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EMPLOYEE HANDBOOK

ISSUED MARCH 2017

Table of Contents

Section 1 – Welcome & Introductory Provisions 1.1 Welcome Message ....................................................................................................... 1 1.2 Introductory Statement ................................................................................................. 1 1.3 Overview of Dougherty Financial Group .................................................................... 2 1.4 Employment At-Will ................................................................................................... 2 1.5 EEO Policy .................................................................................................................. 3 1.6 Prohibition Against Harassment .................................................................................. 3

Section 2 - Rules & Policies 2.1 Artwork ....................................................................................................................... 6 2.2 Wages & Salary Policies .............................................................................................. 7

Timekeeping ......................................................................................................... 7 Overtime ............................................................................................................... 7 Administrative Pay Corrections ............................................................................ 8 Pay Advances ........................................................................................................ 8 Pay Deductions ..................................................................................................... 8 Paydays ................................................................................................................. 8 Minnesota Wage Disclosure Protection ................................................................ 9

2.3 Business/Travel Expense Policy .................................................................................. 9 2.4 Work Schedules .......................................................................................................... 13

Flexible Schedules & Telecommuting ................................................................ 13 Nursing Mothers ................................................................................................. 14

2.5 Performance Management ......................................................................................... 14 Job Descriptions .................................................................................................. 14 Performance Evaluation ...................................................................................... 15 Progressive Discipline ........................................................................................ 15

2.6 Personnel Records ...................................................................................................... 16 2.7 Conflict Resolution Policy ......................................................................................... 18 2.8 Separation or Termination of Employment ............................................................... 19 2.9 Non Solicitation ......................................................................................................... 20 2.10 Safety ....................................................................................................................... 20

First Aid Kits ...................................................................................................... 21 Fire Emergency ................................................................................................... 21 Severe Weather Emergency ................................................................................ 21 Bomb Threat ........................................................................................................ 21 Disaster Recovery ............................................................................................... 23 Everbridge Notification System .......................................................................... 23 Visitors in the Workplace ................................................................................... 23 Security Checks .................................................................................................. 23 Prohibition Against Violence .............................................................................. 24

2.11 Background Check Policy ........................................................................................ 24 2.12 Confidentiality ......................................................................................................... 25 2.13 Conflicts of Interest .................................................................................................. 25 2.14 Personal Relationships in the Workplace ................................................................. 26 2.15 Social Media Policy ................................................................................................. 27

Table of Contents

2.16 Standards of Conduct ............................................................................................... 28 2.17 Whistleblower Policy ............................................................................................... 32

Section 3 – Benefits 3.1 Employee Benefits ..................................................................................................... 34

401(k) Savings Plan ............................................................................................ 34 Health Insurance Plans ........................................................................................ 34 Life Insurance Plans ............................................................................................ 35 Long Term Disability .......................................................................................... 35 Short Term Disability ......................................................................................... 35 Worker’s Compensation ..................................................................................... 36 Flexible Spending Accounts ............................................................................... 36 Service Awards ................................................................................................... 36 Gifts .................................................................................................................... 36 Matching Gifts Program ..................................................................................... 46 Employee Assistance Program ........................................................................... 37

3.2 Time Off .................................................................................................................... 37 Paid Time Off (PTO) .......................................................................................... 37 Holidays .............................................................................................................. 39

3.3 Leaves of Absence .................................................................................................... 42 FMLA ................................................................................................................. 42 Personal Leave .................................................................................................... 44 Bereavement Leave ............................................................................................. 45 Bone Marrow Donation Leave ............................................................................ 45 Military Leave ..................................................................................................... 45 Jury Duty ............................................................................................................. 46 Time Off to Vote ................................................................................................. 47 Witness Duty ....................................................................................................... 48 Parental Leave ..................................................................................................... 49

Section 4 - Acknowledgment 4.1 Employee Acknowledgement Form ........................................................................... 50

SECTION I: WELCOME & INTRODUCTORY PROVISIONS

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1.1 Employee Welcome Message Welcome to the Dougherty Financial Group LLC (DFG) family. It is a pleasure to have you as an employee.

We recognize that our employees represent our most important resource. We believe each employee contributes directly to our growth and success, and we hope you will take pride in being a member of our team.

This Handbook was developed to describe some of the expectations of our employees and to outline the policies, programs, and benefits available to those eligible. Employees should familiarize themselves with the contents of the Handbook as soon as possible, as it will answer many questions about employment with DFG.

We hope that your experience here will be challenging, enjoyable, and rewarding.

1.2 Introductory Statement This Handbook is designed to acquaint you with DFG and its affiliates, which include Dougherty & Company LLC, Dougherty Funding LLC, Dougherty Mortgage LLC, Dougherty Equipment Finance LLC, Dougherty Wealth Advisers LLC, Dougherty Real Estate Equity Advisors LLC, and Dougherty Insurance Agency LLC (hereafter referred to as "the Company") and provide you with information about working conditions, employee benefits, and some of the policies affecting your employment. You should read, understand, and comply with all provisions of the Handbook. It describes many of your responsibilities as an employee and outlines the programs developed by the Company to benefit employees. One of our objectives is to provide a work environment that is conducive to both personal and professional growth.

No employee handbook can anticipate every circumstance or question about policy. This Handbook is intended to provide information for the guidance and reference for all employees. In addition, descriptions of certain benefits in this Handbook are limited. Employees should review the various benefit plan documents and Summary Plan Descriptions for information regarding such benefit plans. If anything said or implied in this Handbook is different from the actual provisions of a benefit plan document or a written benefit insurance contract, the plan document or insurance contract will govern. The Company reserves the right to amend and/or terminate its benefit plans and/or programs at any time at its sole discretion with or without prior notice.

As the Company continues to grow, the need may arise, and the Company reserves the right to revise, supplement, or rescind any policies or portion of the Handbook as it deems appropriate, in its sole and absolute discretion without prior notice. The only item that may not be subject to change is our employment at-will policy permitting you or the Company to end our relationship for any reason at any time. The Company intends to notify employees of such changes to the Handbook as they occur by providing written addenda. Employees will be asked to acknowledge any changes by signing an Addendum Acknowledgment form. The Company also reserves the right to vary from any of the policies and practices, oral and written representation or statements regarding the terms and conditions of your employment with the Company.

The policies in this Handbook are drafted to comply with all applicable state and federal laws. In the case of any inconsistencies between these policies and local, state, or federal law, those laws apply. If you have any questions about the application of any of these policies in the state in which you work, please ask a Human Resources Representative.


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This Handbook supersedes and replaces any and all personnel policies or Handbooks previously distributed to employees. All such previous policies or Handbooks are expressly revoked.

1.3 Overview of Dougherty Financial Group There are approximately 270 employees in the Dougherty Financial Group LLC organization. Approximately 75% of our employees reside in the Wells Fargo Center in downtown Minneapolis. An overview of each company is listed below:

Dougherty Financial Group LLC: Dougherty Financial Group LLC (DFG), headquartered in Minneapolis, is the holding company for the financial services firms listed below.

Dougherty & Company LLC: Dougherty & Company LLC (DCO) is a registered securities broker-dealer with over 35 years of experience, specializing in investment and capital-raising strategies to help clients achieve their long-term investment objectives. As a full-service investment banking and investment services firm, Dougherty & Company offers a wide array of investment products and services to institutions and individuals nationwide.

Dougherty Wealth Advisers LLC: Dougherty Wealth Advisers LLC (DWA) provides financial planning and tax management services to high-net worth individuals and their families. We work with clients at a variety of life stages, including mid-level executives, senior executives, entrepreneurs, retirees and multi-generational family business owners.

Dougherty Funding LLC: Dougherty Funding LLC (DF) specializes in the origination, funding and servicing of commercial real estate and equipment leasing nationwide. The loans are placed as participations to an extensive network of community bank clients. DF’s services are designed to enhance and diversify bank loan portfolios without compromising asset quality.

Dougherty Mortgage LLC: Dougherty Mortgage LLC (DM) is a mortgage banking firm that specializes in financing conventional and affordable multifamily housing, senior housing, student housing and healthcare facilities nationwide. As an approved Fannie Mae DUS® lender, FHA/HUD lender and Fannie Mae issuer, we offer a variety of loan products for the acquisition, refinance, construction or rehabilitation of various property types. Dougherty Mortgage has also been awarded designation as a lender/partner with the USDA under the Communities Facilities Guaranteed Program.

Dougherty Equipment Finance LLC: Dougherty Equipment Finance LLC (DEF) originates, places and services equipment loans and leases that typically involve transportation, energy, manufacturing and other asset types. Dougherty Equipment underwrites each transaction and sells them as single and multi-party participations to an extensive network of community and regional banks. For its leasing transactions, the company acts as lessor, owner trustee and servicer.

Dougherty Real Estate Equity Advisors LLC: Dougherty Real Estate Equity Advisors LLC (DREA) is a real estate asset management company. DREA’s focus is on property acquisition, investment fund structuring, underwriting and asset management services.

Dougherty Insurance Agency: Dougherty Insurance Agency LLC (DIA) is an insurance brokerage providing commercial and personal lines, insurance solutions and products, to organizations and individuals nationally.

1.4 Employment At-Will The provisions contained in this Handbook, and any of the companies’ policies, do not constitute contracts of employment, nor are they promises for continued employment. All Company employees are employed at-will. Employment at-will means that either the Company or an employee may terminate the


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employment relationship at any time without prior notice and for any reason. Nothing anywhere in this Handbook alters the at-will employment relationship.

Employment with the Company is voluntarily entered into, and the employee is free to resign at-will at any time, with or without cause. Similarly, the Company may terminate the employment relationship at-will at any time, with or without notice or cause, so long as there is no violation of applicable federal or state law.

1.5 Equal Employment Opportunity Policy It is the policy of the Company to provide equal employment opportunity to all qualified employees and qualified applicants for employment without regard to religion or religious creed, race, color, ethnic group identification, age, national origin, ancestry, physical disability, mental disability, medical condition, genetic information, marital status, familial status, military and veteran status, and sex, gender, gender identity, gender expression, or sexual orientation, or any other basis protected by law. This policy applies to the terms and conditions of employment including, but not limited to, hiring, placement, training, compensation, transfer, promotion, leave of absence, termination, layoff, and recall.

It is also the stated policy of the Company to prevent and prohibit any kind of harassment, particularly including sexual or racial harassment, with respect to co-employees, subordinate employees, or supervisors.

Any employee who believes he/she has been subjected to any conduct that may violate this Equal Employment Opportunity Policy should bring their complaint to the attention of their supervisor or Human Resources immediately.

The Company considers the implementation and monitoring of this Equal Employment Opportunity Policy to be an important part of each supervisor’s responsibility. Supervisors will inform all employees of the Policy and shall take positive steps in an effort to seek adherence to the Policy by all employees within the sphere of their responsibility.

The failure of any employee to comply fully with the Policy will be grounds for discipline up to and including termination.

Retaliation against any employee who makes a complaint about improper conduct, or against any other employee who provides information in support of the complaining employee, is strictly forbidden.

1.6 Prohibition Against Harassment It is the express policy of the Company that it does not, and will not, tolerate unlawful harassment of any employee. In particular, harassment of any employee (whether by a supervisor, co-employee, or non-employee encountered in connection with work) on the basis of race, creed, color, religion, sex, including sexual orientation and gender identity, national origin, ethnicity, age, disability, genetic condition or information, certain military or veteran status, or any other basis protected from discrimination or harassment by applicable federal, state or local law, is strictly prohibited. Note that additional forms of discrimination or harassment are also prohibited by this policy, even if not explicitly listed here, to the extent that they are prohibited under applicable law. Each employee is responsible for assuring that the work place is free from harassment, and you may be disciplined, up to and including discharge, for any violation of this policy.

Harassment includes actions that denigrate or show hostility or aversion toward persons of a protected class or have the purpose or effect of creating an intimidating, hostile, or offensive work environment,


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unreasonably interfering with an individual’s employment or otherwise adversely affect an individual’s employment opportunities. Depending on the circumstances, prohibited harassment may include, but is not limited to, jokes or other comments that demean any group, based on ethnicity, age, gender, religion or other protected group, racial, sexual, or other slurs, epithets, threatening or intimidating acts, as well as written or graphic material. This may include written, oral, or physical acts, even if they are intended to be jokes or pranks.

Sexual harassment is one of the forms of harassment that is prohibited by this policy, whether by someone of the same or opposite sex. Sexual harassment involves unwelcome (i) sexual advances, (ii) requests for sexual favors, or (iii) other verbal, written, or physical conduct of a sexual nature when:

• submission to the conduct is made a term or condition of an individual’s employment, either explicitly or implicitly;

• submission to, or rejection of the conduct by an individual is used as the basis for any employment decision affecting that individual; or

• the conduct unreasonably interferes with an individual’s employment or creates an intimidating, hostile, or offensive working environment.

Some examples of conduct which may constitute sexual harassment, depending on the circumstances, include the following:

• Unwelcome requests or pressure for sexual favors, including any suggestion that an applicant’s or employee’s giving in to, or rejecting, sexual advances will have an effect on the individual’s employment or terms of employment, including any grant, denial, or withholding of a promotion or other employment benefit or impact on an employee’s status.

• Unwelcome sexual advances or propositions or repeated unwelcome flirtations or suggestions regarding or invitations to, social events, engagements.

• Verbal, visual, or physical conduct of a sexual nature, including repeated remarks of a sexual nature.

• Verbal abuse of a sexual nature. • Displaying sexually suggestive pictures, drawings, cartoons, or objects. • Degrading comments about an individual’s appearance, including his/her body. • Any uninvited, unwelcome, and/or unnecessary touching • Frequent use of profanity. • Viewing or downloading of offensive or pornographic materials from the Internet,

including e-mails, or distributing sexual materials, including jokes, received by email.

In order to promote a work environment that is free from harassment to the greatest extent reasonably possible, each employee should ensure that his/her conduct is respectful and does not, and is not perceived by others to violate this policy.

Complaint Procedure Any employee who believes there has been a violation of policy or law should report the matter immediately to their supervisor, department head, or Human Resources. If the report concerns an employee’s supervisor, or a member of management, the employee should report the concern to Human Resources.

