SEKO - Worldwide Employee Handbook 2019

SEKO - Worldwide Employee Handbook 2019

SEKO WORLDWIDE, LLC EMPLOYEE HANDBOOK

Release Date: August 1, 2019

WELCOME

Dear SEKO Team Member,

Welcome to SEKO Logistics group companies! For more than 40 years, SEKO Logistics has been a leading provider of logistics services. SEKO has made a name for itself as a supply chain differentiator for our customers, and has earned this reputation due to our unique services, our lean and adaptable model, and our overarching commitment to customer-centricity above all else. We’ve been recognized consistently as an industry leader in superior customer service and on-time performance. With your help, we are looking forward to continuing growth and prosperity, as we find new and better ways to serve our customers’ needs. As a member of our team in the United States, we welcome you and want to make you aware of the policies and procedures that impact you. We invite you to read and be familiar with the contents of this Handbook, and to let your manager know if you have any questions or concerns. SEKO wishes you much success in your career with our Company and thanks you for your service, dedication, and adherence to the policies and procedures that ensure our future success.

With my best regards,

William J. Wascher, Chairman

TABLE OF CONTENTS

SECTION 1 GENERAL INFORMATION

SECTION 4 GENERAL EMPLOYEE POLICIES 14

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4.1 Employment At-Will

14 14 15 15 15 16 16

SECTION 2 EMPLOYEE CLASSIFICATIONS 8

4.2 Hours of Work

4.3 Biometric Information

4.4 Paydays

4.5 Training and Development 4.6 Disability Accommodations

2.1 Full-Time Employees 2.2 Part-Time Employees 2.3 Temporary Employees 2.4 Independent Contractors

8 8 8 8

4.7 Accidents

4.8  Emergency Medical and Evacuation Procedures 4.9 Smoke-Free Workplace 16 4.10 Drug and Alcohol-Free Workplace 17 4.11  Employment Applications/ Verifications/Reference Checks 17 4.12 Standards of Professional Conduct 18 4.13  Confidential Information, Intellectual Property, and Work Product 19 4.14 Outside Employment 21 4.15 Property 21 4.16 Internet, E-Mail, Social Media and Voicemail Usage 22 4.17 Mobile Device Usage 24 4.18 Dress Code 25 4.19  Travel and Business Expenses 25 4.20  Question/Complaint Resolution Process 25 4.21 Employee Records 25 4.22 Personal Visitors 25 4.23 Information Requests 25 4.24 Disciplinary Actions 26 4.25 Other Laws 26 16

SECTION 3 EMPLOYEE BENEFITS

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3.1 Vacation Days

9

3.2 Sick/Personal Days

10 10 10

3.3 Holidays 3.4 Jury Duty

3.5 Funeral Leave 10 3.6 Military Leave and Reserve Training 10 3.7 Family and Medical Leave 10 3.8 VESSA Leave 10 3.9 Extended Leaves of Absence 11 3.10 Insurance 11 3.11 401(k) Retirement Savings Plan 11 3.12 Flexible Spending Plan 11 3.13 Health Savings Account 12 3.14 Employee Assistance Program 12

SEKO TIMELINE

Technology Award winner in the Irish Logistics & Transport Awards 2017

SEKO expands operations in Syracuse and Pittsburgh

SEKO named a Multichannel Merchant Top 3PL for 2017

SEKO named Top 10 Leading Vendor in Internet Retailer Magazine's Top 1,000 report

SEKO launches new SaaS division - Gelnius

James Gagne becomes new President

40th Anniversary!

SEKO named a Multichannel Merchant Top 3PL for 2016

SEKO launches new Aerospace and Aviation industry vertical

SEKO recognized as highest ranking Freight Forwarder for customer service in the Logistics Management Quest for Quality Awards

First UK 'Center of Excellence' for Aerospace and Aviation opens in Farnborough

SEKO recognized by Inbound Logistics magazine as a Top 10 3PL

SEKO Profiled as a Top Supply Chain & Logistics Provider in Transport Intelligence Report

SEKO approved as a SmartWay Transportation Partner by the US Environmental Protection Agency

Sponsors Drapers Awards 2016

Omni-channel division wins PwC ‘Start Up Disruptor’ Award

SEKO named Top 10 Logistics Service Provider in Inbound Logistics' Top 100 3PL Providers list SEKO recognized as highest ranking Freight Forwarder for customer service in the Logistics Management Quest for Quality Awards

