6. Administrative Policies

6.1 Safety

Maintaining a safe work environment requires the continuous cooperation of all employees. Curtis will take all reasonable steps to assure a safe environment and compliance with federal, state, and local safety regulations. The Company strongly encourages employees to communicate with fellow employees and their supervisor regarding safety issues. Employees should contact their supervisor, the nearest supervisor, and/or call 911 in the event of an accident or emergency.

If an employee is injured on the job, Curtis provides coverage and protection in accordance with the Worker’s Compensation Law. When an injury is sustained while at work, it must be reported immediately to a supervisor, who in turn will notify Human Resources of the incident for proper documentation. The purpose of the accident report is to correct any safety hazards, comply with insurance requirements, and protect employees from future injury. Failure to report accidents is a serious matter, as it may preclude an employee’s coverage under Worker’s Compensation Insurance and result in disciplinary action. Should you become troubled about the safety of your work environment, discuss your concerns with your supervisor or Human Resources department.

In keeping with this commitment, the Company has established an “Injury and Illness Prevention Program” as part of its safety program. The Facilities and Safety Coordinator has been delegated responsibility for administering and implementing our Injury and Illness Prevention Program.

6.2 Use of Curtis Vehicles

Curtis vehicles are available for accomplishing specific tasks associated with Curtis business. Only those employees who possess a valid driver’s license and who have a business need may use Curtis vehicles for business purposes. When using Company vehicles, employees are expected to exercise care and follow all operating instructions, safety standards, and law. Payment of traffic and parking fines is the responsibility of the operator.

Company vehicles may not be used for personal reasons or activities without the express prior written approval from the Executive Director.

A. Driving Licenses and Records – Company and Employee Vehicles

All employees authorized to drive Company or personal vehicles to conduct Company business, must possess a current, valid California driver’s license and a driving record acceptable to the Company.

Any change in license status or driving record must be reported to your supervisor or Human Resources immediately. As examples: traffic citations, moving violations, accidents, suspended licenses, revoked licenses, etc., WHETHER OCCURRING ON OR OFF THE JOB, must be reported to Human Resources immediately.

From time to time, the Company or its insurance carrier will request reports from the Department of Motor Vehicles regarding the license status and driving record of employees whose job responsibilities include driving. In the event that the license status or driving record of any employee becomes unacceptable to the Company or the Company’s insurance carrier, that employee may be restricted from driving, reassigned, suspended, or terminated, all at management’s discretion.

Employees are personally responsible to pay all fines, citations and tickets incurred while on Company business, unless Company reimbursement is required by applicable law.

B. Safe Driving Habits – Company and Employee Vehicles

A valid California driver’s license must be in your possession while operating a vehicle for Company business. It is the responsibility of every employee to drive safely and obey all traffic, vehicle safety, and parking laws or regulations. Drivers must demonstrate safe driving habits and not drive above the speed limit or recklessly.

Employees must follow all cell phone laws. The use of a cellular telephone, smart phone, PDA or any other electronic device while driving on Company-related business is prohibited. Moreover, the use of a cellular telephone, smartphone, PDA or any other electronic device while driving is prohibited if such use is Company-related. If you must make a cellular telephone call or use your email while driving on Company-related business or make/send a Company-related call/email while driving, then you must find a safe place to pull-over and have your conversation or access your email. If you receive a call or email while driving on Company-related business or if the call/email is Company-related, then you must find a safe place to pull-over and have your conversation or respond to the email.

Employees are not permitted, under any circumstances, to operate a Company vehicle, or a personal vehicle for Company business, when any physical or mental impairment causes the employee to be unable to drive safely. This prohibition includes, but is not limited to, circumstances in which the employee is temporarily unable to operate a vehicle safely or legally because of illness, medication, intoxication, fatigue, etc.

C. Safe Vehicle Maintenance

Company Vehicles: The Company takes responsibility for the mechanical and safe condition of Company vehicles. However, any employee noting a mechanical and/or safety problem with any Company vehicle, must notify the Executive Director immediately. If any safety hazard with a vehicle is detected, the vehicle must not be driven until corrected.

