APG Associate Handbook 2024

Page 1


Revised 9/13/2024

ABOUT THIS HANDBOOK / DISCLAIMER

We prepared this handbook to assist you in finding the answers to many questions that you may have regarding your employment with Adams Publishing Group (hereinafter may be referred to as “the Company” or “APG” Please take the necessary time to read it).

We do not expect this handbook to answer all your questions. Adams Publishing Group operates in many states in the United States and these states have varying laws and requirements which cannot all be contained in this Handbook. Your supervisor or Company Management also will be a major source of information.

Neither this handbook nor any other verbal or written communication by a management representative, is, nor should it be, an agreement, contract of employment, express or implied, or a promise of treatment in any particular manner in any given situation nor does it confer any contractual rights whatsoever.

The policies and benefits stated in this handbook are subject to change at the direction of the Company, and the Company reserves the right to, at any time and without any prior or subsequent notice, change, revise, amend, modify, add and delete, either in whole or in part, any plan, policy, program or statement in this Associate handbook as made necessary by applicable law, changing circumstances and/or to reflect the best interest of our Associates and community.

In the event of a pandemic, natural disaster, or any other unusual or unexpected occurrence impacting business operations (in whole or in part), these policies may be subject to change or be modified at Company management’s discretion.

In those states where permitted, Adams Publishing Group adheres to the policy of “employment at will” which permits the Company or the Associate to terminate the employment relationship at any time, for any reason, with or without cause or notice. The status of “employment at will” may only be modified in an individual case or generally by way of a writing signed by the CEO of the Company.

In those states where employment “at will” is not permitted, the Company will recognize and adhere to applicable law.

Many matters covered by this handbook, such as benefit plan descriptions, are also described in separate Company documents. These Company documents are always controlling over any statement made in this handbook or by any member of management.

This handbook states only general Company guidelines. The Company may, at any time, in its sole discretion, modify or vary from anything stated in this handbook, with or without notice.

This handbook supersedes all prior handbooks.

This handbook is subject to the terms of any applicable collective bargaining agreement.

Nothing in this handbook is intended to interfere with, restrain, or prevent concerted activity as protected by the National Labor Relations Act. Such activity includes Associate communications regarding wages, hours, or other terms or conditions of employment. AGP Associates have the right to engage in or refrain from such activities.

Compliance with State Law

If any provision in this handbook conflicts with the laws of a particular state in which APG is operating, the division[s] in that state will comply with the applicable state law. This shall not affect the validity, legality, and enforceability of the remaining provisions of this handbook that are not in conflict with state law.

*See state specific law on “at will employment.

1-1. Welcome Statement

Governing Principles of Employment

For those of you who are commencing employment with Adams Publishing Group (“Adams Publishing Group” or the “Company”), on behalf of Adams Publishing Group let me extend a warm and sincere welcome. We hope you will enjoy your work here. We are glad to have you with us.

I extend to you my personal best wishes for your success and happiness here at Adams Publishing Group. We understand that it is our Associates who provide the services that our customers rely upon, and who will grow and enable us to create new opportunities in the years to come.

Adams Publishing Group recognizes that Associates are the most valuable resource for continuous improvement. Adams Publishing Group must provide the leadership, training, and tools necessary for Associates to continually improve APG’s products and services. It is our utmost goal to provide a work environment within which all Associates will thrive.

Sincerely,

1-2. Equal Employment Opportunity

Adams Publishing Group is an Equal Opportunity Employer that does not discriminate based on actual or perceived race, creed, color, religion, alienage or national origin, ancestry, citizenship status, age, disability or handicap, sex, marital status, veteran status, sexual orientation, genetic information, arrest record, or any other characteristic protected by applicable federal, state, or local laws. Our management team is dedicated to this policy with respect to recruitment, hiring, placement, promotion, transfer, training, compensation, benefits, Associate activities, and general treatment during employment.

Any Associates with questions or concerns about equal employment opportunities in the workplace are encouraged to bring these issues to the attention of his or her supervisor. Note: If your supervisor is the person toward whom the concern is directed, you should contact any higher-level Manager in your reporting chain. Associates may also contact a member of the Human Resources team if they are uncomfortable for any reason using the above procedure. The Company will not allow any form of

retaliation against individuals who raise issues of equal employment opportunity. To ensure our workplace is free of artificial barriers, violation of this policy will lead to discipline, up to and including discharge. All Associates must cooperate with all investigations.