SEKO named a Multichannel Merchant Top 3PL for 2015

SEKO Cape Town opens

Chino, CA Omni-Channel Logistics hub opens

SEKO selects Greenbriar Equity Group as equity partner

SEKO partners with Caliber to create SEKO Store Development Services

SEKO expands into new 100,000 square ft. facility in San Francisco

SEKO named Top 10 Leading Vendor in Internet Retailer Magazine's Top 1,000 report

SEKO European and US MedTec operations awarded ISO13485 certification

SEKO Milton Keynes distribution center opens > Dallas, Laredo and new Houston location opens

SEKO MedTec opens European Control Center in Ireland

SEKO achieves full Authorized Economic Operator (AEO) certification in Ireland

SEKO invests in eCommerce agency Red Hot Penny

SEKO recognized by Inbound Logistics magazine as a Top 10 3PL > SEKO named a Multichannel Merchant Top 3PL for 2014

SEKO Store Development Services is launched

SEKO joins Advisory Board of the International Omni Retailing Members Association (IORMA)

SEKO sponsors first Home Delivery World conference

SEKO Boise, Gothenberg, Southampton, Manchester, Kansas City and San Antonio open

MySEKO Harmony is launched

SEKO listed in the Sunday Times HSBC Fast Track International 200

SEKO named as an Inc. Magazine Top 5000 Privately Held Company

SEKO Ride25 charity cycle ride initiative is launched

SEKO Denmark obtains Authorized Economic Operator (AEO) status

Recognized as Top 100 3PL by Inbound Logistics magazine

SEKO Synergy rebrands as SEKO Logistics to align with company name

SEKO Norway opens

Global Logistics Carrier Excellence Award received from Owens Corning

SEKO Las Vegas opens

2010 MedTec launched > Salt Lake City, Minneapolis, Rochester, Nashville, Cincinnati and New York open

2003 First SEKO office outside the US opens in the UK with London, making SEKO truly Global > SEKO UK wins BIFA Gold Award > Seattle, Chicago, Miami, Baltimore and Detroit open 2002 William J. Wascher, Tom Cagney and Steven Goldberg purchase SEKO on October 31st > SEKO brand reintroduced > Pittsburgh opens 2004 SEKO UK wins BIFA Gold Award > Portland, Los Angeles and Jacksonville open > MySEKO V1 is launched

2009 SEKO Norfolk opens > MySEKO V3 is launched

2007 SEKO deploys first SaaS TMS solution > Spokane opens

2006 30th Anniversary! > Two offices open in South Africa > MySEKO V2 is launched 2005 SEKO UK wins BIFA Gold Award > San Francisco and Milwaukee open > SEKO RED is launched

2001 SEKO Cleveland opens

1990 Albany, Philadelphia and Providence open

1999 Offices in Indianapolis and Syracuse open

1998 USF SEKO Worldwide becomes USF Worldwide and the SEKO brand as we know it ceases to exist

1988 William J. Wascher, Bob Imhoff, Peter Baker and Joe Blais acquire SEKO Air Freight, Inc. from Norman S. Koppel

1997 SEKO Worldwide becomes USF SEKO Worldwide as part of USF acquisition

1986 10th Anniversary!

1985 SEKO’s first Order Management solution > Buffalo and Louisville open

1996 20th Anniversary! > SEKO Air Freight becomes SEKO Worldwide > Ocean Freight Forwarding launched 1995 Raleigh/Durham opens > Dedicated ground transport division launched 1994 SEKO enters the B2C delivery market with first home delivery customer in the United States

1983 William J. Wascher joins the business

1981 SEKO Atlanta opens

1980 SEKO Charlotte and Phoenix open

1992 Hartford, Memphis, Newark, Orlando and Tampa open

1976 SEKO Air Freight, Inc. is founded in Chicago by Norman S. Koppel from a department of SEKO Messenger, Inc. and the SEKO we know today begins to take shape.

1991 San Diego opens

THE SEKO ORIGIN: The name SEKO is a derivative of Siegel and Koppel. In the 1950s, business partners Norman S. Koppel and Bernard (Bernie) Siegel started SEKO Rocket Enterprises, Inc., which shuttled cars between dealers in new car trading that is common in the auto sales space. They then formed SEKO Messenger, Inc. and bought numerous messenger companies in the Chicagoland area.

