question receives a timely response from supervisors and management. Wepor Proug strives to ensure impartial and honest treatment of all employees. Supervisors, managers, and employees are expected to treat each other with mutual respect. Employees are encouraged to offer positive and constructive criticism.

If employees disagree with established rules of conduct, policies, or practices, they can express their concern through the problem resolution procedure. No employee will be penalized, formally or informally, for voicing a complaint with the company in a reasonable, business-like manner, or for using the problem resolution procedure.

If a situation occurs when employees believe that a condition of employment or a decision affecting them is unjust or inequitable, they are encouraged to make use of the following steps. The employee may discontinue the procedure at any step.

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1.

Employee presents problem to immediate Supervisor after incident occurs. If Supervisor is unavailable or employee believes it would be inappropriate to contact that person, employee may present problem to a Company Officer or any other member of management.

2.

Supervisor responds to problem during discussion or after consulting with appropriate management, when necessary. Supervisor will document the discussion.

3.

Employee presents problem in writing to a Company Officer if problem is unresolved.

4.

Company Officer counsels and advises employee, assists in putting problem in writing, and visits with employee’s manager(s), if necessary.

Not every problem can be resolved to everyone’s total satisfaction, but only through understanding and discussion of mutual problems can employees and management develop confidence in each other. This confidence is important to the operation of an efficient and harmonious work environment.

312 Return of Property Effective Date: 7/1/2005 Revision Date: 10/17/2008 Wepor Proug may loan property, materials or written information to help improve the performance of essential job functions. Employees are responsible for protecting and controlling any Company property on loan.

Should an employee with Wepor Proug belongings be terminated, they will be asked to return all Company property promptly. If property is not returned in a timely manner, legal action may be taken if permissible.

313 Personnel Data Changes Effective Date: 7/1/2005 Revision Date: 10/17/2008 It is the policy of Wepor Proug to keep accurate and updated information pertinent to your employment in personnel files. For that reason, you have a personnel file that contains your application, performance reviews, benefits forms and payroll information. Wepor Proug strives to maintain these files in the strictest confidence.

Additionally, there is a separate confidential file for all medical related information such as group health care, workers’ compensation medical information, or medical information obtained from any physical exam or physician prognosis. A third files containing Form I-9 and related documentation establishing your right to work in this country; will also be maintained in a separate confidential file.

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Common examples of times in which Wepor Proug must be notified include, but are not limited to, changes to:

• • • • • • • • • • • •

Mailing address Telephone number (home, Mobile, etc.)

Name Marital status Filing status Dependents’ information Educational accomplishments Birth/Adoption Reduction in work hours Medicare entitlement Disability Emergency contact information

Employees are to have reasonable access to personnel, medical, I-9 and safety records during business hours. Employees may make copies at their own expense.

Personnel records may be accessed by supervisors and other authorized employees only in the course of employment. Access to medical and/or immigration records will be provided to supervisors and other employees only on a need to know basis in accordance with applicable laws. All employees with access to personnel files will be required to sign a confidentiality agreement prior to access.

Should an employee have a change in information, or if there are questions about what information is required, contact the Controller or Company Officer.

SECTION 4: Safety and Security 401 Safety Effective Date: 7/1/2005 Revision Date: The safety of Wepor Proug employees is a matter taken very seriously. In attempt to maintain a safe and healthy environment for employees, clients, and visitors, Wepor Proug holds workplace safety as a top priority.

There is regular communication with employees about workplace safety and health issues. These communications may include supervisor-employee meetings, bulletin board postings, memos, or other written communications.

A successful safety program depends on everyone being alert and committed to safety. The cooperation of every employee is necessary in making this company a safe place in which to work. Should employees become aware of an unsafe condition, please report it immediately to a Company Officer. Any willful or habitual 27

violation of safety rules will be subject to disciplinary action, up to and including termination. Violations include, but are not limited to: • Causing a hazardous or dangerous situation • Failure to report a hazardous or dangerous situation • Failure to correct a problem (if within power) As an employee of Wepor Proug, individuals have certain rights regarding the use of hazardous materials in the workplace. Employees may request information regarding the following:

1.

2.

3.

4.

5.

What chemicals are used in the workplace? (MSD Sheets) Where the chemicals are located.

Physical and health hazards associated with the chemicals.

Protection measures that must be taken to prevent exposure.

What to do in case of exposure to the chemicals.

For additional information on hazardous materials in the workplace consult a Company Officer.

402 First Aid Effective Date: 7/1/2005 Revision Date: In the event of a life threatening emergency, call 911. If an accident or illness should occur, no matter how slight, notify a Company Officer immediately so that appropriate medical treatment can be administered. With the number of reported cases of AIDS and other blood borne pathogens continuing to rise, it is imperative that employees take extreme care in case of an accident, both on and off the job.

The transfer of any body fluid (blood, saliva, urine, etc.) may pass on a blood borne pathogen. Use caution to avoid contact with these body fluids. Each first aid kit contains plastic gloves, please be sure to use them. If this is not possible, use a strong disinfectant, to clean up afterwards. The first aid kit is kept in the reception area at the front desk.

On the job injuries will be handled in accordance with Workers’ Compensation laws. Any employee who is injured while on the job must notify a Company Officer immediately to be eligible for coverage provided under our Workers’ Compensation policy. As part of a Drug Free Work Place program, employees may also be required to submit to drug testing if injured on the job.

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403 Emergency Procedures Effective Date: 7/15/2008 Revision Date: 9/1/2008 Purpose Proactively protect the health and safety of all Wepor Proug employees.

Practice We recognize that our people drive our business. As our most critical resource, employees are safeguarded through training, provision of appropriate work surroundings, and procedures that foster protection of health and safety. No duty, no matter what its perceived result, is more important than employee health and safety.

General Guidelines in an Emergency Stay calm and think through your actions.

Know important emergency numbers:

• • • • •

Fire/Police/Ambulance 9-1-1 Chief Operating Officer (COO) 913-754-5944 Business Manager 913-754-5910 Operator 0 or page for help

Be aware of your surroundings.

•

Know where exits are located. There are two building exits on the floor of Wepor Proug’s Office. The main exit is located on the West side of the building and the other exit is located on the South side of the building.

• •

In the event of any emergency, do not take elevators, use only stairs.

Do not hesitate to call/alert others if you believe that an emergency is occurring.