Governing Principles of Employment

1-3. Non-Harassment

It is Adams Publishing Group’s policy to prohibit intentional and unintentional harassment of any individual by another person based on any protected classification under federal, state, or local law including, but not limited to, race, color, national origin, disability, religion, marital status, veteran status, sexual orientation, or age. The purpose of this policy is not to regulate our Associates’ personal morality, but to ensure that in the workplace, no one harasses another individual.

You are to conduct yourself at all times in a manner that is respectful of others and their differences. If you are asked to stop doing or saying something that is making another uncomfortable, you are expected to stop what you are doing or saying. Always remember what is acceptable, amusing, and inoffensive to some may be unwelcome, abusive, or offensive to others.

This policy applies to all Associates of the Company, including supervisors and nonsupervisory Associates, and prohibits harassment of Associates in the workplace by any person, including non-Associates. This policy also applies so as to prohibit harassment by or towards Company visitors, vendors, third parties, and other business invitees who are at the Company for a business purpose. This policy also applies to Associates when off duty.

Furthermore, this policy prohibits unlawful harassment in any form, including verbal, physical, electronic and/or visual harassment.

Unlawful harassment may take many forms, such as:

1. Verbal conduct, such as epithets, derogatory comments, slurs, or unwanted sexual advances, invitations or comments whether based on race, sex, age, disability, national origin, religion, or other protected status.

2. Visual conduct, such as derogatory posters, cartoons, drawings, emails, or gestures.

3. Physical conduct, such as assault, blocking normal movement, or interference with work, which is directed at an Associate because of the Associate’s sex or

other protected characteristic.

4. Threats and demands to submit to sexual requests to keep one’s job or to avoid some loss and offers of job benefits in return for sexual favors.

Governing Principles of Employment

5. Retaliation for having reported unlawful harassment.

6. Demeaning, degrading, teasing, verbal abuse or joking about a person or group’s protected status

7. Displaying, e-mailing, or otherwise distributing material that is demeaning, degrading, or joking about a person or group’s protected status

Sexual Harassment

It is Adams Publishing Group’s policy to prohibit harassment of any Associate by any Supervisor, Associate, customer, or vendor on the basis of sex or gender (or other protected status). The purpose of this policy is not to regulate personal morality within the Company. It is to ensure that at the Company all Associates are free from sexual harassment. While it is not always easy to define precisely what types of conduct could constitute sexual harassment, examples of prohibited behavior include but are not limited to:

1. Unwanted physical contact or conduct of any kind, including sexual flirtations, touching, advances, or propositions

2. Verbal abuse of a sexual nature including unwelcome sexual conversation, innuendo, sexual related nicknames, or teasing

3. Jokes of a sexual nature

4. Demeaning, insulting, intimidating, or sexually suggestive comments about an individual’s dress or body

5. The display in the workplace of demeaning, insulting, intimidating, or sexually suggestive objects pictures, cartoons, and or photographs

6. Demeaning, insulting, intimidating, or sexually suggestive written, recorded, or electronically transmitted messages

7. Subtle pressure for sexual favors or explicit demands for sex

8. Conditioning any term or condition of employment on sexual favors or dating

9. Repeatedly asking for a date when the person has refused such a request

10. Offensive gestures, leering, sounds, or comments

11. Inquiries into one’s sexual experiences

12. Discussion of one’s sexual activities.

Associates’ Responsibility

Governing Principles of Employment

Any Associate who believes that a supervisor’s, manager’s, other Associate’s, or nonAssociate’s actions or words constitute unwelcome harassment toward him/her or toward another Associate has a responsibility to report or complain about the situation as soon as possible.

If you believe that you are the victim of such conduct, you should do the following:

1. If comfortable and practical, identify the offensive behavior to the harasser and request that it stop.

2. If it is not comfortable or practical to confront the harasser directly, or if you have done so and the harassment is continuing, notify your local Human Resources Office or the publisher. If it is not comfortable or practical for you to notify your Human Resources Office or the publisher, or if you have done so and the harassment is continuing, you may contact the Human resources department.

