The Employee Handbook (“Handbook”) is a compilation of personnel policies, practices and procedures currently in effect at Creatio, an equal opportunity employer.

As an employee of Creatio, the importance of your contribution cannot be overstated. We are a team, and as a team we maintain a high spirit of cooperation and shared commitment throughout the company. Our goal is to provide the best US Customs Brokerage and transport services to our clients and perform those services with excellent customer service. At all times we strive to go above and beyond to help our clients. You are an important part of this process.

This Handbook has been prepared for your information and understanding of the policies, goals, philosophies, and benefits of Creatio (referred to in this Handbook as “Creatio” “CREATIO” or “the Company”). Following the policies described in this Handbook is considered a condition of employment. However, nothing in this Handbook alters an employee’s “at-will” status. Please read the Handbook carefully. It is each employee’s responsibility to familiarize himself/herself with the content of this Handbook and to acknowledge understanding of the stated policies by signing and returning the acknowledgement letter found in this Handbook.

The policies contained in this employee handbook are not intended as a contract of employment and may be added to or changed as needed by management. Nothing in this handbook is intended as a guarantee of any benefits or rights, or as a guarantee of continuation of any benefits or rights.

The policies in this Handbook are guidelines; Creatio reserves the right to make decisions in the best interests of the company as a whole. There is no guarantee of progressive discipline, promotion, benefits, salary levels, work schedules, etc.

This Handbook does not purport to include every conceivable situation; it is merely meant as a guideline. Personnel Policies are applied at the discretion of CREATIO. Of course, Federal, state, and/or local laws will take precedence over CREATIO policies, where applicable.

In an effort to be responsive to the needs of a growing organization, changes or additions to this Handbook will be made when necessary. Creatio reserves the right to change, withdraw, apply, or amend any of our policies or benefits, including those covered in this Handbook, at any time. CREATIO will notify you of such changes, but may, in its discretion make such changes at any time, without a written revision of this Handbook.

We are glad you are part of the Creatio team, and we hope you will find your work to be both challenging and rewarding.

1.1 AT-WILL EMPLOYMENT

Your employment with Creatio is on an “at-will” basis. This means your employment may be terminated at any time, with or without notice and with or without cause. Likewise, we respect your right to leave the company at any time, with or without notice and with or without cause.

Nothing in the employee handbook or any other Company document should be understood as creating guaranteed or continued employment, a right to termination only “for cause,” or of any other guarantee of continued benefits or employment. Only the President has the authority to make promises or negotiate with regard to guaranteed or continued employment, and any such promises are only effective if placed in writing and signed by the President.

2.0 INTRODUCTORY LANGUAGE AND POLICIES

2.1 ETHICS CODE

Creatio will conduct its business honestly and ethically wherever operations are maintained. We strive to improve the quality of our services and operations and will maintain a reputation for honesty, fairness, respect, responsibility, integrity, trust, and sound business judgment. All employees are expected to adhere to high standards of business and personal integrity as a representation of our business practices.

We expect that employees will not allow personal interests to conflict with the interests of the Company, its clients, or affiliates, nor will they misrepresent the Company or use their Company contacts to advance private or personal interests. The confidentiality of sensitive business information about our Company or operations, or that of our customers or partners, is to be treated with discretion and only be disseminated on a need-to-know basis.

Violation of the Code of Ethics can result in discipline, up to and including termination of employment. The degree of discipline imposed may be influenced by the existence of voluntary disclosure of any ethical violation.

2.2 REVISIONS TO HANDBOOK

This employee handbook is our attempt to keep you informed of the terms and conditions of your employment, including Company policies and procedures. The handbook is not a contract. The Company reserves the right to revise, add, or delete from this handbook as it determines to be in its best interest. When changes are made to the policies and guidelines contained herein, we will endeavor to communicate them in a timely fashion, typically in a written supplement to the handbook or an email to employees.

3.0 HIRING AND ORIENTATION POLICIES

3.1 EEO STATEMENT AND NONHARASSMENT POLICY

Equal Opportunity Statement

Our Company is committed to the principles of equal employment. We are committed to complying with all federal, state, and local laws providing Equal Employment Opportunities, and all other employment laws and regulations. It is our intent to maintain a work environment which is free of harassment or discrimination because of sex, race, religion, color, national origin, physical or mental disability, genetic information, marital status, age, sexual orientation, gender identity, military service, veteran status, or any other status protected by federal, state or local laws. The Company is dedicated to the fulfillment of this policy in regard to all aspects of employment, including but not limited to recruiting, hiring, placement, transfer, training, promotion, rates of pay, and other compensation, termination and all other terms conditions and privileges of employment.

The Company will conduct a prompt and thorough investigation of all allegations of discrimination or any violation of the Company’s Equal Employment Opportunity Policy in a confidential manner. The Company will take appropriate corrective action, if and where warranted. The Company prohibits retaliation against any employee who provides information about, complains, or assists in the investigation of any complaint of discrimination or violation of the Company’s Equal Employment Opportunity Policy.

We are all responsible for upholding the Company’s Equal Employment Opportunity policy and any claimed violations of that policy should be brought to the attention of your manager and/or human resource personnel.

Policy Against Workplace Harassment

Creatio has a strict policy against all types of workplace harassment, including sexual harassment and other forms of workplace harassment based upon an individual’s sex, race, religion, color, national origin, physical or mental disability, marital status, age, sexual orientation, sexual identity or any other status protected by federal, state or local laws. All forms of harassment of, or by, employees, vendors, visitors, customers, and clients are strictly prohibited and will not be tolerated.

Policy Against Sexual Harassment

Sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when (1) submission to such conduct is made either explicitly or implicitly as a term or condition of an individual’s employment (2) submission to, or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual or (3) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment.

While it is not possible to identify each and every act that constitutes or may constitute sexual harassment, the following are some examples of sexual harassment: (a) unwelcome requests for sexual favors; (b) lewd or derogatory comments or jokes; (c) comments regarding sexual behavior or the body of another employee; (d) sexual innuendo and other vocal activity such as catcalls or whistles; (e) obscene letters, notes, emails, invitations, photographs, cartoons, articles, or other written or pictorial materials of a sexual natures; (f) repeated requests for dates after being informed that interest is unwelcome; (g) retaliating against an employee for refusing a sexual advance or reporting an incident of possible sexual harassment to Creatio or any government agency; (h) offering or providing favors or employment benefits such as promotions, favorable evaluations, favorable assigned duties or shifts, etc., in exchange for sexual favors; and (i) any unwanted physical touching or assaults, or blocking or impeding movements.

Other Workplace Harassment

Other workplace harassment is verbal or physical conduct that insults or shows hostility or aversion towards an individual because of the individual’s sex, race, religion, color, national origin, physical or mental disability, marital status, age, sexual orientation or any other status protected by federal, state or local laws, and that: (1) contributes to or has the effect of creating an intimidating, hostile or offensive working environment; (2) unreasonably interferes with an individual’s work performance; or (3) otherwise adversely affects an individual’s employment opportunities.

Again, while it is not possible to list all the circumstances that constitute other forms of workplace harassment, the following are some examples of conduct that may constitute workplace harassment: (a) the use of disparaging or abusive words or phrases, slurs, negative stereotyping, or threatening, intimidating or hostile acts that relate to the above protected categories; (b) written or graphic material that insults, stereotypes or shows aversion or hostility towards an individual or group because of one of the above protected categories and that is placed on walls, bulletin boards, email, voicemail or elsewhere on the Company’s premises, or circulated in the workplace; and (c) a display of symbols, slogans or items that are associated with hate or intolerance towards any select group.

Discrimination and harassment will not be tolerated in the workplace. Any employee who feels that he or she has witnessed, or been subject to, any form of discrimination or harassment is required to immediately notify the President or CFO.

Creatio prohibits retaliation against any employee who provides information about, complains, or assists in the investigation of any complaint of harassment or discrimination.

We will promptly and thoroughly investigate any claim and take appropriate action where we find a claim has merit. Discipline for violation of this policy may include, but is not limited to reprimand, suspension, demotion, transfer, and discharge. If the Company determines that harassment or discrimination occurred, corrective action will be taken to effectively end the harassment. As necessary, the Company may monitor any incident of harassment or discrimination to assure the inappropriate behavior has stopped. In all cases, the Company will follow up as necessary to ensure no retaliation for making a complaint or cooperating with an investigation.

3.2 DISABILITY ACCOMMODATION

The Company complies with federal and state disability regulations, including the Americans with Disabilities Act (ADA). Qualified applicants or employees who inform the Company that they have a physical or mental disability, which requires accommodation in order for them to perform the essential functions of their jobs should inform the President or CFO of this so that we can together discuss what accommodations are available and appropriate.

Procedure for reasonable accommodation requests:

Employee advises the President or CFO of the need for accommodation. Employee puts said accommodation request in writing.

