TABLE OF CONTENTS

Culture................07

Our Work Environment.................16

Benefits.................19

Paid Time Off (PTO)................23

Performance Excellence................26

Your Pay................29

Leaves of Absence................33

Your Workday................43

Human Resources Policies................52

Employee Relations................57

Communication Policies................60

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We are delighted that you’ve chosen to join the Pinnacle Promotions team. On behalf of your colleagues, we welcome you to Pinnacle and look forward to your contributions.

We believe that each employee contributes directly to Pinnacle’s growth and success, and we hope you will take pride in being a member of our team. We are proud to be recognized as a “Best Place to Work” by COUNSELOR magazine year after year.

Creating a great place to work – where employees thrive professionally and personally and where they look forward to getting out of bed and coming back to work every day – is a key priority for us. We’re committed to making something great even better!

This handbook will provide you with important information about Pinnacle Promotions – our history, our culture and the expectations of our employees. Please familiarize yourself with the contents of this handbook carefully, and feel free to ask Human Resources or your manager if you have any questions.

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

Sincerely,

Mitch Weintraub & David Weintraub

Note: Policies and procedures may be subject to change at any time.

Mitch WeintraubCEO

David WeintraubPresident

Welcome to Pinnacle Promotions

Striving For PerfectionFrom an early age, Mitch and Dave Weintraub were taught that impressions matter—the first, the last and every one in between. Paying attention to the details and striving for perfection formed the backbone of their personal values. These same values are infused throughout Pinnacle Promotions, where the brothers have created a culture of caring and innovation in which each order is flawlessly executed and delivered on time, every time.

Born to BrandFrom sports as kids to attending the University of Florida, Mitch and Dave have always been close. So when they decided to attend graduate school in different states it was no surprise that they would be back together at some point soon.

In 1994 Mitch was attending Emory University and nearing the end of his M.B.A. program, while Dave was attending the University of Memphis Law School. After a brief experience working as a financial analyst, Mitch decided that he could make more of a difference teaming up with his brother to create a company that reflected their personal values. Always the entrepreneur, he looked back at his college business of designing and selling t-shirts to the fraternities, bookstores and students, and decided he could do it again on a much larger scale. He and his brother developed what would become Pinnacle Promotions. Within months, Dave moved to Atlanta, passed the bar exam, and together they started to lay the groundwork for the company’s long-term growth from the bedroom of Mitch’s apartment to Pinnacle’s new 22,000 square foot office in Atlanta.

By hiring conscientious people, investing in innovative technologies and adhering to their ongoing pursuit of perfection, the Weintraub brothers have built a business that serves thousands of brands and organizations that are as concerned about making the right impression as they are.

Our Story

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Our vision is to become the most

innovative, diversified & profitable

promotional marketing agency.

5 Reasons Why Pinnacle Is The Best ChoicePinnacle Promotions is a promotional marketing agency with expertise in design, sourcing, and production of branded merchandise and corporate apparel. Since 1994, we have worked with some of the world’s most recognized brands including Coca-Cola, GE, USAA, Merrell and FedEx, and some of the most respected institutions such as Harvard, the Department of Homeland Security and The Crohn’s & Colitis Foundation of America. Whether you represent a large organization or are shopping for a personal event, you can expect an unparalleled buying experience.

Marketing professionals choose Pinnacle Promotions because of our ability to consistently deliver the right product at the right price and provide an exceptional customer experience. Here’s how:

1. The Right People: We hire the smartest, most creative, detail-oriented and caring people, and ensure each of them continually improves their skills through our rigorous training program.

2. Best selection of products: Our team of merchandisers sourced tens of thousands of products that provide the best combination of quality and value.

3. Versatility: We make it possible for our clients to shop the way they want. By offering a dedicated account team, an award-winning website and online company stores for individual brands, we offer various levels of service to match every customer’s needs.

4. Reliability: Our proprietary order management system (OrderWorks™) tracks our clients’ orders from beginning to end and allows us to confidently guarantee that they will get their order on time and as expected.

5. Speed: Our company was built for speed. Our exclusive RocketShip™ 24-Hour Service enables customers on tight timeframes to meet their deadline without sacrificing quality or value.

About Us

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2013• Best Places to Work – Counselor Magazine

2012• Overall Winner in the Blogs Category

– PPAI Technology Awards

2011• Best Places to Work – Counselor Magazine

• PPB Greatest Companies to Work For

2010• Best Places to Work – Counselor Magazine

• PPAI Web Nominee – Functionality/Usability

• PPAI Web Nominee – Visual Design/Creativity

2008• Best Places to Work – Counselor Magazine

Company Awards

Pinnacle Promotions has received numerous awards and accolades for different aspects of our business across the industry.

We Care. We care about our customers, suppliers and each other, and we are invested in what each is trying to achieve.

Do What’s Right.We are guided by the principles of honesty and openness and act with integrity in every situation.

Be Passionate.We are driven by a genuine enthusiasm for what we do and who we work with.

Seek Perfection. We strive to achieve perfection in everything we do because the details matter.

Challenge Yourself.We surround ourselves with people who constantly challenge themselves, both personally and professionally.

Embrace Change.We view change as an opportunity to grow and develop creative ideas for our clients.

Our Values

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Our EmployeesAs you probably already know, Pinnacle Promotions is not like other promotional products companies. We know that good people make a great company, and we make it a priority to focus on our employees. With an active, team-based environment, our employees have fun both in and out of the office. When our employees walk through the door, it’s more than just selling pens and pencils. It’s coming to work with our friends. We work hard and we have fun doing it every day!

At Pinnacle, we strive to create a workplace that encourages creativity and growth throughout the company. Our corporate philosophy is an “open management” style that fosters an entrepreneurial spirit of innovation. All employees are encouraged to provide creative suggestions and are empowered to resolve issues in the most effective way possible. All Pinnacle employees share in our vision for the future and are excited to help the company reach its goals.

We believe that our employees are the backbone of our company. We only hire the best and brightest across a variety of educational backgrounds to fulfill our mission of cultural diversity. After hire, all employees receive extensive industry training and continuing education. We also make every attempt to promote from within and there is unlimited potential for growth and development for everyone. Employees are also encouraged to participate in any number of our employee-headed committees.

Pinnacle Promotions is committed to giving back to our local community and creating an environment where employees can contribute their time and resources toward worthy causes. To help further our community initiatives, we created Pinnacle’s Green and Philanthropy Committees. These committees meet regularly to discuss new and innovative ways to protect and improve our environment, community and workplace. We are also members of 1% for the Planet and have committed to giving one percent of our revenue from the sale of our EarthSmart products to environmental non-profit groups. Pinnacle employees are always encouraged to present new ideas for philanthropic activities and events.

What Makes Us Special What Makes Us Special

Competitive AdvantagesSince 1994, some of the world’s most recognized brands have trusted Pinnacle Promotions to provide them with the right promotional products for their needs. Our dedicated Account Teams and cutting-edge technology allows us to consistently deliver services with quality, speed and reliability that is unmatched in the industry.

Need it Fast?Pinnacle Promotions is built with one thing in mind: Speed. If you wait until the last minute, forget to order your promotional products or need something in a hurry, we can ship it to you in one business day with our RocketShip 24-Hour Express Service™. When you need it quick—think RocketShip!

Looking for Ideas?Don’t spend your time searching through thousands of products and countless websites. We can quickly create an IdeaKit™ that matches the right products to your brand—and deliver it right to your inbox. Simply tell us what you need and we’ll do the rest.

Online Company Stores Made EasyCreate your own branded merchandise store with Pinnacle PLUS™. Our in-house team of web developers, designers and merchandising specialists can customize a private-label store that meets your brand guidelines and promotional needs. It’s a great way to keep an eye on your brand while reigning in costs.

Get CreativeWant to bring an idea to life? We can help. Our creative studio is stacked with talented designers who can create logos, develop new product ideas, extend marketing campaigns and more. We’ll take the same amount of care with your brand as we do with our own. After all, we only look good if you look good!

Satisfaction GuaranteedShop with confidence knowing that your experience is 100% guaranteed. Our Pinnacle Platinum Guarantee™ ensures that your order will arrive on time and exactly as you approved it, or we’ll re-run your order or refund your money. It’s that simple.

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We deliver creative product

ideas from the highest qualitysuppliers shipped in 24 hours.

The Employee Handbook

This Handbook is designed to acquaint you with Pinnacle Promotions and provide you with information about working here. The Handbook is a general source of information and is not all inclusive, but it is intended to provide you with a summary of some of the organization’s guidelines. This version replaces all previously issued editions.

Employment with Pinnacle Promotions is at-will. Employees have the right to end their work relationship with Pinnacle Promotions with or without advance notice, for any reason. Pinnacle Promotions has the same right. The language used in this Handbook and any verbal statements made by management are not a contract of employment, either express or implied, nor are they a guarantee of employment for a specific duration.

No representative of Pinnacle Promotions, other than the President or Chief Executive Officer, has the authority to enter into an agreement of employment for any specified period and such agreement must be in writing, signed by either the President or Chief Executive Officer and the employee.

No Employee Handbook can anticipate every circumstance or question. After reading the Handbook, if you have questions, please speak with your immediate manager, your Director or the Human Resources Department. Also, the need may arise to change the guidelines described in the Handbook. Except for the At-Will nature of employment, Pinnacle Promotions reserves the right to interpret the Handbook’s guidelines and statements, or change them without prior notice and in its sole discretion. In the event that the Handbook information conflicts with applicable law, the law governs.

No supervisor, manager, or other representative of Pinnacle Promotions has the authority to make any verbal promises, commitments, or statements of any kind regarding the employment policies and procedures set herein, or any other employment issues, that are legally binding on the Company.

Business EthicsAnd Code Of ConductThe successful business operation and reputation of the company is built upon the principles of fair dealing and ethical conduct of our employees. Our reputation for integrity and excellence requires careful observance of the spirit and letter of all applicable laws and regulations, as well as a scrupulous regard for the highest standards of conduct and personal integrity.

The continued success of the company is dependent upon our customers’ trust and we are dedicated to preserving that trust. Employees owe a duty to Pinnacle Promotions and its customers to act in a way that will merit the continued trust and confidence of the public. The company will comply with all applicable laws and regulations and expects its directors, officers, and employees to conduct business in accordance with the letter, spirit, and intent of all relevant laws and to refrain from any illegal, dishonest, or unethical conduct.

In general, the use of good judgment, based on high ethical principles, will guide you with respect to lines of acceptable conduct. If a situation arises where it is difficult to determine the proper course of action, the matter should be discussed openly with your immediate supervisor and, if necessary, with Human Resources, for advice and consultation.

Compliance with this policy of business ethics and conduct is the responsibility of each Pinnacle Promotions employee. Disregarding or failing to comply with this standard of business ethics and conduct could lead to disciplinary action, up to and including possible termination of employment. Employment with Pinnacle Promotions is at the mutual consent of Pinnacle Promotions and the employee, and either party may terminate that relationship at any time, with or without cause, and with or without advance notice.

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Equal EmploymentOpportunityPinnacle Promotions strongly believes in fair practices and consideration for others. Our company does not tolerate unlawful discrimination of any kind for any reason. We provide equal employment opportunities to all employees and applicants for employment without regard to race, color, religion, sex, national origin, ancestry, age, mental or physical disability, marital status, sexual orientation, or any other characteristic protected by federal, state or local law. This nondiscrimination policy extends to all terms and conditions of employment as well as the use of all company facilities, participation in all company sponsored activities, and all employment actions including, but not limited to, hiring, placement, promotion, compensation, benefits, and termination of employment.

Any employees with questions or concerns about any type of discrimination in the workplace are encouraged to bring these issues to the attention of Human Resources. Employees may raise concerns and make reports without fear of reprisal. Anyone found to be engaging in any type of unlawful discrimination will be subject to disciplinary action, up to and including termination of employment.

Unlawful HarassmentAnd Discrimination Free WorkplaceWe are committed to providing our employees an open and supportive environment, free from all types of unlawful harassment, discrimination and conduct that can be considered harassing, coercive, or disruptive, including sexual harassment. Actions, words, jokes, or comments based on an individual’s race, color, religion, sex, national origin, ancestry, age, mental or physical disability, marital status, sexual orientation, or any other characteristic protected by federal, state or local law, will not be tolerated. In addition, racial slurs, jokes or other inappropriate comments directed toward any person or group of people are strictly prohibited, and we will not

tolerate violation or ignorance of this philosophy.While it is not always easy to define precisely what sexual harassment is, it does include unwanted sexual advances, or visual, verbal, or physical conduct of a sexual nature. This definition includes many forms of offensive behavior and includes gender based harassment of a person of the same sex as the harasser. The following is a partial list of sexual harassment examples:

• Unwanted sexual advances

• Offering employment benefits in exchange for sexual favors

• Making or threatening reprisals after a negative response to sexual advances

• Visual conduct that includes leering, making sexual gestures, or displaying of sexually suggestive objects or pictures, cartoons or posters

• Verbal conduct that includes making or using derogatory comments, epithets, slurs, or jokes

• Verbal sexual advances or propositions

• Verbal abuse of a sexual nature, graphic verbal commentaries about an individual’s body, sexually degrading words used to describe an individual, or suggestive or obscene letters, notes, or invitations

• Physical conduct that includes touching, assaulting, or impeding or blocking movements

Unwelcome sexual advances (either verbal or physical), requests for sexual favors, and other verbal or physical conduct of a sexual nature constitute sexual harassment when: (1) submission to such conduct is made either explicitly or implicitly a term or condition of employment; (2) submission or rejection of the conduct is used as a basis for making employment decisions; or, (3) the conduct has the purpose or effect of interfering with work performance or creating an intimidating, hostile, or offensive work environment.