If a suspected violation of policy or law reoccurs, or in the event of any attempted interference with, or retaliation for, a good faith filing of a report, a report should also be immediately reported to any of the individuals listed above.


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Complaints will be handled with sensitivity toward confidentiality, understanding that an investigation will often include conferring with the parties involved and potential witnesses, along with those who need to know so as to respond to the complaint.

The Company will determine any responsive action to be taken, which may include disciplinary action up to termination.

The Company will not tolerate interference with, or retaliation against an employee for, a good faith filing of a complaint or for assisting in an investigation. It is a violation of Company policy to file a knowingly false accusation of harassment.

SECTION II: RULES & POLICES

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2.1 Artwork

Common Spaces Pieces from our corporate art collection will be placed in common spaces on floors 43, 44, and 45 of the Wells Fargo Center building. Common areas include elevator areas, lobbies, corridors, reception/seating areas and walls/columns in an employee’s division or department.

Offices and Cubes Employees may place appropriate personal art in his/her office or cubicle; however the Company wants to ensure that cubicles, as well as permanent walls aren't soiled or damaged unnecessarily. In addition, it's important that art which is visible to the public, even though not in "common space" be appropriate and not offensive.

The following list of "do's and don’ts" is a guideline when decorating the work space:

Do's

• Hang only framed photos, posters, awards and other "art" in private offices. Per building management, we are not allowed to hang anything on the outside walls. Employees should call the receptionist to arrange the hanging of his/her art work.

• Employees should feel free to display family pictures, clocks and personal memorabilia on their desk or office furniture.

• Select art for the work space that's appropriate to a business environment (offensive or sexist art or cartoons are prohibited).

• Employees should confine personal artwork to their own space (with nothing visible above or on the outside of their cubicle).

• All employees are responsible for maintaining an uncluttered, classy ambiance of the Company.

Don'ts

• Place any objects on the windowsills, on top of neither cube walls nor the top of flip top cabinets. • Hang clocks or mirrors on cubicle walls. (A clock on a desk is fine.) • Tape, pin or nail anything to the outside of cubicle walls. For walls insides cubicles, "T" pins

work best. These are available from the supply room on the 43rd floor. • Hang coats over the outside of the cubicle walls.

“Appropriate art” for a private office is:

• Consistent with a work environment • Framed, in good condition, under glass (when needed.)

Purchases of corporate art are to be coordinated through the Chairman’s Executive Assistant and must be approved prior to purchase. Public art purchased without following this procedure, may be purchased by the requisitioning individual and moved to personal space or will be returned.


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2.2 Wages & Salary Policies

Timekeeping Accurately recording time worked is the responsibility of every non-exempt employee. Federal and state laws require the Company keep accurate records of time worked in order to calculate employee pay and benefits. Time worked is all the time actually spent on the job performing assigned duties.

Non-exempt employees should accurately record the time they begin and end their work, as well as the beginning and ending time of each meal period. They should also record the beginning and ending time of any departure from work for personal reasons. Overtime work must always be approved before it is performed.

Altering, falsifying, tampering with time records, or recording time on another employee's time record may result in disciplinary action, up to and including termination of employment.

All non-exempt (hourly) employees are required to submit a weekly timecard. The Company's workweek is defined as a consecutive seven-day period beginning on Sunday and ending on Saturday. All timecards must be received by Payroll no later than 10 a.m. on Tuesday for the prior week. All timecards require the signature of an employee’s immediate manager. If an employee’s manager is out of the office, a second level manager may sign his/her timecard. If a timecard is not received by the 10 a.m. deadline, an employee may not receive a check which accurately reflects the time worked. If this occurs, the actual time worked will be reflected on the next practical paycheck.

All time less than whole hours must be recorded in fractions of a quarter of an hour (i.e., .15, .30, and .45). All start and stop times may be rounded up or down to the nearest quarter of an hour. All minutes equal to or greater than 8, 24, 39, and 54 should be rounded up to the nearest quarter of an hour and all numbers equal to or less than 7, 23, 38, 53 should be rounded down to the nearest quarter of an hour. For example, an employee arrives to work at 8:05 and leaves at 5:09. This employee would round down their start time down to 8:00 and round their stop time up to 5:15. This is an averaging principle that is used for timecard calculation purposes only. It does not replace any fixed work schedule that an employee and his/her manager have agreed upon. For example, if an employee is required to work 8-5 he/she may not arrive at 8:07 and round his/her time down to 8:00.

Employees must record all time out of the office during their regularly scheduled work hours (lunch breaks, doctor and dentist appointments, etc.). Employees are allowed up to one hour per day for a non-paid lunch break. All time away from work (except lunch breaks) must be pre-approved by an employee’s manager. It is expected that personal errands will be run during an employee’s lunch hour and not during his/her regularly scheduled work hours.

An electronic read-only version of the Company’s timecard can be found on UltiPro. Employees must complete all of the highlighted areas. In order for the timecard to properly calculate an employee’s hours, all times must be recorded in fractions of a quarter of an hour and with an AM or PM indicated after the time. Example-8:15 a.m.

Overtime 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 as practical to all employees qualified to perform the required work.

Federal law requires that non-exempt employees be paid for all time that is worked. As a result, the Company expects that employees will work their agreed upon hours each week or cover the non-working


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time with PTO. Only in very rare circumstances should an employee record unpaid time on his/her timecard. If an employee has been hired to work 40 hours per week, the combination of his/her worked and non-worked time (PTO) should equal 40 hours. Excessive unpaid time will be treated as an attendance issue which will be subject to disciplinary action up to and including termination.

The Company will pay overtime to any non-exempt employees who work in excess of 40 hours in one week. For purposes of overtime calculations, hours worked will be defined as regular hours, holiday hours, birthday hours, or when the Company makes a decision to close the office (severe weather, etc.). Hours not worked includes vacation, sick, funeral or jury duty time. Overtime will be paid at a rate equal to 1.5 times an employee’s hourly wage. Overtime will not be paid for more than 8 hours worked in one day unless the cumulative worked hours exceed 40 hours for the week. For California employees, overtime pay is based on the number of hours worked in a day. All overtime must be approved in advance by an employee’s manager.

Employees who work overtime without receiving prior authorization from their supervisor may be subject to disciplinary action, up to and including possible termination of employment.

Administrative Pay Corrections The Company takes all reasonable steps to ensure that employees receive the correct amount of pay in each paycheck and that employees are paid promptly on the scheduled payday. If there is a discrepancy in the amount of pay, the employee should promptly bring the discrepancy to the attention of the Payroll Department so that corrections can be made by the next payroll period, if indeed an error occurred.

Pay Advances The Company does not provide pay advances on unearned wages to employees.

Pay Deductions The law requires that the Company make certain deductions from every employee's compensation. Among these are applicable federal, state, and local income taxes. The Company also must deduct Social Security taxes on each employee's earnings up to a specified limit that is called the Social Security "wage base." The Company matches the amount of Social Security taxes paid by each employee.

The Company offers programs and benefits beyond those required by law. Eligible employees may be asked to authorize deductions from their pay checks to cover the costs of participation in certain programs.

Questions concerning why deductions were made from an employee’s pay check or how they were calculated can be directed to Human Resources or Payroll.

Paydays All Company employees, except Dougherty & Company commissioned employees, are paid semimonthly on the 15th and the last business day of the month. Dougherty & Company commissioned employees are paid monthly on the 15th day of the month. Each paycheck will include earnings for all work performed through the end of the previous payroll period.

If a regularly scheduled payday falls on a non-business day such as a weekend or holiday, employees will be paid on the last day of work before the regularly scheduled payday.


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Employees may have pay directly deposited into their bank accounts if they elect to do so under the “Pay” section of UltiPro. Employees have access to an itemized statement of wages when the Company makes direct deposits. Employees who have their pay directly deposited, can access copies of their paystubs on the UltiPro Self Service Portal.

Under Department of Labor Section 409A rules, compensation (which may include retirement benefits, commissions or other incentives) may be considered deferred compensation if not paid in the year earned or within 2 ½ months after year-end.

If an agreement or arrangement includes deferred compensation features and those features are not exempted from Section 409A, they will have to comply in form and operation with the rules. If a feature does not comply, the employee or contractor entitled to the benefit will incur the direct adverse tax consequences.

Unless written approval has been granted by the Firm’s Chief Executive Officer, all compensation for each year will be paid within 2 ½ months of year–end.

Minnesota Wage Disclosure Protection Under the Minnesota Wage Disclosure Protection law, employees have the right to tell any person the amount of their wages. The company cannot retaliate against you for disclosing your own wages. Your remedies under the Wage Disclosure Protection law are to bring a civil action against your employer and/or file a complaint with the Minnesota Department of Labor and Industry at (651) 284-5070 or 1-800-342-5354.

2.3 Business and Travel Expense Policy The Company will reimburse employees for reasonable business travel expenses incurred while on assignments away from the normal work location. All business travel must be approved in advance by the Department Manager.

When approved, the actual costs of travel, meals, lodging, and other expenses directly related to accomplishing business travel objectives will be reimbursed by the Company. Employees are expected to limit expenses to reasonable amounts.

When travel is completed, employees should submit completed travel expense reports on the Concur website within 60 days. Reports must include receipts for all individual expenses as required by the Company for IRS requirements.

Employees should contact their supervisor for guidance and assistance on procedures related to travel arrangements, expense reports, reimbursement for specific expenses, or any other business travel issues.

Airfare Employees are expected to use the most economical method of transportation, which includes making travel arrangements as early as possible to take advantage of discount fares.

Employees are requested to book economy class tickets whenever traveling on company business. The Company will reimburse for reasonable checked bag fees any meals or lodging expenses that result from being bumped from a flight and not reimbursed by the airline will be reimbursed to you by the Company.

Frequent flyer points/mileage earned for business flights are for the employee to use as he/she wishes. The Company reimburses travel expenses based on the cost for the most direct route. Deviations from the most direct route that are not made for business reasons should be recorded as a personal expense, with


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the extra cost excluded from the expense report. The employee will need to provide an image of the airline ticket or other detailed receipt as receipt for the flight.

Corporate Credit Cards The Company does not issue corporate credit cards for employee or corporate use at this time.

Rental Car Employees should reserve a standard to mid-size car and request the most economical rental rates. Employees should purchase loss damage and supplemental insurance from the car rental company. If the employee fails to purchase such coverage and the rental car is damaged in any way, the employee will need to submit any resulting claim using his or her personal auto insurance policy.

Employees who are involved in an accident while traveling on business must promptly report the incident to their immediate supervisor. Vehicles rented by the Company may not be used for personal use without prior approval.

Personal Car Reimbursement for use of a personal automobile will be made using the maximum allowable rate permitted by IRS regulations. This reimbursement will exclude mileage to and from the office. The current mileage rate is intended to reimburse your expenses of operating the vehicle, such as fuel, maintenance, interest, depreciation, insurance and other expenses associated with the vehicle.

If an employee parks his/her car at the airport, he/she will be reimbursed for the airport parking fee as well as the mileage in excess of the normal commute to and from home.

Taxi/Train Taxi or train travel expense to and from airport terminals are reimbursable with receipts. The employee may combine taxi/train expenses into one total on the expense report form as long as the total is less than $25.00. The employee will need to provide a receipt for any one-time taxi or train ride costing more than $25.00 to document this expense.

Lodging An employee is expected to select a hotel of good reputation in a convenient location for the business purpose of travel. Request a room at the minimum rate providing adequate accommodations.

The Company encourages employees to take advantage of "corporate" rate discount programs whenever possible. In order to be reimbursed for hotel expenses, the employee must provide an itemized hotel receipt as an attachment to expense reports. A receipt from the credit card charge will not suffice.

The Company does not reimburse for any hotel charges incurred for movies, spa/athletic fees, laundry/dry cleaning (except as described below), minibar or other charges not directly related to the business purposes of the trip. Room service items (e.g., breakfast, bar and incidentals) should be designated in Concur as Employee Meals and not included in Hotel expense. Dry/cleaning/laundry will be an approved expense only if the employee has been on a trip for at least four days in a one-week period without being home.

Hotel Phone and Internet Phone and internet charges incurred at a hotel will only be reimbursed to the extent they were necessary for the business purpose of the trip. Phone and internet charges should be included in Concur under Hotel Internet and not under Hotel.


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Tipping The Company recognizes that tipping is a necessary and customary expense, and is an acceptable expense when confined to reasonable limits. An employee may lump all tips together in one item on the expense report form as long as the total does not exceed $25.00. Individual tips totaling more than $25.00 will need receipts for documentation The company will accept a line item of $25.00/week for tips assuming a one-week trip.

Spouse Travel An employee's spouse or significant other may accompany the employee on a company paid business trip with advance approval from the department manager. In such event, the employee will be responsible for all expenses incurred on behalf of the spouse that are not business related. Any expenses of the spouse that are business related must be approved by the department manager.

Meals & Entertainment Expenses for meals and entertainment must be either directly related to or associated with the business of the Company. Entertainment to accomplish the Company's objectives is allowed but must be reasonable in type and amount.

For expenses to be considered "directly related" the employee must show that:

1. The Company has more than a general expectation of deriving income or some other specific business benefit (other than goodwill) either now or in the future.

2. An active business meeting, negotiation, discussion, or other transaction is conducted during the meal.

3. The main purpose of the combined business and meal or entertainment was the business transaction.

Expenses are "associated with" the active conduct of business where there is a clear business purpose for incurring the expense, such as bringing in new business or encouraging the continuation of the current business relationship. Meals that are associated with the Company's business must directly precede or follow a "substantial and bona fide" business transaction.

The cost for spouses is reimbursable when entertaining without spouses is impractical.

Meals expenses are reimbursable whenever the employee is away from the base location. The cost of the meal away from home is reimbursable (with receipt) even when a business discussion does not take place. The business purpose for the travel provides the business purpose for the meal. The cost of meals varies greatly between location and under different circumstances. The amount spent for meals en route and at the business destination should conform to the general price levels existing at the location.

