2. Employment Policies

2.1 Ethics at Work

Curtis is committed to the highest ethical and professional standards and fosters a culture of integrity and accountability. We promote the highest standards in supplier relationships, product development, controllership, customer service, and all employment related practices. We practice these commitments by supporting our employees’ families, our local community, and the environment we all live in. It is the responsibility of each employee within the Company to conduct himself or herself in a manner that will reflect the Company’s commitment of acting with the highest ethical and professional standards in every aspect of the Company’s operations.

At Curtis, we are all leaders - responsible not only for our own actions, but for fostering a culture in which compliance with Curtis policy and applicable law is at the core of business-specific activities. It is expected that employees will act with absolute integrity in their daily activities and decisions.

Compliance with this policy of business ethics and conduct is the responsibility of every employee. Disregarding or failing to comply with this standard of business ethics and conduct can lead to disciplinary action, up to and including termination of employment.

2.2 Curtis 10 Points

1. Our people are our most important resource.

2. Our customers are the source of our well-being; every person in the Company is responsible

for exceeding customer expectations.

3. Our products must embody the best technology that is available, while meeting the needs

of our markets.

4. We strive to design and manufacture only one level of quality - the highest.

5. Each person in the Company is responsible for its progress, and each person must share in its success.

6. As a global company, we recognize that strength comes from the diversity of our culture.

7. We believe in a work environment which encourages and permits each person a sense of his/her own worth.

8. Relations with colleagues, with customers, and with vendors must be conducted with integrity and fairness.

9. Creativity in our engineering and in all aspects of our activities is the most essential ingredient of our progress.

10. Curtis companies are citizens of the larger community and we have a responsibility to contribute to its well-being and progress.

2.3 Reporting a Concern

It is the responsibility of each Curtis employee to conduct himself or herself in a manner that will reflect the Company’s commitment to the highest ethical and professional standards. Therefore, the Company has established the following monitoring system which is designed to ensure absolute compliance with our policy of business ethics and conduct.

Questions or concerns about what is proper conduct for you or anyone else should be promptly raised with your manager and/or the Human Resources department, or personally or anonymously . Your manager and/or Human Resources department will ensure employees’ concerns about appropriate conduct are promptly investigated with care and respect. Do not allow anything such as not “making the numbers,” competitive instincts or even a direct order from a supervisor compromise your commitment to integrity. Information received will be treated confidentially to the extent practicable and in no event will any retributive or retaliatory action be taken against any employee who discloses information in good faith.

2.4 Conflict of Interest

Curtis expects its employees to conduct business according to the highest ethical standards. Employees are expected to devote their efforts to the interests of the Company. Business dealings that create or appear to create a conflict between the interests of the Company and an employee are unacceptable. Curtis recognizes the right of employees to engage in activities outside of their employment which are of a private nature and unrelated to our business. However, a potential or actual conflict of interest occurs whenever an employee is in a position to influence a business decision that may result in a personal gain for the employee or an immediate family member (i.e., spouse, registered domestic partner, mother, father, sister, brother, stepmother, stepfather, stepsister, stepbrother, stepchild, niece, nephew, cousin, uncle, aunt, grandparent, grandchild and in-laws) or friends or acquaintances as a result of the Company’s business dealings. The employee must disclose any possible conflicts so that the Company may assess and prevent potential conflicts of interest from arising.

Although it is not possible to specify every action that might create a conflict of interest, this policy sets forth those which most frequently present problems. If an employee has any questions whether an action or proposed course of conduct would create a conflict of interest, they should immediately contact the Human Resources department to obtain advice on the issue.

A violation of this policy will result in immediate and appropriate discipline, up to and including termination of employment.

2.5 Corporate Gifts

Curtis Instruments has the following corporate policy for personnel regarding receipt of gifts or other considerations from vendors:

It is the responsibility and duty of anyone purchasing goods or services for Curtis to maintain an independent relationship with the providers of these goods and services, so that negotiations for obtaining the best possible pricing, quality and service are never influenced by the receipt of gifts or other considerations.