Supervisors/Managers’ Responsibility

Each supervisor or manager has a responsibility to keep the workplace free of any form of harassment, and in particular, sexual harassment. No supervisor or manager is to threaten or insinuate, explicitly or implicitly, that an Associate’s refusal or willingness to submit to sexual advances will affect the Associate’s terms or conditions of employment.

Any supervisor and/or manager who becomes aware of sexual or other prohibited harassment either directly, indirectly or by observation is obligated to report it promptly to any of the following: The General Manager or the Human Resources Office, Failure to do so may result in disciplinary action, up to and including termination.

Reporting Harassment, Unwelcome Conduct or Retaliation

To permit the Company an opportunity to investigate allegations of wrongful conduct and take necessary corrective action as appropriate, all Associates should report information the Associate reasonably believes is evidence of harassment, unwelcome conduct or retaliation verbally, in writing, by email or text in the following manner: You may report harassment, unwelcome conduct, or retaliation by contacting any of the following in any order you feel most comfortable:

• Your manager or Supervisor

• Your Publisher or General Manager

• Your Business Manager or that person at your location responsible for human resources at your location or region

• Directly to the human resources department

Governing Principles of Employment

If you are not contacted by a manager or human resources within three business days of making your complaint, contact the VP of Human Resources of Adams Publishing Group.

Every report of perceived harassment will be fully investigated, and corrective action will be taken where appropriate. Violation of this policy will result in disciplinary action, up to and including discharge.

All complaints will be kept confidential to the extent possible, but confidentiality cannot be guaranteed. Whenever possible, the confidentiality of the complaint will be maintained. At times, however, the details of the complaint or identity of the complaining party or witnesses must be disclosed to effectively investigate or address the complaint. (This includes publishers, human resources staff and the president of the company) In all circumstances, the Company will take all reasonable steps to assure that the complaining party does not suffer any reprisals or retaliations.

The Company will not allow any form of retaliation against individuals who report unwelcome conduct to management or who cooperate in the investigations of such reports in accordance with this policy.

Examples of retaliation include but are not limited to:

1. Adverse employment actions because of a complaint or investigation

2. Interrogating an Associate or placing an Associate under unusual surveillance

3. Sabotaging, damaging, or interfering with an Associate’s work

4. Ostracizing, excluding an Associate from normal work activity, not speaking to an Associate; demeaning or degrading an Associate

5. Not cooperating with another Associate in work activities

6. Other inappropriate behavior

Associates who make complaints in bad faith may be subject to disciplinary action, up to and including discharge. All Associates must cooperate with all investigations.

Anti-Retaliation Policy

It is the policy of Adams Publishing Group to encourage open communication by its Associates. If you have a legitimate concern of any kind, we want to hear from you.

Governing Principles of Employment

It is a violation of Company policy for anyone to retaliate or otherwise victimize an Associate who makes a complaint or provides information as part of an investigation regarding a complaint with respect to Company policies. As part of our commitment to open communication, we prohibit retaliation against anyone who brings a sincere workplace concern to our attention. Examples of such concerns may include, but are not limited to, discrimination, harassment, safety, conduct of managers or other Associates, business ethics and practices, and employment policies and practices.

We encourage you to bring matters of concern to our attention in good faith, including any occasion when you believe this policy, or any policy of Adams Publishing Group has been violated. We will investigate your concern and respond to you within a reasonable period, consistent with our need to conduct an appropriate investigation. We will also maintain confidentiality to the extent that we can, and consistent with the need for a proper investigation.

1-4. Workplace Violence

Adams Publishing Group is strongly committed to providing a safe workplace. The purpose of this policy is to minimize the risk of personal injury to Associates and damage to Company and personal property.

We do not expect you to become an expert in psychology or to physically subdue a threatening or violent individual. Indeed, we specifically discourage you from engaging in any physical confrontation with a violent or potentially violent individual. However, we do expect and encourage you to exercise reasonable judgment in identifying and reporting potentially dangerous situations.