SECTION 1 GENERAL INFORMATION

The contents of this Employee Handbook (the “Handbook”) are provided to outline the policies, procedures, benefits, and culture of SEKO Worldwide, LLC (“SEKO”) and assist you in your professional growth. While we have tried to anticipate all situations, there will be occasions when something occurs that is not specifically covered in this Handbook. In those instances, appropriate action will be determined by the management of SEKO. The policies, procedures and benefits set forth in this Handbook may change and/or be amended from time to time. The contents of this Handbook supersede any and all prior corresponding policies, procedures, guidelines or policy statements made by SEKO representatives. SEKO reserves the right to add to, delete, or otherwise modify this Handbook and/or make exceptions to the policies, procedures and benefits contained in this Handbook at any time - without prior written notice to employees. It also supersedes any customs, practices or oral statements made by SEKO representatives. Any understanding supplemental to or different from what is in the Handbook must be in writing and signed by the CEO, President or Human Resources Department of SEKO.

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SECTION 2 HOW WILL YOU BE CLASSIFIED AS A SEKO EMPLOYEE? 2.1 What is a Full-Time Employee?

2.3 What is a Temporary Employee?

Full-time employees are those employees who are regularly scheduled to work at least thirty (30) hours per week. 2.2 What is a Part-Time Employee? Part-time employees are those employees who are hired with the understanding that they will regularly work less than thirty (30) hours per week. A part- time employee who becomes a full-time employee will earn seniority based on the date the employee becomes full-time. Unless otherwise provided for on an individual basis or required by law, part-time employees are not eligible for any of the employee benefits described in Section 3 of this Handbook.

Temporary employees are those employees who are hired with the understanding that their tenure with SEKO is for a fixed period of time. Temporary employees may work any number of hours up to and including full-time. Unless otherwise provided for on an individual basis or required by law, temporary employees are not eligible for any employee benefits described in Section 3 of this Handbook. A temporary employee who becomes a regular full-time employee will earn seniority and employee benefits based on the date the employee becomes full-time. 2.4 What is an Independent Contractor? Independent Contractors (“ICs”) are retained by SEKO to work on specific projects. ICs are paid through Accounts Payable based upon invoiced hours worked and approved by an Executive or the Human Resources Department. ICs are not eligible for any employee benefits described in Section 3 of this Handbook.

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SECTION 3 FOR WHAT BENEFITS ARE YOU ELIGIBLE

AS A SEKO EMPLOYEE? 3.1 Are you eligible for Vacation Days?

One of SEKO’s Core Values is “Work Hard/Play Hard” - so we understand the importance of taking time to relax, unwind, and enjoy a well-deserved break from work. As such, all full-time employees are eligible to accrue paid vacation time. Vacation is granted as an incentive to future work, not as compensation for past work. Vacation is earned on a pro rata basis, as follows:

Years of Service

Hours Accrued Per Pay Period - Full Time

Maximum Calendar Year Accrual - Full Time

Hire date up to 5 years

3.08 hours

10 days/80 hours

More than 5 years but less than 10 years

4.62 hours

15 days/120 hours

More than 10 years

6.15 hours

20 days/160 hours

ELIGIBLE NEW HIRES. For new hires, vacation time will accrue on a pro-rata basis throughout the calendar year as stated above. Accrued vacation time during an employee’s first full calendar year of employment with SEKO will be reflected pro- rata beginning on the employee’s first paycheck following thirty (30) days of continuous employment. EXISTING EMPLOYEES. Vacation time may be advanced before it is accrued on a case-by-case basis within SEKO’s sole discretion. This policy exists to allow employees to take time off before it is actually accrued and earned throughout the year. Employees advanced time will be expected to continue working to accrue the time already taken before additional time is earned. Employees may carry over a maximum of five (5) vacation days into the following calendar year, provided these vacation days are used within the first quarter of the following calendar year. If not used within the first quarter of the following calendar year, these carried-over days will be lost. Accrued but unused vacation time will not be paid to employees at the end of each calendar year, and will not be banked or carried over to any succeeding calendar year in excess of the allowance in this policy for any “carry over” days.