The accommodation request will be discussed with the employee.

The employee may be required to provide documentation supporting a disability, including medical certification.

If a reasonable appropriate accommodation is readily available, the request will be approved and the accommodation implemented.

If an accommodation is not readily ascertainable, the matter will be pursued further with assistance from appropriate external resources.

The Company will consider the request but reserves the right to offer its own accommodation to the extent permitted by law. The Company will consider cost, the effect that an accommodation will have on current established policies and the burden on operations, including other employees, when determining a reasonable accommodation.

3.3 RELIGIOUS ACCOMMODATION

Creatio is dedicated to treating the religious diversity of all our employees equally and with respect. Employees may request in writing an accommodation when their religious beliefs cause a deviation from CREATIO’s schedule, basic job duties, or other aspects of employment. The Company will consider the request but reserves the right to offer its own accommodation to the extent permitted by law. Accommodations may include but are not limited to changes in current job conditions, a change in position, an exception to the dress code, paid/unpaid leave time, etc. The Company will consider cost, the effect that an accommodation will have on current established policies and the burden on operations, including other employees, when determining a reasonable accommodation. At no time will the Company question the validity of a person’s belief.

3.4 TRAINING PROGRAM

Training and development is considered extremely important at CREATIO. Being informed about the latest updates and changes allows us to serve our clients better. Training can be accomplished on an individual basis or by the Team Lead. Even if an employee has had previous experience in their specified functions, it is necessary for them to learn our specific procedures, as well as the responsibilities of the specific position. If you ever feel you require additional training, please consult your manager or Team Lead. (see also Continuing Education and Professional Development section)

3.5 EMPLOYMENT AUTHORIZATION VERIFICATION

All new hires and current employees are required by federal law to verify their identity and eligibility to work in the United States. You will be required to complete federal Form I-9 on the first day of employment. If this form and verification of employment eligibility is not completed during the first three days of employment, we are required by law to terminate your employment. If you are currently employed and have not complied with this requirement or if your status has changed, please inform Human Resources.

4.0 WAGE AND HOUR POLICIES

4.1 INTRODUCTION

An employee’s pay depends on a wide range of factors, including pay scale surveys, individual effort, profits, and market forces. If you have any questions about your compensation, including matters such as paid time off, overtime, benefits, or paycheck deductions, please speak with Human Resources or the President.

4.2 PAY PERIOD

The standard pay period is bi-weekly for all employees. Pay dates are on Fridays. Should any pay period fall on a holiday, you will be paid on the preceding workday.

4.3 PAYCHECK DEDUCTIONS

The Company is required by federal and state law to make certain deductions from your paycheck. This includes federal income tax, state income and unemployment tax, and FICA contributions (Social Security and Medicare) as well as any other deduction required under state or federal law. The amount of your tax deductions will depend on your earnings and the number of exemptions you list on your W-4 Form. If at any time you do not believe that your paycheck is accurate, please contact Human Resources. Deductions are also taken for your health/life insurance co-pays, IRA contributions and other deductions you may authorize. Any questions about your paycheck should be directed to Human Resources.

4.4 RECORDING TIME

Federal and state laws require us to keep accurate records of hours worked by nonexempt (hourly) employees. You should clock in no more than five minutes ahead of time and clock out no later than five minutes after your quitting time. Every nonexempt employee of the Company is required to enter his or her hours worked accurately, including all lunch periods and any rest periods of more than 15 minutes. Employees are required to notify the company of any pay discrepancies, unrecorded or misrecorded work hours, or any involuntary missed meal or break periods.

Do not complete the time sheet of any other employee or request that they do so for you. Please be sure to indicate your days off. Any changes to your time card must be approved by Human Resources.

Falsification of time records or recording time for another employee may result in discipline, up to and including termination of employment.

4.5 OVERTIME AUTHORIZATION FOR NONEXEMPT EMPLOYEES

If you are a nonexempt employee, you may qualify for overtime pay.

At certain times the Company may require you to work overtime. We will attempt to give as much notice as possible in this instance. However, advance notice may not always be possible. Failure to work overtime when requested or working unauthorized overtime may result in discipline, up to and including termination.

Overtime pay of one and one-half an employee’s regular rate of pay is paid for any hours worked in excess of 40 hours in a workweek. Holidays, vacation days, and sick leave days do not count as time worked for computing overtime.

4.6 ATTENDANCE POLICY

If you know ahead of time that you will be absent or late, provide reasonable advance notice to your manager or team lead. Employees may be required to provide documentation of any medical or other excuse for being absent or late.

The Company reserves the right to apply unused vacation, sick time, or other paid time off to unauthorized absences. Absences resulting from approved leave, vacation, or legal requirements are exceptions to the policy.

4.7 JOB ABANDONMENT

If an employee fails to show up for work or call in with an acceptable reason for the absence for a period of three consecutive days, he or she will be considered to have abandoned his or her job and voluntarily resigned from the company.

4.8 TRAVEL EXPENSES

The purpose of this policy is to define employee travel rules and the authority for incurring and approving travel expenses.

Travel expenses are the reasonable and necessary expenses incurred by employees when traveling on approved Company business trips. Company travel is limited to business activities for which other means of communication is inadequate and for which prior approval of the employee’s manager has been received.

Travel Expenses

The Company pays the actual amounts incurred for appropriate expenses when employees are on travel assignments. Examples of typical expenses include the following:

Airline tickets

Meals and lodging

Car rental, bus, taxi, parking

Other expenses, if necessary to achieve the business purposes

Air Travel

Employees are to use economy or the least expensive class airfares when traveling on Company business.

Hotels

Neither in-room movies nor refreshment bars are approved Company expenses.

Insurance

The Company does not pay for personal travel insurance for employees.

Rental Cars

Employees are to use rental firms having existing relationships with the Company and, where feasible, have negotiated discounts rates.

Personal Vehicles

All employees using their own vehicle for business purposes must maintain insurance coverage as required by law and may not have more than 2 points on their driving record. Travel between the employee’s home and primary office is not considered to be business travel. Employees are not authorized to use personal vehicles for business travel without authorization. Every attempt should be made to utilize the use of courier and delivery services in order to avoid hazard of liability and the time away from work. Employees will be reimbursed for vehicle use at the standard IRS mileage rate. Any deviation from this policy must be approved by management.

Employee Reporting

Employees are to report their approved expenses, including description, purpose, date, place and the participants. Please utilize the CREATIO Expense Report Form. Authorized expenses should be submitted for reimbursement within 90 days of the expense. Expenses older than 90 days may not be reimbursed.

4.9 USE OF COMPANY CREDIT CARDS

Every employee in the possession of a Company issued credit card will adhere to guidelines of responsibility for the proper protection and use of that card.

All sales receipts generated by use of the Company credit card must be turned in at least monthly to the Accounting Department. Company credit cards are not to be used for personal reasons. Use of the company credit card is restricted to approved business related expenses.

Any unauthorized purchases made with a Company issued credit card will be the cardholder’s responsibility. Any such purchase will be reimbursed to the company by the employee within 5 days.

Lost or stolen Company issued cards must be reported immediately to the CFO. Failure to follow this policy may result in disciplinary action up to and including discharge.

4.10 REST AND MEAL PERIODS

The Company strives to provide a safe and healthy work environment and complies with all federal and state regulations regarding rest and meal periods. Please check with your supervisor regarding procedures and schedules for rest and meal breaks. The Company requests that employees accurately observe and record meal and rest periods. All employees are expected to take their daily 60-minute meal period.

5.0 PERFORMANCE, DISCIPLINE, LAYOFF, AND TERMINATION

5.1 PERFORMANCE EVALUATION AND DEVELOPMENT PLANNING

At CREATIO, pay increases and promotions are dependent to a great extent upon how well an employee performs his or her job as well as how the company is performing overall. Therefore, it is important that an employee and his or her supervisor share an understanding of what is expected of the employee.

Your supervisor has an option to complete a performance review for any new employee at the end of ninety (90) days; thereafter, reviews will be conducted annually. For Non-exempt (hourly) employees, annual reviews will be completed typically near the employee’s anniversary date (date of hire) or a date close by. For Exempt (salary) employees, annual reviews will normally be completed at the beginning of each calendar year to coincide with annual goals and budgets. In addition to these regular evaluations, written reviews may be completed on an informal basis.

Items taken into consideration in evaluating overall job performance are: job description, cooperation, initiative, customer service, files completed, accuracy, reliability, attendance, judgement, and acceptance of responsibility.

Supervisors will prepare a written evaluation of each employee’s job performance. Such reviews will include the supervisor’s comments and recommendations, an action plan for both the employee and supervisor, and performance goals for the next evaluation period.

The employee will be given the opportunity to examine the written evaluation and make written comments about any aspect of it. The employee and supervisor are to sign and date the evaluation, a copy of which will be forwarded to Human Resources for review and inclusion in the employee’s file.