Prohibited Conduct

Threats, threatening language, bullying, or any other acts of aggression or violence made toward or by any Company Associate WILL NOT BE TOLERATED. For purposes of this policy, a threat includes any verbal or physical harassment or abuse, any attempt at intimidating or instilling fear in others, menacing gestures, flashing of weapons, stalking or any other hostile, aggressive, injurious, or destructive action undertaken for the purpose of domination or intimidation. To the extent permitted by law, Associates

and visitors are prohibited from carrying weapons on Company premises; this policy may be subject to applicable State law and the Company will adhere to such applicable State laws.

Governing Principles of Employment

Procedures for Reporting a Threat

All potentially dangerous situations, including threats by co-workers, should be reported immediately to any member of management with whom you feel comfortable. Associates may also call the Human resources department.

Reports of threats may be maintained confidential to the extent maintaining confidentiality does not impede our ability to investigate and respond to the complaints. All threats will be promptly investigated. All Associates must cooperate with all investigations. No Associate will be subjected to retaliation, intimidation, or disciplinary action as a result of reporting a threat in good faith under this policy.

If the Company determines, after an appropriate good faith investigation, that someone has violated this policy, the Company will take prompt and appropriate corrective action.

If you are the recipient of a threat made by an outside party, please follow the steps detailed in this section. It is important for us to be aware of any potential danger in our offices. Indeed, we want to take effective measures to protect everyone from the threat of a violent act by an Associate or by anyone else.

1-5. ADA and Religion Accommodation Policy

The Company will endeavor to make reasonable accommodations to the known physical or mental limitations of qualified Associates with disabilities unless the accommodation would impose an undue hardship on the operation of our business. If you need assistance to perform your job duties because of a physical or mental condition, please let your supervisor know. An Associate requesting accommodation may be asked to provide documentation from his/her health care provider regarding the nature of the impairment and the accommodation needed for the Associate to perform the essential functions of his/her job. Medical information obtained during this process will be maintained in confidence. The Company will work with the Association through the interactive process to determine whether reasonable accommodation is available.

The Company will endeavor to accommodate the sincere religious beliefs of its Associates to the extent such accommodation does not pose an undue hardship on the Company’s operations. If you wish to request such an accommodation, please speak to your supervisor. Once a request is received, the Company will work with the Associate through the interactive process to determine whether a reasonable accommodation is available that will enable the Associate to perform the duties of his/her position that does not conflict with his/her sincerely held religious beliefs.

Governing Principles of Employment

If you have requested an accommodation, but have not received a response, or are not satisfied with the response you have received you may contact your local human resources representative or the Human resources department.

2-1. Associate Classifications

For purposes of this handbook, all Associates fall within one of the classifications below.

Full-Time Associates - Associates who regularly work at least (30) hours per week who were not hired on a short-term basis.

Part-Time Associates - Associates who regularly work fewer than (30) hours per week who were not hired on a short-term basis.

Short-Term Temporary Associates - Associates who were hired for a specific shortterm project. Short-Term Associates generally are not eligible for Company benefits but are eligible to receive statutory benefits.

In addition to the above classifications, Associates are categorized as either “exempt” or “non-exempt” for purposes of federal and state wage and hour laws. Associates classified as exempt do not receive overtime pay; they generally receive the same weekly salary regardless of hours worked. Such a salary may be paid less frequently than weekly. You will be informed of your classifications upon hire and informed of any subsequent changes to your classifications.

2-2. Your Employment Records

To obtain your position, you provided us with personal information, such as your address and telephone number. This information is contained in your personnel file as well as maintained in the ADP WorkforceNow database.

Please keep your personnel file up to date by informing human resources of any changes. Also, please inform human resources of any specialized training or skills you may acquire in the future, as well as any changes to any required visas. Unreported changes of address, marital status, etc. can affect your withholding tax and benefit coverage. Further, an “out of date” emergency contact or an inability to reach you in a crisis could cause a severe health or safety risk or other significant problem.

Employment records are the property of the Company; Associate requests for access to employment records will be determined in accordance with applicable state law.

2-3. Introductory Period/At-Will Employment Status

The first (90) days of continuous employment for a new Associate are an introductory period. Each Associate is encouraged to use the first (90) days of employment to

determine whether the position meets his or her expectations. The supervisor will also use this period to evaluate the new Associate’s capabilities, attitude, and work habits.