Our Work Environment Our Work Environment

Reporting An Incident Of Harassment, DiscriminationOr RetaliationPinnacle Promotions strongly urges the reporting of all incidents of discrimination, harassment or retaliation, regardless of the offender’s identity or position. Individuals who believe they have experienced or witnessed conduct that they believe is contrary to Pinnacle Promotions’ policy or who have concerns about such matters should file their complaints with their immediate supervisor, Human Resources or any member of the Senior Management Team before the conduct becomes severe or pervasive. Individuals should not feel obligated to file their complaints with their immediate supervisor first before bringing the matter to the attention of one of the other Pinnacle Promotions designated representatives identified above. You may raise concerns and make reports without fear of reprisal or retaliation. Any supervisor or manager who becomes aware of possible sexual or other unlawful harassment must immediately advise Human Resources or senior management, so it can be investigated in a timely and confidential manner.

Important NoticeTo All Employees:Employees who have experienced conduct they believe is contrary to this policy have an obligation to take advantage of this complaint procedure. An employee’s failure to fulfill this obligation could affect his or her rights in pursuing legal action. Also, please note, federal, state and local discrimination laws establish specific time frames for initiating a legal proceeding pursuant to those laws. Early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment. Therefore, while no fixed reporting period has been established, Pinnacle Promotions strongly urges the prompt reporting of complaints or concerns so that rapid and constructive action can be taken. Pinnacle Promotions will make every effort to stop alleged harassment before it becomes severe or pervasive, but can only do so with the cooperation of its staff/employees.

The availability of this complaint procedure does not preclude individuals who believe they are being subjected to harassing conduct from promptly advising the offender that his or her behavior is unwelcome and requesting that it be discontinued.

THE INVESTIGATIONAny reported allegations of harassment, discrimination or retaliation will be investigated promptly, thoroughly and impartially. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge.

Confidentiality will be maintained throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action.

RESPONSIVE ACTIONMisconduct constituting harassment, discrimination or retaliation will be dealt with promptly and appropriately. Responsive action may include, for example, training, referral to counselling, monitoring of the offender and/or disciplinary action such as warning, reprimand, withholding of a promotion or pay increase, reduction of wages, demotion, reassignment, temporary suspension without pay or termination, as Pinnacle Promotions believes appropriate under the circumstances.

Anyone, regardless of position or title, found through investigation to have engaged in improper harassment will be subject to discipline up to and including discharge. We prohibit any form of discipline or retaliation for reporting in good faith the incidents of harassment in violation of this policy, pursuing any such claim or cooperating in the investigation of such reports.

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Disability AccommodationWe are committed to complying fully with the Americans with Disabilities Act (ADA) and applicable state law, and to ensure equal opportunity in employment for qualified persons with disabilities. All employment practices and activities are conducted on a nondiscriminatory basis.

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

Reasonable accommodations for qualified individuals with known disabilities will be made unless to do so would be an undue hardship. All employment decisions are based on the merits of the situation in accordance with defined criteria, not the disability of the individual.

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

Procedure For RequestingAn AccommodationOn receipt of an accommodation request, Human Resources and your supervisor will meet with you to discuss and identify the precise limitations resulting from the disability and the potential accommodation that Pinnacle Promotions might make to help overcome those limitations.

Pinnacle Promotions will determine the feasibility of the requested accommodation considering various factors, including, but not limited to the nature and cost of the accommodation, the availability of tax credits and deductions, outside funding, Pinnacle Promotions’ overall financial resources and organization, and the accommodation’s impact on the operation of the Company, including its impact on the ability of other employees to perform their duties and on Pinnacle Promotions’ ability to conduct business.

Pinnacle Promotions will inform the employee of its decision on the accommodation request or on how to make the accommodation. If the accommodation request is denied, employees will be advised of their right to appeal the decision by submitting a written statement explaining the reasons for the request. If the request on appeal is denied, that decision is final.

The ADA does not require Pinnacle Promotions to make the best possible accommodation, to reallocate essential job functions, or to provide personal use items (i.e., eyeglasses, hearing aids, wheelchairs etc.).

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

An employee or job applicant who has questions regarding this policy or believes that he or she has been discriminated against based on a disability should notify the Human Resources Department. All such inquiries or complaints will be treated as confidential to the extent permissible by law.

Benefits For Regular Full-Time Employees

PERFORMANCE EXCELLENCE

A consistent Performance Excellence Review process. New employees will set annual goals within 60 days of hire. Formal reviews will be completed quarterly. Annual performance results will include a compensation review.

HEALTH INSURANCE

Regular full-time employees are eligible to participate in our medical benefits beginning the first of the month, after their hire date. Our medical insurance is reviewed annually with an open enrollment date in March. Company participates in the cost of the plan for the individual employee option. Specific plan details should be reviewed with Cassie Bullard at Intrepid – 770-612-4621 or cassie.bullard@nmfn.com.

DENTAL INSURANCE

Regular full-time employees are eligible to participate in our dental benefits beginning the first of the month, after their hire date. Our dental insurance is reviewed annually with an open enrollment date in March. Company participates in the cost of the plan for the individual employee option. Specific plan details should be reviewed with Cassie Bullard at Intrepid – 770-612-4621 or cassie.bullard@nmfn.com.

VISION INSURANCE

Regular full-time employees are eligible to participate in our vision benefits, beginning the first of the month, after their hire date. Our vision insurance is reviewed annually with an open enrollment date in March. Company participates in the cost of the plan for the individual employee option. Specific plan details should be reviewed with Cassie Bullard at Intrepid – 770-612-4621 or cassie.bullard@nmfn.com.

VOLUNTARY STDVoluntary Short-Term Disability Coverage: Benefits begin after 14 days of disability. 60% of weekly earnings - up to $1,000 maximum.

VOLUNTARY LTDVoluntary Long-Term Disability Coverage: Benefits begin after 90th day of disability. 60% of weekly earnings - up to $6,000 maximum.

SIMPLE IRAFull-time employees are eligible to participate in our Simple IRA plan beginning from their date of hire. Company matches up to 3% in contribution. Specific plan details should be reviewed with HR.

PAYROLL Direct deposit is available, as well as 24-hour online payroll stub access.

OBSERVED HOLIDAYS

Pinnacle Promotions provides paid time off for seven observed holidays and one floating holiday each year for all full-time employees.

SPD (Summary Plan Document) overrides any information in this handbook for Health, Dental and Vision Insurance.

Working At Pinnacle Promotions Has Its BenefitsOur company places a great deal of value on your happiness and health, which is why we’re proud to offer an amazing selection of benefits for regular full-time employees.

Our Work Environment Benefits

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JANUARY 1 New Year’s Day

MAY 26 Memorial Day

JULY 4 Independence Day

SEPTEMBER 1 Labor Day

NOVEMBER 27 Thanksgiving Day

NOVEMBER 28 Day After Thanksgiving

DECEMBER 25 Christmas Day

EMPLOYEE DISCRETION Floating Holiday

2014 HolidaysRegular full-time employees are eligible for paid holidays if they are actively employed and regularly scheduled to work on the observed holiday. If eligible nonexempt employees work on a recognized holiday, they will receive holiday pay plus wages at their straight-time rate for the hours worked on the holiday. Paid time off for holidays will be counted as hours worked for the purpose of determining whether overtime pay is owed.

Note: A recognized holiday that falls on a Saturday will be observed on the proceeding Friday. A recognized holiday that falls on a Sunday will be observed on the following Monday. Holiday pay will be calculated based on the employee’s straight time pay rate (as of the day of the holiday), times the number of hours the employee otherwise would have worked that day.

Benefits for regular full-time employees (continued)

SPD (Summary Plan Document) overrides any information in this handbook for Health, Dental and Vision Insurance.

PAID TIME OFF (PTO)

Regular full-time employees become eligible to begin accruing PTO from their date of hire. Allotment is accrued on a pay-period basis, but is granted in advance for usage. Regular full-time employees earn 16 PTO days upon hire. Each year of continuous service, employees are eligible to receive one additional day of PTO on their anniversary date, up-to a maximum of 21 days.

MATERNITY LEAVE

Regular full-time employees who have been with the company for one continuous year of service are eligible for six-weeks of paid maternity leave. There are additional restrictions associated with this benefit – please review with HR.

COBRA

Consolidated Omnibus Budget Reconciliation Act (COBRA) gives regular full-time employees the opportunity to continue health insurance coverage under Pinnacle’s health plan when a qualifying event would normally result in the loss of eligibility. Some common qualifying events are resignation, termination of employment, or death of an employee; reduction in employee’s hours or a leave of absence; employee’s divorce or legal separation, and more. Under COBRA, the employee pays the full cost of coverage at Pinnacle’s group rate plus an administration fee. Please review with HR for additional information and eligibility requirements.

Benefits Benefits

Additional Rewards of Working at Pinnacle Promotions

DRESS CODEOur office dress code is casual, yet professional – jeans are welcome when appropriate.

RECOGNITIONWe have continuous employee recognition opportunities including certificates of appreciation, monthly awards, a spin on our prize wheel, and Pinnacle Pounds.

CELEBRATIONSBirthdays are celebrated on a monthly basis and service anniversaries are recognized for every employee.

EMPLOYEE EVENTS

We have several employee events throughout the year including several onsite cookouts, potlucks, and holiday celebrations. In addition, we provide on-site flu shots annually and hold several offsite events each year.

ONSITE EXTRASOnsite car washes are provided for a fee and up-front parking is available for the Employee of the Month.

GYM MEMBERSHIP

Discounted gym memberships are available to Pinnacle employees through LA Fitness.

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Health, Dental AndVision CoverageFull-time health, dental and vision coverage are very important benefits offered to regular full-time employees at Pinnacle. hPinnacle pays a percentage of the insurance premiums for the employee only option plan. Your percentage of these premiums for all plans is paid with pre-tax dollars. In additions employees may elect to enroll in the Peoples Health Express Plan which provides additional health care benefits. Regular full- time employees are eligible to participate in our health, dental and vision plans beginning the first of the month, after their hire date. Elections must be made within 30 days of the date of hire.

Simple IraWe value our employees and the contributions they make to the company. Therefore, Pinnacle offers a Simple IRA plan to assist in saving for retirement. Fulltime employees are eligible to participate in the Simple IRA as of their date of hire. Company matches up to 3% in contribution. You may elect to contribute a specific dollar amount or percentage of compensation – deductions are made from each paycheck through pre-tax payroll deductions up to the maximum pretax amount determined by the IRS. Our Simple IRA partner is Fidelity Investments. Specific plan details should be reviewed with HR.

Benefits Paid Time Off (PTO)

YEARS OF

SERVICE

PTODAYS

SEMI-MONTHLY EARNED RATE

0-1 16 0.667

1 17 0.708

2 18 0.750

3 19 0.792

4 20 0.833

5+ 21 0.875

Paid Time Off (PTO)Employees need to maintain adequate reserves to cover vacation, illness, injury, pregnancy, disability, doctor’s appointments, school appointments, emergencies or other demands that require time off from work throughout the year. This policy is intended to assist employees in these areas. All available PTO must be exhausted before employees take unpaid time off.

Once employees enter a regular full-time employment classification, they begin to earn PTO semi-monthly according to the schedule below. PTO accrual is earned at the end of each full semi-monthly pay period in which the employee works. PTO does not accrue on unpaid leaves of absence unless otherwise provided by law. Employees may request to use earned PTO time and up to 10 days of unearned PTO time. PTO is offered on an annual basis and does not carry over to the following calendar year.

HIRE MONTH

MAX. # HOURS

PTO DAYS

January 128 16

February 116 14.5

March 104 13

April 96 12

May 84 10.5

June 72 9

HIRE MONTH

MAX. # HOURS

PTO DAYS

July 64 8

August 52 6.5

September 40 5

October 32 4

November 20 2.5

December 8 1

After one (1) year of employment you are eligible for one (1) extra vacation day per year (.33 hours per pay period) and for each year after you will receive one (1) more. The extra day and semi-monthly earnings rates will change on the first full pay period following your date of hire anniversary. For example if you have been here for 5 years you will receive a total of 5 more vacation days, earned one per year. The current maximum number of days is limited at 5 years of service or 21 PTO days.

The length of eligible service is calculated on the basis of a “benefit year.” This is the 12-month period that begins when the employee starts to earn PTO; usage of PTO is based on the calendar year. An employee’s benefit year may be extended for any significant leave of absence except military leave of absence. Military leave has no effect on this calculation.

New full-time employees will begin earning PTO upon their hire date. The following chart is an example of the number of PTO days that may be earned during the remainder of the calendar year. Please note that the below calculations include only eligible PTO, not the additional one day for the floating holiday.

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Scheduling Pto• Employees must complete the online PTO request and obtain their manager’s approval for all of their PTO absences.

• All planned PTO for vacations, must be requested and approved in advance, preferably with at least a month’s notice.

• With manager approval 10 days (80 hours) of PTO days that have yet to be accrued may be advanced for usage during the calendar year.

• PTO days are accrued monthly, calculated as Total 2013 PTO Days divided by 12. For example, 18 Total PTO days will accrue at a rate of 1.5 days per month.

• With manager approval, employees may be advanced up to 10 un-accrued PTO days (80 hours total). For example, at a rate of 1.5 PTO days a month, an employee may be allowed to take 5 PTO days in February, having earned 3 PTO days and being advanced 2 PTO days.

• Employees leaving the company with a negative PTO balance due to advanced PTO will have this balance deducted from their final paycheck.

• Although it is preferable that employee vacations not overlap with another employee’s time off, every effort will be made to accommodate requests. The earlier the request, the greater the likelihood that the request will be approved; however, vacations are minimal during our busy times of the year and some departments may limit PTO time to no more than 7 days in the 4th quarter.

• PTO time may only be taken in increments of half days (four hours) or full days (eight hours).

• Employees who have an unexpected need to be absent from work should notify their direct manager before the scheduled start of their workday, if possible. The direct manager must also be contacted on each additional day of the unexpected absence.

• In the event that available PTO is not used by the end of the calendar year, employees will be eligible to carryover 2 days, which they must schedule to use by the end of February of the following calendar year. Employees will forfeit the earned but unused PTO days in excess of 2 days (except where prohibited by law).