In Case of Fire Evacuation:

•

Employees are notified of a fire by either the fire alarm system or paged announcement.

•

Upon hearing the alarm, immediately evacuate the building using the closest exit, do not use the elevators. Do not delay evacuation to get your coat, personal belongings, finish a phone call, or wait for friends.

•

Notify Emergency Floor Leaders or their backups.

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Floor Leaders/Backups:

• •

Floor Leader: Mike Woods; Backup: Dan Laskero

•

Any employee having mobility, visual, hearing, or other conditions that may hinder them from becoming aware of an emergency or evacuation, should disclose their condition to the COO or Business Manager at the time of hire so that special assistance can be rendered at time of emergency.

•

Upon exiting the building, report to the corner of 127th and Metcalf for headcount confirmation by the Emergency Floor Leaders.

•

If any employee or known guest/visitor is missing, immediately report the missing person’s name to an Emergency Floor Leader who will in turn report it to the proper company and civil authorities.

•

All employees who are not members of a response team should stay together in the location deemed appropriate, so periodic updates on the situation can be communicated. Do not go home, wait in your car, return to the building, or go to another building unless directed by an Emergency Floor Leader to do so.

Emergency Floor Leaders should be the last persons to leave the area.

Floor Leaders should check in conference rooms, lavatories, and offices to be sure all employees have evacuated. All doors should be closed after the Floor Leader clears an area.

If you discover a fire:

• •

Alert other persons in the immediate hazard area.

•

If you have been trained to use a fire extinguisher, following these instructions:

•

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Activate the nearest fire alarm, call 911, call the receptionist, and/or page an emergency announcement.

-

Pull the safety pin

-

Aim the nozzle at the base of the fire

-

Squeeze the operating lever

-

Sweep side to side, covering the base of the fire

When using a fire extinguisher, always stay between the fire and an exit.

Never feel that using a fire extinguisher is required. If the fire is too hot, too smoky, or you are frightened, evacuate immediately.

Medical Emergency

• • •

Upon discovering a medical emergency, call 9-1-1.

•

Send one person to alert a Company Officer so they can notify family members of the ill/injured person.

•

Employees in the immediate vicinity of the emergency, but not involved in the emergency effort, should leave the area.

Call the receptionist or page an emergency announcement.

Stay with the ill/injured person. Be careful not to come into contact with any bodily fluids unless properly trained and protected.

Severe Weather

•

In the event severe weather conditions occur at a time when you have not yet reported to work (or are not at work), you should report to work unless otherwise notified, if able to do so safely.

•

The receptionist will monitor a weather alert radio. If a severe weather warning is issued, (s)he will immediately page an announcement:

•

Employees should immediately seek shelter in the main hallways or exit stairways away from all windows. Employees can also seek shelter in the men’s and women’s restrooms off the main hallway on the first floor of the building.

•

The receptionist will take the weather radio with him/her. When the severe weather warning is cancelled, (s)he will send Emergency Floor Leaders to each shelter area to advise that it is safe to return to office areas. The receptionist will also make a general announcement over the paging system.

Workplace Violence

•

Any employee who feels that (s)he has been threatened should immediately report their concern to their Supervisor and the COO.

•

If you observe anyone exhibiting threatening behavior or making threatening statements, warn others in the area and immediately notify the COO. Stay away from the person exhibiting the threatening behavior.

•

Depending upon the level of concern, (9) 9-1-1 may be called immediately.

• •

Never attempt to confront any person exhibiting threatening behavior.

If you have reason to believe that events in your personal life could result in acts of violence occurring at work, you are strongly urged to confidentially discuss the issue with the COO or CEO so that a prevention plan can be developed.

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404 Security Inspections Effective Date: 7/1/2005 Revision Date: Wepor Proug wants to have a work environment that is free of illegal drugs, alcohol, firearms, explosives, or other improper materials. The possession, transfer, sale, or use of these materials on company premises is strictly prohibited.

Employees may be provided with desks, cabinets, and other storage devices for convenience, but these are always the sole property of Wepor Proug. As such items are company property, Wepor Proug may allow a representative or authorized agent to run inspections at any time, either with or without advance notice. The company also retains the right to inspect items found within company property.

Wepor Proug discourages theft and/or unauthorized possession of property belonging to employees, clients, visitors, and. the company itself. In order to guide the enforcement of this policy, inspection of persons entering and exiting the premises, packages entering and exiting the premises, and employees may be required. If employees wish to avoid having personal belongings inspected, please do not bring them to work.

405 Workplace Monitoring Effective Date: 7/1/2005 Revision Date: Wepor Proug may conduct workplace monitoring to help ensure quality control, employee safety, security, and client satisfaction. Employees who regularly communicate with clients may have their telephone conversations monitored or recorded. Telephone monitoring helps to identify training needs and performance problems.

All computer equipment, services, or technology furnished to employees are the property of the company. Wepor Proug reserves the right to monitor computer activities and data that is stored in or created by company computer systems.

Wepor Proug may perform video surveillance of non-private workplace areas for the sole purpose of identifying safety concerns, maintaining quality control, detection of theft and/or misconduct, and prevention of harassment and violence in the workplace.

In order to be sensitive to employees’ legitimate privacy rights, Wepor Proug will make every effort to guarantee workplace monitoring is done ethically and respectfully.

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SECTION 4: Computing & Telecommunications 501 Computer and Email Usage Effective Date: 7/1/2005 Revision Date: To aid in the efficiency and effectiveness of each employment position, Wepor Proug may give employees access to computers, computer files, the email system, and software. Computers, computer files, the e-mail system, and software furnished to employees are the property of the company and are intended for business use only. Employees should not use a password, access a file, or retrieve any stored communication without proper authorization. To ensure compliance with this policy, Wepor Proug retains the right to monitor all of its electronic and communication systems at its discretion.

Wepor Proug purchases and licenses the use of various computer software for business purposes and does not own the copyright to this software or its related documentation. Unless authorized by the software developer, Wepor Proug does not have the right to reproduce such software for use on more than one computer.

Employees may only use software on local area networks or on multiple machines according to the software license agreement. The company prohibits the illegal duplication of software and its related documentation.

Wepor Proug strives to maintain a workplace free of harassment and sensitive to the diversity of its employees. Therefore, the company prohibits the use of computers and the e-mail system in ways that are disruptive, offensive to others, or harmful to morale. For example, the display or transmission of sexually explicit images, messages, and cartoons is not allowed.