D. Vehicle Insurance – Employees’ Vehicles

Employees authorized to drive their vehicles for Company business must maintain adequate personal automobile liability insurance, from a reputable insurance company. From time to time, the Company or its insurance carrier will require proof of employees’ personal insurance. Employees must not drive for Company business without current, valid personal automobile liability insurance.

The Company reimburses employees for the use of their personal vehicles at the federal IRS approved mileage rate. This rate reimburses employees for all costs incurred, including insurance, when using their vehicles for Company business.

E. Accidents and Accident Reporting – Company and Employee Vehicles

In case of emergency or any injury, phone “911”.

All accidents, no matter how minor, must be reported to the Executive Director immediately regardless of who is at fault. Stop and exchange information with the other driver. Do not admit fault to the other driver or the police. Do not drive the vehicle if it is not in safe condition.

Employees are personally responsible to pay the insurance deductible for all damages incurred while driving (whether when driving a Company vehicle or Employee vehicle), unless Company reimbursement is required by applicable law.

6.3 Electronic Communications

This policy highlights the Company's guidelines with regard to the use of the Company's electronic mail, instant message, text message, voice mail, Internet access and computer systems, as well as Company-issued smartphones and other electronic devices (“Electronic Communications”). The policy also describes guidelines with regard to personal computers, electronic devices, and smartphones used at the Company or for Company business. “Electronic communications” include, among other things, messages, images, text data or any other information used in e-mail, instant messages, text messages, voice mail, fax machines, computers, personal digital assistants (including iPhone, iPad or similar devices), telephones, smartphones, Intranet, Internet, back-up storage, information on a memory or flash key or card, jump or zip drive or any other type of internal or external removable storage drives.

All electronic communications on Company systems, including all individual equipment (e.g., stand-alone computer or hand-held device) are covered by this policy. These systems are important assets of the Company and have been installed/provided at substantial expense to facilitate business communications. The Company respects the individual privacy rights of its employees; however, employee privacy does not extend to the employee's work-related conduct or to the use of Company provided equipment or supplies. The Company operates under this policy for several reasons including: (1) to ensure that these systems are used for business purposes; (2) to follow-up on departing employees' work-in-progress; (3) to ensure that the confidentiality of its trade secrets is being preserved; (4) to monitor employee performance; (5) to maintain the systems; and (6) to monitor our customer service and relations with outside businesses. You should be aware of how the following guidelines may affect your privacy in the workplace.

• The Electronic Communications systems belong to the Company and the contents are to be accessible at all times by management for any purpose, even if password protected. The systems may be subject to periodic unannounced inspections, and should be treated like other shared filing systems. Of course, these systems are intended primarily for business use.
• Do not assume that messages and files are confidential. The Company has the capability to access, review, copy and delete any messages sent, received or stored on the systems. (For example, the Company has the capability to access and review e-mails typed on a Company computer even if sent through a private e-mail account. As another example, the Company has the capability to retrieve text messages sent or received on Company-owned phones). The Company reserves the right to access, review, and copy or delete all such messages for any purpose and to disclose them to any party (inside or outside the Company) it deems appropriate. The Company may utilize or override individual passwords or codes. Back-up copies of electronic messages and computer files may be maintained and referenced for business and legal reasons.
• Employees are not permitted to access the electronic communications of other employees or third parties unless directed to do so by Company management. The Company reserves the right to access and review files and messages and to monitor the use of electronic (e-mail and internet) communications in its sole discretion as is necessary to insure that there is no misuse or violation of Company policy or any law. Employees who misuse these communication systems will be subject to discipline up to and including termination.
• Before using any personally-owned computer or electronic device for Company-related business, you must receive approval from your supervisor. If approval is provided, an employee’s personal computer or electronic device is subject to all inspection and Company protection portions of this policy with respect to Company-related information.
• Employees may not use added software or any mechanism available over the Internet in an attempt to permanently delete (or scrub) any file on any Company computer or system, unless authorized in writing by the President of the Company. Employees also may not reformat any hard drive on any device without the written authorization of the President of the Company.