• Employees may not take more than five consecutive days of PTO at any given time. Exceptions require senior management approval.

• PTO is paid at the employee’s base pay rate at the time of absence for the amount of hours absent. It does not include overtime or any special forms of compensation such as incentives, commissions, bonuses, or shift differentials.

If You Leave The CompanyIf your employment with Pinnacle Promotions ends, any accrued and unused PTO is forfeited, unless otherwise provided by law. If an employee leaves the company and has used PTO days that have not yet been accrued/earned, the employee will be required to reimburse the company. Any owed PTO time will be deducted from the employee’s final paycheck, except where otherwise provided by law.

Rehired Employees• Rehired employees who have been away from the company for less than six months will have their tenure reinstated. The rate of earning PTO will continue at the rate the employee was earning prior to leaving the company.

• Rehired employees who have been away from the company for six months or more will begin earning PTO time based on their rehire date.

Time Off To VoteWe encourage our employees to fulfill their civic responsibilities by participating 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, we will grant up to 2 hours of paid time off to vote. Employees should request time off to vote from their manager at least two working days prior to the Election Day. Advance notice is required so that the necessary time off can be scheduled at the beginning or end of the work shift, whichever provides the least disruption to the normal work schedule.

Employees must submit a voter’s receipt on the first working day following the election to qualify for paid time off.

Witness DutyIf you have been subpoenaed or otherwise requested to testify as a witness by Pinnacle Promotions, you will receive paid time off for the entire period of witness duty.

Employees will be granted a maximum of 4 hours of paid time off to appear in court as a witness at the request of a party other than Pinnacle Promotions. Employees will be paid at their base rate and are free to substitute any remaining paid leave benefits 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 any necessary arrangements can be made to accommodate the employee’s absence. The employee is expected to report for work whenever the court schedule permits.

Jury DutyEmployees will be compensated for jury duty consistent with state law. Regular full-time employees who have completed a minimum of 90 consecutive calendar days of service may request up to one week of paid jury duty leave in a calendar year. Jury duty pay will be calculated on the employee’s base pay rate times the number of hours the employee would otherwise have worked on the day of absence.

If employees are required to serve jury duty beyond the period of paid jury duty leave, they 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 manager as soon as possible so that the supervisor may make arrangements to accommodate their absence. Employees are expected to report for work whenever the court schedule permits.

Either Pinnacle Promotions or the employee may request an excuse from jury duty if, in PinnaclePromotions’ judgment, the employee’s absence would create serious operational difficulties.

Should the jury duty prove to last more than thirty (30) consecutive calendar days, the employee will be placed in an unpaid leave status. We will continue to provide health insurance benefits until the end of the month in which the unpaid jury duty leave begins. Should the jury duty carry over to the following month, the employee may become responsible for the full costs of these benefits if he/she wishes coverage to continue. When the employee returns from jury duty, benefits will again be provided by Pinnacle Promotions according to the applicable plans.

Bereavement LeaveWhen a death occurs in an employee’s immediate family, all regular full time employees may take up to two (2) days off with pay to attend the funeral or make funeral arrangements.

Immediate family members are defined as an employee’s spouse or legal domestic partner, parents, stepparents, siblings, children, stepchildren, grandparent, father-in-law, mother-in-law, brother-in-law, sister-in-law, son-in-law, daughter-in-law, or grandchild.

All regular, full-time employees may take up to one (1) day off with pay to attend the funeral of a close, nonfamily member. This time off will be considered by the employee’s manager on a case-by-case basis.

Paid Time Off (PTO) Paid Time Off (PTO)

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Distinguished PerformanceThis employee consistently goes above and beyond exceeding expectations in all areas of responsibility. This employee possesses all of the previously noted strong qualities and in addition, is a superb communicator, paying excellent attention to detail, leading by example, and motivating and inspiring employees across the company. This employee is consistently out-performing his/her goals, is a leader within the organization and is recognized as a distinguished performer across the organization.

Exceeded Expectations This employee is an inspiring and generous contributor, consistently helping to develop, mentor and lead other employees and is willing to do whatever it takes to get the job done efficiently and successfully, while exhibiting our core values at a high-level. Internally and externally, this employee is a good representation of Pinnacle Promotions and our brand.

Achieved Expectations This employee is a valued member of our team and the company, and is a person who contributes successfully and enthusiastically. This person is consistent with his/her commitment and focus on continued career development and understands the value of a strong work ethic. This employee achieves his/her goals and demonstrates our core values consistently.

Partially Achieved Expectations This employee is performing the perfunctory parts of his/her job and shows interest in wanting to improve, however, is not fully meeting our expectations, has missed or partially achieved his/

her goals, and is not demonstrating our core values.

Unsatisfactory This employee is not performing and not contributing his/her share to the team. He/she has missed his/her goals and is not demonstrating our core values; is showing a lack of commitment, communication, enthusiasm, and teamwork, or perhaps displaying a general apathy toward his/her role in the company. This employee will be placed on a Performance Improvement Plan that will require immediate marked and sustained performance; is ineligible for promotion or transfer until performance has been improved; and, is ineligible for rewards and merit increases.

Performance Excellence Performance Excellence

Annual Compensation And Review GuidelinesThe annual evaluation of an employee’s compensation is also a very important part of the Performance Excellence process and is based on the employee’s accomplishments over the previous year, taking into account company performance, role summary, individual goals, and our Pinnacle Core Values. What follows are the guidelines we use during our PEx Review process. Obviously, if economic conditions change, the company must reserve the right to deviate from the guidelines.

Employee CompensationPinnacle Promotions has four employee compensation classifications: Direct, Indirect, Business Development and Management. These classifications govern the compensation packages for employees under these roles.

Direct employees are compensated through a base salary, an incentive bonus or commission and a company/department bonus pool.Indirect employees are compensated through a base salary. Some Indirect job roles also have an incentive bonus component.

Business Development employees are compensated through a base salary, an incentive bonus or commissions.

Management employees are compensated through a base salary and a management bonus tied to a combination of department and company metrics.

The following guide shows the job roles that are associated with each of the classifications. (Note: this guide may not reflect all job roles and employees should consult their managers if they are unsure which classification they are assigned.)

COMPENSATION CLASSIFICATION

DIRECT INDIRECTBUSINESS

DEVELOPMENTMANAGEMENT

Account Managers

Marketing RolesInside Business Development

Department Managers

Account Coordinators

Finance/Accounting

Roles

Outside Business Development

Department Directors

Relationship Managers

Creative/Art Roles

Department VPs

Program Managers

IT Roles

Program Coordinators

Important Note: We consider your compensation, which includes base salary, commision and/or bonuses, private and confidential. Discussion of your own compensation with other employees is subject to disciplinary action, including possible termination.

Open and honest feedback results in successful development of our employees and our company. We recognize the dedication, persistence and commitment of our employees through our extensive rewards

and recognition process, including Performance Excellence. We believe that employees are critical to the success and continued growth of our business, and because of that, our intent is to be diligent about setting goals, assessing and providing feedback, and creating growth and development plans for each of our employees. Job performance is reviewed formally each quarter, based on the calendar year. Our PEx

form is available via PDF.

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Compensation Guidelines

DIRECT AND BUSINESSDEVELOPMENT EMPLOYEESJob roles and compensation plans are reviewed annually on a calendar year basis. Total compensation packages are made up of a combination of business and department forecasting and comparable position market data. Base salaries and variable components (commissions and bonuses) may be adjusted yearly based on tenure, performance and targeted earnings expectations. Job roles in these categories are not subject to anniversary date reviews. Promotions in this category will receive a new compensation package that affords a greater total compensation potential but may not reflect a base salary increase.

INDIRECT EMPLOYEESJob roles associated with this category will receive a base salary merit review* on the employee’s anniversary date or the date of the last base salary increase. For those job roles that also include an incentive bonus component, that bonus is on an annual basis and is adjusted year to year to reflect the current goals and objectives of the role. Promotions in this category will be reviewed for a base salary increase.

MANAGEMENT EMPLOYEESJob roles associated with this category are reviewed on a calendar year basis and the components of the package are adjusted based on business forecasting. Base salaries may be adjusted, along with any variable component, to reflect a total compensation package commensurate with tenure, performance and targeted expectations. Job roles in these categories are not subject to anniversary date reviews. Promotions in this category will receive a new compensation package that affords a greater total compensation potential but may not reflect a base salary increase.

*BASE SALARY MERIT REVIEWSPinnacle Promotions observes a “pay for performance” policy. Base Salary Merit Reviews are conducted annually on the employee’s anniversary date or date of the last base salary increase, in accordance with the Company’s compensation guidelines. Merit increases, if any, are awarded to eligible employees based on their individual performance relative to assigned responsibilities and current compensation relative to the market. However, a merit review will not necessarily translate into a base salary increase.

Salary adjustments may be made for specific situations such as promotions, demotions, reclassifications or other reasons deemed appropriate by your manager. Promotions may or may not have an impact on base salary depending on the compensation category. Salary adjustments made outside of the normal merit review cycle will result in the subsequent merit increase review date being moved to 12 months from this increase date.

Pinnacle Promotions reserves the right to postpone or cancel Base Salary Merit Reviews if business conditions create a financial position that does not supports these increases. Pinnacle Promotions incorporates cost-of-living as a component of the total compensation package and may be reflected in either the base salary or total potential earnings increases.

Employee Classifications

Performance Excellence Your Pay

REGULARFULL-TIME

Employees who are scheduled to work a minimum of 40 hours per week and are not hired into a temporary position are considered Regular Full-Time. Regular Full-Time employees are eligible to participate in Pinnacle Promotion’s benefit plans as outlined in each plan.

REGULARPART-TIME

Employees who are scheduled to work less than 40 hours per week and are not hired into a temporary position are considered Regular Part-time. Regular Part-time employees may be paid on an hourly or salaried basis based on their positions and job responsibilities. Regular Part-time employees are not eligible to participate in Pinnacle Promotions’ benefits.

TEMPORARY

A temporary employee is hired for a specified project or time frame and works a non-specific schedule of less than 1000 hours in a rolling twelve month period. A temporary employee is paid according to the terms of hire for that individual. Temporary employees do not receive any additional compensation or benefits provided by the Company.

EXEMPT ORNON-EXEMPTSTATUS

Employees are also classified as exempt or non-exempt based on their job responsibilities. Non-exempt employees are eligible for overtime pay for hours worked more than 40 in a work week. Exempt employees are not eligible for overtime pay.

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Time KeepingFederal and state laws require Pinnacle Promotions to keep an accurate record of time worked by non-exempt employees in order to properly calculate employee pay and benefits. Non-exempt employees must accurately record the time they begin and end their workday, the beginning and end of their meal period, and the beginning and end of any split-shift. Overtime work must always be approved before it is performed. Once approved, overtime assignments will be distributed as equitably as practical to all employees qualified to perform the required work. Employees working overtime without approval will be subject to disciplinary action. Overtime compensation is paid to non-exempt employees in accordance with federal and state wage and hour restrictions and based on actual hours worked. Time off on sick leave, PTO, or any leave of absence will not be considered hours “worked” for calculating overtime payments.

All full-time employees are provided with one meal period of 60 minutes in length each workday. Managers will schedule meal periods to accommodate business requirements. Employees will be relieved of all active responsibilities and restrictions during meal periods and will not be compensated for that time. Meal breaks are not accrued or cumulative and cannot be carried over to another day.

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. If there is a mistake in the recording of time worked or concerns regarding an employee’s timekeeping or pay, the employee should inform their manager and HR immediately.

If you are classified as an exempt employee, you will receive a set salary, which is intended to compensate you for any hours you may work. Exempt employees are not required to keep records of their time worked.

Salary AdministrationThe salary administration program at Pinnacle Promotions was created to achieve consistent pay practices, comply with federal and state laws, mirror our commitment to Equal Employment Opportunity, and offer competitive salaries within our labor market. Because recruiting and retaining talented employees

is critical to our success, Pinnacle Promotions is committed to paying its employees equitable wages that reflect the requirements and responsibilities of their positions and are comparable to the pay received by similarly situated employees in other organizations in the area.

Compensation for every position is determined by several factors, including the essential duties and responsibilities of the job, and salary survey data on pay practices of other employers. Pinnacle Promotions periodically reviews its salary administration program and restructures it as necessary.

Employees should bring their compensation-related questions or concerns to the attention of his/her manager.

PaydaysAll employees are paid semimonthly on the 15th and last day of the month. Each paycheck will include earnings for all work performed through the end of the previous payroll period. Overtime payment, which is included with the non-exempt employee’s base salary payment, is also paid semi-monthly with such payment covering hours worked in the prior semi-monthly period.

In the event that a regularly scheduled payday falls on a day off such as a weekend or holiday, employees will receive pay on the last day of work before the regularly scheduled payday.

You are encouraged to take advantage of our direct deposit benefit. Employees can access their individual payroll information and pay stubs online through Paychex at https://benefits.paychex.com. If a regular payday falls on an employee’s vacation and they are receiving paper checks, the employee’s paycheck will be available upon his/her return from vacation.

Pay AdministrationPinnacle Promotions recognizes and emphasizes the importance of properly compensating employees and ensuring continued and complete compliance with all governing wage and hour laws. It is our policy that all employees should be compensated appropriately and in compliance and accordance with the Fair Labor Standards Act, as well as any applicable state and local wage and hour laws. Pinnacle Promotions 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. Pinnacle Promotions strictly prohibits the practice of making improper and unauthorized deductions from employee wages.

Pinnacle Promotions does not provide pay advances on unearned wages to employees.