Other such misuse includes, but is not limited to, ethnic slurs, racial comments, off-color jokes, or anything that may be construed as harassment or showing disrespect for others. E-mail may not be used to solicit others for commercial ventures, religious or political causes, outside organizations, or other nonbusiness matters.

Employees should notify a Company Officer upon learning of violations of this policy. Employees who violate this policy will be subject to disciplinary action, up to and including termination of employment.

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502 Internet Usage Effective Date: 7/1/2005 Revision Date: Internet access to global electronic information resources on the World Wide Web is provided by Wepor Proug to assist employees in obtaining work-related data and technology. The following guidelines have been established to help ensure responsible and productive Internet usage.

All Internet data that is composed, transmitted, or received via our computer communications systems is considered to be part of the official records of Wepor Proug and, as such, is subject to disclosure to law enforcement or other third parties.

Consequently, employees should always ensure that the business information contained in Internet e-mail messages and other transmissions is accurate, appropriate, ethical, and lawful.

The equipment, services, and technology provided to access the Internet remain at all times the property of Wepor Proug. As such, Wepor Proug reserves the right to monitor Internet traffic, and retrieve and read any data composed, sent, or received through online connections and stored in company-owned computer systems.

Data that is composed, transmitted, accessed, or received via the Internet must not contain content that could be considered discriminatory, offensive, obscene, threatening, harassing, intimidating, or disruptive to any employee or other person. Examples of unacceptable content may include, but are not limited to, sexual comments or images, racial slurs, gender-specific comments, or any other comments or images that could reasonably offend someone on the basis of race, age, sex, religious or political beliefs, national origin, disability, sexual orientation, or any other characteristic protected by law.

The unauthorized use, installation, copying, or distribution of copyrighted, trademarked, or patented material on the Internet is expressly prohibited. As a general rule, if an employee did not create material, does not own the rights to it, or has not gotten authorization for its use, it should not be put on the Internet.

Employees are also responsible for ensuring that the person sending any material over the Internet has the appropriate distribution rights.

Abuse of the Internet access provided by Wepor Proug in violation of law or company policies will result in disciplinary action, up to and including termination of employment. Employees may also be held personally liable for any violations of this policy. The following behaviors are examples of previously stated or additional actions and activities that are prohibited and can result in disciplinary action up to and including termination:

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•

Sending or posting discriminatory, harassing, or threatening messages or images

• •

Using the organization’s time and resources for personal gain

•

Copying, pirating, or downloading software and electronic files without permission

•

Sending or posting confidential material, trade secrets, or proprietary information outside of the organization

• • •

Violating copyright law

•

Sending or posting messages or material that could damage the organization’s image or reputation

• • •

Participating in the viewing or exchange of pornography or obscene materials

• •

Refusing to cooperate with a security investigation

•

Using the Internet for political causes or activities, religious activities, or any sort of gambling

•

Jeopardizing the security of the organization’s electronic communications systems

•

Sending or posting messages that disparage another organization’s products or services

• • •

Passing off personal views as representing those of the organization

Stealing, using, or disclosing someone else’s code or password without authorization

Failing to observe licensing agreements Engaging in unauthorized transactions that may incur a cost to the organization or initiate unwanted Internet services and transmissions

Sending or posting messages that defame or slander other individuals Attempting to break into the computer system of another organization or person

Sending or posting chain letters, solicitations, or advertisements not related to business purposes or activities

Sending anonymous e-mail messages Engaging in any other illegal activities

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503 Telephones Effective Date: 7/1/2005 Revision Date: 10/17/2008 Wepor Proug is essentially a sales company and each employee should attempt to be as sales and service oriented as possible. Since many clients never meet employees in person, judgments are made by attitude, eagerness, willingness, and phone performance. Close attention to telephone courtesy and professionalism is critical to the success of Wepor Proug. The use of proper telephone etiquette can be demonstrated by: using the approved greeting, speaking courteously and professionally, repeating information back to the caller, and hanging up only after the caller hangs up.

To ensure that the use of Wepor Proug telephone systems is consistent with the company’s legitimate business interests, we retain the right for authorized representatives of the company to monitor the use of such equipment from time to time to determine if such use is business-related.

Personal Use When necessary, use of the office telephone for local personal calls is permitted. It is expected that employees will not abuse this privilege and be attentive to the time in which they engage in personal calls.

Personal long-distance calls charged to the company are strictly prohibited. All pass codes are the property of the company and no employee may use a pass code that has not been issued to them or that is unknown to the company. Should personal calls incur charges to Wepor Proug, they will be the individual’s responsibility.

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

Mobile or Cellular Use Wepor Proug prohibits the use of mobile or cellular telephones while driving an automobile. It is Wepor Proug’s policy that when using a mobile or cellular telephone while driving an automobile, such an employee shall pull to the side of the road while operating or using the phone. This policy also prohibits text messaging while driving an automobile. Any waiver shall not apply.

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SECTION 6: Benefits 601 Benefits Effective Date: 7/1/2005 Revision Date: 10/17/2008 Wepor Proug is committed to sponsoring a comprehensive benefits program for all eligible employees. In addition to receiving an equitable salary and having an equal opportunity for professional development and advancement, employees may be eligible to enjoy other benefits that will enhance job satisfaction. Benefits begin first of the month after date of hire.

A good benefits program is a solid investment in Wepor Proug’s employees. The company will periodically review the benefits program and will make modifications as appropriate to the company’s condition. Wepor Proug reserves the right to modify, add, or delete the benefits it offers.

Wepor Proug currently offers the following employee benefits for employees to participate in: Health, Dental, Life, Long Term Disability (LTD), Short Term Disability (STD), Flexible Spending Accounts (FSA), Employee Assistance Program (EAP), Retirement and various supplemental products including Vision.

A change in employment classification that would result in loss of eligibility to participate in the health insurance plan, may qualify an employee for benefits continuation under the Consolidated Omnibus Budget Reconciliation Act (COBRA).

Refer to the Benefits Continuation (COBRA) policy for more information.

Details of the insurance plans are described in the Summary Plan Description (SPD) for each benefit. A SPD and information on cost of coverage will be provided in advance of enrollment to eligible employees. Contact a Company Officer for more information about employee benefits.