6.3.1 Prohibited Uses of Electronic Communications:

• The Company’s Electronic Communications systems may not be used in any manner that would be discriminatory, harassing or obscene, or for any other purpose which is illegal, against Company policy or not in the best interests of the Company (unless communications are protected by applicable law). Examples of prohibited uses include, among other things, sexually explicit messages, images, cartoons, or jokes; propositions or love letters; ethnic or racial slurs; or any other message or image that may be in violation of Company policies.
• Proprietary business information may not be downloaded, saved, or sent to a personal laptop, personal storage device, or personal email account under any circumstances without advance written approval from a member of management. “Proprietary business information” means confidential and proprietary information related to the Company's trade secrets, business models, business services, sales agreements, pricing information, drawings, designs, blue prints, manufacturing processes, customer lists, inventions, formulas, vendor agreements, strategic business or marketing plans, expansion plans, contracts, non-public financial performance information and other information that derives economic value by being protected from public consumption or competitors may only be used on Company systems. Proprietary business information does not restrict employee rights to discuss their wages, hours or other terms of employment.
• Employees may not e-mail Company confidential information to their own or others’ personal e-mail accounts. Employees also may not download or transmit Company confidential information to any external media (e.g., memory card, flash drive, employee-owned computer, tablet, cloud storage, CD, DVD, etc.)
• Copying, e-mailing, faxing, uploading to a cloud server, or otherwise transferring or transmitting Company documents for any purpose other than to carry out the Company’s business is strictly prohibited. Copying files for personal use, or transferring or transmitting Company files to personal e-mail accounts or personal computers or other data devices is also strictly prohibited as referenced above.

This policy does not apply to any use of the Electronic Communications system that is protected by applicable law, such as lawful information sent to induce or prepare employees for group action, lawful information sent regarding employment and working conditions, lawful complaints about working conditions and information that is not related to the Company and its employees and customers.

In addition to the terms stated above, every new employee will be provided with, and will be required to sign a copy of the Company’s complete “Internet Policy”, “Corporate Information Security Policy” and “Security Awareness Training and Testing” upon their first day of work. Please contact your Human Resources department if you have any questions or concerns about these policies.

6.4 Company Telephone

Company phone lines are for Curtis business use. Employees should limit personal calls.

6.5 Social Media

“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 web site, social networking or affinity web site, web bulletin board or a chat room, whether or not associated or affiliated with the company.

The company recognizes that social media provides opportunities to participate in interactive discussions and share information on particular topics. Employees’ use of social media, however, can pose risks to the company’s confidential information, can expose the company to discrimination and harassment claims, can appear to endorse or promote a competitor of the company and can jeopardize the company’s compliance with business rules and laws.

Through this policy, the company seeks to minimize these business and legal risks and to ensure that all IT resources and communications systems are used appropriately, as explained below. The company therefore expects its employees to adhere to the following guidelines regarding use of social media, whether via company-owned accounts or personal accounts.

6.5.1 General Guidelines for Social Media

Social media should never be used in a way that violates any of the Company’s policies or any other obligations that you may have to the company or third parties. For example:

A. Follow Curtis Principles

Public communication concerning the Company must not violate any guidelines set forth in this Handbook, whether or not you specifically identify yourself as an employee of the Company. The same principles and guidelines that apply to Company employees in general apply to your activities online.

B. Policies Prohibiting Discrimination, Harassment and Violence

Employees may not use social media to engage in harassing or discriminatory conduct in violation of the Company’s policies or to threaten violence. Do not post or send anything through social media that includes racial, sexist or ethnic slurs or any other discriminatory comments or threats of violence. Small missteps in social media can create big problems for the Company.

C. Intellectual Property Laws

Employees must obtain appropriate permission to use a third party’s copyrights, trademarks, service marks, or other intellectual property. Remember, just because you may have found a photo or an article on the Internet, it does not mean that that material is in the public domain and available for use without permission.