During Family and Medical Leave, VESSA Leave, or other leaves of absence, employees will not accrue any vacation time (unless otherwise required by law). In the event of an employee’s resignation or termination, the monetary equivalent of all accrued but unused vacation time will be paid to the employee. PROCESS FOR SUBMITTING REQUESTS FOR VACATION TIME. All employees must submit vacation time requests through SEKO’s Payroll/ HR System with sufficient advance notice to enable SEKO to meet its business needs. Employees are also encouraged to submit extended vacation requests (i.e., for more than one week’s vacation) at the beginning of the calendar year, or as soon as practically possible, to avoid scheduling conflicts with their coworkers. All vacation requests will be sent to the employee’s immediate supervisor who will either approve or deny the request. SEKO will generally grant requests for vacation time when possible, taking the business needs of SEKO into consideration. If necessary, an employee’s vacation time will be scheduled or re- scheduled to avoid interfering with SEKO’s business or operations. When multiple employees request the same time off for vacation, operational needs and seniority may determine priority in scheduling vacation times.

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3.2 Are you eligible for Sick/Personal Days?

3.6 What if you serve in the Military and need to take Military Leave or Reserve Training? SEKO recognizes that employees may need to be absent from work to serve in the U.S. military and the company supports its employees in such military service. SEKO provides military service leaves of absence to all full-time and part-time employees in compliance with the Uniformed Services Employment and Reemployment Rights Act (USERRA) and applicable state laws. Please see the Human Resources Department for more information. 3.7 What if you experience a family or medical situation and wish to take Family and Medical Leave? In accordance with the Family and Medical Leave Act of 1993, if you have been employed by SEKO for at least twelve (12) months - and have worked at least one thousand two hundred fifty (1,250) hours during the twelve (12) month period preceding the start of the leave at a work-site where fifty (50) or more employees work within seventy-five (75) miles - you are eligible for up to a total of twelve (12) workweeks of unpaid family and medical leave, and up to twenty six (26) weeks for qualifying exigency military reasons (“Family and Medical Leave”) during any rolling twelve (12) month period. Please see the Human Resources Department for more information, including policy documentation and resources available to you if you have a need to take a leave that may qualify under the Family and Medical Leave Act. 3.8 What if you experience domestic or sexual violence and wish to take VESSA Leave? In accordance with the Victims’ Economic Security and Safety Act of 2003 (“VESSA”), employees of SEKO located in Illinois are eligible for up to a total of twelve (12) workweeks of unpaid leave (“VESSA Leave”) during any rolling twelve (12) month period for reasons to include because you are a victim of domestic or sexual violence; or you have a family member who is a victim and you are addressing issues arising from such violence. If you think this applies to you, please contact the Human Resources Department for more information.

All full-time SEKO employees employed by SEKO shall be eligible to accrue an aggregate of five (5) paid sick/personal days. The accrual policy will be based on the number of hours worked. No sick/ personal days can be banked. Sick/personal days will not be paid as an accrued benefit at any time. 3.3 Are you eligible for Holidays? SEKO observes paid holidays for full-time and part-time employees, and releases the dates of the recognized holidays for the following year

in the third quarter of the current year. Please contact the Human Resources Department for more information. 3.4 What if you are called for Jury Duty?

Leave for jury duty will be allowed for all full- time and part-time employees. Regular full-time employees will receive the employee’s regular salary for the duration of jury service. Part-time employees will not be paid during jury service. Jury leave pay will not be duplicated with any other pay such as vacation or sick/personal days. At least three (3) weeks advance notice and approval must be obtained from your manager and the Human Resources Department to be eligible for this benefit. 3.5 What if you experience a death in your family and wish to take Funeral Leave? SEKO will grant funeral leave pay to all regular full-time employees for up to three (3) consecutive business days in the event of the death of an employee’s spouse, domestic partner, child, mother, father, brother, sister, grandmother, grandfather, mother-in-law, father-in-law, brother- in-law or sister-in-law. Funeral leave pay will not be duplicated with any other pay such as vacation or sick/personal days. Additional time off without pay may be arranged with the approval of the Human Resources Department.