In general, Curtis Instruments, Inc. personnel are not permitted to receive cash, gifts, travel costs, vacations or outings, meals or other considerations from those with whom the Company is conducting business.

Promotional material with a value less than $25.00 such as a coffee mug, pen, tee shirt, tie, calendar, calculator, etc. are permitted as long as they are clearly marked with the logo of the company making the gift. Gifts of food, with the exception of liquor, are acceptable as long as they are shared with the general employee population or given to local food pantries.

All other gifts are prohibited and should either be declined, or if this is not possible due to extenuating circumstances, the gift should be reported to the next level of management and returned with a letter of explanation; destroyed; or given to charity.

Travel costs including transportation, lodging and meals are the responsibility of Curtis and offers to pay for these by suppliers should be declined. If the supplier provides accommodations at a supplier-owned facility, the employee should report this to their supervisor who must request that the Accounting department send payment to the supplier. This includes non-work related extensions of business travel arrangements.

Attendance at the invitation of a supplier to a holiday party, open hours, or other supplier-sponsored event is permitted as long as it is reported to your supervisor and approved in advance.

When dining out with a supplier, Curtis personnel should pay for their share of the meal. If the supplier provides a meal during a meeting this can be accepted. In cases where meetings are taking place frequently, Curtis and the supplier are expected to take turns with the cost of the meals. Taking meals at a supplier’s home is generally not acceptable.

2.6 Relationships with Public Officials

When dealing with public officials, employees must avoid any activity that is, or is likely to be perceived as, illegal or unethical, or that reflects favoritism or undue influence. The appearance of impropriety is as damaging to our Company as an actual misdeed.

Employees must exercise caution to prevent relationships and dealings with public officials from becoming subject to question.

2.7 Company Information and Property

The protection of Curtis business information, property and all other Company assets is vital to the interests and success of Curtis. Accordingly, no Curtis-related information or property, including without limitation, documents, files, records, computer files, equipment, office supplies or similar materials (except in the ordinary course of performing duties on behalf of Curtis) may be removed from the Company’s premises.

In addition, when an employee leaves Curtis, the employee must return to the Company all Curtis-related information and property, including without limitation, documents, files, records, manuals, information stored on a personal computer or on any removable storage drives, office supplies, and equipment.

2.8 Agreement to Maintain Company Information Confidential

In the course of your work it is likely that you will have access to information and material that the Company considers to be proprietary and confidential and highly valuable to the Company.

“Confidential Information” includes non-public, proprietary information relating to the company’s trade secrets, business models, business services, sales agreements, pricing information, drawings, designs, blue prints, manufacturing processes, inventions, formulas, vendor agreements, strategic business or marketing plans, expansion plans, contracts, non- public financial performance information, customer databases and other lists and databases of actual and potential customers, non-public information of the company’s customers that has been provided to the company in confidence, whether in written form, oral, recorded, electronic or other medium, and other information that derives economic value by being protected. Confidential Information does not include information which: (1) is or becomes generally available to the public other than as a result of your direct or indirect unauthorized disclosure, or the disclosure of another in violation of any existing confidentiality obligation; (2) becomes available from a third party source which is authorized to disclose it to you and such disclosure is not in breach of any existing confidentiality obligations; or (3) was known to you prior to its disclosure to you by the company.

In addition, your employment activities may relate to, and contribute to, the development and/or manufacture of various inventions, discoveries or improvements with respect to Curtis products. You are advised that ownership of such inventions, discoveries and improvements shall at all times belong to the Company.

Confidential Information does not include information pertaining to the terms and conditions of an employee’s employment, including wages. Nothing in this policy or in this Handbook 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.

