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 Human Resources department 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 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 decision that may result in a personal gain for the employee or an immediate family member (i.e., spouse, qualified 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, he or she 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 the 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. A collection box for this purpose will be established at each Curtis location and the charitable donation committee will distribute to designated charities.

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 his or her 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 in place 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 compliance with applicable immigration law, 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, gender, age, marital status, membership in a domestic partnership, familial status, caregiver status, sexual orientation (including an individual’s actual or perceived romantic, physical or sexual attraction to other persons, or lack thereof, on the basis of gender), gender identity or expression (including status as a transgender person), religion/creed, national origin, ethnicity, ancestry, alienage or citizenship status, pregnancy, disability, genetic predisposition and carrier status, status as a victim of domestic violence, sexual violence, or stalking, uniformed service member or veteran’s status, or any other characteristic protected by applicable federal, state or local law, in a fair and equitable manner.
• 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 Policy Prohibiting Harassment and Retaliation

Curtis strives to maintain a working environment that encourages mutual respect, promotes respectful relationships between employees and prohibits all forms of unlawful discrimination and harassment based on an individual’s membership, perceived membership, or association with other individuals in a Protected Class. Protected Classes include race, religion/creed, color, sex, pregnancy, age, national origin or ancestry, disability, alienage or citizenship status, uniformed service member or veteran status, marital status, membership in a domestic partnership, caregiver status, familial status, sexual orientation (including an individual’s actual or perceived romantic, physical or sexual attraction to other persons, or lack thereof, on the basis of gender), gender identity or expression (including status as a transgender person), genetic information, status as a victim of domestic violence, sexual violence, or stalking, or any other status or condition protected by applicable federal, state or local law.

This policy applies to and protects all employees at all levels of our organization (including supervisors and managers), applicants for employment, interns (whether paid or unpaid), and independent contractors. It also covers third parties, including customers, and those who provide services in the workplace to Curtis, including subcontractors, vendors, suppliers, “gig” workers and temporary workers, and persons providing equipment repair, cleaning services, or any other services pursuant to a contract with Curtis.

Conduct prohibited by this policy is unacceptable: (i) in the workplace; (ii) in any work- related matters that take place off-site, such as during business trips, business meetings and business-related social events; and (iii) in calls, texts, emails, and social media usage by individuals covered by this policy, even if they occur away from the workplace premises, on personal devices or during non-work hours.

2.12.1 Prohibited Harassment

Harassment based on a Protected Class is unlawful and will not be tolerated by Curtis.

Curtis prohibits harassment, including unwelcome verbal, non-verbal or physical conduct that denigrates or shows differential treatment or hostility or aversion towards an individual because of the individual’s membership or perceived membership in a Protected Class, or that of his/her relatives, friends or associates. Prohibited harassment may take many forms, and may occur in person, through written letters, e-mail or other electronic communications, or by phone.

Examples of harassment prohibited by this policy, include, but are not limited to:

• Epithets, slurs, quips, or negative stereotyping that relate to a Protected Class.
• Threatening, intimidating or hostile acts that relate to a Protected Class.
• Written, graphic, or other audio or visual material that denigrates or shows hostility or aversion toward an individual or group because of a Protected Class and that is placed on walls, bulletin boards, computer screens, or elsewhere on the Company’s premises, or circulated or displayed in the workplace.
• Comments, jokes, innuendos, gestures, pranks or other forms of humor that are demeaning or hostile with regard to a Protected Class.

2.12.2 Information Regarding Sexual Harassment

Sexual harassment is a form of harassment prohibited by this policy. It is also unlawful under federal, state and local law.

Sexual harassment includes unwelcome conduct which is either of a sexual nature, or which is directed at an individual because of that individual’s sex when:

• Such conduct is made either explicitly or implicitly a term or condition of employment.
• Submission to or rejection of such conduct is used as a basis for employment decisions affecting an individual’s employment, and/or:
• Such conduct has the purpose or effect of interfering with an individual’s work performance or creating an intimidating, hostile or offensive work environment, even if the reporting individual is not the intended target of the sexual harassment.

Conduct is considered to be directed at an individual because of the person’s sex if the conduct is motivated by sex. In this context “sex” is defined broadly and includes conduct motivated by sexual desire, as well as conduct based on sexual orientation, self-identified or perceived sex, gender expression, gender identity, or the status of being transgender.