602 Holiday Effective Date: 7/1/2005 Revision Date: 1/3/2011 Wepor Proug gives time off to all employees on the following holidays: New Year’s Day Friday, 12/31/10 Memorial Day Monday, 5/30/11 Independence Day Monday, 7/4/11 Labor Day Monday, 9/5/11 Thanksgiving Thursday, 11/24/11 Day after Thanksgiving Friday, 11/25/11 Christmas Day Friday, 12/23/11

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Wepor Proug will grant paid holiday time off to all eligible employees. Holiday pay will be calculated at employee’s straight-time pay rate (as of the holiday) multiplied by the number of hours that would have otherwise been worked on that day.

Wepor Proug paid holidays are limited to 8 paid days per calendar year, and if there is an unassigned company holiday day that such “floating” holiday may be used at employee’s discretion with manager’s approval. There is only access to a “floating” holiday if Wepor Proug does not assign the entire 8 days.

To be eligible for holiday pay, individuals must be working the last day immediately preceding and the first day following the holiday. A recognized holiday that falls on a Saturday will be observed on the preceding Friday; a recognized holiday that falls on a Sunday will be observed on the following Monday. If a recognized holiday falls during an eligible employee’s paid absence (such as vacation or sick), holiday pay will be provided instead of the paid time off benefit that would otherwise have applied. If eligible nonexempt employees work on a recognized holiday, they will receive holiday pay plus their wages at their straight-time rate for the hours they worked on the holiday. Paid time-off for holidays will not be counted as hours worked for the purposes of determining overtime.

603 Paid Time Off Effective Date: 7/1/2005 Revision Date: 5/27/2009 Paid Time Off, or PTO, is available to eligible employees to provide opportunities for periods of temporary absence, whether for illnesses or injuries, or simply for rest, relaxation, and personal pursuits.

Full-time, active administrative employees may use up to sixteen (16) days annually as accrued (earned) per pay period, or one hundred twenty eight (128) hours, of PTO throughout the first five (5) years of employment. On the anniversary of the sixth year of service, a full-time administrative employee may use up to twenty-one (21) days annually, or one-hundred- sixty-eight (168) hours, of PTO for each remaining year. The maximum that can be accrued/carried over from year to year is twenty-one (21) days, or one-hundred-sixty-eight (168) “use them or lose them” hours.

The length of Paid Time Off benefits are calculated on the basis of a “benefit year” for all employees. The first year of employment will likely be a short benefit year running from the date of hire through December 31s. Subsequent years will run on the 12-month period beginning January 1st and ending December 31st.

An employee’s benefit year may be extended for any significant leave of absence except military leave of absence. Military leave has no effect on this calculation (see individual leave of absence policies for more information). Once employees enter an eligible employment classification, they begin to earn paid vacation time according to the schedule, subject to each employee’s employment agreement.

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Time has to be accrued before an employee can use PTO. Employees should notify their immediate Supervisor and the Business Manager through a Time-Off Request Form at least one month in advance of taking PTO. All requests for absence are subject to Supervisor approval. Employees should also communicate dates of planned absences to co-workers to ensure client needs are met.

PTO is paid at the employee’s base pay rate at the time of absence. It does not include overtime or any special forms of compensation such as incentives, commissions, bonuses, or shift differentials. Upon termination of employment, employees will be paid for unused Paid Time Off that has been earned through the last day of work.

604 Non-FMLA Leave of Absence Effective Date: 8/1/2005 Revision Date: 1/26/2009 It is policy of the Company to grant employees, not eligible to take FMLA Leave (see Policy 605 Family and Medical Leave), extended leave of absences under certain circumstances. Generally, employees will not receive compensation during a leave of absence, except as stated below, and can request leave for up to eight (8) weeks.

The employee’s Supervisor, with the advice of a Company Officer, will make a decision on the leave request. The request for leave will be reviewed based on the reason for the request, previous attendance record, previous leave requests and the impact the absence will have on the Company. During extended leave, outside employment is prohibited.

Non-FMLA leaves of absence will be taken concurrently with accrued Paid Time Off (PTO). Using PTO during the leave of absence will allow the employee to be paid during the leave. Once PTO is exhausted, the leave will resume as unpaid.

A Company Officer can provide employees with which benefits, in addition to retained seniority, can be continued during the leave. If an employee is able to continue benefits, it must be arranged for directly with the Controller.

Employees should coordinate a return date with their immediate Supervisor prior to leaving. Should there be a change, Wepor Proug requires at least two (2) days advance notice. In addition, we may require a Fitness for Duty Report from your healthcare provider. If an employee does not return from a leave of absence on the mutually agreed upon date, it will be assumed that the employee decided not to return to work and has voluntarily resigned.

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If the request for leave of absence is for personal reasons, the employee’s Supervisor, with the advice of a Company Officer, will decide whether the current position will be held open, or if a position will be made available upon the employee’s return from leave.

Request for a leave of absence will be considered without regard to race, color, citizenship status, national origin, ancestry, gender, sexual orientation, age, religion, creed, physical or mental disability, marital status or veteran status.

605 Family and Medical Leave Effective Date: 2/1/2009 Revision Date: 1/22/2009 The Family and Medical Leave Act of 1993, as amended, (FMLA or Act) allows ‘‘eligible’’ employees of a covered employer to take job-protected, unpaid leave, or to substitute appropriate paid leave if the employee has earned or accrued it, for up to a total of 12 workweeks in any 12 months because of the birth of a child and to care for the newborn child; because of the placement of a child with the employee for adoption or foster care; because the employee is needed to care for a family member (child, spouse, or parent) with a serious health condition; because the employee’s own serious health condition makes the employee unable to perform the functions of his or her job; or because of any qualifying exigency arising out of the fact that the employee’s spouse, son, daughter, or parent is a covered military member on active duty (or has been notified of an impending call or order to active duty) in support of a contingency operation. In addition, ‘‘eligible’’ employees of a covered employer may take job- protected, unpaid leave, or substitute appropriate paid leave if the employee has earned or accrued it, for up to a total of 26 workweeks in a ‘‘single 12-month period’’ to care for a covered servicemember with a serious injury or illness.

Covered Employer An employer covered by FMLA is any person engaged in commerce or in any industry or activity affecting commerce, who employs 50 or more employees for each working day during each of 20 or more calendar workweeks in the current or preceding calendar year.