When submitting meal receipts for reimbursement in Concur, employees should select Meals Attendees, if there were business guests in attendance. Names, titles and company names for the guests must be listed out in Concur, along with a detailed description of the business purpose and a detailed receipt. When submitting a receipt for a meal while traveling with no guests present, Employee Meals should be selected in Concur. The detailed business purpose of the trip should be included as the business purpose for the meal, and a detailed receipt must be included as well.

Non-reimbursable Meal Expenses Incidental business discussions during an activity do not make the activity eligible for reimbursement as an entertainment expense. As a general rule, the Company does not reimburse employees for lunch meetings or after-hour meetings held within the Minneapolis area or branch office areas between two or more employees, although this is subject to management's discretion.


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Non-Reimbursable Expenses Entertainment such as golf, tennis or movies is not reimbursable unless it is an integral part of the business activity. The Company will not reimburse employees for entertainment activities between two or more employees unless a client or prospect is in attendance. Also included in this category are massages and health club fees at a hotel.

Business Purpose Once an activity qualifies for reimbursement, the employee must be sure to document it completely. All expense reports must include detail about who the employee met with, the business relationship with that person and the business purpose of the expense.

Expenses incurred which are not directly related to the active conduct of business will not be reimbursed. If the required information is on an attached itinerary, the itinerary can be referenced.

Season Tickets Purchase of season tickets for a sporting event for business purpose is the employee’s out-of-pocket expense until the tickets are actually used for client entertainment. As tickets are used, the ticket stubs can be submitted for reimbursement on an expense report in Concur, under the expense type Client Entertainment. A clear statement of the business purpose for the usage, and the detailed attendee information is required.

Client Gifts Prior to giving gifts to clients, employees should check with their manager to ensure compliance with FINRA regulations. When submitting receipts for reimbursement for client gifts, Concur expense type Client Gifts should be used and a detailed list of recipients should be included along with the receipt.

Telephone and Postage Telephone and postage expenditures are reimbursable when their use is required for business purpose.

Expense Report Submission and Time Limit The Company uses Concur Solutions to process expense reports and pay employees via direct deposit. Expenses should be entered into Concur and submitted within 60 days of being paid or incurred. Detailed receipts, attendee information, and business purpose descriptions are required. If expense submissions do not contain required details and receipts, or do not meet company policies, the expense item(s) will be returned to the employee by their manager or by accounting within Concur. The employee will need to correct the issue and resubmit the report in Concur in order to receive reimbursement.

Expense Audit In the event the Company is audited and the IRS determines that expense documentation is inadequate, any disallowed expense will become taxable income to the employee incurring the expense.

Abuse of this business travel expenses policy, including falsifying expense reports to reflect costs not incurred by the employee, can be grounds for disciplinary action, up to and including termination of employment.

Travel Pay for Non-Exempt Employees Travel Time Defined: “Travel time” is defined as including the time the employee arrives at the airport to the time the employee reaches his or her destination. If an employee is traveling to a location, then the destination is either the hotel or the worksite. (If the employee is returning home from a location, the destination is the airport of final arrival).


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Travel Time within Normal Work Hours: Any portion of authorized travel time that takes place within normal work hours (defined as 8:00 a.m. to 5:00 p.m.) on any day of the week, including Saturday and Sunday, is treated as normal work hours.

Travel Time Outside of Normal Work Hours:

• When a nonexempt employee is required to travel as a passenger on a plane outside of normal work hours, he or she will be compensated for that portion of travel time that takes place outside of normal work hours.

• Participating in any business related activities at a conference or seminar. • Participating in social activities that an employer requires the employee to attend.

Time Not Paid:

• Participating in social activities that the employee is not required to attend. • Non-business related meal breaks. • Sleeping • Traveling from home to a local airport, bus depot or train station or vice versa. • Traveling from home to a regular designated worksite or vice versa.

2.4 Work Schedules To maintain a productive work environment, the Company expects employees to be reliable and to be punctual in reporting for scheduled work. Absenteeism and tardiness place a burden on other employees and on the Company. In the rare instances when employees cannot avoid being late to work or are unable to work as scheduled, they should notify their supervisor as soon as possible in advance of the anticipated tardiness or absence. Employees who fail to report to work for three consecutive business days without notifying the company of the absence will be considered as having voluntarily resigned as a result of job abandonment.

Poor attendance and excessive tardiness are disruptive. Either may lead to disciplinary action, up to and including termination of employment.

The normal work schedule for all employees is 8 hours a day, 40 hours a week, not including the one-hour meal period. The work week runs from 12:01 a.m. Sunday through Saturday of each week. Each company sets its own schedule of hours to provide services to clients. Normal business hours are from 8:00 a.m. to 5:00 p.m. Supervisors will advise employees of the times their schedules will normally begin and end. Staffing needs and operational demands may necessitate variations in starting and ending times, as well as variations in the total hours that may be scheduled each day and week.

Flexible Schedules and Telecommuting Flexible scheduling, or flextime, is available in some cases to allow employees to vary their starting and ending times each day within established limits. Flextime may be possible if a mutually workable schedule can be negotiated with the supervisor involved. However, such issues as staffing needs, the employee's performance, and the nature of the job will be considered before approval of flextime. Employees should consult their supervisor to request participation in the flextime program.

Telecommuting is the practice of working at home or at a site near the home instead of physically traveling to a central workplace. It is a work alternative that the Company may offer to some employees when it would benefit both the organization and the employee.


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Employees who believe telecommuting can enhance their ability to get the job done should submit a written request to their manager proposing how it will benefit the Company and themselves. The request should explain how they will be accountable and responsible, what equipment is necessary, and how communication barriers will be overcome.

The Company will base a decision to approve a telecommuting arrangement on factors such as position and job duties, performance history, related work skills, and the impact on the organization and is in the sole discretion of the Company.

The employee's compensation, benefits, work status, work responsibilities, and the amount of time the employee is expected to work per day or per pay period will not change due to participation in the telecommuting program (unless otherwise agreed upon in writing).

The employee's at-home work hours will conform to a schedule agreed upon by the employee and his/her supervisor. If such a schedule has not been agreed upon, the Company assumes the employee's work hours are the same as they were before the employee began telecommuting. The employee's supervisor must pre-approve changes to the schedule.

Telecommuting is an alternative method of meeting the needs of the organization and is not a universal employee benefit. As such, the Company has the right to refuse to make telecommuting available to an employee and to terminate a telecommuting arrangement at any time.

Nursing Mothers Recognizing that for many women and their babies, breastfeeding is important, the Company will provide a comfortable private area to express breast milk.

A nursing mother who returns to work full-time may take breaks for lactation purposes for up to one year after the birth of the child*. Generally, the amount of time for breaks will be the same as rest breaks required by law. The timing of the break can be altered to best accommodate the nursing mother and her work schedule. If additional breaks are needed above and beyond the rest breaks required by law, then those breaks will be unpaid.

*State Specific Provisions For employees in the following states, the policy is: California: Nursing mothers may take breaks for lactation purposes for so long as the mother is

nursing her new baby. Colorado: Nursing mothers may take breaks for lactation purposes for up to two years after the birth

of the child.

2.5 Performance Management

Job Descriptions The Company makes every effort to create and maintain accurate job descriptions for all positions within the organization. The Company maintains job descriptions to aid in orienting new employees to their jobs, identifying the requirements of each position, establishing hiring criteria, setting standards for employee performance evaluations, and establishing a basis for making reasonable accommodations for individuals with disabilities.


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Human Resources and the hiring manager prepare job descriptions when new positions are created. Existing job descriptions are also reviewed and revised in order to ensure that they are up to date. Job descriptions may also be rewritten periodically to reflect any changes in the position's duties and responsibilities. All employees will be expected to help ensure that their job descriptions are accurate and current, reflecting the work being done. Employees should remember that job descriptions do not necessarily cover every task or duty that might be assigned, and that additional responsibilities may be assigned as necessary. Employees may contact Human Resources with any questions or concerns about a job description.

Performance Evaluation Supervisors and employees are strongly encouraged to discuss job performance and goals on an informal, day-to-day basis.

An employee’s professional progress is continually being reviewed formally and informally. It is anticipated that at least once a year, an employee and his/her supervisor will discuss the progress the employee is making on the job in a formal review. These reviews are 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. If an employee and his/her manager believe the employee needs more training or specialized experience, this is the time to talk it over. The management staff will help the employee improve his/her job performance by making objective and constructive recommendations. Any problems should be discussed at this time.

Merit-based pay adjustments are awarded by the Company in an effort to recognize truly superior employee performance. The decision to award such an adjustment is discretionary and dependent upon numerous factors, including the information documented by this formal performance evaluation process and company performance.

In addition to the formal appraisal, supervisors may, from time to time, provide employees with informal feedback on performance. These opportunities are valuable learning experiences and employees should feel free to participate in such discussions to the fullest extent possible.

Progressive Discipline Every employee has the duty and the responsibility to be aware of and abide by existing rules and policies. Employees also have the responsibility to perform his/her duties to the best of his/her ability and to the standards as set forth in his/her job description or as otherwise established.

The Company supports the use of progressive discipline to address issues such as poor work performance or misconduct. Our progressive discipline policy is designed to provide a corrective action process to improve and prevent a recurrence of undesirable behavior and/or performance issues. Our progressive discipline policy has been designed consistent with our organizational values and employment laws.

Outlined below are the steps of our progressive discipline policy and procedure. The Company reserves the right to combine or skip steps in this process depending on the facts of each situation and the nature of the offense. The level of disciplinary intervention may also vary. Some of the factors that will be considered are whether the offense is repeated despite coaching, counseling and/or training; the employee's work record; and the impact the conduct and performance issues have on our organization.

The following outlines the Company’s progressive discipline process:

• Verbal warning: A supervisor verbally counsels an employee about an issue of concern, and a written record of the discussion is placed in the employee's file for future reference.


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• Written warning: Written warnings are used for behavior or violations that a supervisor considers

serious or in situations when a verbal warning has not helped change unacceptable behavior. Written warnings are placed in an employee’s personnel file. Employees should recognize the grave nature of the written warning.

• Performance improvement plan: Whenever an employee has been involved in a disciplinary

situation that has not been readily resolved or when he/she has demonstrated an inability to perform assigned work responsibilities efficiently, the employee may be given a final warning or placed on a performance improvement plan (PIP). PIP status will last for a predetermined amount of time not to exceed 90 days. Within this time period, the employee must demonstrate a willingness and ability to meet and maintain the conduct and/or work requirements as specified by the supervisor and the organization. At the end of the performance improvement period, the performance improvement plan may be closed or, if established goals are not met, dismissal may occur.

The Company reserves the right to determine the appropriate level of discipline for any inappropriate conduct, including oral and written warnings, suspension with or without pay, demotion and termination.

2.6 Personnel Records The Company maintains a personnel file on each employee. The personnel file typically includes such information as the employee's resume, records of training, documentation of performance appraisals, salary increases, and other employment records.

Personnel files are the property of the Company, and access to the information they contain is restricted. Generally, only supervisors and management personnel of the Company who have a legitimate business reason to review information in a file are allowed to do so.

Employees have the right to see the following items:

• Application for employment • Wage/salary/compensation history • Fringe benefit information • Notice of commendation • Authorization for a deduction or withholding of pay • Employment history, including: job title, attendance records, date of promotion/transfer/other

changes, retirement records, performance evaluations, warnings, discipline notices, termination notices, leave records, training records, and policy sign-off forms.

Employees may view their personnel files as required by law from the state in which he/she works. A summary of the various state laws are below.

California: Active employees may view their personnel file relating to performance or grievances at any reasonable time and reasonable interval. A “reasonable time” is considered to be during regular business hours or during an employee’s scheduled time at work. A “reasonable interval” implies once a year or when the file has been changed significantly.

Former employees have the right to view and inspect their file until the statute of limitations on any claim against the Company expires.


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Colorado: Active employees may inspect and obtain a copy of any part of their personnel file at a time convenient to both the employer and employee. A former employee may make one inspection of his or her personnel file after termination of employment. Employers may require access to personnel files to take place in the presence of a person responsible for maintaining personnel files or another employee designated by the employer. Employers are also permitted to require the employee or former employee to pay the reasonable cost of copying any part of the personnel file.

Illinois: Active employees must submit a request in writing to review their personnel file. The

personnel file will be made available to be reviewed within seven business days of the written request and will be furnished during normal business hours, at or near the place of employment, or by mail. An employee may view his/her personnel file twice per calendar year at reasonable intervals. Employees may inspect and copy any personnel documents that are, have been, or are intended to be used in determining his/her qualifications for employment, promotion, transfer, additional compensation, disciplinary action, or termination. Employees may also obtain a copy of his/her personnel file.

If an employee disagrees with the information included in his/her own personnel record, the information may be removed by mutual agreement between the Company and employee. If the Company and employee are unable to agree, the employee may submit an explanatory statement that must be included whenever the information is given to a third party.

Former employees, whose employment with the company has terminated within a year, may view their personnel file by submitting a request in writing. The personnel file will be made available to be reviewed within seven business days of the written request.

Minnesota: Active employees who wish to review their own file should submit a written request to

Human Resources. Employees may review their own personnel file once every six months and within seven working days after receipt of a written request. Employees working in Minnesota may review their own personnel file in the Company's offices and in the presence of an individual appointed by the Company to maintain the files during normal business hours. Employees working outside of the state of Minnesota may review their own personnel files upon written request to Human Resources, within fourteen working days after receipt of the written request and in the presence of an individual appointed by the Company to maintain the files during normal business hours. After the review, and upon the employee's written request, the Company will provide a copy of the personnel file at no cost to the employee. The state of Minnesota allows an employee to place rebuttals in his/her employee file.

Former employees, who provide a written request within the 12 months from the date of separation from the Company, will receive a copy of their personnel files from the Company. Former employees in Minnesota can request to review their personnel file once every 12 months as long as the record is maintained.

If an employee works in a state that does not have regulations addressing access to personnel records, then the requirements under Minnesota law will apply.


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2.7 Conflict Resolution Policy

Purpose Problems, misunderstandings and frustrations may arise in the workplace. It is Dougherty Financial Group’s intent to be responsive to its employees and their concerns. Therefore, an employee who is confronted with a problem may use the procedure described below to resolve or clarify his or her concerns.