Information derived form an employee’s performance evaluation may be considered when making decisions concerning an employee’s training needs and opportunities, pay, promotion, transfer or continued employment.

5.2 STANDARDS OF CONDUCT

Creatio wishes to create a work environment that promotes job satisfaction, respect, responsibility, integrity, and value for all of our employees, clients, customers, and other stakeholders. Every employee has a shared responsibility toward improving the quality of our work environment. By deciding to work at this Company, you agree to follow the Company’s rules.

While it is impossible to list every item that could be considered misconduct in the workplace, what is outlined here is a list of common-sense infractions that could result in discipline, up to and including immediate termination of employment. This policy is not intended to limit the Company’s right to discipline or discharge employees for any reason permitted by law. In fact, while we value our employees, the Company retains the right to terminate an employee on an “at-will” basis.

Examples of inappropriate conduct include:

Violation of the policies and procedures set forth in this handbook.

Possessing, using, distributing, selling, or negotiating the sale of drugs including marijuana or other controlled substances or being under the influence of alcohol, marijuana or drugs during working hours on Company property (including Company vehicles), or on Company business.

Inaccurate reporting of the hours worked by you or any other employee.

Providing inaccurate, incomplete or misleading information in interviews or the preparation of any employment related document including, but not limited to, job applications, personnel files, employment review documents, intra-Company communication, communications with those outside the Company, or expense records.

Taking or destroying Company property.

Possession of potentially hazardous or dangerous property such as firearms, weapons, chemicals, etc., without prior authorization.

Fighting with, or harassment of, any fellow employee, vendor, or customer.

Unauthorized or excessive use of Company property or the property of any visitor, customer, or fellow employee. This includes, but is not limited to, vehicles, supplies, telephones, mail, and computers.

Disclosure of Company trade secrets or proprietary information of the Company, its customers, or fellow employees.

Refusal or failure to follow directions or to perform a requested or required job task.

Refusal or failure to follow safety rules and procedures.

Excessive tardiness or absences

Working unnecessary/not required overtime.

Solicitation of fellow employees on the Company premises during working time.

Failure to dress according to Company policy.

Use of obscene or otherwise inappropriate language or conduct in the workplace.

Outside employment which interferes with your ability to perform your job at this Company.

Gambling on Company premises.

Lending keys or keycards to Company property to unauthorized persons.

Harassment of, or discrimination against, an employee, customer, or visitor because of that person’s race, religion, color, sex, age, sexual preference, disability, or national origin.

Nothing in this policy is intended to limit employee rights under the National Labor Relations Act. Failure to comply with this policy can result in disciplinary action, up to and including immediate termination of employment.

5.3 CRIMINAL ACTIVITY/ARRESTS

Involvement in criminal activity, whether on or off Company property, may result in disciplinary action including suspension or termination of employment. Disciplinary action depends upon a review of all factors involved, including whether or not the employee’s action was work-related, the nature of the act, or circumstances which adversely affect attendance or performance. Any disciplinary action is not dependent upon the disposition of any case in court.

Employees are expected to be on the job, ready to work, when scheduled. Inability to report to work as scheduled as a result of an arrest may lead to disciplinary action, up to and including termination of employment, for violation of an attendance policy or job abandonment.

Any disciplinary action taken will be based on information reasonably available. This information may come from witnesses, police, or any other source as long as management has reason to view the source as credible.

5.4 DRUG AND ALCOHOL POLICY

CREATIO considers drug and alcohol abuse a serious matter which will not be tolerated. The company absolutely prohibits employees from using, selling, possessing, or being under the influence of legal or illegal drugs, alcohol, marijuana or controlled substances or prescription drugs not medically authorized while at their job, on Company property, or while on work time.

Every employee will be required to pass a comprehensive drug screening including a urinalysis prior to employment. CREATIO employs the services of an outside, third party vendor to perform the chemical tests.

Therefore, it is the Company’s policy that:

Employees shall not report to work under the influence of alcohol, illegal drugs, marijuana, or any controlled substance or prescription drug not medically authorized.
Employees shall not possess or use alcohol, tobacco, illegal drugs, marijuana, or any controlled substance or prescription drug not medically authorized while on company property or on company business.

The Company recognizes that drug/alcohol testing is a necessary part of a comprehensive program to maintain a drug-free workplace. Accordingly, the Company reserves the right to require a drug or alcohol test of any employee after an accident, on a random basis or based upon reasonable suspicion. Reasonable suspicion includes, but is not limited to, physical evidence of use, giving the appearance of being under the influence, the causing of an accident, or a substantial drop off in work performance. Failure to take a requested test may lead to discipline, including possible termination of employment.

The Company also cautions against use of prescribed or over-the-counter medication which can affect an employee’s ability to perform his or her job safely or the use of prescribed or over-the-counter medication in a manner violating the recommended dosage or instructions from the doctor. Employees must have a valid prescription for any prescription medication used by employees while working for the Company. Please inform your supervisor prior to working under the influence of a prescribed or over-the-counter medication that may affect your ability to perform your job safely. If the Company determines that the prescribed or over-the-counter medication does not pose a safety risk, you will be allowed to work. Failure to comply with these guidelines concerning prescription or over-the-counter medication may result in disciplinary action, up to and including termination of employment.

Violations

A violation of this policy will result in disciplinary action up to and including termination of employment. The refusal to submit to a drug or alcohol test as provided for in this policy, or refusal to sign a consent form, will be subject to discipline including termination of employment.

5.5 DISCIPLINARY PROCESS

Violation of Company policies or procedures may result in disciplinary action including demotion, transfer, leave without pay, or termination of employment. The Company encourages a system of progressive discipline depending on the type of prohibited conduct. However, the Company is not required to engage in progressive discipline and may discipline or terminate an employee where he or she violates the rules of conduct, or where the quality or value of the employee’s work fails to meet expectations at any time. Again, any attempt at progressive discipline does not imply that your employment is anything other than on an “at will” basis.

In appropriate circumstances, management will provide the employee first with a verbal warning, then with one or more written warnings, and if the conduct is not sufficiently altered, eventual demotion, transfer, forced leave, or termination of employment. Your supervisor will make every effort possible to allow you to respond to any disciplinary action taken. Understand that while the Company is concerned with consistent enforcement of our policies, the Company is not obligated to follow any disciplinary or grievance procedure and that depending on the circumstances, employees may be disciplined or terminated without any prior warning or procedure.

5.6 PROBLEM-SOLVING PROCEDURE

We strive to provide a comfortable, productive, legal, and ethical work environment. To this end, the Company wants you to bring any problems, concerns, or grievances you have about the work place to the attention of your supervisor and, if necessary, to upper level management. To help manage conflict resolution we have instituted the following problem solving procedure:

If you believe there is inappropriate conduct or activity on the part of the Company, management, its employees, vendors, customers, or any other persons or entities related to the Company, bring your concerns to the attention of your supervisor at a time and place that will allow the supervisor to properly listen to your concern. Most problems can be resolved informally through dialogue between you and your immediate supervisor. If you have discussed this matter with your supervisor before and do not believe you have received a sufficient response, or if you believe your supervisor is the source of the problem, we request you present your concerns to Human Resources. Please indicate what the problem is, those persons involved in the problem, efforts you have made to resolve the problem, and any suggested solution you may have.

It is the purpose of this problem solving procedure to help maintain a work environment with respect and responsibility towards each other.

5.7 OUTSIDE EMPLOYMENT

Outside employment which creates a conflict of interest or which affects the quality or value of your work performance or availability at the Company is prohibited. The Company recognizes that employees may seek additional employment during off hours, but expects, in these cases, that any outside employment will not affect job performance, work hours, or scheduling, or otherwise adversely affect the employment relationship. Any conflicts should be reported to your supervisor. Failure to adhere to this policy may result in discipline up to and including termination.

5.8 EXIT INTERVIEW

You may be asked to participate in an exit interview when you leave the Company. The purpose of the exit interview is to provide management with greater insight into employee relations and to avoid unnecessary employee claims. Your cooperation in the exit interview process is appreciated.

5.9 POST-EMPLOYMENT REFERENCE POLICY

The Company policy is to confirm dates of employment and job title only. With written authorization, the Company will confirm compensation. Please forward any requests for employment verification to Human Resources.

6.0 GENERAL POLICIES

6.1 DRIVING RECORD

All employees required to operate a motor vehicle as part of their employment duties must maintain a valid driver’s license and acceptable driving record. The Company may run a motor vehicle department check to determine an employee’s driving record. It is your responsibility to provide a copy of your current driver’s license for your personnel file. Any changes in your driving record, including, but not limited to, driving infractions, must be reported to the Company.