Eligible Employees An eligible employee is one who has been employed by us for at least 12 months (in the past seven years), has been employed by us for at least 1,250 hours of service during the 12-month period immediately preceding the commencement of the leave, and is employed at a worksite where 50 or more employees are employed by us within 75 miles of the worksite. The 12 months that an employee must have been employed by us need not be consecutive months.

Qualifying Reasons for Leave - General Rule Employers covered by FMLA are required to grant leave to eligible employees: (1) For birth of a son or daughter, and to care for the newborn child, (2) For placement with the employee of a son or daughter for adoption or foster care, (3) To care for the employee’s spouse, son, 40

daughter, or parent with a serious health condition, (4) Because of a serious health condition that makes the employee unable to perform the functions of the employee’s job, (5) Because of any qualifying exigency arising out of the fact that the employee’s spouse, son, daughter, or parent is a covered military member on active duty (or has been notified of an impending call or order to active duty) in support of a contingency operation, and (6) To care for a covered servicemember with a serious injury or illness if the employee is the spouse, son, daughter, parent, or next of kin of the servicemember.

Serious Health Condition For purposes of FMLA, ‘‘serious health condition’’ entitling an employee to FMLA leave means an illness, injury, impairment or physical or mental condition that involves inpatient care or continuing treatment by a health care provider.

Inpatient Care Inpatient care means an overnight stay in a hospital, hospice, or residential medical care facility, including any period of incapacity or any subsequent treatment in connection with such inpatient care.

Continuing Treatment A serious health condition involving continuing treatment by a health care provider includes any one or more of the following: (a) Incapacity and treatment. A period of incapacity of more than three consecutive, full calendar days, and any subsequent treatment or period of incapacity relating to the same condition, that also involves: (1) Treatment two or more times, within 30 days of the first day of incapacity, unless extenuating circumstances exist, by a health care provider, by a nurse under direct (e.g., physical therapist) under orders of, or on referral by, a health care provider; or (2) Treatment by a health care provider on at least one occasion, which results in a regimen of continuing treatment under the supervision of the health care provider.

(3) The requirement in paragraphs (a)(1) and (2) of this section for treatment by a health care provider means an in-person visit to a health care provider. The first (or only) in-person treatment visit must take place within seven days of the first day of incapacity.

(4) Whether additional treatment visits or a regimen of continuing treatment is necessary within the 30-day period shall be determined by the health care provider. (b) Pregnancy or prenatal care. This is defined as any period of incapacity due to pregnancy, or for prenatal care. (c) Chronic conditions. This is defined as any period of incapacity or treatment for such incapacity due to a chronic serious health condition. A chronic serious 41

health condition is one which: (1) Requires periodic visits (defined as at least twice a year) for treatment by a health care provider, or by a nurse under direct supervision of a health care provider; (2) Continues over an extended period of time (including recurring episodes of a single underlying condition); and (3) May cause episodic rather than a continuing period of incapacity (e.g., asthma, diabetes, epilepsy, etc.). (d) Permanent or long-term conditions. This is defined as a period of incapacity which is permanent or long-term due to a condition for which treatment may not be effective. The employee or family member must be under the continuing supervision of, but need not be receiving active treatment by, a health care provider.

Leave for Pregnancy or Birth (a) General rules. Eligible employees are entitled to FMLA leave for pregnancy or birth of a child as follows: (1) Both the mother and father are entitled to FMLA leave for the birth of their child.

(2) Both the mother and father are entitled to FMLA leave to be with the healthy newborn child (i.e., bonding time) during the 12-month period beginning on the date of birth. An employee’s entitlement to FMLA leave for a birth expires at the end of the 12- month period beginning on the date of the birth.

(3) A husband and wife who are eligible for FMLA leave and are employed by us will be limited to a combined total of 12 weeks of leave during any 12-month period if the leave is taken for of the employee’s son or daughter or to care for the child after birth, for placement of a son or daughter with the employee for adoption or foster care or to care for the child after placement. (b) Intermittent and reduced schedule leave.

An eligible employee may not use intermittent or reduced schedule leave after the birth to be with a healthy newborn child. (c) Wepor Proug will continue to pay for its share of group health insurance in addition to regular salary for a period of six (6) weeks for an employee on maternity leave.

Leave for Adoption or Foster Care (a) General rules. Eligible employees are entitled to FMLA leave for placement with the employee of a son or daughter for adoption or foster care as follows: (1) Employees may take FMLA leave before the actual placement or adoption of a child if an absence from work is required for the placement for adoption or foster care to proceed. For example, the employee may be required to attend counseling sessions, appear in court, consult with his or her attorney or the doctor(s) representing the birth parent, submit 42

to a physical examination, or travel to another country to complete an adoption. The source of an adopted child (e.g., whether from a licensed placement agency or otherwise) is not a factor in determining eligibility for leave for this purpose.

Unable to Perform the Functions of the Position (a) Definition. An employee is ‘‘unable to perform the functions of the position’’ where the health care provider finds that the employee is unable to work at all or is unable to perform any one of the essential functions of the employee’s position within the meaning of the Americans with Disabilities Act (ADA), as amended. An employee who must be absent from work to receive medical treatment for a serious health condition is considered to be unable to perform the essential functions of the position during the absence for treatment. (b) Statement of functions. We require certification from a health care provider to specify what functions of the employee’s position the employee is unable to perform so that we can then determine whether the employee is unable to perform one or more essential functions of the employee’s position.

Leave Due to a Qualifying Exigency Eligible employees may take FMLA leave while the employee’s spouse, son, daughter, or parent (the ‘‘covered military member’’) is on active duty or call to active duty status for one or more of the following qualifying exigencies: (1) Short-notice deployment (2) Military events and related activities (3) Childcare and school activities (4) Financial and legal arrangements (5) Counseling: To attend counseling provided by someone other than a health care provider (6) Rest and recuperation (7) Post-deployment activities (8) Additional activities. To address other events which arise out of the covered military member’s active duty or call to active duty status provided that the employer and employee agree that such leave shall qualify as an exigency, and agree to both the timing and duration of such leave.

Leave to Care for a Covered Servicemember with a Serious Injury or Illness Eligible employees are entitled to FMLA leave to care for a current member of the Armed Forces, including a member of the National Guard or Reserves, or a member of the Armed Forces, the National Guard or Reserves who is on the temporary disability retired list, who has a serious injury or illness incurred in the line of duty on undergoing medical treatment, recuperation, or therapy; or otherwise in outpatient status; or otherwise on the temporary disability retired list.