Sexual harassment can occur between any individuals in the workplace, regardless of their sex or gender. Harassers can be a superior, a subordinate, a coworker or anyone in the workplace including a customer, an independent contractor or other third parties who provide services in the workplace to Curtis, including subcontractors, vendors, “gig” workers and temporary workers, and persons providing equipment repair, cleaning services, or any other services provided pursuant to a contract with Curtis.

The following are examples of the types of unwelcome acts that are strictly prohibited:

• Physical acts of a sexual nature, such as: (i) touching, pinching, patting, kissing, hugging, grabbing, brushing against another individual’s body or poking another individual’s body; and/or: (ii) rape, sexual battery, molestation or attempts to commit these assaults.
• Unwanted verbal or physical sexual advances, flirtations, or propositions, such as: (i) requests for sexual favors accompanied by implied or overt threats concerning the target’s job performance evaluation, a promotion or other job benefits or detriments; and/or (ii) subtle or obvious pressure for unwelcome sexual activities.
• Sexually oriented gestures, leering, noises, remarks, signs, jokes, or comments about a person’s body, sexuality or sexual experience, prowess or deficiencies.
• Sex stereotyping, such as when conduct or personality traits are considered inappropriate simply because they may not conform to other people’s ideas or perceptions about how individuals of a particular sex should act or look.
• Sexual or discriminatory displays or publications anywhere in the workplace, such as displaying pictures, posters, calendars, graffiti, promotional material, objects, reading materials or other materials that are sexually suggestive, demeaning or pornographic. This includes such sexual displays on workplace computers or cell phones and sharing such displays while in the workplace.
• Hostile actions taken against an individual because of that individual’s sex (as broadly defined above), such as: (i) interfering with, destroying or damaging a person’s workstation, tools or equipment, or otherwise interfering with the individual’s ability to perform the job; (ii) sabotaging an individual’s work; and/or (iii) bullying, yelling, name- calling or other forms of verbal abuse.

2.12.3 Complaint Procedure

1. All of us share the responsibility for enforcing Curtis’ policy prohibiting harassment and retaliation. Curtis strongly encourages the prompt reporting of all conduct that violates this policy, regardless of the offender’s identity or position. Any harassing conduct, even a single incident, can be addressed under this policy.
2. Any complaints or concerns about a violation of this policy should be promptly reported to a Supervisor, a Manager or to Human Resources, so that rapid and constructive action can be taken. Early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment. Therefore, while no fixed reporting period has been established, you are strongly urged to immediately report complaints or concerns so that rapid and constructive action can be taken. An individual must not use peer pressure to discourage another individual from making a complaint under this policy.
3. Anyone who is aware of conduct that violates this policy, even if not the object of the conduct, should immediately report any incidents they witness that may constitute harassment. Employees receiving a complaint of harassment from a non-employee, including applicants for employment, interns (whether paid or unpaid), independent contractors, subcontractors, vendors, suppliers, “gig” workers and temporary workers, and persons providing services to Curtis should also immediately report the complaint.
4. Supervisors and managers are required to immediately notify Human Resources about any complaint of harassment, discrimination, or retaliation that they receive, or any harassing, discriminatory, or retaliatory conduct they observe or otherwise learn or suspect is occurring.
5. Complaints will be accepted orally or in writing (a complaint form is available from the Human Resources department to facilitate reporting under this policy).
6. The availability of this complaint procedure does not preclude individuals who believe they are being subjected to discriminatory or harassing conduct from promptly advising the offender that his/her behavior is unwelcome and requesting that it be discontinued.

2.12.4 Investigative Procedure

Curtis will promptly, thoroughly and impartially investigate all complaints of discrimination, harassment, and retaliation in a manner that ensures due process for all parties, and resolve such complaints in a timely manner, and as quickly as possible. Curtis will also maintain a system for documenting and tracking complaints received, the status of any investigation, and the resolution of those complaints.

While the process may vary from case to case based on the particular circumstances, the investigative procedure will typically include the following steps: (i) an immediate review of a complainant’s allegations, and initiation of interim actions to protect the interests of the parties (e.g., obtaining and securing necessary records and materials); (ii) interviews of the parties involved and relevant witnesses; (iii) documenting the investigation (e.g., summarizing key documents, interviews, and the timeline of relevant events); and (iv) memorializing the outcome of the investigation, including the basis for conclusions reached and remedial actions taken. All investigation documentation will be maintained in a confidential and secure manner.

Individuals involved in the investigation process are expected to provide their full cooperation, and supervisors and managers are required to cooperate with the process.