State law requires all motorists to carry auto liability insurance. It is against the law to drive without insurance. Employees using their own vehicle as a part of their employment duties must provide management with a current proof of insurance statement or card. A new proof of insurance is required every time your policy expires and renews.

6.2 USE OF COMPANY VEHICLES

Company vehicles are to be used for Company business only. Unless the use of the vehicle has been approved for personal use, personal or outside business use is strictly prohibited.

Drivers of Company vehicles are to immediately report all infractions or violations while driving a Company vehicle and all restrictions, suspensions, or revocations against their driver’s license to their supervisor, manager, Human Resources immediately.

When a Company vehicle cannot be operated, is unsafe for use, or has been damaged, notify a supervisor or manager immediately.

The driver of a Company vehicle is responsible for the vehicle while in his or her charge and must not permit unauthorized persons to drive it.

The driver is responsible for the daily housekeeping of the vehicle; it is to remain clean and uncluttered.

No person shall operate a motor vehicle while under the influence of alcohol or a chemical substance or other substance that can impair judgment.

Multiple driving moving violations that appear on the annual state department of motor vehicle check will result in suspension of rights to drive a company vehicle or drive a personal vehicle on company business. Suspension of rights will continue until one (1) year has passed with no infractions. If there are persistent and ongoing problems with driving infractions, and driving a vehicle is a part of successful execution of job responsibilities, termination of employment is possible.

6.3 AUTHORIZATION FOR USE OF PERSONAL VEHICLE

All employees required to operate a motor vehicle as part of their employment duties must maintain a valid driver’s license, acceptable driving record, and appropriate insurance coverage. The Company may run a motor vehicle department check to determine an employee’s driving record. It is your responsibility to provide a copy of your current driver’s license and insurance coverage for your personnel file. Any changes in your driving record, including, but not limited to, driving infractions or changes to your insurance policy, must be reported to the Company.

6.4 NOTICE OF GPS MONITORING POLICY OF COMPANY VEHICLES

Our company desires to strike the appropriate balance between today’s technologies, an employee’s desire for privacy, and the company’s interests in protecting its vehicles, equipment and drivers. Due to safety, efficiency and other business purposes, the Company may use GPS technology to monitor the whereabouts of our vehicles at all times.

Questions concerning the use of the system should be directed to the Human Resources. Questions concerning the proper use of any vehicles should be directed to the employee’s immediate supervisor and/or Human Resources.

Any employee who abuses the privilege of driving company vehicles will be subject to corrective action, up to and including termination of employment. If necessary, the Company will also advise law enforcement officials of any illegal conduct.

6.5 PERSONNEL AND MEDICAL RECORDS

The Company maintains a personnel and medical file for every employee. Medical records will be kept in a separate folder. Every effort will be made to keep your personnel and medical records confidential. Access is on a “need-to-know” basis only. This includes, but is not limited to supervisors and others in management reviewing the file for possible promotion, transfer or layoff.

If an employee wishes to review his or her personnel or medical file he or she may do so after giving the Company reasonable notice. Inspection must occur in the presence of a Company representative. All requests by an outside party for information contained in your personnel file will be directed to the Human Resources department, which is the only department authorized to give out such information.

Intentional falsification of application materials or other personnel records may result in discipline, up to and including termination.

6.6 EMPLOYEE PRIVACY AND RIGHT TO INSPECT

Company property, including but not limited to, lockers, phones, computers, tablets, iPads, desks, work place areas, vehicles, or machinery, remains under the control of the Company and is subject to inspection at any time, without notice to the employee, and without the employee’s presence. Employees should have no expectation of privacy in any of these areas. We assume no responsibility for the loss of, or damage to, any employee property maintained on Company premises including that kept in desks.

6.7 VOICEMAIL, EMAIL, AND INTERNET POLICY

This Voicemail/Email/Internet Policy is intended to provide each employee of the Company with the guidelines associated with the use of the Company’s voicemail/email/Internet system (the system). This policy applies to all employees, contractors, vendors, partners, or associates, and any others accessing and/or using the Company’s system through onsite or remote terminals.

General Provisions

The system, and all data transmitted or received through the system, are the exclusive property of the Company. No individual should have any expectation of privacy in any communication over this system. Any individual permitted to have access to the Company’s system will be given a voicemail, email and/or Internet address and/or access code, and will have use of the system, consistent with this policy.

The Company reserves the right to monitor, intercept, and/or review all data transmitted, received, or downloaded over the system. Any individual who is given access to the system is hereby given notice that the Company will exercise this right periodically, without prior notice and without the prior consent of the employee.

The Company’s interests in monitoring and intercepting data include, but are not limited to: protection of Company proprietary and classified data; managing the use of the Company’s computer system; preventing the transmission or receipt of inappropriate materials by employees; and/or assisting the employee in the management of electronic data during periods of absence. No individual should interpret the use of password protection as creating a right or expectation of privacy. In order to protect everyone involved, no one can have a right or expectation of privacy with regards to the receipt, transmission or storage of data on the Company Voicemail/Email/Internet system.

Any employee who abuses the privilege of access to the Company’s voicemail, email, or the Internet system will be subject to corrective action, up to and including termination of employment. If necessary, the Company will also advise law enforcement officials of any illegal conduct.

6.8 SOCIAL MEDIA POLICY

CREATIO understands that social media is widely used. However, use of social media also presents certain risks and carries with it certain responsibilities. As such, we have established the following guidelines for appropriate employee use of social media. Managers and supervisors should use the supplemental Social Media Management Guidelines for additional guidance in administering the policy.

Guidelines

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

When considering your activities on social media outlets, keep in mind that any of your conduct that adversely affects your job performance or the performance of fellow associates/employees, or that adversely affects customers or suppliers of CREATIO or CREATIO’s legitimate business interests may result in disciplinary action up to and including termination of employment.

Carefully read these guidelines, the CREATIO Ethics Policy, the CREATIO Information Policy and the Discrimination & Harassment Prevention Policy, and ensure your postings are consistent with these policies. Inappropriate postings that may include discriminatory remarks, slander, harassment, and threats of violence or similar inappropriate or unlawful conduct will not be tolerated and may subject you to disciplinary action up to and including termination of employment.

Always be fair and courteous to fellow associates, customers, members, suppliers, or people who work on behalf of the Company. Also, keep in mind that you are more likely to resolve work-related complaints by speaking directly with your co-workers than by posting complaints to a social media outlet. When posting, avoid using statements, photographs, video or audio that reasonably could be viewed as malicious, dishonest, obscene, threatening or intimidating, that disparage customers, members, associates or suppliers, or that might constitute harassment or bullying. Examples of such conduct might include offensive posts meant to intentionally harm someone’s reputation or posts that could contribute to a hostile work environment on the basis of race, sex, disability, religion or any other status protected by law or company policy.

Make sure you are always honest and accurate when posting information or news, and if you make a mistake, correct it quickly. Remember that the Internet archives almost everything; therefore, even deleted postings can be searched. Never post any information or rumors that you know to be false about the Company, fellow associates, members, customers, suppliers, or people working on behalf of CREATIO or competitors.

Do not post internal communications relating to the Company’s trade secrets and private or confidential information such as customer lists. Trade secrets may include information regarding the development of systems, processes, products, know-how and technology. Respect financial disclosure laws. It is illegal to communicate or give a “tip” on inside information to others so that they may buy or sell stocks or securities. Do not create a link from your blog, website or other social networking site to the Company’s website without identifying yourself as a CREATIO associate.

Express only your personal opinions. Never represent yourself as a spokesperson for CREATIO and be clear and open about the fact that you are an associate and that your views do not represent those of CREATIO, fellow associates, members, customers, suppliers or people working on behalf of CREATIO. It is best to include a disclaimer such as “The postings on this site are my own and do not necessarily reflect the views of CREATIO.”

Refrain from using social media while on work time or on Company-provided equipment unless it is work-related as authorized by your manager or consistent with the Company Internet Policy. Do not use company email addresses to register on social networks, blogs, or other online tools utilized for personal use.

CREATIO prohibits taking negative action against any associate for reporting a possible deviation from this policy or for cooperating in an investigation. Any associate who retaliates against another associate for reporting a possible deviation from this policy or for cooperating in an investigation will be subject to disciplinary action, up to and including termination of employment.

If you have questions or need further guidance, please contact your HR representative.

6.9 EMPLOYEE SUGGESTIONS/OPEN DOOR POLICY

We welcome suggestions for continued improvement and welcome your ideas for better ways to do your job, produce or sell the products or services of our Company, or meet customer and client needs. Discuss your ideas with your supervisor or another member of the management team.

We also encourage you to offer any suggestions derived from seminars, magazines, or other outside sources of information you believe would add value to the Company.

Understand that any suggestions, innovations, inventions, or other matter created by you on work time or with Company tools or property are considered to be the property of the Company.