(1) A ‘‘serious injury or illness’’ means an injury or illness incurred by a covered servicemember in the line of duty on active duty that may render the servicemember medically unfit to perform the duties of his or her office, grade, rank or rating.

(2) ‘‘Outpatient status,’’ with respect to a covered servicemember, means the status of a member of the Armed Forces assigned to either a military medical treatment facility as an outpatient; or a unit established for the purpose of

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providing command and control of members of the Armed Forces receiving medical care as outpatients. In order to care for a covered servicemember, an eligible employee must be the spouse, son, daughter, or parent, or next of kin of a covered servicemember.

(3) An eligible employee is entitled to a combined total of 26 workweeks of leave for any FMLA-qualifying reason during the ‘‘single 12-month period’’ described in paragraph (c) of this section, provided that the employee is entitled to no more than 12 weeks of leave for one or more of the following: because of the birth of a son or daughter of the employee and in order to care for such son or daughter; because of the placement of a son or daughter with the employee for adoption or foster care; in order to care for the spouse, son, daughter, or parent with a serious health condition; because of the employee’s own serious health condition; or because of a qualifying exigency.

A husband and wife who are eligible for FMLA leave and are both employed by us will be limited to a combined total of 26 workweeks of leave during the ‘‘single 12-month period’’ if the leave is taken for birth of the employee’s son or daughter or to care for the child after birth, for placement of a son or daughter with the employee for adoption or foster care, or to care for the child after placement, to care for the employee’s parent with a serious health condition where a portion of the combined 26 weeks of leave is to care for a covered servicemember with a serious injury or illness.

Amount of Leave Except in the case of leave to care or a covered servicemember with a serious injury or illness, an eligible employee’s FMLA leave entitlement is limited to a total of 12 workweeks of leave during any 12-month period. The 12-month period is calculated as follows: a ‘‘rolling’’ 12-month period measured backward from the date an employee uses any FMLA leave.

Intermittent Leave or Reduced Leave Schedule FMLA leave may be taken ‘‘intermittently or on a reduced leave schedule’’ under certain circumstances. Intermittent leave is FMLA leave taken in separate blocks of time due to a single qualifying reason. A reduced leave schedule is a leave schedule that reduces an employee’s usual number of working hours per workweek, or hours per workday. A reduced leave schedule is a change in the employee’s schedule for a period of time, normally from full-time to part-time.

Substitution of Paid Leave Our employees are required to use accrued paid leave during FMLA leave. FMLA leave runs concurrently with other types of leave.

Maintenance of Employee Benefits Group health plan benefits will be maintained on the same basis as coverage would have been provided if the employee had been continuously employed during the FMLA leave period. Therefore, any share of group health plan premiums which had 44

been paid by the employee prior to FMLA leave must continue to be paid by the employee during the FMLA leave period.

If the FMLA leave is substituted paid leave, your share of premiums will be paid by the method normally used during any paid leave, such as payroll deduction.

If FMLA leave is unpaid, payment is due on the same schedule as payments are made under COBRA which is the first day of the month.

Before we drop coverage for an employee whose premium payment is late, we will provide written notice to you that the payment has not been received. Such notice will be mailed to the employee at least 15 days before coverage is to cease, advising that coverage will be dropped on a specified date at least 15 days after the date of the letter unless the payment has been received by that date.

Key Employee General Rule. A ‘‘key employee’’ is a salaried FMLA-eligible employee who is among the highest paid 10 percent of all the employees employed by the employer within 75 miles of the employee’s worksite.

Substantial and Grievous Economic Injury. In order to deny restoration to a key employee, we must determine that the restoration of the employee to employment will cause ‘‘substantial and grievous economic injury’’ to our operations, not whether the absence of the employee will cause such substantial and grievous injury.

Rights of a Key Employee. If we believe that reinstatement may be denied to a key employee, we will give written notice to the employee at the time the employee gives notice of the need for FMLA leave (or when FMLA leave commences, if earlier) that he or she qualifies as a key employee. At the same time, the employer must also fully inform the employee of the potential consequences with respect to reinstatement and maintenance of health benefits if the employer should determine that substantial and grievous economic injury to the employer’s operations will result if the employee is reinstated from FMLA leave.

Complying with Employer Policy If employees have advance notice of their need to be absent, employees should request time off directly from their Supervisor, while also notifying the Controller. In the rare instance when employees cannot avoid being late to work or are unable to work as scheduled, notification should be given to the front desk Receptionist and immediate Supervisor as soon as possible in advance of the anticipated tardiness or absence.

Employee Notice Requirements for Unforeseeable FMLA Leave Calling in ‘‘sick’’ without providing more information will not be considered sufficient notice to trigger an employer’s obligations under the Act. Scheduling Planned Medical Treatment When planning medical treatment, the employee must consult with us and make a reasonable effort to schedule the 45

treatment so as not to unduly disrupt our operations, subject to the approval of the health care provider. Employees are ordinarily expected to consult with us prior to the scheduling of treatment in order to work out a treatment schedule which best suits our needs and the needs of the employee subject to the approval of the health care provider.

Intermittent leave or leave on a reduced leave schedule must be medically necessary due to a serious health condition or a serious injury or illness. An employee shall advise the employer, upon request, of the reasons why the intermittent/reduced leave schedule is necessary and of the schedule for treatment, if applicable. The employee and employer shall attempt to work out a schedule for such leave that meets the employee’s needs without unduly disrupting our operations, subject to the approval of the health care provider.

Certification General Rule. We will require that an employee’s leave to care for the employee’s covered family member with a serious health condition, or due to the employee’s own serious health condition that makes the employee unable to perform one or more of the essential functions of the employee’s position, be supported by a certification issued by the health care provider of the employee or the employee’s family member. We also require that an employee’s leave because of a qualifying exigency or to care for a covered servicemember with a serious injury or illness be supported by a certification.

Timing The employee must provide the requested certification to us within 15 calendar days after our request, unless it is not practicable under the particular circumstances to do so despite the employee’s diligent, good faith efforts. The employee must provide a complete and sufficient certification to the employer.

A certification is considered incomplete if we receive a certification, but one or more of the applicable entries have not been completed.

