CONDUCT AND BEHAVIOR

CONDUCT AND BEHAVIOR

Orderly and efficient operation of the Company requires that employees maintain proper standards of conduct and observe certain procedures. These guidelines are provided for informational purposes only and are not intended to be all-inclusive. The Company expects each employee to act in a professional, mature, and responsible manner at all times. Employees who fail to adhere to the Company’s General Conduct Guidelines are subject to disciplinary action, up to and including termination.

Listed below are some actions and / or conduct that are considered to be inappropriate and will not be tolerated at any time on the part of any employee.

1. Negligence, carelessness or inconsiderate treatment of clients and/or their matters/files.
2. Obtaining unauthorized confidential information pertaining to clients or employees.
3. Taking or giving bribes of any nature, or anything of value, as an inducement to obtain special treatment, to provide confidential information or to obtain a position. Acceptance of any gratuities or gifts must be reported to a supervisor or manager.
4. Illegal gambling on Company premises.
5. Insubordination or refusing to follow instructions from a supervisor or manager; refusal or unwillingness to accept a job assignment or to perform job requirements.
6. Working under the influence of illegal drugs.
7. Possession, distribution, sale, transfer or use of illegal drugs in the workplace, while on duty or while operating employer-owned vehicles or equipment.
8. Theft or inappropriate removal or possession of Company property or the property of a fellow employee.
9. Unauthorized disclosure of the Company’s proprietary or confidential information.
10. Willfully or carelessly damaging, defacing or mishandling property of a customer, the Company or other employees.
11. Possession of weapons or dangerous materials, such as explosives or firearms, in the workplace.
12. Fighting or threatening violence in the workplace.
13. Sexual or other harassment.
14. Using excessively abusive, threatening or obscene language.8
15. Using intimidation tactics and making threats.
16. Sabotaging another's work.
17. Making malicious, false, and harmful statements about others.
18. Publicly disclosing another’s private information.
19. Failure to comply with any Company policies or procedures, including but not limited to those contained in this Employee Handbook.
20. Falsifying documents.

WORK ASSIGNMENTS

In addition to specific duties that may accompany an individual’s job responsibilities, each job also includes "and other assigned duties." From time to time, employees may be required to perform duties or tasks of a fellow employee. Employees will be compensated at their regular rate of pay while performing other assigned duties on a temporary basis.

NONDISCRIMINATION, HARASSMENT, BULLYING, AND RETALIATION

The Company is committed to a work environment in which all individuals are treated with respect and dignity. Each individual has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore, The Company expects that all relationships among persons in the office will be business-like and free of explicit bias, prejudice, and harassment.

The Company has developed this policy to ensure that all its employees can work in an environment free from discrimination, harassment, bullying and retaliation. The Company will make every reasonable effort to ensure that all concerned are familiar with these policies and are aware that any complaint in violation of such policies will be investigated and resolved appropriately. Violations of this policy may result in disciplinary action up to and including termination.

RETALIATION

The Company encourages good faith reporting of all perceived incidents of discrimination or harassment. It is the policy of The Company to promptly and thoroughly investigate such reports. The Company prohibits retaliation against any individual who reports discrimination, harassment, bullying or participates in an investigation of such reports.

SEXUAL HARASSMENT

Sexual harassment constitutes discrimination and is illegal under federal, state and local laws. For the purposes of this policy, “sexual harassment” is defined, as in the Equal Employment Opportunity Commission Guidelines, as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when, for example: a) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment, b) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.

Title VII of the Civil Rights Act of 1964 recognizes two types of sexual harassment: a) quid pro quo and b) hostile work environment. Sexual harassment may include a range of subtle and not-so-subtle behaviors and may involve individuals of the same or different gender. Depending on the circumstances, these behaviors may include unwanted sexual advances or requests for sexual favors; sexual jokes and innuendo; verbal abuse of a sexual nature; commentary about an individual’s body, sexual prowess or sexual deficiencies; leering, whistling or touching; insulting or obscene comments or gestures; display in the workplace of sexually suggestive objects or pictures; and other physical, verbal or visual conduct of a sexual nature.