If an individual refuses to participate in an inquiry: (i) the individual may be subject to disciplinary action for violating this policy; and (ii) Curtis will base its conclusions on the other information gathered during the inquiry and inferences drawn from all of the credible evidence.

During the investigation, confidentiality will be maintained by Curtis to the extent consistent with a thorough and impartial investigation (and subject to any legal obligation to disclose information related to the complaint, i.e., complete confidentiality is not guaranteed). Individuals are frequently directed to maintain confidentiality regarding certain aspects of the investigation, based on the circumstances of a particular matter, and are expected to comply with such directions.

Upon completion of the investigation, Curtis will promptly notify the individual who made the complaint and the individual who was the subject of the complaint of its final determination and implement any corrective actions it identified during the investigation.

2.12.5 Remedial Action

If it is determined that a violation of this policy has occurred, prompt, remedial action will be taken, as determined by Curtis at its sole discretion. This may include restoring any lost terms, conditions or benefits of employment to the complaining employee.

Additionally, Curtis will discipline the individual(s) who engaged in harassment or other conduct in violation of this policy, at Curtis’s discretion, which may include placing an employee on a leave of absence, reassignment, suspension, probation, demotion, suspension without pay, and/or termination of employment. Curtis also reserve the right to require counseling, training and/or monitoring as a condition of continued employment even where a violation is not found. In addition, conduct that is unlawful may subject individuals engaging in such conduct to civil and, in some cases, criminal liability, up to and including termination of employment.

Supervisors or managers may also be subject to discipline if they fail to report harassment, discrimination, or retaliation that is reported to them, or otherwise comes to their attention.

If Curtis determines that conduct contrary to this policy has been committed by a third party who is not employed by the Company (e.g., a customer, independent contractor, subcontractor, vendor, or another individual providing services in the workplace), the Company will take appropriate action to stop the conduct at issue.

2.12.6 Retaliation is Prohibited

Retaliation is a serious violation of Curtis’s policy. It is also a violation of federal, state and local law.

Curtis will not retaliate against an individual for engaging in activities such as: (i) making a complaint of harassment, discrimination, or retaliation, either internally or externally (by filing a lawsuit in court or with a fair employment practices government agency); (ii) testifying, cooperating with, or providing assistance in an internal or external proceeding involving claims of harassment, discrimination, or retaliation under federal, state, or local anti-discrimination laws; (iii) opposing harassment, discrimination, or retaliation (e.g., making a complaint of harassment regarding yourself or another individual); or (iv) encouraging another individual to report harassment, discrimination, or retaliation.

The prohibition against retaliation includes, but is not limited to, remarks, threats, physical or verbal abuse, any discrimination in terms of pay, advancement, opportunities, termination of employment, job assignments or reassignments, unwelcome or unwarranted transfers, threats of punishment or revenge, actual punishment or revenge (for reporting or assisting in discrimination and/or harassment inquiries), or other acts that could be reasonably likely to dissuade or deter a person from complaining about discrimination or harassment, pursuing a claim, or cooperating or participating in a related investigation, or otherwise be interpreted as retaliatory. In certain situations, retaliatory actions may also include actions that are not job-related or actions that do not occur in the workplace (e.g., threats of physical violence outside of work hours). None of these actions are tolerated by Curtis.

If you feel that you are being retaliated against, or observe retaliation, you should immediately report this by using the Complaint Procedure described in this policy.

Additionally, if a manager or supervisor learns of such conduct, these individuals must report it Human Resources. Curtis will take appropriate disciplinary action against individuals who engage in retaliation or condone or ignore violations of this policy (as described in the Remedial Action section of this policy).

2.12.7 Additional Complaint Reporting

New York City, New York State and the federal government have agencies whose purpose is to address unlawful harassment, discrimination and retaliation in the workplace. While Curtis believes that its complaint procedure (described above) will be effective in resolving such complaints, affected individuals may also choose to direct their complaints to these agencies.

A federal charge may be filed with the Equal Employment Opportunity Commission (“EEOC”), www.eeoc.gov, (1-800-669-4000). In California, employees may choose to direct complaints to the California Department of Fair Employment and Housing (“DFEH”), https://www.dfeh.ca.gov, (1-800-884-1684), or to any equivalent state or local fair employment practices agency in the location in which they work. In New York, complaints may be directed to: (i) the New York State Division of Human Rights (“DHR”), www.dhr.ny.gov, 718-741-8400; or (ii) the New York City Commission on Human Rights (“NYCCHR”), https://www1.nyc.gov/site/cchr/index.page 718-722-3131 (or 311).