Pinnacle Promotions reserves the right to withholdamounts from employees’ pay. These deductionsinclude, but may not be limited to:

• Social Security taxes;

• Federal and state taxes;

• Participation in the Company’s benefit plans;

• Full or partial days not worked during the first or last week of employment; and

• Unpaid leave under the Family and Medical Leave Act, whether taken in full or partial day segments Eligible employees may voluntarily authorize deductions from their paychecks to cover the cost of any voluntary programs offered by your employer. Pay setoffs are pay deductions taken by Pinnacle Promotions, usually to help pay off a debt or obligation to Pinnacle Promotions or others and will be made where applicable in compliance with federal and state law.

Under federal and state law, your salary is subject to certain deductions. For example, absent contrary state law requirements, your salary may be reduced for the following reasons:

• Full day absence for personal reasons including sickness, disability and FMLA, if all your PTO has been exhausted.

• Partial day of absence for non-exempt employees for personal reasons including sickness, disability and FMLA, if all PTO has been exhausted.

• Full day disciplinary suspensions for infractions of our written policies and procedures.

• To offset amounts received as payment for jury and witness fees or military pay.

• Full days not worked in the pay-period in the case of new hires that start in the middle of a pay period or terminated employees whose last day is in the middle of the pay period.

Your Pay Your Pay

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Non-Exempt EmployeesNon-exempt employees are paid current based on working 40 hours per week. If a non-exempt employee works less than 40 hours in a work week and does not use any eligible paid time off to cover those hours, the hours not worked will be deducted from their pay in the next available pay period. The deduction will be based on the unpaid hours times the employee’s hourly rate of pay. Also, any overtime hours earn in a pay period will be paid in the next available pay period.

Exempt EmployeeThe regular base salary of exempt employees is a pre-determined amount constituting all or part of their compensation. For exempt leaders and managers, deductions from salary are generally prohibited, except as provided by law, and will be assessed on a case-by-case basis.

Deductions From PayPinnacle Promotions prohibits all deductions from the salary of exempt leaders and managers which are not proper under applicable law. Each employee is responsible for reviewing his or her paycheck upon receipt. In the unlikely event that there is an error in the amount of pay, the employee should promptly bring the discrepancy to the attention of their manager, Finance or Human Resources so that corrections can be made as quickly as possible. Pinnacle Promotions will promptly reimburse the employee for an improper deduction and, in good faith, will take any necessary corrective actions to prevent similar improper deductions in the future.

Your salary will not be reduced for any of the following reasons:

• Absences for jury duty, attendance as a witness, or military leave in any week in which you have performed any work.

• Any other deductions prohibited by state or federal law.

Please note it is not an improper deduction to reduce an employee’s accrued vacation, personal or other forms of paid time off from an employee’s leave bank for full or partial day absences for personal reasons, or for sickness or disability if the employer has a sickness or disability policy that provides for wage replacement benefits.

If an employee has been paid in excess of what he/she has earned, the employee will need to return the overpayment to Pinnacle as soon as possible. No employee is entitled to retain any pay in excess of the amount he/she has earned according to the agreed-upon rate of pay. If a wage overpayment occurs, the overpayment will be regarded as an advance of future wages payable and will be deducted in whole or in part from the next available paycheck(s) until the overpaid amount has been fully repaid unless otherwise prohibited by law. The employee who received the overpayment will be expected to sign a wage deduction authorization agreement authorizing such a deduction.

If you have questions concerning why deductions were made from your paycheck or how they were calculated, please contact Human Resources. We ask that employees realize that pay errors are not intentional and that employees be understanding if such an event occurs.

Family And MedicalLeave Act (FMLA)The Family and Medical Leave Act (FMLA) provides eligible employees with up to 12 work weeks of unpaid leave for certain family and medical reasons during a 12 month period. During this leave, an eligible employee is entitled to continued group health plan coverage as if the employee had continued to work. At the conclusion of the leave, subject to some exceptions, an employee generally has a right to return to the same or equivalent position.

EMPLOYEE ELIGIBILITY CRITERIATo be eligible for FMLA leave, an employee must have been employed by Pinnacle Promotions:

• for at least 12 months (which need not be consecutive);

• for at least 1,250 hours during the 12 month period immediately preceding the commencement of the leave; and

EVENTS WHICH MAY ENTITLEAN EMPLOYEE TO FMLA LEAVE1. Birth/Placement (Bonding) -- Leave for the birth and/or care of your newborn child, or for the placement of a child with you for adoption or foster care, and/or to care for the child following birth or placement for adoption or foster care. This leave applies equally to men and women. Eligibility for this leave expires 12 months after the child’s birth or placement.

2. Family Medical – Leave to care for a qualifying spouse, child, or parent with a serious health condition. “To care for” a family member includes (1) physical and/or psychological care, and (2) instances when the employee is needed to fill in for others providing care for a spouse, child, or parent with a serious health condition, or to arrange for third-party care of a child, spouse, or parent who is currently receiving in-patient or home care for a serious health condition.

Eligible family members are defined as follows:

• “Spouse” is defined in accordance with the state law of the employee’s state of residence and includes common law marriages where recognized by the state of residency. The Company also recognizes same sex domestic partners as “qualifying” under this definition.

• “Child” is defined as any biological, adopted, or foster children, as well as stepchild, legal ward or a child of a person acting in the capacity of a parent. The child must be under the age of 18 or can be over the age of 18 if “incapable of self-care” because of a physical or mental disability.

• “Parent” is defined as biological parents, as well as persons acting in the capacity of a parent towards the employee. This definition does not include, however, parents-in-law.

3. Employee Medical – Leave for your own qualifying serious health condition that makes you unable to perform your job. This means you: (1) are unable to work at all, or (2) are unable to perform any of the essential functions of your position at the time notice is given or leave commenced.

4. Qualifying Exigency -- Leave for any qualifying exigency arising out of the active duty or call to active duty of your spouse, child, or parent serving as a member or reservist of the U.S. Armed Forces or as a member or reservist in the National Guard in support of a contingency operation.

5. Injured Service member (Military Caregiver) – Leave to care for a service member with a serious illness or injury who is a current member of the Armed Forces and who is your parent, child, spouse or next of kin.

Your Pay Leaves of Absence

Regular full-time employees may be eligible for certain leaves of absence. Complete policy information and forms to request a leave of absence are available from Human Resources.

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AMOUNT OF LEAVEIf you are eligible, you may take unpaid Family and Medical Leave of up to 12 weeks in a rolling 12-month period (or such additional leave as may be provided by applicable state law) for any of the reasons defined above.

If you are eligible, you may take unpaid Family and Medical Leave of up to 26 weeks in a rolling 12-month period to care for a spouse, child, parent or next of kin who is a covered service member. A covered service member is a current member of the Armed Forces, including a member of the National Guard or Reserves, who is undergoing medical treatment, recuperation, or therapy, is otherwise in outpatient status, or is otherwise on the temporary disability retired list, for a serious injury or illness (incurred or aggravated in the line of active duty in the Armed Forces). If you qualify for leave under this provision and leave for any other FMLA-covered reason, you are only entitled to a combined total of 26 weeks during any 12-month period.

To determine the amount of leave you are eligible to take, the 12-month period is measured backwards from the date you request your present Family and Medical Leave to begin. In other words, the amount of leave will be determined by calculating the FMLA leave the employee has already used in the prior 12 months, and counting backwards from the newleave-request date.

If you and your spouse both work for Pinnacle, you are limited to a combined total of 12 weeks of family leave to cover the time you need (1) after the birth or placement of a child; (2) to care for a seriously ill parent; or (3) when taking leave due to your child’s call to active duty. If you and your spouse both work for the Company, you are limited to a combined total

of 26 weeks of family leave to cover the time off you need to care for a wounded child, who is a member of the uniformed services. However, both you and your spouse are eligible to take any unused portion of the 12 weeks for your own serious health condition, the care of a seriously ill child, or the care of the other spouse with a serious health condition.

Family medical leave can be taken in a numberof ways:

• Leave can be taken as a block of consecutive days.

• In most cases, leave can be taken on an intermittent basis and can be taken in increments as small as 15-minutes. This is permissible when the time is taken due to a serious health condition, or for medical treatment of a serious health condition, or for recovery from such treatment.

• Leave can also be taken on a reduced, part-time leave schedule basis. For example, your scheduled hours may be temporarily reduced to meet the needs arising from a serious health condition.

LEAVE RULES:Leave for Birth/Placement must be completed within the 12-month period beginning on the date of the birth or placement.

If you and your spouse both work for the Company, you are limited to a combined total of 12 weeks of family leave to cover the time you need (1) after the birth or placement of a child; (2) to care for a seriously ill parent; or (3) when taking leave due to your child’s call to active duty. If you and your spouse both work for the Company, you are limited to a combined total of 26 weeks of family leave to cover the time off you need to care for a wounded child, who is a member of the uniformed services. However, both you and your spouse are eligible to take any unused portion of the 12 weeks for your own serious health condition, the care of a seriously ill child, or the care of the other spouse with a serious health condition.

Employees will not be granted FMLA leave to gain employment or work elsewhere. This includesself-employment.

Employees who misrepresent facts in order to be granted FMLA lease will be subject to corrective action, up to and including suspension and/or termination of employment.

Pinnacle Promotions prohibits any employee from maintaining secondary employment while on FMLA leave, which is inconsistent with the need for a leave of absence. Violations will result in disciplinary action up to and including termination of employment. An employee who intends to continue to work a second job that he/she already had before the leave commenced, must have the written permission of his/her manager.

MILITARY CAREGIVER LEAVEIf you are eligible, you may take an unpaid Family and Medical Leave of up to 26 weeks in a rolling 12-month period (or such additional leave as may be provided by applicable state law) to care for a covered service member, which is defined as a current member of the Armed Forces who is undergoing medical treatment, recuperation or therapy, is otherwise in an outpatient status, or is otherwise on the temporary disability retired list, for a serious injury or illness incurred in the line of duty while on active duty.

A covered service member can be a child, parent, spouse, or next of kin. Unlike the definition above, “child” for military caregiver leave purposes includes children over the age of 18. “Next of kin” is defined as the nearest blood relative other than the covered service member’s spouse, parent, or child in the following order of priority:

• Blood relatives who have been granted legal custody of the service member by court decree or statute;

• Brothers, sister and grandparents;

• Aunts and uncles; and

• First cousins.

Covered service members may specifically designate in writing another blood relative as his/her “next of kin” for FMLA purposes. The Company reserves the right to require confirmation of the family relationship to the service member.

Leaves of Absence Leaves of Absence

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SERIOUS HEALTH CONDITIONA serious health condition is an illness, injury, impairment, or physical or mental condition that involves one or more of the following:

• Inpatient care in a hospital, hospice, residential medical care facility, or mental health/chemical dependency facility;

• Continuing treatment by a health care provider. To qualify, a condition must involve a period of incapacity of more than three consecutive calendar days and the continuing treatment must include treatment by a health care provider on at least one occasion within the first seven (7) days of the start of the incapacity and must have either: (1) a second visit within 30 days of the start of incapacity, or (2) a regimen of continuing treatment. A regimen of continuing treatment includes a course of prescription medication or therapy requiring special equipment to resolve or alleviate the health condition;

• Any period of incapacity due to pregnancy, or prenatal care;

• A chronic health condition which requires treatment by a health care provider two or more times per year;

• Any period of incapacity due to an ongoing chronic condition such as asthma, diabetes, or a mental disorder;

• Any period of incapacity that is permanent or long- term due to a condition for which treatment may not be effective, e.g., Alzheimer’s, a severe stroke, terminal stages of a disease; or

• Any period of absence to receive multiple treatments by a health care provider which, if not received, would result in an absence of three or more days, such as restorative surgery after an accident or medical intervention or multiple treatments such as chemotherapy or dialysis.

• “Incapacity” means inability to work, attend school, or perform other regular daily activities due to the serious health condition, or due to the treatment of, recovery from, or subsequent treatment of the serious health condition.

Unless hospitalization occurs, complications arise, or the criteria above are satisfied, the common cold, the flu, ear aches, upset stomach, minor ulcers, cosmetic treatments, and routine dental or orthodontic problems are generally not considered serious health conditions.

INTERMITTENT LEAVEThis type of leave can be used when it is medically necessary for: (1) the treatment of a serious health condition by and under the supervision of a health care provider; (2) for the recovery from the treatment of a serious health condition; (3) for the employee’s own serious health condition; or (4) to provide care for a qualifying family member with a serious health condition. Intermittent leave is generally not available for the birth or placement of a child. Intermittent leave for this purpose is subject to the manager’s discretion and approval, and the Company reserves the right to deny such requests.

Calculation of the amount of intermittent leave available to an employee is measured by the employee’s actual workweek. For example, if an employee is a regular, full-time employee with a 40-hour workweek, the employee is entitled to 480 hours of intermittent leave (12 weeks x 40 hours = 480 hours). If an employee’s workweek is a 30-hour workweek, the employee is entitled to 360 hours of intermittent leave (12 weeks x 30 hours = 360 hours).

If you have some control over the timing of your leave, you are expected to consult with your supervisor to try to arrange a mutually acceptable time. You must make all reasonable efforts possible to schedule appointments and treatments outside your work hours and in a way that will not unduly interfere with the Company’s operations.

If your need for intermittent FMLA leave only requires you to miss part of the work day, you are expected to work the remainder of the work day, whether before or after your required period of leave.

The Company prohibits any employee from maintaining secondary employment while on FMLA leave, which is inconsistent with the need for a leave of absence. Violations will result in disciplinary action up to and including termination of employment. An employee who intends to continue to work a second job that he/she already had before the leave commenced, must have the written permission ofhis/her manager.

During intermittent FMLA leave, the Company reserves the right to temporarily transfer you to an alternative position, provided the position has equivalent pay and benefits and accommodates the required leave.

If you have exhausted all of your accrued paid leave or choose not to use accrued leave concurrently with intermittent unpaid FMLA leave, you will receive reduced compensation consistent with the hours you actually work.

REQUESTS FOR FMLA LEAVEAn employee should request FMLA leave by completing the Request for Family Medical Leave form and submitting it to Human Resources.