D. Treat Confidential Information Confidentially

Do not disclose any of the Confidential Information (defined above in the Agreement to Maintain Company Information Confidential) of the company or its vendors and customers.

E. Use Good Judgment

Social media posts can often be created and posted quickly. You should treat social media posts seriously and ensure that you do not say anything in social media that you would not be happy to see in any of the company’s other communications. Whether in or outside of the workplace, remember that you are responsible for all content that you post or send.

F. The Company’s Social Media Sites

Employees may not create an official company presence on any social media site or create a company-sponsored site, unless you receive approval from the company. Please be aware that the company retains the absolute right (but not the obligation) to delete or modify any content on its social media accounts that it deems inappropriate at its sole discretion. Further, the company has the right to require any employee involved in posting any such content to stop posting immediately.

G. Personal Social Media Sites

As noted above, if you discuss, endorse, or praise the company’s products on a private social media account, please be sure to disclose your relationship with the company, particularly when your connection with the company would not otherwise be clear to your audience. Such disclosure may be made in plain language within the text of your post or be in the form of an acceptable hashtag: #employee.

If you identify yourself as a Curtis employee or regularly or substantively discuss Curtis publicly, you should make it clear that the views expressed in the blog are yours alone and do not necessarily represent the views of your employer. Transparency is key.

Personal social media accounts must not be used for internal business-related communications between fellow employees or company-contracted influencers engaged to post on the Company’s behalf.

H. Employee Rights

Nothing in this policy is intended to preclude or dissuade employees from: (a) reporting possible or suspected violations of law or regulation to any governmental agency or entity, cooperating with any such agency in an investigation, or making other legally protected disclosures; or (b) engaging in any other activity protected by federal, state or local law.

Failure to follow these guidelines may result in disciplinary action, up to and including discharge, to the maximum extent permitted by applicable law. Employees should keep in mind that they may be held legally responsible for any content published on the Internet. Employees should also keep in mind that even if they write anonymously or under a pseudonym, their identity can still be revealed.

If you have questions or need further guidance about the Company’s social media policy, please contact Human Resources.

6.6 Protection of Social Security Numbers and Other Personal Information

In compliance with state law, no employee may: (1) publicly post or display an employee’s social security number; (2) visibly print a social security number on any identification badge or card, including any time card; (3) place a social security number in files with unrestricted access; or (4) communicate an employee’s “personally identifying information” to the general public. For purposes of this policy, “personally identifying information” means an employee’s social security number, home address or telephone number, personal electronic mail address, internet identification name or password, parent’s surname prior to marriage, or drivers’ license number.

6.7 Travel & Expense Policy Statement

If you travel on official Curtis business and your expenses are authorized, you will be reimbursed for expenses in accordance with the Travel & Expense policy. This policy outlines the policies, procedures, and responsibilities related to Curtis travel. Travel costs are generally allowable when they are directly attributed to specific work on a Company event or project. Employees should exercise the same care in expending Curtis funds as they would exercise with their own money.

For additional information on the Travel & Expense policy, please contact Human Resources.

6.8 Resignation

A voluntary separation from Curtis is generally considered a resignation and is initiated by the employee. When an employee decides to leave for any reason, their supervisor and the Human Resources Department would like the opportunity to discuss the resignation before final action is taken. The Company requests that you provide two weeks advanced written notice of your resignation. The Company retains the discretion to advance the employee’s separation date.

6.9 Exit Interview

Human Resources is responsible for scheduling an exit interview with a terminating employee by the employee’s last day of employment and for arranging the return of Company property including:

• Company keys
• Company issued credit cards
• Company manuals
• System Passwords
• Any additional Company-owned or issued property

Human Resources will provide departing employees with information concerning their benefits.

6.9.1 Final Paycheck

If Curtis terminates an employee, all wages (including accrued but unused PTO) are due and payable, in accordance with applicable law.