6.10 COMPANY BULLETIN BOARDS

CREATIO maintains an official bulletin board located in the employee kitchen/break area for the purpose of providing employees with its official notices, including wage and hour laws, changes in policies, and other employment-related notices. At times the Company may also post information of general interest to the employees on the bulletin board. Please keep informed about this material by periodically reviewing the Company bulletin board. Only authorized personnel are allowed to add and remove notices from the Company bulletin board.

6.11 NONSOLICITATION/NONDISTRIBUTION POLICY

To avoid disruption of business operations or disturbance of employees, visitors, and others, the Company has implemented a Nonsolicitation Policy. For purposes of the Nonsolicitation Policy, “solicitation” includes canvassing, soliciting or seeking to obtain membership in or support for any organization, requesting contributions, and posting or distributing handbills, pamphlets, petitions, and other materials on Company property or using Company resources (including without limitation bulletin boards, computers, mail, email and telecommunication systems, photocopiers, and telephone lists and databases). Solicitation performed through verbal, written, or electronic means is covered by the Nonsolicitation Policy.

Employees are also prohibited from soliciting other employees for any cause during their assigned working time. For this purpose, working time means time during which either the soliciting employees or the employees who are the object of the solicitation are expected to be actively engaged with assigned work. Employees may conduct solicitations during their lunch period, coffee breaks, or other authorized nonwork periods, so long as they do so when the other employees are on their lunch or break periods. Employees are prohibited from soliciting an employee who requests not to be solicited, even if on a break period.

6.11 CONFLICTS OF INTEREST

All employees have a duty to further the Company’s aims and goals, and to work on behalf of its best interest. Employees should not place themselves in a position where the employee’s actions or personal interests may be in conflict with those of Creatio. Employees must avoid all transactions and situations that may create an actual or apparent conflict of interest. A conflict of interest exists when an employee’s loyalties are divided between what is best for the Company and what is best for the employee or a third party. Working for a competitor while working for the Company, inviting or accepting substantial gifts from a vendor or customer, are examples or situations that may result in divided loyalties.

The following guidelines should be observed:

If you, the employee, intend to participate in outside work or business activities you must discuss this in advance with your manager to avoid any possible or perceived conflict of interest. The Company will decide whether you can continue employment under those circumstances.
You may not give or accept gifts or personal favors of more than token or nominal value from any actual or potential supplier, customer, or customer representative. Likewise, you should not give or accept entertainment or meals with customers or suppliers without a legitimate business purpose.

You should not accept employment from, or perform services for, competitors or suppliers while employed by the Company.

Violation of this policy may result in disciplinary action, up to termination of employment.

6.12 PERSONAL APPEARANCE

Your personal appearance reflects on the reputation and integrity of the company. All employees are required to report to work neatly groomed and dressed. You are expected to maintain personal hygiene habits that are generally accepted in the community, i.e. clean clothing, good grooming and personal hygiene, and appropriate social behavior.

Your choice of clothing should always be in good taste. Business casual dress should be observed most days, unless a specific dress down day has been designated, such as Casual Friday. Please keep it appropriate for an office environment.

If you are attending an outside meeting, such as meeting with a client or customer and including a trade show or convention, your dress should be business appropriate.

If you come to work inappropriately dressed, you will be asked to go home and return to work dressed appropriately. Recurring problems will result in discipline up to and including termination of employment.

6.13 COMPANY SOCIAL EVENTS

CREATIO may, from time to time, hold social events for employees. Please be advised that your attendance at these events is typically voluntary and does not constitute part of your work-related duties as an employee.

Alcoholic beverages may be available at these events. If you choose to drink alcoholic beverages, please do so in a responsible manner. Do not drink and drive. Instead, please call a taxi or appoint a designated driver. If needed and requested, the company will reimburse a reasonable amount for a taxi ride.

6.14 TELEPHONE USE

Our phones are principally for work-related communications. Employees should limit personal use of the telephone to brief communications during rest periods where possible. Casual conversation with friends and relatives during working hours is strongly discouraged. Telephone use is subject to the Voicemail/Email/Internet Usage Policy.

6.15 COMPANY-PROVIDED CELL PHONE/MOBILE DEVICE POLICY

The purpose of this policy is to provide guidance to departments and employees regarding eligibility for Company-provided cell phones and plans, and the appropriate use of the phone and plan.

An employee must have a legitimate business need for a cell phone/mobile device and the issuance of same to the employee must be approved by the employee’s supervisor or Human Resources. The typical legitimate reasons why an employee may need a cell phone/mobile device include frequent traveler needs or when the employee is a member of key personnel who must be immediately reachable in the event of an emergency.

When the cell phone/mobile device is used for personal reasons and the activity results in additional cost to the Company, the individual is responsible for the cost of that usage, including all applicable taxes. The employee should make note of personal calls and reimburse the Company after review of the monthly call detail.

If the cell phone/mobile device has a flat rate airtime/data plan, the user is responsible for reimbursing the Company when personal activities cause the plan threshold to be exceeded. The employee, with concurrence of an authorized signer on the account, should determine the amount of personal use that caused the usage to exceed the plan and reimburse the Company for that amount plus all applicable taxes. Employees who drive a vehicle during the course of their employment may not use any cell phone/mobile device or other communication device while driving unless the device is equipped or configured with a “hands-free” listening/speaking option, and the “hands-free” device is in fact utilized by the employee.

The company owns and remains entitled to all cell phone/mobile devices, including all passwords controlling access to them. You may not change those passwords except with permission. At the time of employment termination, all such equipment and passwords must be returned to the company in operable condition.

6.16 PERSONAL CELL PHONE/MOBILE DEVICE USE

Personal cell phone use at work is distracting and can be disruptive. All personal cell phones/mobile devices are to be kept in your desk drawer, your coat, purse, etc. while you are at work. In addition to telephone service, many cell phones or cellular providers offer a host of additional functions and/or services, including text messaging and digital photography. Employees are prohibited from using these services while at work.

We understand some personal calls are necessary. We request that personal calls and texting be done away from your desk. You may use your cell phone during lunch or on breaks. During this time, please use your phone in a manner that is courteous to those around you. Employees should avoid loud or distracting ringtones, and should keep their phones on silent or vibrate whenever possible.

While operating a vehicle on company time, the company requires that the driver’s personal cell phone/mobile device to be turned off. If you need to make or receive a phone call, pull off the road to a safe location unless you have the correct hands-free equipment for the device that is in compliance with applicable state laws.

Violation of this policy will subject an employee to disciplinary action up to and including termination of employment.

6.17 SECURITY

Every employee is responsible for helping to make this a secure work environment. Upon leaving work, lock all desks and doors protecting valuable or sensitive material in your work area and report any lost or stolen keys, passes, or other similar devices to your supervisor immediately. You should refrain from discussing with nonemployees specifics regarding Company security systems, alarms, passwords, etc.

We also request that you immediately advise your supervisor of any known or potential security risks and/or suspicious conduct of employees, customers, or guests of the Company. Safety and security is the responsibility of every employee and we rely on you to help us keep our premises secure.

6.18 COMPUTER SECURITY AND COPYING OF SOFTWARE

Software programs purchased and provided by the Company are to be used only for creating, researching, and processing Company-related materials. By using the Company’s hardware, software, and networking systems you assume personal responsibility for their appropriate use and agree to comply with this policy and other applicable Company policies, as well as city, state, and federal laws and regulations.

All software acquired for or on behalf of the Company or developed by Company employees or contract personnel on behalf of the Company is and shall be deemed Company property. It is the policy of the Company to respect all computer software rights and to adhere to the terms of all software licenses to which the Company is a party.

Company users may not duplicate any licensed software or related documentation for use either on Company premises or elsewhere unless the Company is expressly authorized to do so by agreement with the licenser. Unauthorized duplication of software may subject users and/or the Company to both civil and criminal penalties under the United States Copyright Act. To purchase software, users must obtain the approval of their manager.

Users may not duplicate, copy, or give software to any outsiders including clients, contractors, customers, and others. Company users may use software on local area networks or on multiple machines only in accordance with applicable license agreements entered into by the Company.

6.19 THIRD PARTY DISCLOSURES

From time to time, our Company may become involved in news stories or potential or actual legal proceedings of various kinds. When that happens, lawyers, former employees, newspapers, law enforcement agencies, and other outside persons may contact our employees to obtain information about the incident or the actual or potential lawsuit.

If you receive such a contact, you should not discuss the matter with the caller but refer the call to the President or CFO.

6.20 PERSONAL DATA CHANGES

It is your obligation to provide the Company with all of your current contact information, including current mailing address and telephone number. Please inform the Company of any changes to your marital or tax withholding status. Failure to do so may result in loss of benefits or delayed receipt of W-2 and other mailings.