When leave is foreseeable for childbirth, placement of a child or planned medical treatment for the employee’s or family member’s serious health condition, the employee must provide Pinnacle Promotions with at least 30 days advance notice, or such shorter notice as is practicable (i.e., within 1 or 2 business days of learning of the need for the leave). When the timing of the leave is not foreseeable, the employee must provide Pinnacle Promotions with notice of the need for leave as soon as practicable (i.e., within 1 or 2 business days of learning of the need for the leave).

Employees requesting FMLA leave are still required to follow proper call off procedures unless the serious health condition at issue prevents them from doing so. In that case, the employee must follow the proper call off procedures as soon as they are medically able.

The Company may, in its sole discretion, designate an employee’s absences as FMLA leave. If the Company is aware of the needed leave, but has been unable to confirm that the leave qualifies for FMLA, a preliminary designation will be made and the employee will be notified. If it is later learned that the leave does not qualify, the Company will withdraw the designation in a written notice to the employee.

Leaves of Absence Leaves of Absence

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REQUIRED DOCUMENTATIONWhen leave is taken to care for a family member, Pinnacle Promotions may require the employee to provide documentation or statement of family relationship (e.g., birth certificate or court document).

All medical/military information an employee submits to the supervisor must be sent to Human Resources and not retained in the employee’s branch, office, etc. or with the employee’s supervisor or manager. Leave for a “qualifying exigency” arising out of the fact that a spouse, son, daughter, or parent of the employee is on active duty, or has been notified of an impending call to active duty status, in support of a contingency operation must be supported by certification in such time and manner as approved by the Department of Labor.

Medical Certification / Second or Third Opinions for Employee Medical Leave

If you are requesting leave for your own medical condition, you must provide a medical certification from a health care provider. You may obtain forms from Human Resources. You must provide medical certification before the leave commences if the need for leave is known in advance. Where the need for leave is not known in advance, the medical certification must be provided within 15 days after the certification is requested by the Company. If you fail to provide timely medical certification, your leave may be denied or delayed.

If you are requesting leave for your own medical condition, you must provide a medical certification from a health care provider. You may obtain forms from Human Resources. You must provide medical certification before the leave commences if the need for leave is known in advance. Where the need for leave is not known in advance, the medical certification must be provided within 15 days after the certification is requested by the Company. If you fail to provide timely medical certification, your leave may be denied or delayed.

The Company, in its sole discretion, may require a second and third medical opinion. The Company may require periodic recertification during a leave. The Company may also request authentication and/or clarification of any medical certification submitted. All forms must be complete and legible.

If you are on intermittent leave for an on-going medical condition, the Company will request recertification every 6 months, at the beginning of each new 12-month FMLA period, when there is suspected abuse of the leave, and/or when circumstances described in the previous certification have changed or need to be clarified.

Independent Medical Evaluation

As allowed by law, the Company may require that a second opinion from an independent medical provider be obtained at the Company’s expense. If there is a conflict in the two opinions, the Company may pay for a third health care provider (agreed upon by both the Company and the employee) to render a third and final, binding opinion.

The Company reserves the right to use a human resources professional, a health care provider, a leave administrator, or a management official to contact an employee’s health care provider to verify or authenticate a medical certification. If the Company deems a medical certification is incomplete or insufficient, the Company will notify the employee in writing and the employee will be given seven (7) days to cure the deficiency.

USE OF PAID AND UNPAID LEAVEGenerally, FMLA leave is unpaid. If your leave also qualifies as maternity leave, workers compensation, short-term disability or long-term disability, your FMLA leave will run concurrently with leave taken under such program or plan. Similarly, if you are using accrued Paid Time Off (“PTO”) (e.g. use of PTO during the short-term disability waiting period), your FMLA leave will run concurrently with the PTO.

If an employee has accrued PTO, the employee has the option to use PTO leave first. Your FMLA leave will run concurrently with this use of PTO. The remainder of the 12 workweeks of leave, if any, will be unpaid FMLA leave. Any paid leave used for an FMLA qualifying reason will be charged against an employee’s entitlement to FMLA leave. This includes leave for disability or workers’ compensation injury/illness, provided that the leave meets FMLA requirements. The substitution of paid leave for unpaid leave does not extend the 12 workweek leave period.

MAINTENANCE OF HEALTH BENEFITSDuring FMLA leave an employee is entitled to continued group health plan coverage under the same conditions as if the employee had continued to work.

To the extent that an employee’s FMLA leave is paid, the employee’s portion of health insurance premiums will be deducted from the employee’s salary. For the portion of FMLA leave that is unpaid, the employee’s portion of health insurance premiums may be paid in accordance with the employer’s rules for leave without pay.

If the employee’s payment of health insurance premiums is more than 30 days late, Pinnacle Promotions may discontinue health insurance coverage upon notice to the employee. Health insurance coverage will also be discontinued 15 days after the employee receives notice from Pinnacle Promotions.

EMPLOYEE RESPONSIBILITIESWHILE ON LEAVE You will be required to periodically advise the Company of your status and intent to return to

work at the conclusion of FMLA leave. You must also provide notice to the Company at least two (2) business days prior to your return to work.

RETURN FROM LEAVEBefore the employee returns to work from FMLA leave for the employee’s own serious health condition, the employee may be required to submit a fitness for duty certification from the employee’s health care provider, with respect to the condition for which the leave was taken, stating that the employee is able to resume work. FMLA leave or return to work may be delayed or denied if the appropriate documentation is not provided in a timely manner. Also, a failure to provide requested documentation of the reason for an absence from work may lead to termination of employment.

If you qualify for FMLA leave and protections, the Company will hold your job, or an equivalent job, for the required time period. After that time period, the Company is not required to protect your job. Generally, upon return from FMLA, you will be reinstated to the same position or to an equivalent position with equivalent pay, benefits, and other employment terms, to the extent required by law. If you take leave because of your own serious health condition, you will be required to present a fitness-for-duty certification upon return to work. If you fail to provide a release to return to work which allows you to perform the essential functions of your job, with or without reasonable accommodations, when required to do so, you will not be permitted to resume work until it is provided. If after the 12-week period, you must remain on a leave, and only if business circumstances permit, as determined solely in the Company’s discretion, you may extend your leave with the understanding that at the end of the leave, you will have a maximum of 30 days to find a suitable job for which you are reasonably trained and qualified. During this 30-day period, you will be on a personal unpaid leave. If a suitable position cannot be found, your employment will terminate at the end of the 30-day period unless otherwise provided for by state or federal law or as part of a reasonable accommodation.

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RETURN FROM LEAVE (CONTINUED)During an employment reduction or reorganization, managers will review employees who are on leaves of absence using the same processes as if those employees had remained at work. If business circumstances require, such as in a workforce reduction, and your job or the equivalent job may be eliminated and thus, may not be available when you are ready to return to work at the end of your FMLA leave. In addition, when a business reorganization occurs during an employee’s leave, when the employee returns to work, the employee may be subject to changes in his/her former position including reassignment or severance of employment. If an employee is subject to a reduction in force while on leave, then when the employee is ready to return to work he/she will have up to 30 days to find a suitable job for which he/she is reasonably trained and qualified. During this 30-day period, the employee will be on a personal unpaid leave. If a suitable position cannot be found, his/her employment will terminate at the end of the 30-day period unless otherwise provided for by state or federal law or as part of a reasonable accommodation.

Key employees, who are notified of their status when they first request FMLA leave, are reinstated to their former or equivalent positions at the end of FMLA leave only if their reinstatement does not cause the Company substantial and grievous economic injury.

FAILURE TO RETURN TO WORK FOLLOWING FMLA LEAVEIf the employee does not return to work following the conclusion of FMLA leave, the employee will be considered to have voluntarily resigned. Pinnacle Promotions may recover health insurance premiums that Pinnacle Promotions paid on behalf of the employee during any unpaid FMLA leave except that Pinnacle Promotions share of such premiums may not be recovered if the employee fails to return to work because of the employee’s or a family member’s serious health condition or because of other circumstances beyond the employee’s control. In such cases, Pinnacle Promotions may require the employee to provide medical certification of the employee’s or the family member’s serious health condition.

ADDITIONAL INFORMATIONFor further information or clarification about FMLA leave, please contact Human Resources.

This policy does not constitute a contract or any contractual obligation and does not alter the at-will nature of employment at the Company. Each request for leave will be reviewed and governed on a case-by-case basis. The Company reserves the right in its sole discretion to amend, modify, discontinue, or interpret the policy without prior notice, notwithstanding any person’s acts, omissions, or statements to the contrary.

Maternity BenefitsWe believe that individuals can enjoy their fullest potential when work and family are integrated and balanced. Our maternity policy is a generous benefit that matches or exceeds that of companies much larger than ours, and is provided to our employees to reinforce the family-based culture we have here.

Regular full-time employees who have completed one year of employment prior to the birth of a child are eligible for maternity benefits.

• Employee will receive six (6) weeks of paid maternity leave following the birth of her child paid retroactively when the employee return to work. If eligible for FMLA the employee may take an additional six (6) weeks of unpaid leave. Please refer to the FMLA policy for more information. The employee will continue to accrue PTO during this time.

• Complete eligibility and requirements should be discussed with Human Resources, prior to taking your leave.

Military LeaveAn employee who is a member of the United States Army, Navy, Air Force, Marines, Coast Guard, National Guard, Reserves or Public Health Service who is required to be deployed or to attend military training under appropriate official military orders will be granted an unpaid leave of absence for military service, training or related obligations in accordance with applicable law. Employees on military leave may substitute their accrued paid leave time for unpaid leave, but they are not required to do so. Employees are not eligible for paid holidays occurring while on military leave. Employees granted military leaves of absence are re-employed and paid in accordance with the laws governing veteran’s re-employment rights. Employees on military leave may use paid vacation time, but they are not required to do so.

CONTINUATION OF BENEFITSDuring a military leave of less than 31 days, an employee is entitled to continued group health plan coverage under the same conditions as if the employee had continued to work. For military leaves of more than 30 days, an employee may elect to continue his/her health coverage for up to 24 months of uniformed service, but may be required to pay all or part of the premium for the continuation coverage, calculated in the same manner as that required by COBRA.

Additionally, bereavement leave, jury duty pay, and holiday pay are not granted while on a leave of absence.

Requests for Leave

LEAVE FOR ACTIVE OR RESERVE DUTYUpon receipt of orders for active or reserve duty, an employee should notify his/her supervisor, as well as Human Resources, as soon as possible, and submit a copy of the military orders to his/her supervisor and Human Resources, unless he/she is unable to do so because of military necessity or it is otherwise impossible or unreasonable.

LEAVE FOR TRAINING AND OTHER RELATED OBLIGATIONS (E.G. FITNESS FOR SERVICE EXAMINATIONS)Employees will also be granted time off for military training (normally 14 days plus travel time) and other related obligations, such as for an examination to determine fitness to perform service. Employees should advise their supervisor and/or department head of their training schedule and/or other related obligations as far in advance as possible. Employees should retain their military pay vouchers. Upon return from training, the employee should submit his/her military pay voucher to the Human Resources Department; the Company will pay an employee’s full salary, less base military pay, for the training period.

RETURN FROM MILITARY LEAVEAt the conclusion of the leave, upon the receipt of required notification and satisfaction of certain conditions, an employee generally has a right to return to the same position he or she held prior to the leave or to a position with like seniority, status and pay that the employee is qualified to perform.

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Personal LeaveA personal leave of absence may be granted at the company’s discretion to regular full-time employees on a case-by-case basis. Requests for personal leave will be evaluated based on a number of factors, including anticipated workload requirements and staffing considerations during the proposed period of absence. Eligible employees may request personal leave after having completed 90 calendar days of service. As soon as eligible employees become aware of the need for a personal leave of absence, they should complete the Request for Non-FMLA Leave form to their Manager for approval. All Personal Non-FMLA Leave requests also require the approval of the CEO.

A personal leave may be granted for a period of up to seven (7) calendar days for every one calendar year. If this initial period of absence proves insufficient, consideration will be given to a written request for a single extension of no more than seven (7) calendar days. With management and Human Resources approval, an employee may take any accrued PTOas part of the approved period of leave.

• Subject to the terms, conditions, and limitations of the applicable plans, health insurance benefits will be provided by the company if the employee already participates in our plans, until the end of the month in which the approved personal leave begins. At that time, employees will become responsible for the full costs of these benefits if they wish coverage to continue. When the employee returns from personal leave, benefits will once again be provided/ available by the company according to the applicable plans.

• When a personal leave ends, every reasonable effort will be made to return the employee to the same position, if it is available, or to a similar available position for which the employee is qualified. However, the company cannot guarantee reinstatement in all cases. 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.

Introductory PeriodAll new and rehired employees work on an introductory basis for the first 90 calendar days after their date of hire. The introductory period is intended to give new employees the opportunity to demonstrate their ability to achieve a satisfactory level of performance and to determine whether the new position meets their expectations. Pinnacle Promotions uses this period to evaluate employee capabilities, work habits, and overall performance. Either the employee or Pinnacle Promotions may end the employment relationship at will at any time during or after the introductory period, with or without cause or advance notice.

Any significant absence will automatically extend an introductory period by the length of the absence. If the company determines that the designated introductory period does not allow sufficient time to thoroughly evaluate the employee’s performance, the introductory period may be extended for a specified period.

During the introductory period, new employees are eligible for those benefits that are required by law, such as workers’ compensation insurance and Social Security. They may also be eligible for other Pinnacle Promotions-provided benefits, subject to the terms and conditions of each benefits program. Employees should review eligibility with Human Resources.

Work SchedulesThe normal work schedule for all full-time employees is eight hours a day, five days a week. Managers will advise employees of the times their schedules will normally begin and end. Our office will be open from 8 am – 6 pm ET. Staffing needs and operational demands may necessitate variations in start and end times, as well as variations in the total hours that may be worked each day and week. Your manager will schedule your one-hour lunch break based on the needs of the business. Employees should speak with their manager if they need a specific time for their lunch break.