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3.9 How are your Extended Leaves of Absence coordinated with other benefits? COORDINATION OF LEAVES/BENEFITS The following rules explain how the time off policies and certain insurance benefits are coordinated: • All leaves of absence that you may qualify for at the same time are to be taken at the same time. • All time missed from work that qualifies for compensation, workers’ compensation, disability and/or Family and Medical Leave will be counted toward the employee’s twelve (12) weeks of Family and Medical Leave. • If you otherwise qualify for workers’ compensation or other disability benefits, you shall collect such payments at the same time you are on Family and Medical Leave. • If you otherwise qualify for other types of paid- time-off programs, such as vacation or sick/ personal days, you must substitute those paid days for unpaid Family and Medical Leave. This means that you must take such paid-time- off at the same time you are taking unpaid Family and Medical Leave. Days on which you qualify for workers’ compensation or other disability payments are not unpaid, so paid- time-off cannot be substituted. If your absence is governed by workers’ compensation, then applicable law shall govern any conflicts between this policy and the law. CONTINUATION OF INSURANCE SEKO will continue to provide medical and life insurance coverage for up to twelve (12) weeks during the period of approved leave, provided you continue to pay your share of premium payments on a timely basis. Failure to pay your share of the premiums on time could result in cancellation of coverage. If your insurance is cancelled because of late or non-payment of the premium, the availability of health insurance may be restricted or limited under the federal law commonly known as HIPAA. You may have other options available to you when you lose group health coverage. For example, you may be eligible to buy an individual plan through the Health Insurance Marketplace.

3.10 What types of Insurance does SEKO offer? SEKO provides the following insurance benefits:

• Medical Insurance • Dental Insurance • Vision Insurance • Life Insurance • Optional Life Insurance

• Long-Term and Short-Term Disability Insurance • Accidental Death and Dismemberment Insurance Please contact the Human Resources Department for additional information and policy documentation regarding these insurance benefits. 3.11 Does SEKO offer a 401(k) Retirement Savings Plan? SEKO sponsors a 401(k) plan designed to provide eligible employees with the opportunity to save a portion of their earnings for retirement. SEKO will match a portion of employee contributions. Please see the Human Resources Department for beneficiary designation and other information regarding this plan. 3.12 Does SEKO offer a Flexible Spending Plan? SEKO offers a Flexible Spending Plan under Section 125 of the Internal Revenue Code, commonly known as a “Cafeteria Plan”- which enables you to elect to save, on a pre-tax basis, a portion of your salary into accounts that you can use to pay your share of medical expenses, dental or eye care costs, child care, and other items, subject to certain limits. Please contact the Human Resources Department for additional information regarding this plan.

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3.13 Does SEKO offer a Health Savings Account? SEKO offers a Health Savings Account under Section 125 of the Internal Revenue Code, commonly known as a “Cafeteria Plan”- which enables you to elect to save, on a pre-tax basis, a portion of your salary into an account that you can use to pay your share of medical expenses, dental or eye care costs, and other items, subject to certain limits. The Health Savings Account may only be used by employees if they elect the high deductible medical plan option offered by SEKO. Please contact the Human Resources Department for additional information regarding this plan. 3.14 Does SEKO offer an Employee Assistance Program? SEKO offers an Employee Assistance Program (“EAP”). The EAP provides twenty-four (24) hour confidential access to assistance and counseling for personal and workplace issues. Please contact the Human Resources Department for additional information regarding this plan. SEKO may from time to time offer other benefits. Please contact the Human Resources Department for further information.

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EVERYTHING WE DO IS FOCUSED ON MAKING OUR CUSTOMERS’ LIVES EASIER

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SECTION 4 ARE THERE GENERAL EMPLOYEE POLICIES WHICH APPLY TO YOU? 4.1 Is your SEKO Employment At-Will? All employees are employed at the will of SEKO for an indefinite period, unless the CEO or President of SEKO has signed an agreement on behalf of SEKO stating otherwise. Any employee may resign from SEKO at any time, for any reason; likewise, any employee may be terminated, for any reason or for no reason at all, with or without notice. No fixed term of employment is expressed or implied by SEKO. Any written or oral statement to the contrary by an advisor or other agent of SEKO is invalid and should not be relied on by any prospective or current employee. 4.2 What Hours of Work are expected of you? HOURS OF WORK Due to the nature of SEKO’s work, your regular hours of work may vary and/or change as assigned by your department manager, from time to time. Employees are entitled to receive one (1) hour of unpaid lunch beginning no later than five (5) hours after commencing work in each seven and one-half (7½) hour work period and two (2) fifteen (15) minute breaks, one (1) during the first four (4) hours of your shift and one (1) during the second four (4) hours of your shift, as scheduled by your department manager. To service our customers, it is anticipated that from time to time you may be required to work longer hours and/or change personal plans on short notice, although SEKO will use its best efforts to minimize these inconveniences.