7.0 BENEFITS

7.1 REGULAR FULL-TIME EMPLOYEES

A regular full-time employee is an employee who has completed his or her introductory period and is regularly scheduled to work in excess of 31 hours per week. Unless stated otherwise, all the benefits provided to employees are for regular full-time employees only. This includes vacation, holiday pay, health insurance and other benefits coverage.

Health Insurance and Related Benefits: Certain health insurance and related benefits such as Dental, Vision, Disability, etc. may be provided to regular full-time employees, after completion of three months of continuous employment. These benefit packages are subject to change from time to time, and typically do change at times of annual enrollment periods. For an up-to-date list of all benefits provided, and their respective costs and other specific details, contact Human Resources.

Simple IRA Program: Regular full time employees are eligible to enroll in the Company sponsored Simple IRA program after completion of three months of continuous employment. CREATIO provides a matching program to those desiring to save for retirement. Please contact Human Resources for information on this benefit.

The Company reserves the right to terminate or amend any benefit plans at any time or to require or increase employee premium contributions.

7.2 REGULAR PART-TIME EMPLOYEES

Any employee who works less than 30 hours per week is considered a part-time employee. Part-time employees are not eligible for Company benefits unless specified otherwise in this handbook or in the benefit plan summaries.

7.3 TEMPORARY EMPLOYEES

Temporary employees are hired for a specific period or specific work project. The Company reserves the right to extend the duration of temporary employment where necessary. Temporary employees are not eligible for employee benefits.

7.4 EXEMPT EMPLOYEES

If you are classified as an exempt employee at the time of your hiring, you are not eligible for overtime pay as otherwise required by federal, state, or local laws. If you have a question regarding whether you are an exempt or nonexempt employee, contact Human Resources for clarification.

7.5 CONTINUING EDUCATION POLICY, PROFESSIONAL DEVELOPMENT AND TUITION ASSISTANCE

We believe in the continuing education and professional development of our employees. CREATIO’s philosophy is that by staying on top of trends and changes within our industry it allows us to provide the best possible advice and customer service our clients. CREATIO also believes in providing professional development opportunities to allow each employee to reach his/her highest potential. CREATIO will make every effort to hold in-house training and professional development classes on appropriate subjects and industry trends. These sessions may be taught by Team Leads or others, or may take the form of webinars.

The Company strongly encourages employees to study for and take the exam to become a licensed US Customs Broker. As a special incentive, CREATIO offers a bonus program for those that pass the US Customs Broker Exam and become licensed.

If the Company sends you to a class or training program during normal working hours related to your employment and you are a nonexempt employee, you will be paid training pay for that time. If you are interested in attending an outside class and having the Company pay for your attendance, you are required to provide advance written notice indicating a description of the class, including the subject matter, length, and cost. Depending on the type of training, the Company may reimburse some or all of the fees, including materials expenses, meals, and transportation. If your Team Lead approves of your attendance at a noncompany-sponsored class, you will be reimbursed once you have attended and paid for the class.

7.6 HOLIDAY PAY

CREATIO offers the following paid holidays each year:

New Year’s Day

Memorial Day

Independence Day

Labor Day

Thanksgiving Day

Christmas Day

Two Floating Holidays

When a Company holiday falls on a Saturday, it will be observed the preceding Friday. Holidays falling on a Sunday will be observed the following Monday.

Holiday pay for full-time employees is computed at the straight time rate of eight hours. In no case may an employee receive more than a normal day’s wage for any holiday unless they worked that day.

After six months’ employment full time employees becomes entitled to two additional paid holidays on an annual basis called a “floating holiday.” Out of respect for other religious holidays that employees may wish to observe or to accommodate an employee with special time off needs, this “floating holiday” policy exists. This policy entitles you to take off for one day, at a regular day’s pay (e.g. Rosh Hashanah, Good Friday, your birthday, the day after Thanksgiving, etc.) Floating holidays will not be counted as a vacation or personal day. Unfortunately, not everyone can be granted a floating holiday on the same day, for example the day after Thanksgiving. Due to staffing requirements, including work volume, please inform your supervisor or manager of your plans as early as possible and reasonable accommodations will be made.

7.7 PAID TIME OFF (PTO)

7.16 VACATION POLICY

Employees are encouraged to take full advantage of earned vacation time as a source of rest and renewal during the year.

Vacation is paid to regular full-time employees as follows:

Upon completion of six (6) months of continuous employment, one (1) day is allowed per every two (2) months of completed employment, retroactive to the initial date of employment.

After completion of (6) months, and each calendar year thereafter, beginning January 1: ten (10) days.

After completion of four entire calendar years and all thereafter: fifteen (15) days.

All employees are required to give reasonable notice to their supervisor of their vacation plans. Vacation plans must be approved in advance by your supervisor or manager. You will not be eligible to receive pay instead of vacation time, except with Company permission or upon termination. Any conflict in vacation requests will be decided based on employee seniority and Company needs. You will not accrue vacation during periods when you are not working and taking time off from the company.

Vacation hours are designed to be used in half day or full day increments.

We understand that summer/peak season can be a popular time for vacations. Vacation requests during the Company’s busy peak season (June 15 to September 15) will be handled on a case by case basis. If vacation is planned during this period, you are encouraged to request time off as much in advance as possible. Due to Company needs during this busy time period, a request of more than one week of vacation will typically not be granted. The Company will assess the workload to make certain the appropriate number of people are present. Typically, vacation periods will be staggered to make certain not more than one person is absent at a time.

Maximum Accrual

You may carry over up to one week of unused vacation time from year to year, not to exceed the allowed time per year. Once you reach the maximum allowed vacation time you will not accrue any more vacation time until you have used some vacation. Once you have used some vacation your accrual will resume.

7.8 SICK PAY

The Company allows its regular full-time employees who have completed their introductory ninety-day period five (5) sick days per calendar year. Give your supervisor as much advance notice as possible if you are going to take sick time off. There may be occasions, such as sudden illness, when you cannot notify your supervisor in advance. In those situations, you must inform your supervisor of your circumstances as soon as possible. You may also be requested to provide a certificate of illness to your supervisor.

You may use sick leave benefits for the purpose of dental or doctor visits as well as to care for immediate family members who are sick. Unused sick days may not be converted to a cash payment. You may be required to use available sick leave during family and medical leave, disability leave, or other leave.

Sick time cannot be carried forward to the following year.

7.9 LEAVES OF ABSENCE

A leave of absence (leave) is defined as an unpaid approved absence from work for a specified period of time for medical, parental, military, or other approved reasons. If an employee finds that he she must be out of work for more than three days, he or she should contact the Human Resources department to determine if a leave of absence may be necessary.

Leaves of absence will start on the date of request or date of need. While on leave, an employee must contact the Human Resources department at least every 30 days. Failure to contact HR upon request may result in voluntary termination of employment. Failure to return to work upon the expiration of the leave or refusing an offer of reinstatement for which the employee is qualified will also result in voluntary termination of employment.

Required Documentation

All requests for a leave of absence must be made on a Leave of Absence Request Form for the particular leave (FMLA, disability accommodation, military, pregnancy, other medical leave, personal leave, etc.) and submitted to the immediate supervisor. An employee must provide 30 days’ advance notice when the need for the leave or absence is foreseeable; for instance, if medical treatments or other events are planned or known in advance. If the leave of absence is not foreseeable, the employee must provide notice to his or her immediate supervisor as soon as possible. Medical certifications and/or other documentation supporting the need for the leave may be required.

Job Benefits

For leaves other than approved FMLA leaves, CREATIO will pay its portion of the cost of the employee’s benefits including health, dental, life, and disability insurance benefits while an employee is on leave for the end of the monthly billing cycle at which time a COBRA notification will be issued. Family and Medical Leave Act (FMLA) leaves of absence allow for up to 12 weeks of group health insurance continuation coverage in the same manner as if the employee continued to work. The employee must continue to pay his or her portion of the benefits which may be made by payroll deductions (when applicable) or by check which must be submitted to the Human Resources department each pay period unless other arrangements have been made. If the employee fails to pay his or her portion of the benefits for more than 30 days, the employee’s coverage(s) will be terminated and the employee will be offered COBRA to continue benefits coverage.

While on leave, employees may be required to use any vacation or sick time. (See Paid Time Off/Sick/Vacation Policy)

No benefits will be accrued while an employee is on leave. Except as otherwise provided by law, time spent on a leave of absence, except for military reserve duty, will not be counted as time employed in determining an employee’s eligibility for benefits that accrue on the basis of length of employment.

Return to Work

Upon return to work, the employee may be required to take a fitness for duty exam or otherwise provide medical clearance.

7.10 FAMILY AND MEDICAL LEAVE OF ABSENCE POLICY

The Company complies with the Family and Medical Leave Act of 1993 (FMLA), as amended.