Being on time for work is essential and expected. Absenteeism and tardiness place a burden on other employees and on the company and are disruptive. In the rare instances when employees cannot avoid being late to work or are unable to work as scheduled, they should notify their manager as soon as possible

in advance of the anticipated tardiness or absence. Failure to maintain the expected working schedule, may lead to disciplinary action, up to and including termination of employment.(Refer to the Attendance and Tardy Policy)

FLEXIBLE WORK SCHEDULEPinnacle Promotions supports a work/life balance for their employees. This policy is intended to offer employee’s optional work schedules that may be better suited for their personal work/life balance needs.

Flexible schedule options are subject to the business needs of the department and role. Not every position may be eligible for a flexible work schedule option.

The following are the minimum eligibility requirements for requesting a flexible work schedule:

• Exempt level role

• Minimum 1 year of service

• Performance level of ‘Achieve Expectations’ or above

Pinnacle Promotions’ regular office hours and work schedule is 9:00 AM to 6:00 PM Eastern Time. Flexible schedule options are: (All times is Eastern Time)

• 8:00 AM to 5:00 PM

• 8:30 AM to 5:30 PM

• 9:30 AM to 6:30 PM

Employees who wish to change their work schedule should contact their manager to determine if the schedule option they prefer will meet the business needs of their role and department. Each request will be handled on an individual basis.

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Flexible Work Schedule (CONTINUED)Flexible work schedules operate just like the core office work schedule. Employee’s who are on a flexible schedule must report to work at the defined time and not leave before the defined time.

Example: Employee has been approved to work the 8:00 AM to 5:00 PM work schedule. They are expected to be at their desk ready to work at 8:00 AM every day. They do not have the flexibility to come in at 8:00 AM one day and 9:00 AM the next day. If they report to work after 8:00 AM they will be considered late and subject to the tardy policy.

Employees who have been approved for a flexible work schedule, are expected to occasionally alter that schedule to meet the needs of the business.

Example: Employee has been approved to work the 9:30 AM to 6:30 PM work schedule. The department has a meeting that begins at 9:00 AM. The employee is expected to attend the meeting at 9:00 AM. If the employee is in an exempt level position, they should still work their full work day and leave at the regular time at 6:30 PM.

Flexible work schedules must be in place for a minimum of 6 months before the employee can request a change. This is to ensure consistency of operations and minimal disruption to the work flow and interaction with other employees or clients. In some cases, employees may request a shorter trial period. This is subject to the approval of the department manager.

Employee may be required to return to the core work schedule if business needs require. Manager will make every effort to provide as much advance notice as possible.

Severe WeatherIn the event of inclement weather or other emergencies such as fires, power failures, or earthquake, your safety is our utmost concern. In extreme cases, these circumstances may require the closing of the office. When operations are officially closed for a full day due to emergency conditions, employees will be required to use a PTO day. If the operations are officially closed for a partial day, such as a late opening, non-exempt employees will be paid for only the hours worked that day. Employees in essential operations may be asked to work on a day when operations are officially closed. In these circumstances, employees who work will receive regular pay.

Personal AppearanceDress, grooming, and personal cleanliness standards contribute to the morale of all employees and affect the business image Pinnacle Promotions presents to customers and visitors. During business hours or when representing Pinnacle Promotions, you are expected to present a clean, neat and tasteful appearance. You should dress and groom yourself according to the requirements of your position and accepted social standards. This is particularly true if your job involves dealing with customers or visitors in person.

Your manager is responsible for establishing a reasonable dress code appropriate to the job you perform. Consult your manager if you have questions as to what constitutes appropriate appearance. Where necessary, a reasonable accommodation may be made to a person with a disability.

The dress code at the company is casual. There are a few items we ask that you not wear at any time – these are simply too casual for our business setting – short shorts, halter tops, camisole tank tops, or clothing with excessive rips or tears. Jeans are allowed.

For Women: Tank tops with two-inch straps may be worn. Skirts are to be knee length or longer. Sandals are allowed. On Fridays you may wear long shorts and flip-flops.

For Men: Collared shirts should be worn during the week including button-downs or polo shirts. Nice tee shirts may be worn on Fridays.

Please wear clothing that conceals all under clothes and does not allow for the stomach or other inappropriate bodily areas or undergarments to be seen. Although the dress is casual, employees are expected to use good judgment in wearing attire appropriate for the workplace as clients do occasionally visit the office.

If you are in violation you will be asked to leave the office and change immediately. That will be your lunch hour for that day.

Good hygiene is essential to an individual’s personal appearance; however, perfume and scented body products should not be worn during office hours.

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Workplace Violence PreventionWe are committed to preventing workplace violence and to maintaining a safe work environment. We have adopted the following guidelines to deal with intimidation, harassment, or other threats of (or actual) violence that may occur during business hours or on our premises.

All employees, including supervisors and temporary employees, should be treated with courtesy and respect at all times. Employees are expected to refrain from fighting, “horseplay,” or other conduct that may be dangerous to others. Firearms, weapons, and other dangerous or hazardous devices or substances are prohibited from the premises of Pinnacle Promotions without proper authorization from management.

Conduct that threatens, intimidates, or coerces another employee, a customer, or a member of the public at any time, including off-duty periods, will not be tolerated. This prohibition includes all acts of harassment, including harassment that is based on an individual’s sex, race, age, or any characteristic protected by federal, state, or local law.

All threats of (or actual) violence, both direct and indirect, should be reported as soon as possible to your immediate supervisor or Human Resources. This includes threats by employees, as well as threats by customers, vendors, solicitors, or other members of the public. When reporting a threat of violence, you should be as specific and detailed as possible. All suspicious individuals or activities should also be reported as soon as possible to a supervisor. Do not place yourself in peril. If you see or hear a commotion or disturbance near your workstation, do not try to intercede or see what is happening.

We will promptly and thoroughly investigate all reports of threats of (or actual) violence and of suspicious individuals or activities. The identity of the individual making a report will be protected as much as is practical. In order to maintain workplace safety and the integrity of its investigation, we 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 of employment.

We encourage employees to bring their disputes or differences with other employees to the attention of their supervisors or Human Resources before the situation escalates into potential violence. We are eager to assist in the resolution of employee disputes, and will not discipline employees for raising such concerns.

Electronic WorkplaceThroughout the company we use email, voicemail, chat, and the internet to facilitate the efficient and rapid flow of information. All of these communication tools should only be used for professional and business reasons during work time. Use of the communication and computer systems to solicit any business, commercial, organizational, or personal purpose is prohibited. Employees’ who participate in the unacceptable use of electronic communication will be subject to disciplinary action, up to and including termination.

Tobacco-Free WorkplaceIn keeping with the company’s intent to provide a safe and healthy work environment, smoking is prohibited throughout the workplace. We ask that employees refrain from using all tobacco products, including smokeless tobacco, during office hours and on our premises. This policy applies equally to all employees, customers and visitors.

Any violation of or disputes arising under this policy should be reported immediately to your manager or Human Resources. Violation of this policy may result in appropriate corrective action, up to and including discharge. The Company will promptly investigate any disputes arising under this policy and in resolving disputes, shall give priority to the health concerns of the employee desiring a smoke-free area.

Each employee is protected from retaliatory action or from being subjected to any adverse personnel action for exercising or attempting to exercise his/her rights under the smoking policy. Any employee who feels that he/she has been subject to a retaliatory adverse personnel action for exercising or attempting to exercise any rights under this policy or under any applicable law or regulation concerning the subject matter of this policy shall inform Human Resources which will promptly investigate the complaint and provide for adequate redress where necessary.

Drug- And Alcohol-Free WorkplaceWe are proud to provide a drug- and alcohol-free, healthy and safe workplace. The manufacture, distribution, dispensation, possession, or use of any illegal drug, alcohol, or controlled substance while on Company premises is strictly prohibited. For the safety of all of our employees, employees are required to report to work in appropriate mental and physical condition to perform their jobs in a safe and satisfactory manner. Job applicants and employees may be asked to provide body substance samples, such as urine and/or blood, to determine the illicit or illegal use of drugs.

While on Pinnacle Promotions’ premises and while conducting business-related activities off Pinnacle Promotions’ premises, no employee may use, possess, distribute, sell, or be under the influence of alcohol or illegal drugs. The legal use of prescribed drugs is permitted on the job only if it does not impair an employee’s ability to perform the essential functions of the job effectively and in a safe manner that does not endanger other individuals in the workplace.

There may be limited exceptions to this policy regarding alcohol, only at specific Pinnacle-sponsored events.

Violations of this policy may lead to disciplinary action, up to and including immediate terminationof employment. Such violations could also have legal consequences.

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Workers’ CompensationMaintaining a safe work environment requires the continuous cooperation of all employees. Pinnacle Promotions strongly encourages employees to communicate with fellow employees and their supervisor regarding safety issues. All employees will be provided care, first-aid and emergency service, as required, for injuries or illnesses while on Pinnacle Promotions premises. Employees should contact their supervisor, the nearest supervisor, and/or 911 in the event of an accident or emergency.

Pinnacle Promotions 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 the applicable legal requirements, workers compensation insurance provides benefits after a short waiting period or, if the employee is hospitalized, immediately. Employees who sustain work-related injuries or illnesses should inform their supervisor immediately. No matter how minor an on-the-job injury may appear, it is important that it be reported immediately. This will enable an eligible employee to qualify for coverage as quickly as possible. Failure to report accidents is a serious matter as it may preclude an employee’s coverage under Worker’s Compensation Insurance.

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

Visitors In The WorkplaceTo 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 maintain safety standards, protects against theft, ensures security of equipment, protects confidential information, safeguards employee welfare, and avoids potential distractions and disturbances.

All visitors should enter Pinnacle Promotions at the main entrance. Authorized visitors will need to sign-in at the front desk and receive a visitor badge, and be escorted to their destination. Visitors must wear the visitor badge in a visible area while on the premises. Employees are responsible for the conduct and safety of their visitors. If an unauthorized individual is observed on our company’s premises, employees should immediately notify their manager or, if necessary, direct the individual to the main entrance.

Safe Work EnvironmentTo ensure our work environment is safe for all of us, we prohibit employees from carrying any type of weapon, including firearms and knives, on company premises. Even if you are legally licensed to carry a firearm, you may not do so on company premises. Since the parking lot is also considered company property, this policy includes keeping any of these items in your car while parked in any company parking lot.

While on the company’s premises, employees have no expectation of privacy in their belongings or in workplace areas which include, but are not limited to, offices, cubicles, work locations, company provided parking areas, desks, computers, rest or eating areas, and any personal belongings on or in any of the above. Storage devices including desks, drawers, computers, jump drives, packages, and more, may be provided for the convenience of employees but remains the sole property of the company. Accordingly, they, as well as articles found within them, may be inspected by a manager of the company at any time, without prior notice.

From time to time, Pinnacle Promotions may conduct internal investigations pertaining to security, auditing or work-related matters. Employees are required to cooperate fully with and assist in these investigations if requested to do so. Whenever necessary, at the Company’s discretion, work areas (i.e., desks, file cabinets, etc.) and personal belongings (i.e., brief cases, handbags, etc.) may be subject to a search without notice. Employees are required to cooperate. Pinnacle Promotions will generally try to obtain an employee’s consent before conducting a search of work areas or personal belongings, but may not always be able to do so.

We have on-site security cameras to monitor our premises and ensure safety within the building. This footage is recorded and may be monitored. In addition to our cameras, our main entrance is equipped with an auto-lock device that requires a key-fob for entrance.

When you enter or exit through the front door, please be sure to manually close the door behind you and make sure the lock latches properly (you should hear a clicking noise). It is important to everyone’s safety throughout the day, that the front door is locked properly at all times.

Some of the best safety improvement ideas come from employees. Those with ideas, concerns, or suggestions for improved safety in the workplace are encouraged to raise them with their manager, or with another supervisor or manager. Reports and concerns about workplace safety issues may be made anonymously if the employee wishes. All reports can be made without fear of reprisal.

Each employee is expected to obey safety rules and to exercise caution in all work activities. Employees must comply with all occupational safety and health standards and regulations established by the Occupational Safety and Health Act and state and local regulations. Employees must immediately report any unsafe condition to the appropriate supervisor. Employees who violate safety standards, who cause hazardous or dangerous situations; or who fail to report or, where appropriate, remedy such situations; may be subject to disciplinary action, up to and including suspension and/or termination of employment.

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.

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Voice Or VideoRecording PolicyEmployees are not permitted to record conversations or events with a voice or video recorder or other recording device unless prior approval is received from your supervisor or a member of upper-level management or all parties to the conversation give their consent.

The purpose of this policy is to eliminate a chilling effect on the expression of views that may exist when one person is concerned that his or her conversation or interactions with another is being secretly recorded. This concern can inhibit spontaneous and honest dialogue especially when sensitive or confidential matters are being discussed.

Violation of this policy will result in disciplinary action, up to and including immediate terminationof employment.

SolicitationIn the interest of maintaining a positive working environment, the Company limits employee solicitations and the distribution of literature to pre-approved activities, such as Company-sponsored and approved charitable campaigns, wellness campaigns and blood drives.

Solicitation and distribution of written, printed, or electronic literature or other materials of any kind by non-employees is prohibited at all times on Company property, including parking lots and break rooms, unless otherwise pre-approved by the President or Chief Executive Officer for a Company-sponsored activity or business partner.

No employee may solicit another employee for any purpose that is not pre-approved while either employee is at work. Solicitation by employees for commercial sale of items for the employee’s personal gain or profit is strictly prohibited. Solicitation to support and/or invitations pertaining to third-party groups or organizations is prohibited unless pre-approved by the President or Chief Executive Officer.

Invitations of a purely personal nature, such as invitations to parties, showers, etc., are not prohibited. However, these invitations must not be sent using

Company resources, such as email and computer, and must not occur during working time or in working areas.