Complaints of unlawful discrimination, harassment, or retaliation must be filed with the EEOC, or the applicable state or local fair employment practices agency, within specific periods of time, which may vary depending on the location in which an individual works and the nature of the individual’s claim. For example, in New York, a one-year limitations period applies for filing such claims under state law with the DHR. Complaints filed with the EEOC must be filed within 300 days.

Individuals may also file a lawsuit in state court or, after filing an administrative complaint, may file a lawsuit in federal court.

The government agencies discussed above will investigate complaints and determine whether there is probable cause to believe that harassment, discrimination, or retaliation has occurred in violation of applicable law (e.g., the federal anti-discrimination laws, the New York State Human Rights Law, and the New York City Human Rights Law). If a state or local agency determines that an unlawful employment action occurred, the agency has the power to award relief, which varies but may include requiring an employer to take remedial action, or redress the damage caused, including paying of monetary damages, attorney’s fees and civil fines. If a complaint is made to the EEOC, the EEOC may take other action, including pursuing cases in federal court on behalf of complaining parties. The courts may award similar remedies if discrimination, harassment, or retaliation is found to have occurred.

Additionally, if the harassment involves physical touching or assault, individuals may choose to contact the local police department.

2.13 Reasonable Accommodations Disabilities

Curtis will adhere to all applicable federal, state and local laws and will make reasonable accommodation whenever possible for qualified employees or applicants with disabilities once the Company has been made aware of the disability, provided that such accommodation does not constitute an undue hardship on the Company.

Employees with a disability who believe they need an accommodation to perform the essential functions of their job should contact the Human Resources department. Curtis provides accommodation to the disabled to the full extent required by law. Any questions regarding this policy should be addressed to the Human Resources department.

2.13.1 Pregnancy and Related Conditions

Curtis also complies with all applicable laws regarding reasonable accommodations due to pregnancy, having a child or a medical or common condition related to pregnancy.

Examples of pregnancy-related accommodations include providing frequent bathroom breaks and rest breaks, assistance with manual labor or lifting items, changes to a work environment, light duty, leave, and breaks to express milk.

2.13.2 Religious Beliefs

Curtis will also provide a reasonable accommodation for an individual’s sincerely held religious belief if the accommodation would resolve a conflict between the individual’s religious beliefs or practices and a work requirement (or as otherwise required by law), unless doing so would create an undue hardship.

2.13.3 Domestic Violence

Curtis will also provide a reasonable accommodation to employees who are victims of domestic violence when the reasonable accommodations do not pose an undue hardship to Curtis. Examples of accommodations include leave for medical attention and psychological counseling, obtaining social services, relocating, seeking legal assistance and participating in legal proceedings.

2.13.4 Lactation

Any employee who is nursing will be provided reasonable break times to express milk throughout the day, each time she needs to express milk, for as long as the employee has a need to express milk. Curtis will make reasonable efforts to provide a room or other location, in close proximity to the work area, where an employee can express milk in privacy. Consistent with this policy, managers should thoughtfully respond to requests for accommodation for lactation breaks and ensure there are no negative consequences to employees who use time as provided by this policy.

Nursing mothers who need to express milk during the working day should contact the Human Resources department. Working with the nursing mother, Curtis will identify an appropriate private location for the nursing mother to express breast milk.

Retaliation against an employee who chooses to express breast milk in the workplace is strictly prohibited. Curtis will also comply with any applicable law that provides benefits for nursing mothers in excess of the benefits provided in this policy.

2.13.5 Reporting Discrimination and Requesting Accommodations

An employee or job applicant who has questions regarding this policy or who believes that he or she has been discriminated against or denied a reasonable accommodation should notify the Human Resources department. All such inquiries or complaints will be treated as confidential to the extent permissible by law. No employee will suffer retaliation or intimidation as a result of requesting a reasonable accommodation, making a report of behavior believed to be unlawfully discriminatory or providing information requested during the investigation of a complaint.

2.14 Workplace Violence Policy Statement

Curtis is committed to providing a safe, violence-free workplace and strictly prohibits employees, consultants, customers, visitors, or any one 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, he or she 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 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’s 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 a 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.

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 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” as spouse, qualified domestic partner, daughter, son, mother, father, sister, brother, 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 qualified 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 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 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 personal mailing addresses, telephone numbers, email addresses, number and names of dependents, marital status, and individuals to be contacted in the event of an emergency.