The FMLA requires covered employers to provide up to 12 weeks of unpaid, benefits and job-protected leave to eligible employees for the following reasons:

For incapacity due to pregnancy, prenatal medical care, or child birth;

To care for the employee’s child after birth, or placement for adoption or foster care;

To care for the employee’s spouse, son or daughter, parent, or in certain circumstances care for those in nontraditional family arrangements, who has a serious health condition; or

For a serious health condition that makes the employee unable to perform the employee’s job.

Military Family Leave Entitlements

Eligible employees with a spouse, son, daughter, or parent on active duty or call to covered active duty status may use their 12-week leave entitlement to address certain qualifying exigencies. Qualifying exigencies may include attending certain military events, arranging for alternative childcare, addressing certain financial and legal arrangements, attending certain counseling sessions, and attending post-deployment reintegration briefings.

FMLA also includes a special leave entitlement that permits eligible employees to take up to 26 weeks of leave to care for a covered servicemember during a single 12-month period. A covered servicemember is: 1) 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 on the temporary disability retired list for a serious injury or illness*; or 2) a veteran who was discharged or released under conditions other than dishonorable at any time during the five-year period prior to the first date the eligible employee takes FMLA leave to care for the covered veteran, and who is undergoing medical treatment, recuperation, or therapy for a serious injury or illness.

*The FMLA definition of “serious injury or illness” for current servicemembers and veterans is distinct from the FMLA definition of “serious health condition.”

During FMLA leave, the company will maintain the employee’s group health coverage on the same terms as if the employee had continued to work. Upon return from FMLA leave, most employees will be restored to their original or equivalent positions with equivalent pay, benefits, and other employment terms.

Use of FMLA leave cannot result in the loss of any employment benefit that accrued prior to the start of an employee’s leave.

Eligibility Requirements

Employees are eligible if they have worked for a covered employer for at least one year, for 1,250 hours over the previous 12 months, and if at least 50 employees are employed by the company within 75 miles.

Definition of Serious Health Condition

A serious health condition is an illness, injury, impairment, or physical or mental condition that involves either an overnight stay in a medical care facility, or continuing treatment by a health care provider for a condition that either prevents the employee from performing the functions of the employee’s job, or prevents the qualified family member from participating in school or other daily activities.

Subject to certain conditions, the continuing treatment requirement may be met by a period of incapacity of more than three consecutive calendar days combined with at least two visits to a health care provider or one visit and a regimen of continuing treatment, or incapacity due to pregnancy, or incapacity due to a chronic condition. Other conditions may meet the definition of continuing treatment.

An employee does not need to use this leave entitlement in one block. Leave can be taken intermittently or on a reduced leave schedule when medically necessary. Employees must make reasonable efforts to schedule leave for planned medical treatment so as not to unduly disrupt the company’s operations. Leave due to qualifying exigencies may also be taken on an intermittent basis.

The company may require use of accrued paid leave while taking FMLA leave. In order to use paid leave for FMLA leave, employees must comply with the company’s normal paid leave policies.

Employees must provide 30 days advance notice of the need to take FMLA leave when the need is foreseeable. When 30 days’ notice is not possible, the employee must provide notice as soon as practicable and generally must comply with the company’s normal call-in procedures.

Employees must provide sufficient information so that the company can determine if the leave may qualify for FMLA protection and the anticipated timing and duration of the leave. Sufficient information may include that the employee is unable to perform job functions, the family member is unable to perform daily activities, the need for hospitalization or continuing treatment by a health care provider, or circumstances supporting the need for military family leave. Employees also must inform the employer if the requested leave is for a reason for which FMLA leave was previously taken or certified. Employees will be required to provide a certification and periodic recertification supporting the need for leave.

If you have any questions about FMLA leave, please contact Human Resources.

7.11 MILITARY LEAVE (USERRA)

The company complies with applicable federal and state law regarding military leave and re-employment rights. Unpaid military leave of absence will be granted to members of the uniformed services in accordance with the Uniformed Services Employment and Reemployment Rights Act of 1994 (with amendments) and all applicable state law. Appropriate documentation of the need for the leave is required to be submitted to Human Resources prior to the leave unless military necessity makes this impossible. An employee returning from military leave of absence will be reinstated to his or her previous or similar job in accordance with state and federal law. You must notify your manager of your intent to return to employment based on requirements of the law. For more information regarding status, compensation, benefits and reinstatement upon return from military leave, please contact Human Resources.

7.12 JURY DUTY AND WITNESS LEAVE

If you are summoned for jury duty, please make scheduling arrangements with your supervisor as soon as you receive your summons or subpoena. You will receive up to 5 days per year for paid jury duty leave. You may use vacation pay during the unpaid jury leave.

7.13 VOTING LEAVE

If your work schedule prevents you from voting on Election Day, the Company will allow you a reasonable time off to vote. The time when you can go to vote will be at the discretion of your supervisor, consistent with applicable legal requirements.

7.14 BEREAVEMENT LEAVE

CREATIO recognizes the importance of taking leave on the occasion of a death in the family. Employees are entitled to up to 3 days off with pay for the funeral of an immediate relative (mother, father, sister, brother, spouse, child, or in-law equivalents, grandparent, or grandchild). Pay is based on the regular rate for an eight-hour day. Authorized leave without pay is available for extended funeral matters. Personal leave time may also be taken when necessary. Employees taking bereavement leave must notify Human Resources of their intention to do so. The Company may request documentation to support absences for bereavement leave.

7.15 WORKERS' COMPENSATION INSURANCE

Workers’ compensation is a no-fault system designed to provide benefits to all employees for work related injuries. Workers’ compensation insurance coverage is paid for by the employer and governed by state law. The workers’ compensation system provides for coverage of medical treatment and expenses, occupational disability leave, rehabilitation services, as well as payment for lost wages due to work related injuries. If you are injured on the job, no matter how slightly, you are to report the incident immediately to your supervisor. Consistent with applicable state law, failure to report an injury within a reasonable period of time could jeopardize your claim for benefits.

To receive workers’ compensation benefits, notify your supervisor immediately of your claim. If your injury is the result of an on-the-job accident, you must fill out an accident report. You will be required to submit a medical release before you can return to work.

7.16 UNEMPLOYMENT COMPENSATION INSURANCE

Unemployment compensation insurance is paid for by the Company and provides temporary income for employees who have lost their job under certain circumstances. Your eligibility for unemployment compensation will, in part, be determined by the reasons for your separation from the Company.

7.17 COBRA

COBRA, the Consolidated Omnibus Budget Reconciliation Act, provides the opportunity for employees and their beneficiaries to continue health insurance coverage under the company health plan when a "qualifying event" could result in the loss of eligibility. Qualifying events include resignation, termination of employment, death of an employee, reduction in hours, a leave of absence, divorce or legal separation, entitlement to Medicare, or where a dependent child no longer meets eligibility requirements.

Please contact human resources to learn more about your COBRA rights.

8.0 SAFETY AND LOSS PREVENTION

8.1 GENERAL SAFETY POLICY

It is the responsibility of every employee of the Company to maintain a healthy and safe work environment. Please report all safety hazards and occupational illnesses or injuries to your supervisor immediately and complete an occupational illness or injury form as needed. Failure to follow the Company’s health and safety rules can result in disciplinary action, up to and including termination of employment.

8.2 NONSMOKING POLICY

CREATIO is concerned about the effect that smoking and second hand smoke inhalation can have on its employees and clients. In respect for the health and safety of our employees we maintain a smoke free environment. Smoking in the office, client areas, and restrooms is prohibited.

Those employees who choose to smoke are required to do so outside of 10 feet of any office and only on designated breaks or lunch times.

8.3 POLICY AGAINST VIOLENCE

The safety and security of our employees, residents, tenants, vendors, contractors, and the general public is of essential importance. Threats or acts of violence made by an employee against another person’s life, health, well-being, family, or property will not be tolerated. Any act of intimidation, threat of violence, or act of violence committed against any person on Company property is prohibited. The following definitions apply:

Intimidation: A physical or verbal act toward another person, the result of which causes that person to reasonably fear for his or her safety or the safety of others.

Threat of violence: A physical or verbal act which threatens bodily harm to another person or damage to the property of another.

Act of violence: A physical act, whether or not it causes actual bodily harm to another person or damage to the property of another.

No person shall possess or have control of any firearm, deadly weapon, or prohibited knife, as legally defined, while on Company property, except as required in the lawful course of business or as authorized by law.

The following are prohibited:

Any act or threat of violence made by an employee against another person’s life, health, well-being, family, or property.
Any act or threat of violence, which endangers the safety of employees, residents, tenants, vendors, contractors, or the general public.
Any act or threat of violence made directly or indirectly by words, gestures, symbols, or email.
Use or possession of a weapon on the Company’s premises or on premises managed by the Company.

It is a requirement that employees report to their supervisor or Human Resources, in accordance with this policy, any behavior that compromises the Company’s ability to maintain a safe work environment. All reports will be investigated immediately and kept confidential, except where there is a legitimate need to know.