Solicitations for charitable organizations are limited to those organizations that have been reviewed and approved by the appropriate management official and are Company-sponsored organizations or business partners. All charitable organizations must correspond with the Company philosophy and community service mission.

The use of Company resources, such as computer, email, and/or other electronic device, for solicitations that are not Company-sponsored or required is prohibited. Bulletin boards may not be used for solicitations of any sort that are not Company-sponsored or required.

Use of Equipmentand VehiclesEquipment and vehicles essential in accomplishing job duties are expensive and may be difficult to replace. When using property, employees are expected to exercise care, perform required maintenance, and follow all operating instructions, safety standards, and guidelines.

Please notify the supervisor if any equipment, machines, tools, or vehicles appear to be damaged, defective, or in need of repair. Prompt reporting of damages, defects, and the need for repairs could prevent deterioration of equipment and possible injury to employees or others. The supervisor can answer any questions about an employee’s responsibility for maintenance and care of equipment or vehicles used on the job.

The improper, careless, negligent, destructive, or unsafe use or operation of equipment or vehicles, as well as excessive or avoidable traffic and parking violations, can result in disciplinary action, up to and including termination of employment.

Business TravelPinnacle Promotions 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 Controller of Pinnacle Promotions.

Employees whose travel plans have been approved are responsible for making their own travel arrangements.

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

Expenses that generally will be reimbursed include the following:

• Airfare or train fare for travel in coach or economy class or the lowest available fare.

• Car rental fees, only for compact or mid-sized cars.

• Fares for shuttle or airport bus service, where available; costs of public transportation for other ground travel.

• Taxi fares, only when there is no less expensive alternative to take.

• Mileage costs for use of personal cars, only when less expensive transportation is not available.

• Cost of standard accommodations in low to mid- priced hotels, motels, or similar lodgings.

• Cost of meals, no more lavish than would be eaten at the employee’s own expense.

• Tips not exceeding 15% of the total cost of a meal 10% of a taxi fare.

• Charges for telephone calls, fax, and similar services required for business purposes.

Employees who are involved in an accident while traveling on business must promptly report the incident to their immediate manager. Vehicles owned, leased, or rented by Pinnacle Promotions may not be used for personal use without prior approval.

When travel is completed, employees should submit completed travel expense reports within 10 days. Reports should be accompanied by receipts for all individual expenses.

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EmploymentEmployment with Pinnacle Promotions is “at will” and is entered into voluntarily and both you and Pinnacle Promotions are free to end the employment relationship at any time, for any reason, with or without cause or advance notice so long as there is no violation of applicable federal or state law.

Policies set forth in this handbook are not intended to create a contract, nor are they to be construed to constitute contractual obligations of any kind or a contract of employment between Pinnacle Promotions and any of its employees. The provisions of the handbook have been developed at the discretion of management and, except for its policy of employment at will, may be amended or cancelled at any time, at Pinnacle Promotions’ sole discretion.

These provisions supersede all existing policies and practices and may not be amended or added to without the express written approval of the chief executive officer of Pinnacle Promotions.

Non-DisclosureAnd ConfidentialityThe protection of confidential business information and trade secrets is vital to the interests and the success of Pinnacle Promotions. Such confidential information includes, but is not limited to, the following examples:

• Computer Programs and Codes

• Customer Lists

• Customer Preferences

• Financial Information

• Marketing Strategies

•Pending Projects and Proposals

• Research and Development Strategies

Employees who improperly use or disclose trade secrets or confidential business information will be subject to disciplinary action, up to and including termination of employment, even if they do not actually benefit from the disclosed information. These issues are addressed more completely in a separate document.

Each employee or contractor who works for Pinnacle Promotions is required to sign a Non-Disclosure/Confidentiality/Non-Compete agreement prior to employment. This agreement is a material inducement to your employment (new or continued). Please consult with an attorney if you have questions or issues concerning this agreement.

ImmigrationLaw ComplianceWe are committed to employing only United States citizens and aliens who are authorized to work in theUnited States and do not unlawfully discriminate on the basis of citizenship or national origin.

In compliance with the Immigration Reform and Control Act of 1986, each new employee, as a condition of employment, must complete the Employment Eligibility Verification Form I-9 and present documentation establishing identity and employment eligibility. Former employees who are rehired must also complete the form.

Employees with questions or seeking more information on immigration law issues are encouraged to contact their immediate supervisor. Employees may raise questions or complaints about immigration law compliance without fear of reprisal.

Non-adherence to any of the following policies may result in disciplinary action, up to,and including termination of employment.

Conflicts Of InterestEmployees have an obligation to conduct business within guidelines that prohibit actual or potential conflicts of interest. This policy establishes only the framework within which Pinnacle Promotions 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 Owners of Pinnacle Promotions 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 Pinnacle Promotions. 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 either, 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 and/or acquaintance as a result of Pinnacle Promotions’ 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.

If employees have any influence on transactions involving purchases, contracts, or leases, it is imperative that they disclose to an officer of Pinnacle Promotions as soon as possible the existence of any actual or potential conflict of interest so that safeguards can be established to protect all parties. Personal gain may result not only in cases where an employee or relative has a significant ownership in a firm with which Pinnacle Promotions does business, but also when an employee or relative receives any kickback, bribe, substantial gift, or special consideration as a result of any transaction or business dealings involving Pinnacle Promotions.

ACCEPTANCE OF GIFTSNo employee may solicit or accept gifts of significant value (i.e., in excess of $50.00), lavish entertainment or other benefits from potential and actual customers, suppliers or competitors. Special care must be taken to avoid even the impression of a conflict of interest.

An employee may entertain potential or actual customers if such entertainment is consistent with accepted business practices, does not violate any law or generally accepted ethical standards and the public disclosure of facts will not embarrass the Company. Any questions regarding this policy should be addressed to the Human Resources Department.

WORK PRODUCT OWNERSHIPAll Pinnacle Promotions employees must be aware that Pinnacle Promotions retains legal ownership of the product of their Inventions which are conceived by employee solely or jointly with others and (i) relates to the actual or anticipated business, research or development of Company, (ii) results from any work performed by employee using any equipment, facilities, materials, Confidential Information or personnel of Company, or (iii) is suggested by or results from any task assigned or performed by Employee for or on behalf of Company. “Invention” means any idea, invention, discovery, improvement, innovation, design, process, method, formula, technique, machine, article of manufacture, composition of matter, algorithm or computer program, as well as improvements thereto.

Human Resources Policies Human Resources Policies

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WORK PRODUCT OWNERSHIP(CONTINUED)No work product created while employed by Pinnacle Promotions can be claimed, construed, or presented as property of the individual, even after employment by Pinnacle Promotions has been terminated or the relevant project completed. This includes written and electronic documents, audio and video recordings, system code, and also any concepts, ideas, or other intellectual property developed for Pinnacle Promotions, regardless of whether the intellectual property is actually used by Pinnacle Promotions. Although it is acceptable for an employee to display and/or discuss a portion or the whole of certain work product as an example in certain situations (e.g., on a resume, in a freelancer’s meeting with a prospective client), one must bear in mind that information classified as confidential must remain so even after the end of employment, and that supplying certain other entities with certain types of information may constitute a conflict of interest. In any event, it must always be made clear that work product is the sole and exclusive property of Pinnacle Promotions. Freelancers and temporary employees must be particularly careful in the course of any work they discuss doing, or actually do, for a competitor of Pinnacle Promotions.

REPORTING POTENTIAL CONFLICTSAn employee must promptly disclose actual or potential conflicts of interest, in writing, to his or her supervisor. Approval will not be given unless the relationship will not interfere with the employee’s duties or will not damage the Company’s relationship.

If an actual or potential conflict of interest occurs, Pinnacle Promotions will take prompt disciplinary action, up to and including, termination of employment.

Hiring Of RelativesThe employment of relatives in the same area of an organization may cause serious conflicts and problems with favoritism and employee morale. In addition to claims of partiality in treatment of work, personal conflicts from outside the work environment can be carried over into day-to-day working relationships.

For 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.

Members of an employee’s immediate family will be considered for employment on the basis of their qualifications. Immediate family may not be hired, however, if employment would:

(i) Create a supervisor/subordinate relationship with a family member;

(ii) Have the potential for creating an adverse impact on work performance; or

(iii) Create either an actual conflict of interest or the appearance of a conflict of interest.

Employees who become immediate family members or establish a romantic relationship may continue employment as long as it does not involve any of the above. If one of the conditions outlined should occur, attempts will be made to find a suitable position within Pinnacle Promotions to which one of the employees will transfer or if a transfer is not feasible, Pinnacle Promotions may terminate the employment of one or both of the individuals involved.

Romantic OrSexual RelationshipsConsenting “romantic” or sexual relationships between a supervisor/manager and an employee may at some point lead to unhappy complications and significant difficulties for all concerned - the employee, the supervisor/manager and Pinnacle Promotions. Any such relationship may, therefore, be contrary to the best interests of Pinnacle Promotions and is prohibited.

Accordingly, Pinnacle Promotions strongly prohibits such relationships and any conduct (such as dating between a supervisor/manager and an employee) that is designed or may reasonably be expected to lead to the formation of a “romantic” or sexual relationship.

By its prohibition of romantic and sexual relationships, Pinnacle Promotions does not intend to inhibit the social interaction (such as lunches or dinners or attendance at entertainment events) that are or should be an important part or extension of the working environment; and the policy articulated above is not to be relied upon as justification or excuse for a supervisor’s/manager’s refusal to engage in such social interaction with employees.

If a romantic or sexual relationship between a supervisor/manager and an employee should develop, it shall be the responsibility and mandatory obligation of the supervisor/manager promptly to disclose the existence of the relationship to President and CEO. The employee may make the disclosure as well, but the burden of doing so shall be upon the supervisor/manager.

The company recognizes the ambiguity of and the variety of meanings that can be given to the term “romantic”. It is assumed, or at least hoped, however, that either or both of the parties to such a relationship will appreciate the meaning of the term as it applies to either or both of them and will act in a manner consistent with this policy.

Upon being informed or learning of the existence of such a relationship, the Company will take all steps it deems appropriate. At a minimum, the employee and supervisor/manager will not thereafter be permitted to work together on the same matters (including matters pending at the time disclosure

of the relationship is made), and the supervisor/manager must withdraw from participation in activities or decisions (including, but not limited to, hiring, evaluations, promotions, compensation, work assignments and discipline) that may reward or disadvantage any employee with whom the supervisor/manager has or has had such a relationship.

In addition, and in order for the Company to deal effectively with any potentially adverse consequences such a relationship may have for the working environment, any person who believes that he or she has been adversely affected by such a relationship, notwithstanding its disclosure, is encouraged to make his or her views about the matter known to the CEO, President or Human Resources.

This policy shall apply without regard to gender and without regard to the sexual orientation of the participants in a relationship of the kind described.

Outside EmploymentEmployees may hold outside jobs as long as the outside employment does not create the appearance or reality of a conflict of interest to Pinnacle Promotions. Outside employment that constitutes a conflict of interest is prohibited. Employees may not receive any income or material gain from individuals outside Pinnacle Promotions for materials produced or services rendered while performing their jobs.

Further, the secondary employment may not interfere with the employee’s responsibilities to Pinnacle Promotions and will be subject to Pinnacle Promotions’ scheduling demands, regardless of any existing outside work requirements.

If we determine that an employee’s outside work interferes with performance or the ability to meet the requirements of Pinnacle Promotions as they are modified from time to time, the employee may be asked to terminate the outside employment if he or she wishes to remain with Pinnacle Promotions.

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Access To Personnel FileWe maintain a personnel file on each employee. The personnel file includes such information as the employee’s job application, resume, records of training, documentation of performance appraisals and salary increases, and other employment records.

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

With reasonable advance notice, employees may review their own personnel files in Pinnacle Promotions’ offices and in the presence of an individual appointed by Pinnacle Promotions to maintain the files.

Personnel Data ChangesIt is the responsibility of each employee to promptly notify Pinnacle Promotions of any changes in personnel data. Personal mailing addresses, telephone numbers, number and names of dependents, individuals to be contacted in the event of an emergency, educational accomplishment, and other such status reports should be accurate and current at all times. If any personnel data has changed, please complete the Personnel Data Change form and submit

it to Accounting/Payroll.

Leaving Pinnacle PromotionsResignation is a voluntary act initiated by the employee to terminate employment with Pinnacle Promotions. We request at least two weeks’ written resignation notice from all employees.

If an employee does not provide advance notice as requested, the employee will be considered ineligible for rehire.

Upon leaving the company, all employees are responsible for returning all Pinnacle Promotions property, materials, or written information that was issued to them or in their possession or control, on or before their last day of work. Where applicable by law, the company may withhold from the employee’s final paycheck, the cost of any items that are not returned when required.

Problem ResolutionWe are committed to all employees. Part of this commitment is encouraging an open and honest atmosphere in which any problem, complaint, suggestion, or question receives a timely response from the company’s management.

We strive to ensure fair treatment of all employees. Managers and employees are expected to treat each other with mutual respect. Employees are encouraged to offer positive and constructive criticism.

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

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

1. Employee presents the problem to their direct manager after the incident occurs. If their direct manager is unavailable or employee believes it would be inappropriate to contact that person, employee may present the problem to Human Resources. Their direct manager or HR will respond to the issue during discussion or after consulting with appropriate parties.

2. If the problem remains unresolved by their direct manager, employee should present the issue to Human Resources.

3. HR assists in putting the problem in writing and completes any necessary investigation. Results will be shared with employee.

4. If the problem still persists, the employee should review with the Owners. The owners will inform the employee of the decision and provide a written response for record. The Owners have full authority to make adjustments deemed appropriate to resolve the issue.