The purpose of this policy is to provide a quick, effective and consistently applied method for a nonsupervisory employee to present his or her concerns to management, and have those concerns addressed.

Procedures

Step 1: Discussion with Supervisor/Human Resources a) Initially, employees should bring their concerns or complaints to their immediate supervisor. If

the complaint involves the employee’s supervisor, the employee should schedule an appointment with Human Resources to discuss the problem within five working days of the date the incident occurred.

b) The immediate supervisor (or Human Resources) should respond to the complaint within a reasonable amount of time after being informed of the incident.

Step 2: Written complaint and decision a) If the discussion with the immediate supervisor does not resolve the problem to the mutual

satisfaction of the employee and the supervisor, or if the supervisor does not respond to the complaint, the employee may submit a written complaint to Human Resources.

b) If the written complaint is received by the supervisor, the supervisor should forward a copy to Human Resources.

i. The submission of a written complaint is due within five working days of the response from the supervisor. The complaint should include:

• The problem and the date when the incident occurred. • Suggestions on ways to resolve the problem. • A copy of the immediate supervisor’s written response or a summary of his or

her verbal response and the date when the employee met with the immediate supervisor. If the supervisor did not respond, the complaint should state this.

ii. Upon receipt of the written complaint, the supervisor and/or Human Resources department must schedule a meeting with the employee within five working days to discuss the complaint. Within approximately five working days after the discussion, the supervisor and/or Human Resources should respond both in writing and orally to the employee filing the complaint.

Step 3: Appeal a) Ideally, the response should reflect a satisfactory resolution of the situation.

b) If the employee is dissatisfied with the response, the employee may, within five working days, appeal in writing to the Human Resources department.


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c) The Human Resources department may call a meeting with the parties directly involved to facilitate a resolution. Or the Human Resources department may refer complaints to upper management if the complaint raises serious questions of fact or interpretation of policy. The Human Resources department may gather further information from involved parties. All involved individuals, other than HR representatives, should not discuss the situation with any other employee or with the complaining employee.

Timely Resolution If an employee fails to appeal a proposed resolution within the time limits stated above, the problem should be considered settled. The problem should not be subject to further consideration.

Because problems are best resolved on an individual basis, this conflict resolution procedure may be initiated only by individual employees and not by groups of employees. All complaints must be made in good faith.

No employee will be subject to retaliation for filing a complaint under this policy.

2.8 Separation or Termination of Employment

Voluntary Termination A voluntary termination of employment occurs when an employee informs his or her supervisor of the employee’s resignation or when an employee is absent from work for three consecutive workdays and fails to contact his or her supervisor.

Employees are requested to provide a minimum of two weeks’ notice of their intention to separate from the Company to allow a reasonable amount of time to transfer ongoing workloads. The employee should provide a written resignation letter or notification to his or her manager.

The Company 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 debts to the Company, or return of the Company-owned property. Suggestions, complaints, and questions can also be voiced.

Involuntary Termination An involuntary termination of employment is a management-initiated dismissal.

The inability of an employee to perform the essential functions of his or her job with or without a reasonable accommodation may also result in an involuntary termination. An employee may also be terminated for any legal reason, e.g., misconduct, tardiness, absenteeism, unsatisfactory performance or inability to perform.

Reemployment If a break in service occurs by resignation or Company action and the employee is subsequently reemployed, the Company will consider the employee to be a new employee for all purposes to the extent not governed by applicable government regulations or other agreements.

If the employee is rehired within a year, the Company may consider reinstating vacation accrual, time of service, employee wedding gifts, etc. at the rate the employee had when he/she left. Non-exempt employees may receive the same hourly wage if he/she is returned to the same position.

Return of Property


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Employees are responsible for all the Company property, materials, or written information issued to them or in their possession or control. Employees must return all Company property immediately upon request or upon termination of employment. The Company may also take all action deemed appropriate to recover or protect its property.

If a terminated employee uses their personal cell phone to access company email via an exchange account, the employee must delete the exchange account upon termination. Terminated employees must show proof of deletion to Human Resources or IT. If the terminated employee is remote, they must send proof by way of screen shots.

Final Pay An employee who resigns or is terminated will be paid through the last day of work, plus any unused paid time off (PTO), less outstanding loans or other agreements the employee may have with the Company.

Severance Pay The Company may provide severance pay to eligible employees whose employment is terminated for reasons that are not prejudicial to the Company, as determined by the Company, in its sole discretion.

Specifically excluded from benefits under this provision are employees who: were hired as temporary employees for a specified period of time; were offered but refused to accept another suitable position with the organization; were provided the opportunity to be retained for any length of time by the Company.

2.9 Non Solicitation In an effort to ensure a productive and harmonious work environment, persons not employed by the Company may not solicit or distribute literature in the workplace at any time for any purpose.

The Company recognizes that employees may have interests in events and organizations outside the workplace. However, employees may not solicit or distribute literature concerning these activities during working time. (Working time does not include lunch periods, work breaks, or any other periods in which employees are not on duty.) In addition, the posting of written solicitations on company bulletin boards is restricted.

If an employee has a message of interest to the workplace, he/she may submit it to Human Resources for approval. All approved messages will be posted by Human Resources.

All solicitation on company property is limited to the posting of such materials on the company posting board in the kitchen or in the Classifieds section of the employee newsletter. The direct solicitation to employees is not permitted on company premises.

2.10 Safety Each employee is responsible for acting in a safe and reasonable manner at work, for obeying any safety rules established by the Company, and for reporting any unsafe condition to his/her supervisor so it may be corrected.

The Company provides information to employees about workplace safety and health issues through regular internal communication channels such as supervisor-employee meetings, bulletin board postings, memos, or other written communications.


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In the case of accidents that result in injury, regardless of how insignificant the injury may appear, employees should immediately notify the appropriate supervisor. Such reports are necessary to comply with laws and initiate insurance and workers' compensation benefits procedures.

First-Aid Kits First-aid kits should be maintained in each location. If a branch office needs assistance in obtaining a first-aid kit, please call the Distribution Center Supervisor in the Minneapolis office.

In Minneapolis, first-aid kits can be found at the 43rd floor receptionist, 44th floor kitchen, and 45th floor kitchen by accounting.

Fire Emergency 1. Calmly follow the instructions of the Company’s Floor Warden. 2. An automatic siren occurs on the fire floor and one floor above and below, as well as at the lobby

level. 3. Close office doors as people leave. 4. If not in danger and alarm is not already sounding, call 911 and alert all employees of the

situation. 5. Everyone should proceed quickly but calmly to the nearest stairwell. 6. Do not use elevators.

Severe Weather Emergency Public warning will come over the radio, TV, or a five minute steady blasts of sirens by the Municipal Defense warning system. Should a severe storm or tornado occur, the following guidelines should be observed:

1. Move away from the exterior of the building to an interior area near the center of building, such as a stairwell or an elevator lobby.

2. Try to close the doors of rooms which have windows. 3. Go to the center corridor. People should protect themselves by putting their head as close to their

knees as possible or kneel protecting their head. Stairwells are safe. If crowded, move down to a lower level for shelter. DO NOT USE THE ELEVATOR.

4. Do not go to the first floor lobby or outside the building. People trapped in an outside office, should seek protection under a desk.

Bomb Threat In the event of a bomb threat, try to get as much information as possible about the location and type of bomb, its detonation time and the reason for its placement. Be aware of any deliveries made prior to the bomb threat, even if made by normal means.

Use the checklist below as a guide. Then follow these procedures.

1. Dial 911. Identify who is calling, the company by name and suite number, and the building. 2. Notify the Management Office 3. Immediately after receipt of notification of a bomb threat, several steps should be taken:

• Do not turn lights on or off. • If time allows, have all company personnel inspect their own work areas without

touching or disturbing any unknown, unusual, or foreign object. i. Realize it is physically impossible for the property manager to inspect the entire

building. The tenant personnel are most familiar with the offices and the contents.


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• Report any such objects to the police at 911 and property management.

Bomb Threat Checklist

• Date/Time Received

• Caller ID number?

• Where is the bomb?

• What time is it set to go off?

• What kind of bomb is it?

• Method of activation (i.e., mechanical or chemical?)

• What does it look like?

• Why did you place the bomb?

• Caller's Voice (circle) o Male o Female o Young o Old o Calm o Stutter o Giggling o Stressed o Disguised o Slow o Deep o Accent o Nasal o Sincere o Crying o Loud o Angry o Lisp o Squeaky o Slurred o Broken o Rapid o Excited o Normal

• Did you recognize the voice?

• Were there any background noises?

• Remarks:

• Name, suite number, telephone number of recipient:


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Disaster Recovery In the event of a business disruption and if the office is unavailable, employees will be notified as to whether they should stay home or go to the recovery site.

You will receive specific instructions as to when you should arrive at the recovery site; or if working remotely, when services will be available and any login information that you may need.

Everbridge Notification System The safety and security of our employees and business are of the utmost importance. In the event of a business disruption we have tools and resources in place to allow us to continue operations with minimal interruptions.

The Everbridge notification system allows us to communicate messages quickly and easily to all of our employees through phone calls, text and emails. Through Everbridge we can target communications to groups of individuals based on their geographic location, company, department and many other criteria.

We will update Everbridge on a regular basis with our employees’ contact information. It is important you update UltiPro any time your contact information changes.

In the event of a disaster, we will contact our employees in the order below.

1. A call to your cell phone. 2. A text to your cell phone. 3. An email to your work address. 4. A call to your home phone. 5. An email to your personal address.

During an emergency, once the system is able to reach you, there will be no further attempts to contact you. For example, if you answer the call to your cell phone, you will not receive a text message.

Visitors in the Workplace To provide for the safety and security of employees and the facilities at the Company, only authorized visitors are allowed in the workplace. Restricting unauthorized visitors helps protects against theft, ensures security of equipment, protects confidential information, safeguards employee welfare, and avoids potential distractions and disturbances.

All visitors should enter via the lobby. If the visitor is not being escorted around with an employee, the visitor should wear a visitor badge. Authorized visitors will receive directions or be escorted to their destination. Employees are responsible for the conduct and safety of their visitors.

If an unauthorized individual is observed on Company premises, employees should immediately notify their supervisor or, if necessary, direct the individual to the Company lobby.

Security Checks The Company is concerned with protecting the health, and providing safety and security of all of its employees. We also want to protect the Company and employee property and our facilities. As a result, the Company prohibits anyone from:


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• Bringing drugs, alcohol, weapons, and/or other unauthorized or illegal substances or materials onto Company premises;

• Taking or removing equipment, materials, files, and/or other property without authorization; or • Intentionally damaging any property

In order to enforce these prohibitions, the Company expressly reserves the right, in its discretion:

• To question any employee or other person before he/she enters or leaves the premises; • To search or inspect the vehicle, desk, containers, handbags, briefcases, packages, parcels, and

personal belongings of any employee or other person; and • To search any Company vehicle or any personal vehicle used by an employee on Company

business, at any time.

Any employee who refuses to submit to, and cooperate with Company officials in conducting a search will be disciplined, up to and including termination.

Prohibition Against Violence It is the policy of the company that workplace violence of any kind will not be tolerated. Any employee who threatens to engage, or in fact does engage, in workplace-related violence will be subject to disciplinary action, up to and including immediate termination. This includes, but is not limited to, such actions as abusive or offensive comments, threats, and stalking, or aggressive and/or unwelcome physical contact.

An employee should report all threats of (or actual) violence, both direct and indirect, as soon as possible to his/her immediate supervisor, any other member of management, or Human Resources. This includes threats by employees, as well as threats by customers, vendors, solicitors, or other members of the public.

The Company will promptly and thoroughly investigate all reports of threats of (or actual) violence and of suspicious individuals or activities. The Company will protect the identity of the individual making a report as much as is practical. In order to maintain workplace safety and the integrity of its investigation, the Company may suspend employees, either with or without pay, pending investigation.

Anyone determined to be responsible for threats of (or actual) violence or other conduct that is in violation of these guidelines will be subject to prompt disciplinary action up to and including termination.

The Company encourages employees to bring their disputes or differences with other employees to the attention of his/her Supervisors or Human Resources before the situation escalates into potential violence. The Company is eager to assist in the resolution of employee disputes, and will not discipline employees for raising a concern in good faith.

2.11 Background Check Policy To ensure that individuals who join the Company are well qualified and have a strong potential to be productive and successful employees, it is DFG’s policy to investigate the backgrounds and employment references of applicants who are offered employment. In addition, the Company may conduct background investigations when employees are being considered for promotions or transfers. Background investigations will be conducted at DFG’s discretion and in accordance with federal and state law.

All background checks will be conducted by a consumer reporting agency and will follow the guidelines and regulations set by the Fair Credit Reporting Act. No background checks will be conducted without the written consent of the applicant or employee. Information gathered will be used solely for employment-related purposes.


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Only Human Resources will have access to the information collected during the background check process. The information will be kept as confidential as practical and will only be shared on a need-to-know basis. Information collected as part of the background check process will be securely maintained, separate from an employee’s personnel file, by Human Resources for seven years.

DFG relies on the accuracy of information contained in employment applications, as well as the accuracy of other data presented throughout the hiring process and during employment. Any misrepresentations, falsifications, or material omissions in any of this information or these data may result in an applicant being excluded from further consideration for employment or, if an individual has already been hired, termination of employment.

2.12 Confidentiality Any information and/or records concerning the business affairs of the Company, its customers, and its employees (including names and addresses of employees) is confidential and restricted information.

No employee may disclose any such confidential information to anyone without proper authority. Any request that you may receive for any such information must be referred to your supervisor. For example, a request by an outsider, including an attorney, asking for information about another employee should be rejected and referred to your supervisor or Human Resources.

Violation of this policy will subject you to disciplinary action, up to and including termination.

2.13 Conflicts of Interest 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 the Company wishes the business to operate. The purpose of these guidelines is to provide general direction so that employees can seek further clarification on issues related to the subject of acceptable standards of operation. Contact the President, General Counsel, or Compliance for more information or questions about conflicts of interest.