Additionally, notwithstanding any other provision of this policy, pursuant to the Economic Espionage Act of 1996, as amended by the Defend Trade Secrets Act of 2016, an employee will not be held criminally or civilly liable under any federal or state trade secret law for any disclosure of a trade secret that: (i) is made in confidence to a federal, state, or local government official, either directly or indirectly, or to an attorney, and solely for the purpose of reporting or investigating a suspected violation of law; or (ii) is made in a complaint or other document filed in a lawsuit or other proceeding, if such filing is made under seal. If an employee files a lawsuit for alleged retaliation by the Company for reporting a suspected violation of law, the employee may disclose the Company’s trade secrets to his or her attorney and use the trade secret information in the court proceeding if the employee: (i) files any document containing the trade secret under seal; and (ii) does not disclose the trade secret, except pursuant to court order.

All employees will be given upon their first day of work a copy of the “Proprietary Information and Inventions Policy” for review and signature of agreement to the terms described within. Any questions regarding the content described, please contact a member of your HR department.

2.9 Employment Eligibility

In accordance with the Immigration Reform and Control Act, Curtis is committed to employing only individuals who are authorized to work in the United States.

All new employees are required to complete an Employment Eligibility Verification form (form I-9) and produce documents establishing identity and authorization to work no later than the third day after starting employment.

If an employee is authorized to work in this country for a limited time period, the individual will be required to submit proof of renewed employment eligibility no later than the day on which the current work authorization expires in order to remain employed by the company.

2.10 Minors

A “Permit to Employ” is required for minors under 18 years of age who are not high school graduates. A permit can be obtained from the minor’s junior high or high school and is issued by the superintendent or the superintendent’s authorized representative of the school district in which the minor resides.

2.11 Equal Employment Opportunity

Curtis maintains a firm commitment to equal employment opportunity and affirmative action. To ensure that this commitment is carried out in practice, Curtis shall:

• Administer all personnel actions including, but not limited to, recruiting, hiring, training, compensating, providing benefits, promoting, laying off, termination, recalling, and all other terms and conditions of employment without regard to race, color, marital status, registered domestic partner status, sexual orientation, religion, national origin, ethnicity, ancestry, age (over 40), sex/gender (including gender identity, gender expression, pregnancy, child-birth and related conditions), physical disability, mental disability, medical condition, genetic characteristics/information, uniformed service member or veteran status, status as a victim of domestic violence, sexual violence, or stalking, or any other characteristic protected by law, in a fair and equitable manner. Actions shall also not be influenced by a perception that an individual falls within any of these categories or is associated with someone who falls within any of these categories. This policy applies to every aspect of employment, including, but not limited to: hiring, advancement, transfer, demotion, lay-off, termination, compensation, benefits, training and working conditions.
• Provide a work environment that is free of unlawful harassment, including sexual harassment, intimidation or coercion for all employees.
• Seek out and employ disabled veterans, disabled persons, and veterans of the Vietnam era; and provide all disabled employees with reasonable accommodations.
• If you have any questions or concerns, please let your supervisor, a manager, or Human Resources know.
• Any individual at any time, even after separation from employment, who feels this policy has been violated, should immediately contact his/her immediate supervisor or the Human Resources department. Employees can raise concerns and make reports without fear of reprisal. Anyone found to be engaging in any violation of this policy will be subject to disciplinary action, up to and including suspension without pay and/or termination of employment.

2.12 Disability, Pregnancy, and Lactation Accommodation

In furtherance of our society’s commitment to end discrimination against qualified disabled individuals, it is Curtis’ policy that no program or activity administered by the Company shall exclude from participation, deny benefits to or subject to discrimination any individual by reason of their disability as defined under state and federal laws.

Curtis provides accommodation to the disabled to the full extent required by law. Requests for Accommodation should be made in writing to Human Resources. Curtis may require medical certification of both the disability and the need for accommodation. Keep in mind that Curtis can only seek to accommodate the known physical or mental limitations of an otherwise qualified disabled individual. Therefore, it is your responsibility to come forward if you are in need of an accommodation. We further recognize that employees with life-threatening illnesses, including but not limited to cancer, heart disease and AIDS, may wish to continue engaging in as many of their normal pursuits as their condition allows, including work. As long as these employees are able to meet acceptable performance standards with or without reasonable accommodation, and medical evidence indicates that their working does not present a significant threat (as defined by law) to themselves or others, they will be permitted to do so.