Unforeseeable Leave When the need for FMLA leave is unforeseeable and an employee fails to give notice, the extent to which an employer may delay FMLA coverage for leave will be determined based upon the facts of the particular case.

Interaction with Federal and State Anti-Discrimination Laws We will not discriminate against employees as a result of the approved use of family care or medical leave or a proper request for such leave. Requests for family care and medical leave will be considered without regard to race, color, citizenship status, national origin, ancestry, gender, sexual orientation, age, religion, creed, physical or mental disability, marital status or veteran status.

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606 Bereavement/ Funeral Leave Effective Date: 7/1/2005 Revision Date: 10/1/2008 Wepor Proug provides three (3) days paid leave for employees who wish to take time off due to the death of an immediate family member. “Immediate family” is defined as the employee’s spouse, parent, step-parent, grandparent, child, grandchild and/ or sibling. We will also consider requests for bereavement leave if someone dies who was as close to you as an immediate family member.

Paid bereavement leave, as determined by Wepor Proug, will be provided to eligible employees in the following classification(s):

• Active, regular full-time exempt employees • Active, regular full-time non-exempt employees

Employees should notify their supervisor immediately when the need for such leave arises. Bereavement leave will normally be granted unless there are unusual business needs or staffing requirements. Prior to granting paid Bereavement/Funeral leave, Wepor Proug reserves the right to request documentation of death (death certificate, funeral notice, etc.) Employees may, with their supervisors’ approval, use any available paid leave for additional time off as necessary.

607 Jury Duty Leave Effective Date: 7/1/2005 Revision Date: 10/17/2008 Wepor Proug encourages employees to fulfill their civic responsibilities by serving jury duty when required. Employees may request jury duty leave for the length of absence. If desired, employees may use any available paid time off (for example, PTO). Employees must show the jury duty summons to their supervisor as soon as possible so that the supervisor may make arrangements to accommodate their absence. Of course, employees are expected to report for work whenever the court schedule permits.

Either Wepor Proug or the employee may request an excuse from jury duty if, in Wepor Proug’s judgment, the employee’s absence would create serious operational difficulties. Wepor Proug will continue to provide health insurance benefits for the full term of the jury duty absence.

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608 Section 125/Flexible Spending Accounts Effective Date: 7/1/2005 Revision Date: 10/17/2008 For the benefit of our employees, Wepor Proug has instituted a Section 125 Plan and full Flexible Spending Account (FSA). This plan allows employees who contribute toward the cost of their health insurance to pay on a pre-tax basis. Participants in the plan can potentially reduce actual out-of-pocket costs by 20% or more, depending on individual tax brackets.

Election forms for the 125 Plan are available every year during the Section 125 Plan open enrollment period. When electing to participate in the 125 Plan, employees must maintain elections for the full year. There are, however, certain changes in family circumstances that the IRS will consider as valid reasons to make mid-year plan changes. Only Group Health, Group Dental, and Voluntary Vision insurance premiums may be paid through the use of the Section 125 Plan.

In addition to insurance premiums being paid on a pre-tax basis, employees can contribute dollars into accounts to pay for qualified medical expenses not covered by insurance and/or qualified dependent daycare expenses. These additional accounts are referred to as Medical FSA and Dependent Care FSA. The same election form will be used in order to participate in the Section 125, Medical FSA, and Dependent Care FSA. If employees would like additional information or guidance, please contact the Controller or a Company Officer.

609 Workers’ Compensation Insurance Effective Date: 7/1/2005 Revision Date: Wepor Proug provides a comprehensive workers’ compensation insurance program at no cost to employees. This program covers any injury or illness sustained in the course of employment that requires medical, surgical, or hospital treatment. Subject to applicable legal requirements, workers’ compensation insurance provides benefits after a short waiting period or, if the employee is hospitalized, immediately.

Employees who sustain work-related injuries or illnesses should inform their supervisor immediately. No matter how minor an on-the-job injury may appear, it is important that it be reported immediately. This will enable an eligible employee to qualify for coverage as quickly as possible. As a drug-free workplace, Wepor Proug employees may be required to take a drug test following involvement in an accidental injury.

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Neither Wepor Proug nor the insurance carrier will be liable for the payment of workers’ compensation benefits for injuries that occur during an employee’s voluntary participation in any off-duty recreational, social, or athletic activity sponsored by the Company.

610 Benefits Continuation (COBRA) Effective Date: 7/1/2005 Revision Date: The federal Consolidated Omnibus Budget Reconciliation Act (COBRA) gives employees and their qualified beneficiaries the opportunity to continue health insurance coverage under Wepor Proug’s health plan when a “qualifying event” would normally result in the loss of eligibility.

Some common qualifying events are: • Resignation • Termination of employment • Death of an employee • Reduction in employee’s hours • Leave of absence • Divorce or legal separation • Ineligibility of dependent child Under COBRA, the employee or beneficiary pays the full cost of coverage at Wepor Proug’s group rates plus an additional 2% of premium acting as an administration fee. Wepor Proug provides each eligible employee with a written notice describing rights granted under COBRA when the employee becomes eligible for coverage under Wepor Proug’s health insurance plan. The notice contains important information about the employee’s rights and obligations. If employees have not received this notice, or would like additional information, they should contact a Company Officer.

611 Additional Benefits Effective Date: 5/1/2007 Revision Date: 10/17/2008 Summer Hours Policy Wepor Proug summer hour’s policy allows employees to extend their weekends, while continuing to work the standard number of hours per week from Monday through Friday on a biweekly basis during dates as determined by the Company.

This policy may not extend to all jobs or all departments and is dependent on the needs of the company. Program participation is set at each Supervisor’s discretion.

If said, department participates, it will be the immediate Supervisors responsibility to develop a schedule for appropriate department coverage to assure the highest quality of standards are maintained for client services at all times. Therefore, any client activities or internal company requirements needing attention on a particular Friday afternoon will take precedence over the compressed workweek.

Summer hours will work as follows. On the week you take your half day off on Friday, you will work an extra 45 minutes Monday through Thursday of that week, and then

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will be permitted to leave after a 4-hour shift on Friday. In addition, Friday you start (no exceptions) your shift at your regular indicated time. Extra time worked must take place before or after your regular indicated shift, extra time worked cannot be earned during your lunch hour. Employees taking a day off (PTO) will not be eligible to participate in the compressed summer workweek for that particular week.