Transactions with outside firms must be conducted within a framework established and controlled by the executive level of the Company and by any code of ethics and regulatory requirements applicable to the individual companies. Business dealings with outside firms should not result in unusual gains for those firms. Unusual gain refers to bribes, product bonuses, special fringe benefits, unusual price breaks, and other windfalls designed to ultimately benefit the employer, the employee, or both. Promotional plans that could be interpreted to involve unusual gain require specific executive-level approval.

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 the Company'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.

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 their supervisor as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to mitigate all parties.

Personal gain may result not only in cases where an employee or relative has a significant ownership in a firm with which the Company does business, but also when an employee or relative receives any bribe, substantial gift, or special consideration as a result of any transaction or business dealings involving the Company.


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Outside Employment/Outside Business Activity Generally, an employee may have outside employment or outside business activity as long as there is no actual or potential conflict of interest; he/she satisfactorily performs his/her job responsibilities with the Company; and is compliant with the reporting requirements, and other requirements, as described in applicable policies, manuals, code of ethics, and regulations.

All employees will be judged by performance standards and will be subject to the Company's scheduling demands, regardless of any existing outside work requirements.

If the Company determines that an employee's outside work interferes with performance or the ability to meet the requirements of the Company or regulatory requirements, which are modified from time to time, the employee may be asked to terminate the outside employment if he/she wishes to remain with the Company. Outside employment or business activity will present a conflict of interest if it has an adverse impact on the Company.

Employees are required to notify the Compliance Department in writing within 10 calendar days of hire of any outside business activities, whether or not they are securities-related. The Compliance Officer will consult with senior management regarding the allowance of such activity. Examples include: sales of non-securities products, board membership of a non-profit organization, outside employment, consulting engagements, etc. Introductions of Dougherty Financial Group clients to other firms may be restricted/prohibited, regardless of whether a Dougherty Financial Group employee is compensated.

2.14 Personal Relationships in the Workplace Members of a family may work in the same department in the Company; however, to be sensitive to the issues of favoritism that these special relationships may imply and to avoid any conflict of interest, no employee may initiate or participate in decisions involving a direct benefit (initial employment, retention, job classification, salary, work assignments, performance appraisals, etc.) to members of the employee's immediate family, domestic partner or member of the same household. Beyond the definition of family as described, employees should always be sensitive to the possibility of a conflict of interest or the appearance of a conflict of interest when they participate in employment decisions which may involve extended family or friendships.

Conflicts of interest also exist when there is a consensual romantic or sexual relationship in the context of employment supervision or evaluation. Therefore, no supervisor may participate, directly or indirectly, in decisions involving a direct benefit to an employee with whom such a relationship exists. Any supervisor involved in a consensual romantic or sexual relationship, in the context of employment supervision, must discuss the matter on a confidential basis with his or her own supervisor and with human resources, so that the implications for the workplace can be assessed, and arrangements made to ensure that employment-related decisions are made in an appropriate and unbiased setting. A supervisor's failure to report such a relationship will be regarded as a serious lapse in his or her management of the workplace and grounds for appropriate disciplinary action including termination of employment (particularly in cases where bias or harassment has occurred in connection with a direct benefit).

A supervisor bears an affirmative responsibility for sustaining a positive workplace environment and one which is conducive to the professional growth of all employees. A supervisor must be regarded as trustworthy and fair for such an environment to exist. It is important to understand that even when


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arrangements have been made to minimize conflicts of interest regarding particular employment-related decisions; it is necessarily more difficult for a supervisor to be fair when a close relationship exists with an employee. Disruption to the workplace can be particularly acute when a sexual or romantic relationship involving a supervisor is known to exist but is not discussed. Supervisors should also understand that even in a consenting relationship there are substantial risks of charges of sexual harassment or favoritism when supervision is involved.

Any supervisor who receives the report that someone who reports to him or her is involved in a consensual romantic or sexual relationship with an employee he or she supervises will be expected to speak confidentially with the person(s) involved. If the relationship exists, appropriate steps should be taken to ensure that employment-related decisions are made in an unbiased setting.

Individuals who have questions or are uncertain as to the application of this policy should speak in confidence to the Human Resources Department.

2.15 Social Media Policy The Company understands that social media can be a fun and rewarding way to share your life and opinions with family, friends, and co-workers. However, use of social media also presents certain risks and carries with it certain responsibilities. To assist you in making responsible decisions about your use of social media, we have established these guidelines for appropriate use of social media. This policy applies to all employees who work for the Company.

Guidelines In the rapidly expanding world of electronic communication, social media can mean many things. Social media includes all means of communicating or posting information or content of any sort on the Internet, including your own or someone else’s web log (blog), journal or diary, personal web site, social networking or affinity web site, web bulletin board or a chat room, whether or not associated or affiliated with the Company, as well as any other form of electronic communication.

The same principles and guidelines found in other Company policies apply to your activities online. Ultimately, you are solely responsible for what you post online. Before creating online content, consider some of the risks and rewards that are involved. Keep in mind that any of your conduct that adversely affects customers, vendors, and people who work on behalf of the Company or the Company’s legitimate business interests may result in disciplinary action up to and including termination.

Know and Follow the Rules Carefully read these guidelines, the Company’s Confidentiality Policy, the Prohibition Against Harassment, and insure that your postings are consistent with these policies. Inappropriate postings that may include discriminatory remarks, harassment, and threats of violence or similar inappropriate or unlawful conduct will not be tolerated and may subject you to disciplinary action up to and including termination.

The posting of messages on any boards or conversations in chat rooms that pertains to any financial services the Company makes a market in or provides research for is strictly prohibited.

Text messaging with clients for business purposes is prohibited for certain regulated entities. If a text message is received from a client of a regulated entity, it must be maintained in firm records as correspondence. Instruct clients not to send text messages.


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If employees participate in social networking sites (e.g., Facebook, LinkedIn, etc.), they may reference name of their employer if they have obtained approval by the Compliance Department, but may not transact firm business, solicit firm business or do any firm marketing through the social networking site.

Communications and Internet access should be conducted in a responsible and professional manner reflecting the Firm’s commitment to ethical business practice. The Company restricts electronic access to certain internet websites/subjects.

2.16 Standards of Conduct

Employee Conduct and Work Rules To ensure orderly operations and provide the best possible work environment, the Company expects employees to follow rules of conduct that will protect the interests and safety of all employees and the organization.

It is not possible to list all forms of behavior that are considered unacceptable in the workplace. The following are examples, not meant to be all inclusive, of rule infractions that may result in disciplinary action, up to and including termination of employment:

• Theft or inappropriate removal or possession of property • Falsification of timekeeping records • Fighting or threatening violence in the workplace • Excessive absenteeism or any absence without notice • Unauthorized use of telephones, mail system, or other employer-owned equipment • Unsatisfactory performance or conduct

Workplace Etiquette The Company strives to maintain a positive work environment where employees treat each other with respect and courtesy. Sometimes issues arise when employees are unaware that their behavior in the workplace may be disruptive to others. Many of these day-to-day issues can be addressed by politely talking with a coworker to bring the perceived problem to his/her attention. In most cases, common sense will dictate an appropriate resolution. The Company encourages all employees to keep an open mind and graciously accept constructive feedback or a request to change behavior that may be affecting another employee's ability to concentrate and be productive.

The following workplace etiquette guidelines are not necessarily intended to be hard and fast work rules with disciplinary consequences. They are simply suggestions for appropriate workplace behavior to help everyone be more conscientious and considerate of coworkers and the work environment. Employees with comments, concerns, or suggestions regarding these workplace etiquette guidelines should contact Human Resources.

E-Mail Usage The E-Mail system and all electronic mail communications are company records and are the property of the Company. The system is designed for the Company and affiliates business communications. Employees should be aware that these communications are not private but are considered business records. The excessive use of the E-Mail system for personal business is prohibited. To ensure that the use of this system is consistent with the Company’s legitimate business interests, authorized representatives of the Company may monitor messages from time to time. Such monitoring may include printing and reading E-Mails incoming, outgoing or stored in the system.


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The Company prohibits the use of E-mail for religious or political activities, personal gain, solicitation, or in support of illegal activities.

The Company strives to maintain a workplace free of harassment and sensitive to the diversity of its employees. Therefore, the Company prohibits the use of the E-mail system in ways that are disruptive to others, or harmful to morale.

E-Mail Storage and Retention Policy The Company is committed to improving the reliability, capacity and functionality of our E-mail service. In order to attain this goal, an E-mail retention policy has been implemented.

Retention Schedule:

• Inbound and Outbound Messages are deleted every 6 months (180 days). • Trash Bin is automatically deleted every 7 days. • E-mail messages (both inbound and outbound) will be automatically purged by the E-mail system

every six months (180 days). To preserve messages, users should archive the data or print the messages for retention purposes. The trash bin will automatically purge messages after seven days. This retention schedule is subject to the books and records requirements of the rules and regulations governing our business.

E-Mail Disclaimer Statement ALL Dougherty & Company LLC external E-mail communications will contain the following disclaimer:

If you are not the intended recipient of this message, please notify the sender. The information contained herein is confidential and intended only for the recipient or recipients named above and for the purposes indicated. Further distribution of this message without the prior written consent of the author is prohibited. Any opinions expressed herein do not necessarily reflect the opinion of Dougherty & Company LLC.

Dougherty & Company LLC will not accept transaction orders or time-sensitive action-oriented messages or check requests via e-mail or other electronic delivery. Dougherty & Company LLC and its affiliates reserve the right to monitor all e-mail.

For additional disclosure information see http://www.doughertymarkets.com/disclosure.htm

Member SIPC/FINRA

All other entities external E-mail communications will contain the following disclaimer:

This E-mail and any attachment contains information which is private and confidential and is intended for the addressee only. If you are not an addressee, you are not authorized to read, copy or use the E-mail or any attachment. If you have received this E-mail in error, please notify the sender by return E-mail and then destroy it.

E-Mail Viruses E-mail attachments can contain viruses (e.g., .exe, .vbs, .html, .doc, .xls). To avoid exposing the Company’s network to unknown viruses, do not run software executable, such as downloadable screen savers, demo software, or software upgrades (excluding anti-virus updates provided by the IT department) without first consulting the IT Help Desk.

http://www.doughertymarkets.com/disclosure.htm


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Today's viruses can also be contained within an E-mail message (and not part of an attachment). To avoid exposing the network to the new strain of viruses, please do not open E-mail messages from unknown sources. Delete the messages and immediately empty your E-mail trash bin.

Internet/Intranet Use Policy Communications and Internet\Intranet access should be conducted in a responsible and professional manner reflecting the firm's commitment to honest, ethical and non-discriminatory business practice. Internet browsing in the workplace is intended for business purposes only. Visiting Internet sites that contain obscene, pornographic, hateful or other objectionable materials is prohibited. Sending or receiving any material that is obscene or defamatory is also prohibited. The Company attempts to restrict access to websites containing such materials.

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.

Employees should notify their immediate supervisor, Human Resources or any member of management 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.

Workplace monitoring may be conducted by the Company to ensure quality control, employee safety, security, and customer satisfaction.

Because the Company is sensitive to the legitimate privacy rights of employees, the Company will take reasonable steps to conduct its workplace monitoring in an ethical and respectful manner.

Cyber Security Policy The Cyber Security Policy, available on Dougherty Planet under Notices & Policies, informs employees of obligatory requirements for protecting the technology and information assets of the company and describes user’s responsibilities and privileges. The policy also contains procedures for responding to incidents that threaten the security of the company computer systems and network.

Use of Equipment Equipment essential in accomplishing job duties is often expensive and may be difficult to replace. When using company property, employees are expected to exercise care, and follow all operating instructions, safety standards, and guidelines. The improper, careless, negligent, destructive, or unsafe use or operation of equipment can result in disciplinary action, up to and including termination of employment.

Please notify the supervisor, distribution center, IT or other appropriate departments if any equipment appears to be damaged, defective, or in need of repair. Prompt reporting of damages, defects, and the need for repairs could prevent deterioration of equipment.

Use of Telephones and Mail Systems The Company may require reimbursement from employees for any charges resulting from the employee's personal use of the telephone or mail system.

All personal communications should be kept to a minimum.

Cellular Phone Company employees are prohibited from using a cell phone, which includes sending text messages and/or accessing the web, while operating a motor vehicle for business use unless it is absolutely necessary and:


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1. The cell phone is equipped with "hands-free" or voice-activated "autodial" features; or 2. The employee is using a cell phone from a motor vehicle that is completely stopped and parked in

a safe location. (stopped at a red light in the middle of an intersection is not considered a safe location)

Access Cards All downtown Minneapolis employees will be given an access card upon employment. Access cards are given to downtown Minneapolis employees to access the office and the stairwells during business hours and the offices and building during non-business hours. Employees will be charged $15.00 to replace a lost card.

Personal Appearance We encourage all of our employees to take pride in the Company’s professional image. As representatives of the Company we request that all employees be neat, well-groomed and dressed in job-appropriate attire that reflects the Company’s professional image. Please refrain from wearing sloppy, wrinkled or overly provocative clothing in the office.

On Fridays, the Company permits business casual attire. For men this includes all shirts with a collar, knot polo-style shirts, twill or oxford button down-shirts, khaki trousers, sport coat, vest, or sweater. For women, this includes casual blouses, professional knit tops, ankle-length pants and capri pants of a tasteful and professional length and image.

Business professional attire should be worn during regular working hours Monday through Thursday. Some examples of appropriate business attire include:

For Men For Women

• Business Suit • Pant or skirt suit • Long sleeve, button down dress shirts • Dress slacks • Tie • Skirt and dresses (should be at or close to knee • Professional trousers length and below) • Dress socks • Blazer or Blouse • Professional dress shoes • Sweater, sweater set and cardigan • Belt • Professional dress shoes

Smoking In keeping with the Company's intent to provide a safe and healthful work environment, smoking is prohibited throughout the workplace. This policy applies equally to all employees, customers, and visitors.

Employees in Minnesota must comply with the Minnesota Clean Indoor Air Act (MCIAA) and the Freedom to Breathe Act. These acts prohibit smoking in public places, places of employment, public transportation, and at public meetings. If a vehicle is used for work purposes, either all the time or even part of the time, the vehicle is considered a place of employment. Employees using a vehicle for work purposes are prohibited from smoking inside the vehicle during business hours if more than one person is present.