Employees who violate this policy may be subject to criminal charges as well as discipline up to and including immediate termination of employment.

9.0 TRADE SECRETS AND INVENTIONS

9.1 CONFIDENTIALITY AND NONDISCLOSURE OF TRADE SECRETS

As a condition of employment, Company employees are required to protect the confidentiality of Company trade secrets and confidential information. Employees may come into contact with customer lists, operational procedures, or other confidential information. Access to this information should be limited to a “need to know” basis and should not be used for personal benefit, disclosed, or released without prior authorization from a supervisor.

Any employee who has information that leads them to suspect that an employee or competitor is obtaining the Company’s confidential information is required to inform their supervisor, Human Resources or the President.

Unauthorized disclosure of trade secrets, or other confidential information, may result in the discipline or termination of any employee, as well as subject the employee to civil liability. Employees may not disclose or communicate, in any manner, directly or indirectly, information about the Company, its operations, clientele, or any other information, that relates to the business of the Company, including, but not limited to, the names of its customers or clients, its marketing strategies, operations, or any other information which would be deemed confidential, a trade secret, a customer or client list, or other form of proprietary information of the Company. If you believe you must disclose confidential information, you may do so only after obtaining prior authorization from your supervisor. Any breach of this provision, or of any other confidentiality and nondisclosure obligation, is a material breach of the terms of employment.

10.0 CUSTOMER RELATIONS

10.1 CUSTOMER, CLIENT, AND VISITOR RELATIONS

We strive to provide the best service possible to our customers and clients. Our customers and clients support this business and generate your wages. You are expected to treat every customer, client, or visitor with the utmost respect and courtesy. You should never argue or act in a disrespectful manner towards a visitor or customer. If you are having problems with a customer, client, or visitor, please notify your supervisor immediately. If a customer, client, or visitor voices a suggestion, complaint, or concern regarding our products or services, please inform your supervisor or a member of management. Lastly, please make every effort to be prompt in following up on customer, client, or visitor orders or questions. Positive customer, client, and visitor relations will go a long way to establishing our Company as a leader in its field.

11.0 ACKNOWLEDGMENT OF RECEIPT AND REVIEW

11.1 ACKNOWLEDGMENT OF RECEIPT AND REVIEW

By signing below, I acknowledge that I have received a copy of the Employee Handbook and understand that it is my responsibility to read the Employee Handbook in its entirety. I agree to comply with the rules, policies, and procedures set forth herein, as well as any revisions made to the Employee Handbook in the future. I also understand that if I violate the rules, policies, and procedures set forth herein that I may be subject to discipline, up to and including termination of my employment.

I understand that the Employee Handbook contains information about the employment policies and practices of the Company. I understand that the policies outlined in this Employee Handbook are management guidelines only, which in a developing business will require changes from time to time. I understand that the Company retains the right to make decisions involving employment as needed in order to conduct its work in a manner that is beneficial to the employees and the Company. I understand that this Employee Handbook supersedes and replaces any and all prior Employee Handbooks and any inconsistent verbal or written policy statements.

I understand that except for the policy of at-will employment, which can only be changed by the President of the Company, the Company reserves the right to revise, delete, and add to the provisions of this Employee Handbook at any time without further notice. I understand that no oral statements or representations can change the provisions of this Employee Handbook. I understand that this Employee Handbook is not intended to create contractual obligations with respect to any matters it covers and that the Employee Handbook does not create a contract guaranteeing that I will be employed for any specific time period. I understand nothing in this handbook is created to infringe on any available legal rights.

I understand that this Employee Handbook refers to current benefit plans maintained by the Company and that I must refer to the actual plan documents and summary plan descriptions as these documents are controlling.

If I have questions about the content or interpretation of the Employee Handbook, I will ask my supervisor or Human Resources.

______________________________

Date

_______________________________________________________

Signature of Employee

_______________________________________________________

Print Name

Leave this empty:

Your legal name

Your email address

Please Confirm full name and signature.

Draw Signature
Type In Signature

Draw your signature with your mouse, tablet or smartphone Clear

I agree that I am and I agree this is a legal representation of my signature for all purposes just the same as a pen-and-paper signature

I agree that I am and I understand this is a legal representation of my signature

Adopt & Sign

Timestamp

Audit

February 10, 2021 11:04 am MDT

Employee Handbook Uploaded by Jack Walsh - jack@creatio.org IP 73.229.117.237

WELCOME

1.1 AT-WILL EMPLOYMENT

2.0 INTRODUCTORY LANGUAGE AND POLICIES

2.1 ETHICS CODE

2.2 REVISIONS TO HANDBOOK

3.0 HIRING AND ORIENTATION POLICIES

3.1 EEO STATEMENT AND NONHARASSMENT POLICY

3.2 DISABILITY ACCOMMODATION

3.3 RELIGIOUS ACCOMMODATION

3.4 TRAINING PROGRAM

3.5 EMPLOYMENT AUTHORIZATION VERIFICATION

4.0 WAGE AND HOUR POLICIES

4.1 INTRODUCTION

4.2 PAY PERIOD

4.3 PAYCHECK DEDUCTIONS

4.4 RECORDING TIME

4.5 OVERTIME AUTHORIZATION FOR NONEXEMPT EMPLOYEES

4.6 ATTENDANCE POLICY

4.7 JOB ABANDONMENT

4.8 TRAVEL EXPENSES

4.9 USE OF COMPANY CREDIT CARDS

4.10 REST AND MEAL PERIODS

5.0 PERFORMANCE, DISCIPLINE, LAYOFF, AND TERMINATION

5.1 PERFORMANCE EVALUATION AND DEVELOPMENT PLANNING

5.2 STANDARDS OF CONDUCT

5.3 CRIMINAL ACTIVITY/ARRESTS

5.4 DRUG AND ALCOHOL POLICY

5.5 DISCIPLINARY PROCESS

5.6 PROBLEM-SOLVING PROCEDURE

5.7 OUTSIDE EMPLOYMENT

5.8 EXIT INTERVIEW

5.9 POST-EMPLOYMENT REFERENCE POLICY

6.0 GENERAL POLICIES

6.1 DRIVING RECORD

6.2 USE OF COMPANY VEHICLES

6.3 AUTHORIZATION FOR USE OF PERSONAL VEHICLE

6.4 NOTICE OF GPS MONITORING POLICY OF COMPANY VEHICLES

6.5 PERSONNEL AND MEDICAL RECORDS

6.6 EMPLOYEE PRIVACY AND RIGHT TO INSPECT

6.7 VOICEMAIL, EMAIL, AND INTERNET POLICY

6.8 SOCIAL MEDIA POLICY

6.9 EMPLOYEE SUGGESTIONS/OPEN DOOR POLICY

6.10 COMPANY BULLETIN BOARDS

6.11 NONSOLICITATION/NONDISTRIBUTION POLICY

6.11 CONFLICTS OF INTEREST

6.12 PERSONAL APPEARANCE

6.13 COMPANY SOCIAL EVENTS

6.14 TELEPHONE USE

6.15 COMPANY-PROVIDED CELL PHONE/MOBILE DEVICE POLICY

6.16 PERSONAL CELL PHONE/MOBILE DEVICE USE

6.17 SECURITY

6.18 COMPUTER SECURITY AND COPYING OF SOFTWARE

6.19 THIRD PARTY DISCLOSURES

6.20 PERSONAL DATA CHANGES

7.0 BENEFITS

7.1 REGULAR FULL-TIME EMPLOYEES

7.2 REGULAR PART-TIME EMPLOYEES

7.3 TEMPORARY EMPLOYEES

7.4 EXEMPT EMPLOYEES

7.5 CONTINUING EDUCATION POLICY, PROFESSIONAL DEVELOPMENT AND TUITION ASSISTANCE

7.6 HOLIDAY PAY

7.7 PAID TIME OFF (PTO)

7.8 SICK PAY

7.9 LEAVES OF ABSENCE

7.10 FAMILY AND MEDICAL LEAVE OF ABSENCE POLICY

7.11 MILITARY LEAVE (USERRA)

7.12 JURY DUTY AND WITNESS LEAVE

7.13 VOTING LEAVE

7.14 BEREAVEMENT LEAVE

7.15 WORKERS' COMPENSATION INSURANCE

7.16 UNEMPLOYMENT COMPENSATION INSURANCE

7.17 COBRA

8.0 SAFETY AND LOSS PREVENTION

8.1 GENERAL SAFETY POLICY

8.2 NONSMOKING POLICY

8.3 POLICY AGAINST VIOLENCE

9.0 TRADE SECRETS AND INVENTIONS

9.1 CONFIDENTIALITY AND NONDISCLOSURE OF TRADE SECRETS

10.0 CUSTOMER RELATIONS

10.1 CUSTOMER, CLIENT, AND VISITOR RELATIONS