RECORDING OF TIME All hourly and part-time employees are responsible for keeping an accurate record of all hours they work using Biometric Information (see section 4.3 of this Handbook). Time records should reflect the time they start and stop work, as well as the time they start and stop their meal period. The beginning and end of any split shift, leaving the office for any non-work related purpose (including a meal break) or departure from work for personal reasons must be reflected on time records. Hourly employees are prohibited from starting before their scheduled starting time or working beyond their scheduled stopping time, without the express approval of their manager. Any correction or adjustment that is made to time records must be approved and initialed by your manager. OVERTIME COMPENSATION Hourly employees will be paid at one and one- half (1.5) times their regular hourly rate of pay for time worked in excess of forty (40) hours in any week. Hours paid but not worked, such as vacation or sick/personal days, are not counted towards hours worked for overtime. Overtime is not at the employee’s discretion and should be approved in advance by your supervisor. Working unauthorized overtime may lead to disciplinary action up to and including termination. ABSENTEEISM AND TARDINESS You are expected to be at work on time each scheduled day. In those cases where you cannot attend work due to sickness or other event, you must attempt to first contact your manager at the earliest possible time via phone, preferably well in advance of your absence. If unable to reach your manager, then you must attempt to reach your manager’s manager or the Human Resources Department. Failure to maintain regular attendance and/or dishonesty regarding absence from work due to illness or any other reason may result in your termination. You are not permitted to make up time due to a late arrival without the prior written approval of your department manager.

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4.3 How do you provide Biometric Information to record the hours you work? SEKO collects employees’ Biometric Information in the form of a Hand Scan, Finger Scan or otherwise, for purposes of punching in and out for work. This device protects everyone from fraudulent transactions by ensuring that only the authorized individual can initiate a time punch. In this way, the collection of Biometric Information protects our employees’ privacy by ensuring that no one else can conduct transactions on your behalf. A Hand Scan or Finger Scan, as the case may be, is a biometric device that identifies an image of your hand or finger geometry. This technology is not the same as a “fingerprint” and Hand or Finger Scanners do not record the surface details of your hand or finger. Rather, the Scanners work by capturing a three-dimensional image of your hand or finger and developing a template by running your unique hand or finger measurements through an algorithm that concentrates the information. The unique template is then stored as a mathematical value, along with the employee’s ID number. There is no way that a person’s hand or finger shape can be digitally reconstructed from the stored Biometric template. SEKO collects and stores your Biometric Identifier upon your date of hire. The Biometric Identifiers are used exclusively for the purpose set forth in this Policy – for verifying the employee time punches. SEKO takes measures to ensure that this Biometric Information is kept confidential and does not disclose this Information to third parties. The Biometric Identifier is retained in SEKO’s Payroll system throughout your employment. Upon termination of your employment, the Biometric Identifier will be destroyed as soon as reasonably possible and the Human Resources Department will delete this Information as part of the termination process. In no event will the employee’s Biometric Identifier be retained for a period longer than three (3) years from the date of termination with SEKO. By signing the Handbook Acknowledgement contained herein, I acknowledge receipt of SEKO’s Policy on Biometric Information. I hereby consent to the use of my Biometric Identifier for the purposes described herein.

4.4 When will you be paid? All SEKO employees are paid bi-weekly, approximately one (1) week in arrears. If a payday falls on a holiday or a weekend, then the payday occurs on the prior workday. A direct deposit program is available and you are encouraged to have your paycheck deposited directly into your personal bank account(s). Notify the Human Resources Department if you wish to enroll. After turning in the paperwork for this program, it normally takes two (2) paycheck periods to take effect. Should you have any questions about your paycheck, please notify Payroll. 4.5 Does SEKO provide Training and Development? TRAINING From time to time, SEKO changes its office equipment and other equipment. As a condition of employment, all employees must be amenable to training on new equipment, and must achieve acceptable performance standards in the operation of such equipment. Although SEKO establishes company-wide training objectives from time to time, managers are responsible for determining the training needs of their employees - following through to ensure the employee receives the desired training, and keeping detailed and accurate records of the training received. PERFORMANCE EVALUATIONS In addition to performance feedback given on an informal basis throughout the year, all employees will participate in performance reviews twice each calendar year. Two-way communication is encouraged as we mutually review performance and establish new goals and objectives for the next year. EMPLOYEE DEVELOPMENT SEKO is committed to the development and individual growth of its employees. Employees who are interested in professional growth and development should see their department manager or the Human Resources Department to discuss their development.