Employees should familiarize themselves and comply with any local or state smoking bans that may apply to their work sites.


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2.17 Whistleblower Policy

Purpose A whistleblower is defined by this policy as an employee of the Company who reports an activity that he/she considers to be illegal, fraudulent, or unethical. The whistleblower is not responsible for investigating the activity or for determining fault or corrective measures; appropriate management officials are charged with these responsibilities.

Examples of illegal or fraudulent activities are violations of federal, state, or local laws; billing for services not performed, other fraudulent financial reporting, or insider trading.

If an employee has knowledge of or a concern of illegal or dishonest fraudulent activity, the employee is to contact the Chief Compliance Officer, Legal department, or Human Resources department. While the Company does not encourage frivolous complaints, the Company does expect its employees to report any irregularities and other suspected wrongdoing regarding illegal or fraudulent activities.

Protection This policy and the related procedures offer protection from retaliation against officers, employees and agents who make any complaint with respect to perceived violations (referred to herein as a “Reporting Person”), provided the complaint is made in good faith. “Good faith” means that the Reporting Person has a reasonably held belief that the complaint made is true and has not been made either for personal gain or for any ulterior motive.

The Company will not terminate, demote, suspend, threaten, harass or in any manner discriminate or otherwise retaliate against any Reporting Person in the terms or conditions of his or her employment with the Company based upon such Reporting Person’s submitting in good faith any complaint regarding an Accounting Violation. Any acts of retaliation against a Reporting Person will be treated by the Company as a serious violation of Company policy and could result in dismissal.

Confidentiality The Company will keep the identity of any Reporting Person confidential and privileged under all circumstances to the fullest extent allowed by law, unless the Inside Reporting Person has authorized the Company to disclose his or her identity.

Submitting Complaints Reporting Persons should submit complaints concerning illegal or fraudulent activity by contacting the Compliance or Human Resources departments. Complaints may be submitted in person or via email.

Reporting Persons may report complaints anonymously, however, the Company urges any employee that is considering making an anonymous complaint to strongly consider that anonymous complaints are, by their nature, susceptible to abuse, less reliable, and more difficult to resolve. In addition, employees considering making an anonymous complaint should be aware that there are significant rights and protections available to them if they identify themselves when making a complaint, and that these rights and protections may be lost if they make the complaint on an anonymous basis. Therefore, the Company encourages employees to identify themselves when making reports of illegal or fraudulent activity.

Investigation of Complaints Upon receipt of a complaint, the Compliance and/or Human Resources department will confirm the complaint pertains to an illegal or fraudulent activity. Investigations will be conducted as quickly as possible, taking into account the nature and complexity of the complaint and the issues raised therein.


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Any complaints submitted pursuant to this Policy that do not relate to an illegal or fraudulent activity will be returned to the Reporting Person, unless the Reporting Person’s identity is unknown.

The Senior Vice President of Compliance and/or Human Resources may enlist employees of the Company and outside legal, accounting and other advisors, as appropriate, to conduct an investigation of a complaint.

The results of each investigation will be reported timely to upper management, which will then apprise all appropriate parties, and prompt and appropriate remedial action will be taken as warranted in the judgment of the Chairman or CEO of the respective company or as otherwise directed. Any actions taken in response to a complaint will be reported to the Reporting Person to the extent allowed by law, unless the complaint was submitted on an anonymous basis.

A Reporting Person who is not satisfied with the outcome of the initial investigation or the remedial action taken with respect thereto, if any, may submit directly to the Chairman or CEO of the respective company for review a written complaint with an explanation of why the investigation or remedial action was inadequate. A Reporting Person may submit a revised complaint on an anonymous basis in his or her sole discretion. The Reporting Person should forward the revised complaint to the attention of the Chairman in the same manner as set out above for the original complaint.

The Chairman or CEO of the respective company will review the Reporting Person's revised complaint, together with documentation of the initial investigation, and determine in its sole discretion if the revised complaint merits further investigation. A subsequent investigation will be conducted to the extent and in the manner it deems appropriate. The Chairman or CEO of the respective company may enlist employees of the Company and outside legal, accounting and other advisors, as appropriate, to undertake the subsequent investigation. The Chairman or CEO of the respective company, or a designated representative will inform the Reporting Person of any remedial action taken in response to a Revised Complaint to the extent allowed by law, unless the company was submitted on an anonymous basis.

Retention of Complaints The Senior Vice President of Compliance and/or Human Resources will maintain all complaints received, tracking their receipt, investigation and resolution. All complaints and reports will be maintained in accordance with the Company’s confidentiality and document retention policies.

Unsubstantiated Allegations If a Reporting Person makes a complaint in good faith pursuant to this Policy and any facts alleged therein are not confirmed by a subsequent investigation, no action will be taken against the Reporting Person. In submitting complaints, Reporting Persons should exercise due care to ensure the accuracy of the information reported. If, after an investigation, it is determined that a complaint is without substance or was made for malicious or frivolous reasons or otherwise submitted in bad faith, the Reporting Person could be subject to disciplinary action. Where alleged facts reported pursuant to this Policy are found to be without merit or unsubstantiated: (1) the conclusions of the investigation will be made known to both the Reporting Person, unless the complaint was submitted on an anonymous basis, and, if appropriate, to the persons against whom any allegation was made in the complaint, and (2) the allegations will be dismissed.

SECTION III: BENEFITS

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3.1 Employee Benefits Benefits are an important part of an employee’s compensation. Eligible employees at the Company are provided a wide range of benefits. A number of the programs (such as Social Security, workers' compensation, state disability, and unemployment insurance) cover all employees in the manner prescribed by law.

Benefits eligibility is dependent upon a variety of factors, including employee classification. Contact Human Resources for a current list of benefits. Benefit summaries can also be found on the UltiPro Self Service Portal.

Delays in enrolling could make employees ineligible for coverage until the next open enrollment date, or could require employees to furnish evidence of insurability.

Some benefit programs require contributions from the employee; others are fully-paid by the Company.

A comprehensive listing of current benefits is available in the most current Benefits Guide which can be found on UltiPro.

401(k) Savings Plan The Company has established a 401(k) savings plan administered by Schwab Retirement Plan Services to provide employees the potential for future financial security for retirement. Eligible employees may participate in the 401(k) plan subject to all terms and conditions of the plan.

The 401(k) savings plan allows eligible employees to elect a percentage of salary to contribute to the plan and to direct the investments of their plan account, so they can tailor a retirement package to meet their individual needs. Employees have the option of enrolling in a pre-tax 401(k) or Roth 401(k). The Company may also contribute an additional matching amount to each employee's 401(k) contribution. To participate in employer contributions, see the Summary Plan Description for specific qualifying information.

Complete details of the 401(k) savings plan are described in the Summary Plan Description provided to eligible employees. Contact Human Resources for more information about the 401(k) plan.

Health Insurance Plans The Company's medical, dental, and vision insurance plans provide employees and their eligible dependents access to health insurance benefits. Employees in the following employment classifications are eligible to participate in the health insurance plan:

• All regular employees working at least 30 hours per week

Eligible employees may participate in the health insurance plans subject to all terms and conditions of the agreement between the Company and the insurance carriers.

A change in employment classification that would result in loss of eligibility to participate in the medical, dental, and vision insurance plans 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.

Please refer to the most recent Benefit Guide for more information about available medical, dental, and vision plans.


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Life Insurance Life insurance offers employees and their family important financial protection. The Company provides a basic life insurance plan for eligible employees, their spouses and children. Additional supplemental and/or dependent life insurance coverage may also be purchased by the employee.

Accidental Death and Dismemberment (AD&D) insurance provides protection in cases of serious injury or death resulting from an accident. AD&D insurance coverage is provided as part of the basic life insurance plan.

Employees in the following employment classifications are eligible to participate in the life insurance plan:

• All regular employees working at least 30 hours per week

Eligible employees may participate in the life insurance plan subject to all terms and conditions of the agreement between the Company and the insurance carrier.

Details of the basic life insurance plan including benefit amounts are described in the Summary Plan Description provided to eligible employees. Contact Human Resources for more information about life insurance benefits.

Long-Term Disability The Company provides a long-term disability (LTD) benefits plan to help eligible employees cope with an illness or injury that result in a long-term absence from employment. LTD is designed to ensure a continuing income for employees who are disabled and unable to work.

All regular employees working at least 30 hours per week are eligible to participate in the LTD plan.

Eligible employees may participate in the LTD plan subject to all terms and conditions of the agreement between the Company and the insurance carrier.

Details of the LTD benefits plan including benefit amounts, definition of disability, and limitations and restrictions are described in the Summary Plan Description provided to eligible employees. Contact Human Resources for more information about LTD benefits.

Short Term Disability The Company provides a short term disability (STD) benefits plan to eligible employees who are unable to work because of a qualifying disability due to an injury or illness.

Employees who work at least 30 hours per week are eligible to participate in the STD plan after one year of service.

Eligible employees may participate in the STD plan subject to all terms and conditions of the agreement between the Company and the insurance carrier.

Details of the STD benefits plan including benefit amounts, definition of disability, and limitations and restrictions are described in the Summary Plan Description provided to eligible employees. Contact Human Resources for more information about STD benefits.


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Workers’ Compensation The Company 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.

Flexible Spending Accounts The Company provides a Flexible Spending Account (FSA) program that allows employees to have pre-tax dollars deducted from their salaries to pay for eligible out-of-pocket expenses. The pre-tax contributions made to the FSA can be used to pay for predictable non-reimbursed health care expenses, dependent care expenses, eligible parking, and transportation expenses during the plan year. Through the FSA program, an employee can reduce his/her taxable income, allowing employees to keep more of the money they earn.

Please refer to the most recent Benefit Guide for more details on the Company’s Flexible Spending Accounts.

Service Awards The Company believes that its employees are a vital part of the Company’s overall growth and success. As a token of appreciation of our employees’ dedication and hard work, employees may be provided with monetary awards when they reach certain years of service.

5 years of service $ 250 25 years of service Gift 10 years of service $1,000 30 years of service $5,000 15 years of service $2,000 35 years of service $7,500 20 years of service $3,000

Gifts The Company wishes to recognize and celebrate the important life events that our employees experience. For that reason, gifts may be provided to employees for the following milestones:

Getting Married Dougherty celebrates this milestone with a monetary gift that’s based on years of service, as follows:

1 to 3 years: $ 50 6 to 10 years: $150 4 to 5 years: $100 10+ years: $200

Birth of Baby Employees receive a $100 monetary gift from Dougherty for the birth or adoption of a baby.

Adoption Assistance Dougherty will reimburse up to 80% of eligible expenses up to $2,000 per child adopted. Part-time employees will receive a pro-rated benefit.

Matching Gifts Plan The Company matching gifts plan was established to support the interests and concerns of our employees, and to recognize and encourage active community involvement. Under the plan provisions, cash or hourly donations made by employees to qualified charitable, educational, and other nonprofit organizations are matched by the Company with dollar-for-dollar contributions called matching gifts.


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Regular full-time and regular part-time employees are eligible to participate in the matching gifts plan as described in this policy:

Eligible employees may participate in the matching gifts plan only after completing 90 calendar days of service. Eligible employees may request up to a maximum of $100.00 per calendar year to match their personal cash donations or $10.00 per hour to match their volunteer hours to qualified nonprofit organizations. A minimum donation of $5.00 to a single organization is required to qualify for a matching gift. Employees may choose to divide the Company matching gift maximum amount between one or more nonprofit organizations.

The Company will match employees' cash donations or volunteer hours to nonprofit organizations as long as the organization does not discriminate on the basis of race, color, religion, sex, national origin, age, disability, or any other characteristic protected by federal, state, or local law.

The Company, in its sole discretion, will determine what donations they can or cannot match. Examples of donations the Company cannot match include, but are not limited to:

• Donations that generate a tangible return to the contributor such as discounts, tickets, improved seating, or promotional items

• Payments to educational institutions that cover the cost of services, tuition, books, or student fees • Donations supporting political parties or candidates • Dues payable to alumni groups or other membership organizations • Gifts to individuals

Employees may request matching gifts by completing the matching gifts request form and forwarding it to Human Resources along with proof of contribution or the employee's personal check. If the request is approved, the Company will mail a company check and the employee's personal check directly to the recipient organization.

Contact Human Resources for more information. The matching gifts request form can be found on UltiPro.

Employee Assistance Program From time to time, we all need help balancing our personal, work, and family lives. Through Unum’s work-life balance EAP, you have unlimited access to consultants by telephone, resources and tools online, and up to three face-to-face visits with counselors for help with a short-term problem.

All employees and their family members, regardless of employment status and participation in the Company medical plan are eligible for this benefit. Coverage begins on the first day of the month following your hire date.

For more detailed information about these plans, log in to UltiPro and go to My Company/Company Benefits/Employee Assistance Program (EAP) section.

3.2 Time Off

Paid Time Off (PTO) Paid Time Off (PTO) is an all-purpose time off policy for eligible employees to use for vacation, illness or injury, doctor's appointments and personal business. It combines traditional vacation and sick leave plans into one flexible, paid time-off policy. Other time off, such as jury duty, bereavement leave, birthday leave, etc., are separate from PTO.


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Employees in the following employment classification(s) are eligible to earn and use PTO as described in this policy:

• Regular full-time non-commissioned employees • Regular part-time non-commissioned employees scheduled to work at least 30 hours per week

The following employees are not eligible for PTO:

• Part-time employees scheduled to work less than 24 hours per week • Temporary employees • Temporary Interns • Commission and incentive based employees • Members

Once employees enter an eligible employment classification, they begin to earn PTO according to the schedule below. They can request use of PTO after it is earned. PTO may be taken before it has been accrued with approval from an employee’s supervisor/manager.

The amount of PTO an employee receives each year increases with the length of their employment as shown in the following schedule:

• Upon initial eligibility the employee is entitled to 16 PTO days (128 hours) each year, accrued monthly at the rate of 1.333 days (10.68 hours).

• After 36 months of eligible service the employee is entitled to 21 PTO days (168 hours) each year, accrued monthly at the rate of 1.75 days (14 hours).