Therefore, any employee that takes a Friday off will have to use a full 8 hours of PTO. Any workweek in which a paid holiday or early closing is observed will not apply. The week you are not off early on Friday, you will work your regular indicated shift.

Charitable Contributions Denim Dollars. Wepor Proug employees have the opportunity to make a charitable contribution through a program called Denim Dollars. This program was established to encourage employees to reach out to the community by donating a portion of their pay to a charity. The Denim Dollars program recognizes and rewards employees for their donation by allowing him/her to wear denim clothing (jeans, jean jackets, jean skirts, etc.) on Fridays. An employee can either designate the amount of pay they want taken out for the year or an employee can choose to take out a particular amount each pay period. The minimum amount needed to be taken out of one’s pay in order to qualify is one dollar ($1) per week. Wepor Proug matches what the employees have contributed. Employees are not obligated to participate in this program; participation is voluntary.

Charity Information - See current information in break room.

Adopt a Family - See current information in break room.

Academic Acknowledgements Wepor Proug has established a policy to commend and recognize young people each semester for above average performance in school. To be eligible for such a benefit, the student must be a child of a Wepor Proug employee. “Child” is defined as any employee’s biological, step, or foster child attending primary school.

To receive academic recognition for performance, students must maintain no less that a “C” or “2.0” average or better within a given semester.

A check will be issued in the child’s name within ten (10) business days of receiving a copy of the semester’s grades.

Recognition amounts will be based upon the following scale: Grade Recognition Amount* Straight “A” Bonus 1st through 8th $3.00 per “A” $10.00 9th through 12th $10.00 per “A” $25.00 *Recognition amount will be $3.00 per “A” or the equivalent rating to an “A” Please direct any questions to your immediate supervisor or the Business Manager.

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612 Higher Education Bonus Incentive Effective Date: 05/01/2010 Revision Date: Wepor Proug offers an incentive bonus to regular full-time employees who wish to pursue education and training in areas related to their current positions or that will prepare them for more advanced positions within the Company. Upon successful completion of an approved degree or certification program, a bonus will be rewarded, up to the limits specified below, to eligible employees who meet all of the requirements of this policy and follow all of the procedures set forth below.

Eligibility • All regular full-time employees who have completed six (6) months of continuous service are eligible to participate in Wepor Proug’s incentive program.

• Continued eligibility and bonus reward is contingent upon full-time employment with Wepor Proug and continued good performance, conduct, and attendance.

• Approved Programs/Degrees • Bonus incentive is available for courses offered by fully accredited colleges, universities, trade or technical schools. This includes independent-study, selfstudy, and correspondence courses.

• Certificate programs must be related to the employee’s current position or prepare the employee for more advanced positions within Wepor Proug and must be approved in advance by the employee’s immediate supervisor.

• Bonus Incentive • An incentive bonus will be rewarded in accordance with the policy upon successful completion of degree or certification program, up to the following amounts: -Secondary Degree: $2,000 bonus -Bachelor’s Degree: $1,000 bonus -Associate’s Degree: $500 bonus -Designations related to current position: $500

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INDEX POLICY SECTION

A Absenteeism.......................................................301, 302, 306, 307 ADA.....................................................................205 Alcohol Use.........................................................107, 301, 302 Appearance.........................................................305 Attendance..........................................................306 Automobile Use...................................................311 B Benefits Insurance.........................................................601 Change of Status.............................................314, 601 Termination.......................................................104, 304 Eligibility...........................................................304 Enrollment........................................................203, 304, 602, 608 Additional Benefits...........................................611 Bereavement Leave.............................................606 Business Expenses.............................................307 C Changes-Personnel Information..........................314, 601 COBRA................................................................601, 610 Complaints..........................................................104, 205, 207, 312 Computer Usage.................................................404, 501, 502 Conduct...............................................................106, 207, 301, 302, 303, 304 Confidentiality......................................................102, 205, 301, 302, 502 Conflict of Interest...............................................105, 204, Contract...............................................................Intro, Employee ............................................................................Acknowledgement Form 104 D Disability Accommodation...................................205 Discipline.............................................................201, 304 Disclosure............................................................102, 302, 502 Discharge of Employee.......................................104, 207, 503 Discrimination......................................................201, 203, 207 Death...................................................................610 Dress Code.........................................................305 Drug Use.............................................................107, 301, 302, 402, 403, 609 53

E Email Usage........................................................501, 502 Emergency Procedures.......................................402 Equal Employment Opportunity..........................201, 205, 207, 601 ERISA..................................................................204 Ethics...................................................................303 Exit Interviews.....................................................104 F First Aid...............................................................402 Funeral Leave......................................................606 G Grooming............................................................305 H Harassment.........................................................207, 301, 302, 404, 501, 502 HIPPA..................................................................203 Holiday................................................................310, 603, I-9........................................................................202 Illness..................................................................205, 306, 402, 604, 605, 609 I Immigration..........................................................202 Injury....................................................................402, 604, 608 Internet Usage.....................................................502 Introductory Period..............................................103, 106, 603 J Jury Duty.............................................................607 L Lateness..............................................................306 Layoff ..................................................................104, 609 M Mileage Reimbursement.....................................307, 310 Military Leave......................................................206, 602 Monitoring...........................................................404, 501, 502, 503 N New Hires............................................................103, 202 Non-Disclosures..................................................102 O

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Open Enrollment.................................................203, 601, 608 Outside Employment...........................................105, 204 Overtime..............................................................310, 602, 603 P Problem Resolution.............................................311 Property – Personal & Company.........................301, 306, 310, 312, 404, 405, ...........................................................................501, 502, 503, 104 Punctuality...........................................................306 R Rules....................................................................301, 302, 303, 401, 312 Resignation..........................................................101, 104, 306, 609 Retirement...........................................................104, 204 S Safety Section 125...............................................301, 302, 401, 404, 125, 608 Sick Leave...........................................................206, 306, 310, 603, 604 Suspension..........................................................304, 306 Special Enrollment..............................................203 T Tardiness.............................................................306 Telephones..........................................................301, 302, 314, 404, 503 Termination..........................................................104, 304, 610 Travel...................................................................206, 307 U USERRA..............................................................206 V Vacation...............................................................206, 302, 310, 602, 603, 604, 605, 606, 607 W Workers’ Compensation .....................................103, 402, 609

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