Curtis may refuse to adopt an accommodation for reasons including, but not limited to, the following:

• the accommodation does not enable the disabled employee to sufficiently perform the “essential functions” of the job position;
• the accommodation poses a significant and imminent risk of substantial harm to the employee or others;
• the accommodation requires that the Company violate safety laws, rules, regulations, or orders under the California Occupational Safety and Health Act or other state or federal laws; and
• the accommodation otherwise creates an undue hardship on the Company.

Also, Curtis will, upon the employee’s request, and on the advice of her health care provider, grant requests for reasonable accommodation (including, without limitation requests for transfer to less strenuous positions) for pregnancy, childbirth or related medical conditions. Curtis may require a doctor’s certification of the condition and need for accommodation.

Further, Curtis complies with all applicable law pertaining to lactation accommodation.

Curtis will not retaliate or otherwise discriminate against an individual for requesting a reasonable accommodation relating to disability, pregnancy or lactation, regardless of whether the request is granted.

Finally, Curtis is committed to not discriminating against any employee or applicant because they are related to or associated with a person with a disability.

2.13 Policy Prohibiting Unlawful Harassment and Retaliation

Curtis is committed to providing a work environment free of unlawful harassment. We do not take this commitment lightly. In keeping with this objective, Curtis maintains a strict policy prohibiting unlawful harassment, including harassment based on any of the following categories: race, color, national origin, ancestry, sex/gender (including gender identity, gender expression, pregnancy, childbirth, and related medical conditions), sexual orientation, age (40 and over), religion/religious creed (including religious dress and grooming practices), physical or mental disability, medical condition, genetic characteristics/information, marital status, registered domestic partner status, military and veteran status, or any other status protected by applicable state or federal law, or local ordinance. Employees, applicants and unpaid interns are also protected if they associate with a person who is, or is perceived to be, in one of those classifications. All such harassment is prohibited.

The Company's policy prohibits all employees (including co-workers, supervisors and managers) from engaging in harassment whether directed toward other employees or non-employees with whom the Company has a business, service or professional relationship (including unpaid interns, volunteers, and persons providing services pursuant to a contract). Similarly, all non-employees are prohibited from engaging in harassment at the Company. Employees who engage in unlawful harassment may be held personally liable for their conduct.

2.13.1 Prohibited Harassment

Prohibited behaviors include, but are not limited to, the following:

• Verbal conduct; e.g., suggestive, insulting or derogatory comments, epithets, innuendoes, sounds, jokes, teasing or slurs based on any of the above categories, and sexual propositions or threats.
• Physical conduct; e.g., assault, impeding or blocking movement, or any unwanted physical contact or interference with normal work or movement, including touching, pinching, or brushing the body, when directed at an individual because of any of the above categories.
• Use of computers and any other electronic device, including the Internet and the email system, to transmit, communicate or receive sexually suggestive, pornographic, or sexually explicit pictures, messages or materials.
• Visual conduct; e.g., derogatory posters, cartoons, graffiti, e-mails, blog or social media website postings, suggestive objects, pictures, letters or drawings; also such actions as leering, whistling or obscene gestures based on any of the above categories.
• Unwanted sexual advances; threats or demands to submit to sexual requests as a condition of continued employment, or to avoid some other loss, and offers of employment or some other contract benefits in return for sexual favors.
• Retaliation for having reported or threatened to report harassment.

In particular, sexual harassment is defined as any unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature which (1) has been made either explicitly or implicitly a term or condition of an individual's employment (or other contract or internship relationship), (2) is used as a basis for employment (or other contract or internship) decisions such as promotions and benefits affecting such individual, or (3) substantially interferes with an individual's work (or contract or internship) performance or creates an intimidating, hostile, or offensive working environment.

In addition, conduct based on any of the categories listed above, or any other characteristic protected by law, is not appropriate for the workplace and is prohibited, regardless of whether an individual makes a complaint of prohibited behaviors.