• After 120 months of eligible service the employee is entitled to 26 PTO days (208 hours) each year, accrued monthly at the rate of 2.167 days (17.34 hours).

• After 240 months of eligible service the employee is entitled to 31 PTO days (248 hours) each year, accrued monthly at the rate of 2.58 days (20.66 hours).

Part-time employees will accrue PTO based on the Full-Time Equivalent (FTE) ratio.

Individuals who are rehired within one year from their date of termination will begin accruing PTO based on their total amount of service.

The length of eligible service is calculated on the basis of a "benefit year." This is the 12-month period that begins the first day of hire and ends one year later. PTO will not accrue during any significant leave of absence.

In the event that available PTO is not used by the end of the calendar year, employees may carry over up to one-half of the accrual rate to the next benefit year.

PTO can be used in minimum increments of 1/2 day for exempt employees and quarter hour for non-exempt employees.

Employees who have an unexpected need to be absent from work should notify their direct supervisor before the scheduled start of their workday, if practicable. Employees must contact their supervisor for each additional day of unexpected absence. The company may require certification from a health care provider at any time for absences due to illness.


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Employees who change from full-time to part-time or vice versa will accrue PTO in accordance with the computation for their new status. This will become effective on the first of the month in which the change occurs. The employee will still be eligible for any unused hours that accrued at their previous status.

To schedule planned PTO, employees should request advance approval from their supervisor and should submit a PTO notice in advance. In the event of illness or emergency preventing the salaried employee from requesting PTO in advance, the salaried employee must submit a PTO notice to their supervisor no later than 14 calendar days from the day in which they returned from the absence. Once a PTO notice is completed by the employee and approved by the manager, the PTO notice must be submitted to Payroll.

PTO requests will be reviewed based on a number of factors, including business needs and staffing requirements. Managers may deny a request if the absence will unduly disrupt business or if an employee has not accrued the amount of requested PTO.

Employees can be counseled for excessive use of unscheduled PTO when it negatively impacts their performance, customers or co-workers. The Company considers unscheduled PTO as any requested time off without 24-hour notice. As a general guideline, if an employee has more than six unscheduled occurrences, discipline may result. Managers may look at scheduled versus unscheduled absences over the past 12 months.

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, or bonuses.

As an additional condition of eligibility for PTO, an employee on an extended absence for illness or injury must apply for any other available compensation and benefits, such as short term disability, etc. PTO will be used to supplement any payments that an employee is eligible to receive from state disability insurance, workers' compensation, or Company-provided disability insurance programs. The combination of any such disability payments and PTO cannot exceed the employee's base pay rate.

In the event that available PTO is not used by the end of the "calendar year", December 31, employees may carry over up to one-half* of the accrual rate to the next benefit year.

Upon termination of employment, the Company will pay the employee unused PTO earned through the last full month worked. PTO accrues at the end of the month. The employee must be employed on the last day of the month to accrue PTO for that month. If an employee terminates before earning the full amount of PTO already taken, the Company will require the employee to reimburse the Company for the unearned portion of PTO through a deduction from the final pay and/or direct payment of amounts owed to the Company.* Authorization of a deduction from the final pay check for unearned portions of PTO taken is given by signing the Employee Handbook Acknowledgment form.

* California Employees working in the state of California may accrue to a maximum of 1.5 times the annual accrual rate. No PTO accrues until the balance falls below the cap.

If an employee working in the state of California terminates before earning the full amount of PTO already taken, the Company will not require the employee to reimburse the Company for the unearned portion of PTO.

Holidays Holidays are declared for all employees when:

1. The Company is closed for a recognized holiday published by the Company. 2. The Company closes early as officially declared by written notice from Human Resources,

Company Presidents, or Mike Dougherty.


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3. The Company is closed due to inclement weather as officially declared by Human Resources, Company Presidents, or Mike Dougherty.

The Company will generally grant holiday time off to all employees on the holidays listed below:

• New Year's Day (January 1) • Martin Luther King, Jr. Day (third Monday in January) • Presidents' Day (third Monday in February) • Good Friday (Friday before Easter) • Memorial Day (last Monday in May) • Independence Day (July 4) • Labor Day (first Monday in September) • Thanksgiving (fourth Thursday in November) • Friday after Thanksgiving (unless required to work for business needs) • Christmas (December 25)

Actual holiday schedules may vary by company during the year and are based on the New York Stock Exchange schedule. Holidays not taken by December 31 will be forfeited. The Company will grant paid holiday time off to all eligible employees immediately upon assignment to an eligible employment classification.

Exempt Employees If an exempt employee is engaged in a project which requires his/her continuous attendance, he/she may be asked to work on a holiday. In such an event, he/she may take another day off with pay. If a recognized full-day or half-day holiday falls during an eligible employee's paid absence (e.g., PTO), the employee will be eligible for holiday pay. The holiday will not count against his/her paid absence. If a holiday falls during Family Medical Leave and/or short term disability the holiday will count against the leave.

All Non-exempt Employees If the office closes early or opens late, employees will receive holiday pay to accurately reflect the hours of the business. Normal business hours are 8:00 a.m. to 5:00 p.m. All non-exempt employees will receive the same amount of holiday pay hours regardless of their schedule they actually worked on the day the office closes early or opens late. Employees must work their regular scheduled hours to be eligible for the holiday pay. Any changes to an employee’s regular schedule must be approved in advance by their supervisor.

For example, the normal close of business is 5:00 p.m., and the Company closes early at 2:00 p.m., all non-exempt employees will receive 3 holiday hours.

Normal Schedule 8:00 a.m. to 5:00 p.m. 7:00 a.m. to 3:30 p.m. 8:00 a.m. to 5:00 p.m. In 8:00 a.m. 7:00 a.m. 8:00 a.m. Out 12:00 p.m. 11:00 a.m. 12:00 p.m. In 1:00 p.m. 11:30 a.m. 1:00 p.m. Out 2:00 p.m. 2:00 p.m. 3:00 p.m. Hours Worked 5 hours 6.5 hours 6 hours Holiday Hours 3 hours 3 hours 3 hours Total Hours 8 hours 9.5 hours 9 hours

If the office closes early or opens late, during an eligible employee's paid absence (e.g., PTO, birthday leave), the employee will not be eligible for holiday pay.


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Paid time off for holidays will be counted as hours worked for the purposes of determining whether overtime pay is owed.

Non-exempt Full-time Employees If a non-exempt full-time employee is engaged in a project which requires his/her continuous attendance, he/she may be asked to work on a holiday. If an eligible non-exempt full-time employee works on a recognized holiday, he/she will receive holiday pay at one and one-half times his/her straight-time wage rate for the hours worked on the holiday.

If a recognized holiday falls during an eligible employee's paid absence (e.g., PTO), the employee will be eligible for holiday pay. The holiday will not count against his/her paid absence. If a holiday falls during Family Medical Leave and/or short term disability the holiday will count against the leave.

Non-exempt Part-time Employees Non-exempt part-time employees will be eligible for holiday pay only for those holidays which fall on a day when the employee is regularly scheduled to work. Holiday pay will reflect the employee's regular scheduled hours.

Examples:

• An employee normally works a full day Monday. If the holiday falls on a Monday they will receive 8 hours of holiday pay.

• If an employee normally works 6 hours every day, they will receive 6 hours of holiday pay. • If an employee normally does not work Mondays and the holiday falls on a Monday, the

employee will not receive holiday pay.

If an eligible non-exempt part-time employee works on a recognized holiday, he/she will receive holiday pay at one and one-half times his/her straight-time wage rate for the hours worked on the holiday.

If a recognized holiday falls on a day during an eligible part-time employee's paid absence (e.g., PTO, birthday leave), the employee will be eligible for holiday pay ONLY if the holiday falls on a regularly schedule day. The holiday will not count against his/her paid absence. If a holiday falls during Family Medical Leave and/or short term disability the holiday will count against the leave.

Temporary employees are not eligible for holiday pay.

Birthday Holiday Employees may take off their birthday as a Company paid holiday. The day an employee takes off must either be his/her birthday or a day during the week of his/her birthday. If an employee’s birthday falls on a Saturday or Sunday, the employee may choose to take the proceeding Friday or following Monday off as his/her birthday leave. If business needs do not allow for an employee to take a day off during the week of his/her birthday, the day needs to be taken by the end of the following week. Employees, who are already on a leave other than Paid Time Off, when their birthday occurs, are not eligible for birthday leave. Employees cannot carry forward their birthday holiday to substitute for another day during the year.

Wedding Holiday The Company understands the importance of the occasion when an employee gets married. For that reason, employees will receive one paid day off for his/her wedding. The day must be taken at the time of an employee’s wedding.


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3.3 Leaves of Absence

Family Medical Leave Act (FMLA) Under the Family Medical Leave Act (FMLA) eligible employees may be entitled to up to 12 weeks of unpaid leave every twelve-month period for various family or medical reasons. The twelve-month period is calculated on a rolling basis, meaning the first day of leave is the first day of the period. Employees who have been actively employed for a total of at least 12 months; worked at least 1,250 hours during the preceding 12-month period prior to their leave; and work at a location where at least 50 employees are employed at the location or within 75 miles of the location are eligible for FMLA. For employees not eligible for family and medical leave, the Company will review business considerations and the individual circumstances involved. Except for those employees designated as "key employees", an employee taking family and medical leave may return to the same or a substantially equivalent position upon return from leave. The Company will notify "key employees" of their designation as a “key employee” prior to the approval of their leave.

The Company will measure an employee's 12 weeks of leave entitlement from the date of the employee’s first day of FMLA leave. The 12 weeks of leave will include any PTO used by the employee.

FMLA is an unpaid leave. Employees may be eligible to receive Short Term Disability benefits from the Company in the event of the employees own serious health condition. Employees may also use PTO.

If intermittent FMLA leave is approved, an employee may be allowed to make up time to replace lost wages. However, regularly scheduled work missed due to intermittent FMLA leave will still be counted toward the employee’s FMLA entitlement. Make-up time will be allowed only if the FMLA leave is unpaid and taken in increments of two (2) hours or less per day; and must be made up during the workweek in which the leave was taken. If the FMLA leave is paid (i.e., PTO or Short Term Disability is used), then make-up time is prohibited.

All employees who meet the applicable time-of-service requirements may be granted a total of twelve weeks of family leave (this includes PTO, short term disability and personal leave combined) during any 12-month period for the following reasons:

1. the birth of the employee's child and in order to care for the newborn child; 2. the placement of a child with the employee for adoption or foster care; 3. to care for an immediate family member (spouse, child, or parent) with a serious health condition; 4. a serious health condition that renders the employee incapable of performing the functions of

his/her job; 5. A qualifying exigency caused by a family member’s (spouse, child, parent, or next of kin) active

military duty as described below.

Employees who have a family member in the Reserves or National Guard who is called to active duty or who have a family member on regular active duty may be eligible for an exigency leave. Qualifying exigencies may include attending certain military events, arranging for alternative childcare, addressing certain financial and legal arrangements, attending certain counseling sessions, and attending post-deployment reintegration briefings.

The entitlement to leave for the birth or placement of a child for adoption or foster care will expire 12 months from the date of the birth or adoption.

In addition, employees who meet the applicable time-of-service requirements may be granted a total of twenty-six (26) weeks of family leave for leaves due to the care of a family member (spouse, child,


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parent, or next of kin) seriously injured or made ill in the line of active military duty or to care for a veteran who is undergoing medical treatment, recuperation, or therapy for an illness or injury, as long as care is obtained within five years of the veteran’s military service.

In situations where both spouses are employed by the Company, the Company has the right to limit leaves to twelve weeks combined for the following situations:

1. The birth and care of a newborn child or placement of an adopted or fostered child. 2. Care of an employee’s parent who has a serious health condition. 3. Qualifying exigencies.

In all cases, an employee requesting leave must complete a Request for Family or Medical Leave form and return it to Human Resources. The completed form must state the reason for the leave, the duration of the leave, and the starting and ending dates of the leave.

An employee intending to take family or medical leave because of any expected birth or placement of a child for adoption or foster care, or because of a planned medical treatment, must submit an application for leave at least 30 days before the leave is to begin. If the leave is unforeseeable, the employee must notify Human Resources as soon as the need for the leave arises.

An application for leave based upon the serious health condition of the employee or the employee's spouse, child, or parent must also be accompanied by a "Medical Certification Statement" completed by the applicable health care provider. The certification must state the date on which the health condition commenced, the probable duration of the condition, and the appropriate medical facts regarding the condition.

If the employee is needed to care for the spouse, child or parent, the certification must so state along with an estimate of the amount of time the employee will need. If the employee has a serious health condition, the certification must state that the employee cannot perform the functions of his/her job.

An application for leave for the placement of a child with the employee for adoption or foster care must be accompanied by the appropriate court documents.

The medical certification form may be obtained from Human Resources and must be completed and returned to Human Resources within 15 days of receipt.

During a period of family and medical leave, an employee will remain on the Company's insurance plans under the same conditions that applied before leave commenced. To continue coverage, the employee must continue to make any contributions that he/she made to the plan(s) before taking leave. If the employee is receiving short term disability benefits during all or a portion of the leave, the Company will take the employee's normal benefits deductions out of the disability check paid on the 15th of each month. The Company will require the employee to submit a check for the full amount of the benefits deductions to Human Resources by the 15th of each month in the event the employee is not receiving disability benefits or the deductions exceed the amount of the check. Failure of the employee to pay his/her share of health insurance premium may result in loss of coverage.

If the employee fails to return to work after the expiration of the leave, the employee will be required to reimburse the Company for payment of health insurance premiums during the leave, unless the reason the employee fails to return to work is the presence of a serious health condition which prevents the employee from performing his/her job or to circumstances beyond the employee's control.


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An employee is not entitled to the accrual of any seniority or employment benefits that would have accrued if not for the taking of the leave. An employee who takes family or medical leave will not lose any seniority of employment benefits that accrued before the leave began. During the leave, an employee will not accrue PTO. Holiday’s will not be paid during any unpaid portion of leave. The Company will count paid holidays against FMLA.

The period of time during which employees are being paid PTO or disability pay will run concurrently with the 12 weeks of FMLA leave. After all paid leave has been exhausted; the remainder of the leave will be unpaid.