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

Attendance, Punctuality And DependabilityBecause Pinnacle Promotions depends heavily upon its employees, it is important that employees attend work as scheduled. Dependability, attendance, punctuality, and a commitment to do the job right are essential functions of the job at all times. As such, employees are expected at work on all scheduled work days and during all scheduled work hours and to report to work on time. Moreover, an employee must notify his/her supervisor or the Human Resources Department as far in advance as possible, but not later than one hour before his/her scheduled starting time if he/she expects to be late or absent. This policy applies for each day of his/her absence. An employee who fails to contact his/her immediate supervisor for more than three days may be considered as having voluntarily resigned. A careful record of absenteeism and lateness is kept by the employee’s supervisor and becomes part of the personnel record. To the extent permitted by law, absenteeism and lateness lessen an employee’s chances for advancement and may result in dismissal.

Human Resources Policies Employee Relations

We believe that the work conditions, wages, and benefits it offers to its employees are competitive with those offered by other employers in this area and in this industry. If employees have concerns about work conditions or compensation, they are strongly encouraged to voice these concerns openly and directly to

their direct manager or Human Resources.

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Progressive DisciplineWe administer equitable and consistent discipline for unsatisfactory conduct in the workplace. The best disciplinary measure is the one that does not have to be enforced and comes from strong management and fair supervision at all employment levels. It is in our best interest to ensure fair treatment of all employees and in making certain that disciplinary actions are prompt, uniform and impartial. The purpose of any disciplinary action is to correct the problem, prevent recurrence and prepare the employee for satisfactory service in the future.

All employees are expected to meet Pinnacle Promotions’ standards of work performance. Work performance encompasses many factors, including performance, responsibilities, attendance, punctuality, personal conduct, job proficiency and general compliance with the Company’s policies and procedures.

If an employee does not meet these standards, the Company may, under appropriate circumstances, take corrective action. Generally, corrective action is a three step process in which the employee’s

deficiencies and guidelines for improvement are explained and detailed. Corrective action encourages open, two-way communication between supervisors and subordinates; makes the employee aware of performance concerns or unacceptable behavior; and provides employees with clear performance objectives and timeframes so they will understand the expectations to correct or improve performance or behavior.

In the Company’s sole discretion and based on the circumstances, there may be circumstances when one or more steps are bypassed. Supervisors maintain responsibility to document performance accordingly.

Nothing in this policy is intended to alter the at-will relationship between Pinnacle Promotions and its employees or in any way limit Pinnacle Promotions’ ability to make personnel decisions concerning its employees when, in the Company’s sole discretion and judgment, such decisions are necessary.

PerformanceImprovement Process

STEP ONE – VERBAL REMINDERThis is the initial step in the Performance Improvement Process. Prior to the verbal reminder, the manager will have informally counseled the employee regarding the performance issue. The verbal reminder is given when there has not been any improvement. The verbal reminder changes the employee’s overall performance rating to ‘Practically Achieved Expectations’. While administered verbally in a one-on-one communication between the employee and their supervisor, the supervisor is required to document the meeting. The documentation should be in the form of a follow up email from the supervisor to the employee restating the performance issue discussed in the meeting, the action steps required by the employee, the measurement for improvement, the timeframe for improvement and the consequences of not improving. These consequences should include movement to the next step in the Performance Improvement Process, ‘Written Reminder’, and a change in overall performance rating to ‘Unsatisfactory Performance’. Verbal reminders remain in effect for up to 6 months which means that if the performance, conduct or behavior is repeated during this time, the employee will be given a written reminder.

STEP TWO – WRITTEN REMINDERThis is the second step in the Performance Improvement Process and the performance rating will be changed to ’Unsatisfactory Performance’. The manager will present a written document to the employee that identifies the performance issues and recaps the informal and formal conversations they have had to help correct the problem. This document, which will become part of the employee’s personnel file, will identify specific action steps designed to bring the employee’s performance back to an acceptable level. It will also provide specific dates for accomplishment of each action item. The time given to rectify the employee’s performance issue and return them to an acceptable performance level will vary and will depend on the type of actions that are needed. The document will conclude with the specific consequences the employee could face if they are not able to improve their performance to an acceptable level. These consequences may include an extension,

if management feels effort is being put in and some progress has been made or possible termination if the employee has not shown any effort toward the action steps. If an extension is granted, the employee’s performance rating will remain at an ‘Unsatisfactory Performance’ rating through the extension period.

The copy of the reminder which is forwarded for filing in the employee’s personnel file should be signed by the employee to show that he/she has read and discussed its contents with his/her manager. If the employee refuses to sign it, the manager may make an indication to that effect on the report. The manager may also request a witness (preferably Human Resources or another Manager) to acknowledge and confirm the employee’s refusal to sign. Human Resources will work with the employee and manager to attempt to resolve the problem. Immediate and sustained improvement is expected and required of the employee.

STEP THREE – CONCLUSIONThis is the final step in the Performance Improvement Process. Employees who have met all the objectives of their Performance Improvement Process plan will see their performance rating returned to ‘Achieved Expectations’.

A written document will be given to the employee and placed in their personnel file that will recap the progress they made and state their fulfillment of all requirements needed to be at an acceptable level of performance. The document will also indicate that should a repetition of the issues identified in the Performance Improvement Process occur within six months, the employee could face immediate termination or be returned to an ‘Unsatisfactory’ Performance rating and Step Two of the Performance Improvement Process.

Employees who are unable to improve their performance to an acceptable level may be subject to termination of employment.

Note: Employees who have had formal verbal or written reminders are not eligible for salary increases, commission, bonus awards, promotions or transfers during the warning period.

Employee Relations Employee Relations

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Publicity/StatementsTo The Media To protect the privacy of customers, employees, and the proprietary business of the Company, employees are not permitted to speak for the Company, answer questions from the media, or conduct an interview with the media concerning any aspect of the Company’s business, members, employees, and role with the Company, without the prior knowledge and permission of the CEO or President. All media requests must be referred to the CEO or President. This policy applies to all forms of media, including social media

sites, forums, and platforms.

Social MediaTo protect the privacy of customers, employees, and the proprietary business of the Company, employees are not permitted to speak for the Company, answer questions from the media, or conduct an interview with the media concerning any aspect of the Company’s business, members, employees, and role with the Company, without the prior knowledge and permission of the CEO or President. All media requests must be referred to the CEO or President. This policy applies to all forms of media, including social media sites, forums, and platforms.

Electronic CommunicationPinnacle Promotions’ e-mail and other electronic systems and all content are valuable business assets. The messages sent and received on the e-mail system of whatever kind are the property of the Company. All messages composed, sent, or received on the e-mail system are and remain the property of the Company. They are not the private property of any employee or any other individual authorized to use the e-mail system. The confidentiality of any message should not be assumed.

E-mail addresses and distribution lists are the property of the Company regardless of the originator of such lists. As such, e-mail distribution lists cannot be released to anyone outside of the Company and can never be used for any purpose other than for Company/member business.

As a company, we share a lot of important information via phone, email and other electronic means. These policies extend to all features of the company’s electronic systems including computers, software, email, storage media, connections to the internet, internal and external networks, voicemail, facsimiles, messaging and instant messaging, telephones and company cell phones. Any other form of electronic communication used by employees currently, or in the future, is also intended to be encompassed by this policy. Please use good judgment when using these business tools while serving the interests of the company and of our customers.

You are responsiblefor the following:

• Keep your passwords secure. You are solely responsible for protecting your passwords and the access you gain to our systems.

• Do not share email accounts. You are solely responsible for your email account.

• Protect sensitive/confidential information. Local computer drives and storage devices should never contain personnel and/or customer data. You may not provide information about, or lists of, employees to parties outside of the company without express written permission from an owner of the company.

• Protect company confidential/sensitive information: • Credit card information is considered company confidential/sensitive information in addition to being covered by Payment Card Industry (PCI) Data Security Standards (DSS) and should be protected from disclosure at all times.

• Personally Identifiable Information (PII), whether customer or employee sourced, is considered company confidential/sensitive and should be protected from disclosure at all times.

• Use electronic communication only for job-related matters.

• Refrain from emailing jokes, offensive or inappropriate material to coworkers or vendors.

• Understand that email should not be used to promote personal causes and events that Pinnacle does not sponsor or to sell personal items.

• Return upon demand any and all employer provided equipment including computer files, disks, etc.

Employees’ who participate in the unacceptable use of electronic communication will be subject to disciplinary action, up to and including termination of employment.

Communications may not contain content that may be reasonably considered offensive or disruptive to any employee. Offensive content would include, but is not limited to, sexual comments or images, racial slurs, gender specific comments, or any comments that might reasonably offend someone on the basis of his or her age, sexual orientation, religious or political beliefs, national origin or disability.

Employees’ who participate in the unacceptable use of electronic communication will be subject to disciplinary action, up to and including termination of employment.

Employees may access only messages, files or programs that they have permission to enter.

Messages created, sent, and received are, and remain, the property of the company. Due to the nature of the systems and backup procedures used at Pinnacle, messages that have been deleted by a user may be recoverable by IT personnel.

All Pinnacle computers, systems, networks, and information assets are privately owned and are monitored and logged at times. Users have no expectation of any ‘right of privacy’ on any Pinnacle system. You must assume that someone, other than the intended recipient, may read any and all messages. Monitoring of all electronic communication activity will take place and Pinnacle reserves the right to monitor, gain access to and read any copy of all electronic communications, email, voicemail, and material stored in, transmitted by and received by any electronic communication device.

Communication Policies Communication Policies

Pinnacle Promotions is committed to protecting all employees and the company from illegal or damaging actions by individuals, either knowingly or unknowingly. These policies apply to all employees, contractors,

consultants, and others working at Pinnacle Promotions, including personnel affiliated with third parties. The intention of these policies is to increase your awareness and understanding of the importance of protecting you, your coworkers, and the company in regards to our advanced electronic resources.

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Acceptable Uses OfElectronic Communication:

• Communications should be for professional, business reasons during working time. Treat your audience and recipients with the same respect you would expect in any individual interaction. Do not use obscenity, personal insults, ethnic slurs, or other questionable language.

• Personal internet, email or telephone usage must be limited to meal time, before or after work. Internet access is permitted only for lawful purposes. No expectation of privacy should exist.

• Ensure the information you are communicating is truthful, accurate and useful. If a mistake is found or pointed out by your recipients or audience, you should take action to quickly correct the mistake and clearly note the correction.

• Use proper spelling, grammar, punctuation, and good writing techniques to get your thoughts and

ideas across to your recipients.

Unacceptable Uses OfElectronic Communication:Employees are strictly prohibited from using the Company provided Internet services in connection with any of the following activities:

• Engaging in illegal, fraudulent, or malicious conduct.

• Disclosure of information considered confidential, proprietary, or trade secret, including without limitation, addresses, phone numbers, banking information, credit card information, or Social Security numbers, and health information. Disclosure of such information is not only a violation of company policy but may lead to violation of the law, identity theft, or other harms.

• Unauthorized or personal use of the company’s intellectual property such as slogans, logos, trademarks, or other media or material.

• Working on the behalf of organizations without any professional or business affiliation with the Company.

• Sending, receiving, storing, browsing or viewing any material that may be, or is deemed to be, discriminatory, harassing, offensive, obscene or defamatory.

• Using the communication and computer systems to solicit for any business, commercial, organizational, or personal purpose.

• Engaging in personal newsgroup, mailing list, bulletin board, or other type of discussion forum that is not job-related during work time.

• Annoying or harassing other individuals.

• Monitoring or intercepting the files or electronic communications of employees or third parties.

• Obtaining unauthorized access to any of the computer system.

• Using another individuals account or identity without explicit authorization.

• Unauthorized use, installation, copying, or distributing copyrighted, trademarked, or patented material on the internet.

• Attempting to test, circumvent, or defeat security or auditing systems of the Company or any other organization without prior authorization.

• Permitting any unauthorized individual to access the Company’s e-mail system.

• Downloading or installing unauthorized software applications. Authorization of any software must be approved by the System Administrator.

• Other conduct detrimental to the best interests of

Pinnacle Promotions.

Phone And Mail SystemsPersonal use of the telephone for long-distance and toll calls is not permitted. Employees should practice discretion when making local personal calls and may be required to reimburse Pinnacle Promotions for any charges resulting from their personal use of the telephone.

To ensure effective telephone communications, employees should always use the approved greeting and speak in a courteous and professional manner. Please confirm information received from the caller and hang up only after the caller has done so.

The use of Pinnacle Promotions-paid postage for

personal correspondence is not permitted.

Cell Phone UsageIf you are provided a cellular phone by Pinnacle Promotions it is provided to you as a business tool only. Cellular phones are provided to assist employees in communicating with management and other employees, their clients, associates, and others with whom they may conduct business. Cell phone use is intended for business-related calls only and personal calls are not permitted. Cell phone invoices may be regularly monitored.

Whether the cellular phone is provided by Pinnacle Promotions or the employee is using his or her own cell phone, employees who have access to a cell phone while in their cars should remember that their primary responsibility is driving safely and obeying the rules of the road. Employees are prohibited from using cell phones to conduct business while driving and should safely pull off the road and come to a complete stop before dialing or talking on the phone.

As a representative of Pinnacle Promotions, cell phone users are reminded that the regular business etiquette employed when speaking from office phones or in meetings applies to conversations conducted over a cell phone. If bringing cell phone into a meeting, please ensure that it is set to silent and is properly stowed.

Personal cell phones are not to be used during an employee’s work time either for personal phone calls or as a tool for connecting to any internet-

related services.

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

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

Employees should notify their immediate manager, the Owner or any member of management upon

learning of violations of this policy.

Workplace MonitoringWorkplace monitoring may be conducted by Pinnacle Promotions to ensure quality control, employee safety, security, and customer satisfaction.

Employees who regularly communicate with customers via the telephone may have their conversations monitored or recorded. Telephone monitoring is used to identify and correct performance problems through targeted training. Improved job performance enhances our customers’ image of Pinnacle Promotions as well as their satisfaction with our service.

Computers furnished to employees are the property of Pinnacle Promotions. As such, computer usage and files, including e-mail usage and related files, may be

monitored or accessed.

Communication Policies Communication Policies