The Company encourages applicants, employees, unpaid interns and non-employees to report any incidents of behaviors forbidden by this policy immediately so that complaints can be quickly and fairly resolved. (Please refer to the "Complaint Procedure" within this Policy, below.)

All employees will be provided with harassment prevention training in compliance with the law.

2.13.2 No Retaliation

The Company will not retaliate against any employee, applicant, or unpaid intern for making a complaint of harassment, discrimination, or retaliation or for participating in any harassment, discrimination or retaliation investigation, proceeding or hearing. Any employee, applicant, or unpaid intern who believes they have been retaliated against should immediately notify their supervisor, a manager, or Human Resources so that a fair, impartial, timely and thorough internal investigation can be conducted. Supervisors must refer all complaints of retaliation to their supervisor or Human Resources. If the Company reasonably concludes, after investigation, that a violation of this no-retaliation policy has occurred, effective remedial action will be taken, up to and including termination of employment.

2.13.3 Complaint Procedure

Any employee, applicant, or unpaid intern who believes they have been subjected to or witnessed prohibited conduct in violation of this Policy should immediately report the facts of the incident or incidents, the names of the individuals involved, and the names of any witnesses to their supervisor (if not the wrongdoer), a manager, or Human Resources. Supervisors must immediately report any complaint they receive from an employee, applicant, unpaid intern or non-employee to their immediate supervisor or Human Resources for follow-up.

After a report is received, qualified personnel will conduct a fair, impartial, timely and thorough internal investigation, given the individual circumstances of the complaint. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge. Confidentiality will be maintained throughout the investigation process to the extent practicable, i.e., to the extent consistent with adequate investigation and appropriate corrective action.

If the Company concludes, after investigation, that a violation of this policy has occurred, effective remedial action will be taken in accordance with the circumstances involved. Any supervisor, employee or agent of the company who has been found by the Company to have violated this policy will be subject to discipline and/or other sanctions. Discipline may range from a warning up to and including termination (even for a first offense). Non-employees may be warned and could lose their business, service or professional relationship with the Company.

The Company will notify the complaining individual in a timely manner of the outcome of the investigation and any action taken to correct the situation. The Company encourages employees, applicants, unpaid interns and non-employees to report any incidents of behaviors forbidden by this policy immediately so that complaints can be quickly and fairly resolved.

If the internal investigation does not remedy the illegal discrimination, harassment or retaliation to the employee's satisfaction, the employee may file a charge with the local office of the Department of Fair Employment and Housing (DFEH) or the Equal Employment Opportunity Commission (EEOC). Remedies available include back pay and reinstatement, as well as civil penalties. The law prohibits any employer from retaliating against any employee, applicant or unpaid intern for filing a charge with the DFEH or EEOC or for cooperating in any manner with the DFEH or EEOC in its investigation of the charge. Contact information for the DFEH and EEOC may be found on the Internet or at the number listed in your local telephone directory.

If you have any questions concerning this policy, please feel free to contact Human Resources.

2.14 Workplace Violence Policy Statement

Curtis is committed to providing a safe, violence-free workplace and strictly prohibits employees, consultants, customers, visitors, or anyone else on Company premises or engaging in a Company- related activity from behaving in a violent or threatening manner. As part of this policy, Curtis seeks to prevent workplace violence before it occurs.

Workplace violence includes:

• Threatening or violent behavior, such as intimidation of or attempts to instill fear in others.
• Theft, sabotage or defacing of Company or employee property.
• With the exception of security personnel, bringing weapons or firearms of any kind on Company premises, in Company parking lots, while conducting Company business, or participating in Company-sponsored events.

If any employee observes or becomes aware of such actions or behavior by an employee, customer, consultant, visitor, or anyone else, they should notify Human Resources immediately. In case of emergency, dial “911”.

Further, an employee should notify Human Resources if any restraining order is in effect, or if a potentially violent non-work-related situation exists that could result in violence in the workplace.