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4.6 What if you become Disabled? SEKO complies with the Americans with Disabilities Act (“ADA”), as amended by the ADA Amendments Act (“ADAAA”), and all applicable state and local fair employment practices laws - and is committed to providing equal employment opportunities to qualified individuals with disabilities. Consistent with this commitment, SEKO will provide a reasonable accommodation to disabled applicants and employees if the reasonable accommodation would allow the individual to perform the essential functions of the job, unless doing so would create an undue hardship. Please see the Human Resources Department for more information, including policy documentation and procedure for requesting an accommodation. 4.7 What if you have an Accident? Any accident, no matter how slight or trivial it may appear, should be reported immediately to the Human Resources Department. This applies to accidents involving employees, clients or other visitors.

4.8 What if you have a Medical Emergency or need to Evacuate the workplace? If an employee is in need of medical attention, please notify your manager and request assistance. If you believe the situation merits trained medical personnel, please contact 911 immediately and inform 911 of the individual’s symptoms, location and any other information 911 requests. For evacuation procedures in Itasca, Illinois, please see the SEKO Emergency Evacuation Policy. All other locations, please see the local Emergency Evacuation Policy. 4.9 Does SEKO have a Smoking Policy? SEKO values the health of our employees and, therefore, has a no-smoking policy. Smoking by employees is strictly prohibited at all times in all areas on the premises (including the building and the parking lot), except in designated smoking areas. The Itasca, Illinois smoking area is in a designated area in the parking lot on the west side of the building and employees are required to stand a certain number of feet from the building entrance. This policy applies equally to all employees, clients, and visitors.

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4.10 Does SEKO allow Drugs or Alcohol in the Workplace? SEKO is committed to programs that promote safety in the workplace and employee health and well-being. Employee involvement with drugs and alcohol can adversely affect job performance and employee morale - and jeopardize employee safety. It is our goal to establish and maintain a healthy and efficient work force free from the effects of drug and alcohol abuse. USE, POSSESSION, TRANSPORTATION, SALE, DISTRIBUTION The use, possession, sale, transportation, or distribution of any controlled or illegal substance or alcohol (except for alcohol served at business social events consumed within the legal limits for the operation of a motor vehicle) by any employee while on SEKO property, or while conducting SEKO business off SEKO property, is cause for disciplinary action. TESTING FOR DRUGS OR ALCOHOL SEKO requires a pre-employment drug test for all job applicants and, upon reasonable suspicion of drug or alcohol use, an employee may immediately be required to submit to blood or urine tests, or to other diagnostic tests to detect alcohol or drugs in his or her system. Any employee who refuses to submit to testing under these circumstances shall be subject to disciplinary action. REPORTING CONVICTIONS Employees must, as a condition of employment, abide by the terms of the above policy, and report any conviction under a criminal drug statute for violations occurring on or off SEKO property while conducting SEKO business. A report of a conviction must be made within five (5) days after the conviction. This requirement is mandated by the Drug-Free Workplace Act of 1988. EMPLOYEE ASSISTANCE PROGRAM SEKO encourages any employee with a drug or alcohol problem to contact his or her manager or the Human Resources Department. SEKO will, at the employee’s request, refer him or her for professional assistance. All communications will be kept as confidential as possible. Employees will not be subject to discipline for voluntarily acknowledging a drug or alcohol problem prior to detection.

4.11 Will SEKO verify the information in your Employment Application? Will SEKO respond to Reference Checks about you? SEKO relies upon the accuracy of information contained in the employment application, as well as the accuracy of other >Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 16 Page 17 Page 18 Page 19 Page 20 Page 21 Page 22 Page 23 Page 24 Page 25 Page 26 Page 27 Page 28

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