Employees on leave due to their own serious health condition may supplement their disability checks with PTO payments, not to exceed 100% of their pre-disability earnings.

The Company will restore an employee to his/her old position or an equivalent position with equivalent pay, benefits, and other terms and conditions of employment when the eligible employee returns from family and medical leave with the exception of those employees designated as key employees. The Company cannot guarantee the employee will return to his/her original job. The Company will determine if a position is an equivalent position.

Any employee returning from leave due to their own serious health condition, must submit a letter to Human Resources from their physician stating the date the employee is authorized to return to work and describing any restrictions applied to the employee. If an employee wishes to return to work prior to the expiration of a family or medical leave of absence, the employee must notify Human Resources at least five working days prior to the employee's planned return date.

An employee is expected to return to work on the date indicated on the Request for Family or Medical Leave form. The failure of an employee to return to work upon the expiration of a family or medical leave of absence will subject the employee to immediate termination unless an extension is granted.

An employee who requests an extension of leave due to the continuation, recurrence or onset of his/her own serious health condition, or of the serious health condition of the employee's spouse, child, or parent must submit a request for an extension, in writing, to Human Resources as soon as practicable. The Company may extend the leave for no more than 12 weeks. If an employee is granted an extension, the Company will provide health insurance benefits, subject to the terms, condition, and limitations of the applicable plans, until the end of the month in which the extension was granted. The employee will then be offered the opportunity to purchase continuing coverage, at his/her own expense, under state and federal COBRA continuation rules. For example, if an employee is granted an extension beginning on May 15, the employee’s benefits will continue until May 31, at which time the employee will then be offered to continue coverage through COBRA effective June 1. Please see the Benefits Continuation (COBRA) policy for more information regarding COBRA.

Personal Leave From time to time it may be necessary for an employee to be away from work for an extended period of time for various personal reasons, under circumstances that would not qualify for one of the types of leaves discussed in this Handbook. All employees are eligible to request personal leave.

As soon as an eligible employee becomes aware of the need for a personal leave of absence, the employee should request, in writing, a leave from his/her supervisor.

Unpaid personal leave may be granted for a period of up to one year.


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The Company will consider written requests for unpaid personal leave based on a number of factors, including anticipated work load requirements and staffing considerations during the proposed period of absence.

The Company will provide health insurance benefits, subject to the terms, condition, and limitations of the applicable plans, until the end of the month in which the approved personal leave begins. At that time employees will be offered the opportunity to purchase continuing coverage under state and federal COBRA continuation rules. When the employee returns from personal leave, benefits will again be provided by the Company according to the applicable plans.

The Company will suspend seniority and benefit accruals, such PTO, sick leave, or holiday benefits, during the leave. The seniority and benefit accruals will resume upon return to active employment at the rate in place at the time when the personal leave commenced.

The Company will make a reasonable effort to return the employee to the same position, if it is available, or to a similar available position for which the employee is qualified when the personal leave ends. However, there is no guarantee reinstatement following return from personal leave.

If an employee fails to report to work promptly at the expiration of the approved leave period, the Company will assume the employee has resigned.

Bereavement Leave Employees who wish to take time off due to the death of an immediate family member should notify their supervisor immediately. Up to three (3) days of paid bereavement leave will be provided to all employees.

Bereavement pay is calculated based on the base pay rate at the time of absence and will not include any special forms of compensation, such as incentives, commissions, bonuses, or shift differentials.

Bereavement leave will normally be granted unless there are unusual business needs or staffing requirements. Employees may, with their supervisors' approval, use any available paid leave for additional time off as necessary.

The Company defines "immediate family" members include spouse, partner, parents, children, grandparent, great-grandparent, grandchildren, brother, sister, spouse's or partner's parents, spouse's or partner's grandparent's, brother/sister in-law, and any other person who has acted a legal guardian for an employee, an employee’s spouse or child. Special consideration will also be given to any other person whose association with the employee was similar to any of the above relationships.

If more time is required, additional days may be charged against PTO or treated as an unpaid leave.

Bone Marrow Donation Leave The Company provides a maximum of 40 hours of paid leave to an employee who seeks to undergo a medical procedure to donate bone marrow. The Company may require verification by a physician of the purpose and length of the leave.

The amount of Federal Family and Medical leave available to an employee is not reduced by the amount of bone marrow donation leave taken.

Military Leave The Company will grant military leave of absence to employees who are absent from work because of service in the U.S. uniformed services in accordance with the Uniformed Services Employment and Reemployment Rights Act (USERRA). Advance notice of military service is required, unless military necessity prevents such notice or it is otherwise impossible or unreasonable.


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The Company will grant a leave of absence for an employee who, as part of a military obligation, is required to continue in an active reserve status and serve two weeks of active duty annually. This period is in addition to the regular paid time off allowance. The Company will pay returning employees the difference between their normal base compensation and the pay (excluding expense pay) received while on military duty upon presentation of satisfactory military pay verification data.

The portion of any military leaves of absence in excess of two weeks may be unpaid. However, employees may use any available paid time off for the absence.

Continuation of health insurance benefits is available as required by USERRA based on the length of the leave and subject to the terms, conditions and limitations of the applicable plans for which the employee is otherwise eligible.

Employees on military leave for up to 30 days are required to return to work for the first regularly scheduled business day after the end of service, allowing reasonable travel time. Employees on longer military leave must apply for reinstatement in accordance with USERRA and all applicable state laws.

Upon completion of the period of active service the Company will restore the employee to a position of like seniority, status and pay provided:

• The employee has received a certificate attesting to the satisfactory completion of his/her military service.

• The employee is still qualified to perform the duties of his/her former position. • The employee makes application for reemployment within 90 days after his/her discharge from

military service. • The Company's circumstances have not changed so as to make it impossible or unreasonable to

rehire the employee.

For purpose of determining benefits based on length of service, the Company will treat returning employees as though they were continuously employed during the military leave.

Contact Human Resources for more information or questions about military leave.

Jury Duty The Company encourages employees to fulfill their civic responsibilities by serving jury duty when required. Employees in an eligible classification may request up to 2 weeks of paid jury duty leave over any twelve-month period

Employee classifications that qualify for paid jury duty leave are:

• Regular full-time employees • Regular part-time employees

If an employee is required to serve jury duty beyond the period of paid jury duty leave, he/she may use any available paid time off or may request an unpaid jury duty leave of absence.

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 the Company or the employee may request an excuse from jury duty if, in the Company's judgment, the employee's absence would create serious operational difficulties.


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The Company will continue to provide health insurance benefits to eligible employees for the full term of the jury duty absence.

Benefits, such as PTO, will continue to accrue during the time of the jury duty absence.

Time Off to Vote The Company encourages employees to fulfill their civic responsibilities by voting in elections. Generally, employees are able to find time to vote either before or after their regular work schedule. If employees are unable to vote in an election during their nonworking hours, the Company will grant employees enough time away from work which is necessary for the employee to appear at his/her polling place, cast a ballot, and return to work*. If an employee is unable to vote during non-working hours, the employee should make arrangements in advance with his/her supervisor for time off, either at the beginning or end of his/her scheduled work day. Because most polling centers operate from early morning until late in the evening, most employees should have ample time to vote outside of working hours.

*State Specific Provisions For employees in the following states, the policy is: Arizona: Employees in the state of must request time off prior to the day of election. Employees

with less than three hours between the opening of the polls and the beginning of their normal work hours or the end of their normal work hours and the closing of the polls may take paid leave up to three consecutive hours to vote. The time of the day employees can take off to vote may be determined by the Company.

California: Employees who do not have sufficient time outside of work to vote may take up to two

hours of paid time off to vote at the beginning or end of his/her normal work schedule. Colorado: Employees who provide prior notice to the Company may take up to two hours of paid

time off to vote. The time of the day employees take off to vote may be determined by the Company. Time off to vote is not available if there are three or more hours between the time of opening and the closing of the polls in which the employee is not required to be on the job.

Florida: No state specific provision. Illinois: Employees who provide prior notice to the Company may take up to two hours of paid

time off to vote, if the employee’s work schedule begins less than two hours after the opening of the polls and ends less than two hours before the closing of the polls.

Iowa: Employees who do not have three consecutive hours outside of their normal work

schedule during the hours the polls are open may have up to three hours of paid time off to vote. The time of the day employees can take off to vote may be determined by the Company.

Maine: No state specific provision. Massachusetts: Employees who provide prior notice to the Company may take the first two hours the

polls are open as unpaid time off. Missouri: Employees who provide prior notice to the Company may take three hours off work to

vote if there are not three consecutive hours when the polls are open outside of the his/her


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normal work schedule. If the request for time off is made prior to the day of the election, the time off from work will be paid.

New Jersey: No state specific provision. New York: Employees who do not have four consecutive hours outside of their normal work

schedule during the hours the polls are open may have up to two hours of paid time off to vote. The time of the day employees can take off to vote may be determined by the Company.

North Dakota: Employees who provide prior notice to the Company may take a reasonable amount of

time off if regular work schedules conflict with the times polls are open. Pennsylvania: No state specific provision. South Dakota: Employees who do not have two consecutive hours outside of their normal work schedule

during the hours the polls are open may have up to two hours of paid time off to vote. The time of the day employees can take off to vote may be determined by the Company.

Tennessee: Employees who do not have three consecutive hours outside of their normal work

schedule during the hours the polls are open may have up to three hours of paid time off to vote. The time of the day employees can take off to vote may be determined by the Company

Texas: If the polls are not open for two consecutive hours outside an employee’s normal work

schedule, then he/she may take paid time off to vote. Virginia: No state specific provision. Washington: If the polls are not open for two consecutive hours outside an employee’s normal work

schedule or the employee does not have time to get an absentee ballot, then he/she may take up to two hours of paid time off to vote.

Wisconsin: Employees who provide prior notice to the Company may take three hours off unpaid

time off to vote. If the request for time off is made prior to the day of the election, the time off from work will be paid.

Witness Duty The Company encourages employees to appear in court for witness duty when subpoenaed to do so.

If employees have been subpoenaed or otherwise requested to testify as witnesses by the Company, they will receive normal pay for the entire period of witness duty.

Employees will be granted a maximum of 40 hours of paid time off to appear in court as a witness at the request of a party other than the Company. Employees will be paid at their base rate and are free to use any remaining paid leave benefits (such as PTO) to receive compensation for any period of witness duty absence that would otherwise be unpaid.

The subpoena should be shown to the employee's supervisor immediately after it is received so that operating requirements can be adjusted, where necessary, to accommodate the employee's absence. The employee is expected to report for work whenever the court schedule permits.


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Parental Leave for School Visits The Company recognizes the value of parental involvement in children's education. For this reason, the Company provides employees who are parents, guardians, or custodians of children in licensed day care facilities or kindergarten through grade 12 unpaid time off for the purpose of school visits. Parental leave for school visits allows employees to participate in activities sponsored, approved, or supervised by the school or daycare such as parent/teacher conferences or field trips.

Employees may request up to 16 hours of parental leave for school visits within any calendar year. Any available paid leave may be substituted for unpaid leave for school visits. Employees must provide their immediate supervisors reasonable advance notice of the need for parental leave for school visits. Upon return from the leave, employees must provide documentation to their supervisor from the school verifying the date and time of the visit. Employees should contact their supervisor for more information or questions about and requests for parental leave for school visits.

Pregnancy and Parental Leave Act (Minnesota Employees Only) Eligible employees may be allowed up to twelve (12) weeks of unpaid leave to care for the employee’s child after birth or placement for adoption. Employees are eligible if they have been actively employed by the Company for a total of at least 12 months, and worked an average of at least 20 hours per week during the previous 12 months immediately prior to their leave. Leave for the birth or adoption of a child may begin not more than six (6) weeks after the birth or adoption; except that, where the child must remain in the hospital longer than the mother, the leave must begin within six (6) weeks after the child leaves the hospital.

Employees on leave are required to exhaust all PTO in excess of 40 hours. The length of this leave will be reduced by any period of paid disability leave so that the total leave does not exceed twelve weeks.

If an employee is also eligible for FMLA leave, the twelve weeks of parenting leave under this policy will run concurrently with the twelve weeks of FMLA leave. If an employee is not eligible for FMLA leave, or if the employee has used up his/her FMLA leave for other purposes, this policy will apply. An employee using this leave is entitled to reinstatement to the employee’s position or an equivalent one.

The Company will provide health insurance benefits, subject to the terms, condition, and limitations of the applicable plans, until the end of the month in which the leave was granted. Employees will then be offered the opportunity to purchase continuing coverage under state and federal COBRA continuation rules.

SECTION IV: EMPLOYEE ACKNOWLEDGMENT

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4.1 Employee Acknowledgment Form The employee handbook describes important information about the Company. I understand that I should consult Human Resources or my supervisor regarding any questions not answered in the handbook. I have entered into my employment relationship with the Company voluntarily and acknowledge that there is no specified length of employment. Accordingly, either I or the Company can terminate the relationship at-will, with or without cause, at any time, so long as there is no violation of applicable federal or state law.

Since the information, policies, and benefits described here are necessarily subject to change, I acknowledge that revisions to the handbook may occur, except to the Company's policy of employment at-will. The Company reserves the right to vary from any of the policies and practices, oral or written representation or statements regarding the terms and condition of my employment with the Company and affiliates. Only the Chief Executive Officer of the Company or his/her designee(s) has the ability to adopt any revisions to the policies in this Handbook.

I acknowledge that this handbook is neither a contract of employment nor a legal document. I have received the handbook, and I understand that it is my responsibility to read and comply with the policies contained in this handbook and any revisions made to it.

I acknowledge that if I am eligible to participate in the Paid Time Off program, by signing this employee acknowledgement form, I am authorizing a deduction from my final pay check for unearned portions of PTO taken if my employment relationship with the company terminates.

I acknowledge that the Company may conduct workplace monitoring. I acknowledge that the use of Company property, including but not limited to, e-mail, phones, the Internet, and workspace areas, is not private and may be monitored from time to time.

EMPLOYEE'S NAME (printed): ________________________________________

EMPLOYEE'S SIGNATURE: ____________________________________________

COMPANY NAME: ____________________________________________

DATE: __________________________________

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