HARASSMENT

Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal, written or physical conduct that denigrates or shows hostility or aversion toward an individual because of his or her race, color, religion, sex, sexual orientation, gender identity or expression, national origin, age, disability, marital status, citizenship, genetic information, or any other characteristic protected by law, or that of his or her relatives, friends or associates, and that: a) has the purpose or effect of creating an intimidating, hostile or offensive work environment, b) has the purpose or effect of unreasonably interfering with an individual’s work performance, or c) otherwise adversely affects an individual’s employment opportunities.

Harassing conduct includes epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion toward an individual or group that is placed on walls or elsewhere on the employer’s premises or circulated in the workplace, on Company time or using Company equipment by e-mail, phone (including voice messages), text messages, social networking sites or other means.

ANTI-BULLYING

The Company believes all employees should be able to work in an environment free of bullying. Workplace bullying includes repeated, unreasonable actions of individuals (or a group) directed towards an employee (or a group of employees), which are intended to intimidate, degrade, humiliate or undermine; or which create a risk to the health or safety of the employee(s). Some examples of workplace bullying include repeated acts such as unwarranted or invalid criticism, blame without factual justification, being treated differently than the rest of the employees in a work group, being the target of cussing or disrespectful language, exclusion or social isolation, being the target of shouting or other behavior intended to humiliate the employee, excessive “prank” jokes or teasing of an employee.

INDIVIDUALS AND COVERED CONDUCT

These policies apply to all applicants and employees, whether related to conduct engaged in by fellow employees or by someone not directly connected to The Company (e.g., an outside vendor, consultant or customer). Conduct prohibited by these policies is unacceptable in the workplace and in any work- related setting outside the workplace, such as during business trips, business meetings and business- related social events.

REPORTING AN INCIDENT OF HARASSMENT, DISCRIMINATION, OR RETALIATION

The Company encourages good faith reporting of all perceived incidents of discrimination, harassment, bullying or retaliation, regardless of the offender’s identity or position. Individuals who believe that they have been the victim of such conduct should discuss their concerns with their immediate supervisor and/or Human Resources. See the complaint procedure described below.

In addition, The Company encourages individuals who believe they are being subjected to such conduct to promptly advise the offender that his or her behavior is unwelcome and to request that it be discontinued. Often this action alone will resolve the problem. The Company recognizes, however, that an individual may prefer to pursue the matter through complaint procedures. False and/or malicious complaints of harassment, discrimination or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) may be the subject to disciplinary action up to and including termination.

COMPLAINT PROCUEDURE

Individuals who believe they have been the victims of conduct prohibited by this policy or believe they have witnessed such conduct should discuss their concerns with their immediate supervisor and/or Human Resources.

The Company encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken before relationships become irreparably strained. Therefore, while no fixed reporting period has been established, early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment.

Any reported allegations of discrimination, harassment, bullying or retaliation will be investigated promptly. 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. The Company will maintain as much confidentiality as possible throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action.

BUSINESS GIFTS

The Company wishes to avoid the appearance of impropriety in the acceptance of gifts from business contacts or clients. It is the express policy of the Company that employees are prohibited from, either directly or indirectly, asking, demanding, exacting, soliciting, or seeking, anything of value for oneself or for any other person or entity.

It is the express policy of the Company that employees are prohibited from, either directly or indirectly, accepting, receiving, or agreeing to receive anything of value for oneself or for any other person or entity (other than employee pay checks from the Company) for or in connection with any transaction or business of the Company that has a value of $50 or more. If an employee is promised, offered, or given anything of value from any member, perspective member, customer, or perspective customer for or in connection with any transaction or business of the Company, employees are to advise their supervisor or manager at once.

TRAVEL AND ENTERTAINMENT

It is the Company’s policy to reimburse employees for reasonable travel and entertainment expenses that are directly connected with or pertain to the transaction of Company business. Such expenses need to be properly documented and reported. While employees are expected to neither gain or lose financially when traveling on Company business, employees should be prudent regarding expenses and must comply with the Company’s Travel and Entertainment policy. Both employees and their managers are responsible for ensuring compliance with this policy. Failure to comply with the policy will result in denial of reimbursement for claimed expenses and/or other disciplinary action up to and including termination of employment.

CONFIDENTIALITY / CONFLICT OF INTEREST

All employees are expected to meet the conditions outlined in the Agreement of Non-Disclosure, Non-Competition and Non-Solicitation.