All reports of workplace violence will be taken seriously and will be investigated promptly and thoroughly. In appropriate circumstances, Curtis will inform the reporting individual of the results of the investigation. To the extent possible, Curtis will maintain the confidentiality of the reporting employee and of the investigation but may need to disclose results in appropriate circumstances in order to protect individual safety. Curtis will not tolerate retaliation against any employee who reports workplace violence in good faith.

If Curtis determines that workplace violence has occurred, Curtis will take appropriate corrective action and will impose discipline upon offending employees. The appropriate discipline will depend on the particular facts but may include written or oral warnings, probation, reassignment of responsibilities, suspension without pay, and/or termination. If the violent behavior is that of a non-employee, Curtis will take appropriate corrective action in an attempt to ensure that such behavior is not repeated.

2.15 Open Door Policy

Direct and open communication is fundamental to Curtis’ culture. Curtis makes an ongoing effort to treat its employees fairly and considerately. Good communication means that a healthy environment of mutual trust and respect exists in which employees and managers can comfortably discuss work issues or employment concerns. However, in any large group of employees, disagreements and misunderstandings do happen and dissatisfaction can occur. Curtis wants to know about these problems when they first occur so that they can be resolved as soon as possible. Curtis’ open door policy encourages open communication, feedback, and discussion about matters of importance to an employee. This means that employees may discuss any problem or area of concern or ask any question of any member of Management. If you have a problem, a complaint, a suggestion, or an observation, your supervisor and Human Resources department are committed to listening and responding to you.

2.16 Personal Property and Workplace Privacy

Employees should have no expectation that their workplace and/or materials contained within their workspace are private and not subject to disclosure. From time to time, supervisors and other authorized persons may have a legitimate business need to enter an employee’s workspace including, but not limited to, offices, computers, cabinets, and desks, to search for documents, files, and other work-related items. In addition, in cases of suspected employee misconduct or criminal activity, Curtis, along with law enforcement may search the workplace for evidence of such misconduct and will cooperate with law enforcement officials in any criminal investigation.

The Company has the right to inspect employee workplaces. The Company understands and respects the privacy interests of all of its employees. We hope that our employees will also understand and respect the Company’s obligation to provide a safe, effective and productive working environment. To ensure that the Company fulfills this obligation and has the ability to enforce the policies set forth in this Handbook, the Company must have the authority to conduct inspections of items in areas that an employee may otherwise consider personal or private. Consequently, the Company reserves the right to inspect personal packages or other articles brought to the Company, all desk and work areas, and all Company equipment.

Personal Packages and Articles: Management has the authority to inspect packages or other articles entering or leaving Company’s premises in the possession of any employee. If employees desire to avoid such inspections, they should refrain from having packages or other articles on Company’s premises. The Company is not responsible for lost, damaged, destroyed or stolen personal items that are on the premises.

Work Area Inspection Policy: Keep in mind that desks, file cabinets, work areas and offices are made available for the convenience of employees while at work and remain the sole property of the Company. The Company reserves the right to inspect desks, file cabinets, work areas and offices, as well as any contents, effects, or articles that are in those areas. Such an inspection can occur at any time, with or without advance notice. An inspection may be conducted before, during, or after working hours by management.

Vehicle Inspection Policy: All Company owned or leased vehicles are subject to inspection by management at any time without notice.

Prohibited materials, including weapons, explosives, alcohol and non-prescribed drugs or medications (excluding over the counter medications), may not be brought into or left on Company premises. Perishable items also should not be stored in work areas for prolonged periods. Employees who, if requested, fail to cooperate in any inspection will be subject to disciplinary action, including termination. The Company is not responsible for any personal articles that are placed or left in work areas that are lost, damaged, stolen or destroyed.

2.17 Request for Information Regarding Current or Former Employees

All requests from prospective employers or others for references for current or former employees should be directed to the Human Resources department. The Human Resources department is the only entity authorized or permitted to release references for a current or former employee. A written disclosure authorization and release, available from the Human Resources department, may be required before any information is furnished.

Unless there are exceptional circumstances, such as a request from a government agency, auditor, or subpoena, Curtis will respond to all reference requests by providing only dates of employment and positions held.

2.18 Recruitment

Curtis may communicate job opportunity openings by utilizing the Company shared drive, employee email and the Curtis website.

2.19 No Solicitation/Distribution

The following policy has been created in order to avoid interference with work.

1. Distribution by Employees:

Employees may not distribute non-work related advertising material, handbills, posters or written literature of any kind anywhere on Curtis’ premises during working time. Working time does not include lunch periods or breaks. Employees may not distribute non-work related advertising material, handbills, posters or written literature of any kind in a work area at any time. The term “work area” applies to all places where employees regularly work or conduct business, but does not apply to the employee cafeteria, restrooms, or any other area set aside for exclusive employee non-work use.

2. Solicitation by Employees:

Solicitation of any kind (including but not limited to soliciting for participation, membership, subscriptions, or payment of money) by one employee of another employee anywhere on Curtis’ premises is prohibited during the working time of either the employee doing the soliciting or the employee being solicited. Working time does not include lunch periods or breaks.

3. Solicitation and/or Distribution by Non-employees:

Solicitation of any kind and distribution of literature of any kind on Curtis’ premises by any person or organization not employed by Curtis is prohibited at all times.

4. The selling or distribution of commercial products on Curtis’ premises is prohibited at all times.

2.20 Employment of Relatives

To avoid conflicts of interest and the appearance of favoritism or bias and to enhance supervision, security and morale, the Company generally prohibits the employment of relatives.

Curtis defines “relatives” for the purposes of this policy as spouse, registered domestic partner, mother, father, sister, brother, son, daughter, stepmother, stepfather, stepsister, stepbrother, stepchild, niece, nephew, cousin, uncle, aunt, grandparent, grandchild and in-laws within these categories.

In the event a relative of an employee is employed within the organization, the relative of the employee may not be employed in the following circumstances:

• Under each other’s direct supervision or in the same department.
• Where the potential for a conflict of interest may exist in the performance of duties.
• Where the potential for creating an adverse impact in the work environment exists, presenting problems in supervision, safety, security or morale.

Employees who become registered domestic partners or marry or become related by marriage may continue their employment if they do not work in a direct supervisory relationship or otherwise present actual or potential problems in supervision, safety, security or morale. If there are problems, they should be reported to the Manager of Human Resources. The Company will investigate and, if necessary, will then attempt to reassign one or both of the employees to available positions for which the employees are qualified in order to eliminate the problem.

If, however, no such position is available, one of the employees may be asked to leave the Company. The employees will have 30 days to decide which of them will leave. If the employees do not decide, one or both may be terminated.

This policy will be applied in accordance with applicable laws.

Questions or comments about the policy and its application may be addressed to the local Human Resources Manager or to the VP of Human Resources.

2.21 Access to Personnel Files

The Human Resources department maintains your official personnel file. Upon request, current and former Curtis employees are generally permitted the opportunity to review the information in their personnel files, accompanied by a staff member in the Human Resources department. Copies of signed documents in the individual’s personnel file may be obtained by requesting them from Human Resources. Supervisors may access personnel files only for employees whom they supervise.

2.22 Employee Medical Records

All employee medical records will be held in confidence in order to avoid unauthorized disclosure. In compliance with state and federal laws, the Company shall keep your medical records separate from your personnel files. Access to your medical records shall be limited to those in management on a need to know basis. Information gathered in the course of the administration of benefits will be respected as confidential and will be disclosed only as necessary in the course of the administration of benefits.

2.23 Personal Data Changes

It is important that all employees’ personal information be kept current. It is the responsibility of each employee to promptly notify Human Resources of any changes in personal data, such as name, personal mailing addresses, telephone numbers, email addresses, number and names of dependents, marital status, registered domestic partner status (if relevant for benefits), and individuals to be contacted in the event of an emergency.