The Associate’s status always is that of an at-will Associate, subject to applicable state laws. The Company recognizes that some states do not recognize the status of “at-will” employment and the Company will comply with the law as it applies in those states. In those states where at-will employment applies either the Associate or the Company may end the employment relationship at any time with or without cause or with or without notice both during and after the initial (90) days of employment. Successful completion of this period does not imply a contract for employment and should not be construed as a guarantee of employment for any specific duration.

2-4. Working Hours and Schedule

Adams Publishing Group conducts business hours on a varied schedule based on business unit and location. You will be assigned a work schedule, and you will be expected to begin and end work according to the schedule. To accommodate the needs of our business, at some point the company may need to change individual work schedules on either a short-term or long-term basis.

Associates will be provided meal and rest periods as required by federal state or local law and are established according to department practice and workload. Meal periods are scheduled by the Associate’s supervisor to ensure compliance with applicable laws, and that the department and office are adequately staffed to handle normal business functions. Your supervisor will provide further details.

Associates are not paid for the meal period, during which they are to be completely relieved of their work during any meal period of at least 30 minutes or more. Generally, two paid work breaks are allowed during the day to provide a change of pace and rest for the Associate. Work breaks, each of approximately ten minutes duration, are scheduled by the supervisor to ensure that the department or office is adequately always staffed. If an Associate does not receive a meal period or is asked to perform work during a meal or break period, he or she should note this on the time record; if this occurs with frequency, the Associate should advise his or her supervisor, general manager of the location or the Human resources department.

2-5. Timekeeping Procedures

Associates must record their actual time worked for payroll and benefit purposes. Non-exempt Associates must record the time work begins and ends, as well as the

beginning and ending time of any departure from work for any non-work-related reason, through online software or on paper forms as prescribed by management.

Altering, falsifying, or tampering with time records is prohibited and subjects the Associate to discipline, up to and including discharge. This is what your pay is based on, so it needs to be accurate.

Exempt Associates are required to record their full and half days of absence from work for reasons such as leaves of absence or Paid Time Off (PTO).

Non-exempt Associates may not start work until their scheduled starting time. It is your responsibility to sign your time record to certify the accuracy of all time recorded. Any errors in your time record should be reported immediately to your supervisor, who will attempt to correct legitimate errors.

2-6. Overtime

Like most successful companies, we experience periods of extremely high activity. During these busy periods, additional work is required from all of us. Your supervisor is responsible for monitoring business activity and requesting overtime work if it is necessary. Effort will be made to provide you with adequate advance notice in such situations.

Any non-exempt Associate who works overtime will be compensated at the rate of one and one-half times (1.5) his/her normal regular rate (usually the hourly wage) for all time worked in excess of forty (40) hours each week, unless otherwise required by law.

Associates may work overtime only with prior supervisor authorization. Corrective action may be appropriate against an Associate for not following this department procedure.

For purposes of calculating overtime for non-exempt Associates, the workweek begins at 12 a.m. on Saturday and ends 168 hours later at midnight on the following Friday.

2-7. Travel Time for Non-Exempt Associates

Overnight, Out-of-Town Trips

Non-exempt Associates will be compensated for time spent traveling (except for meal periods) during the Associate’s normal working hours, which occur on days they are routinely scheduled to work and on unscheduled workdays (such as weekends).

Non-exempt Associates also will be paid for any time spent performing job duties during otherwise non-compensable travel time; however, such work should be limited absent advance management authorization.

Out-of-Town Trips for One Day

Non-exempt Associates who travel out of town for a one-day assignment will be paid for all travel time, except for, among other things: (i) time spent traveling between the Associate’s home and the local railroad, bus or plane terminal; and (ii) meal periods.

Commuting Time

Under the Portal-to-Portal Act, travel from home to work and from work to home is generally non-compensable. However, if a non-exempt Associate regularly reports to a worksite near his/her home but is required to report to a worksite farther away than the regular worksite, the additional time spent traveling is compensable.

If compensable travel time results in more than 40 hours worked by a non-exempt Associate, the Associate will be compensated at an overtime rate of one and onehalf times the regular rate.

2-8. Safe Harbor Policy for Exempt Associates

It is our policy and practice to accurately compensate Associates and to do so in compliance with all applicable state and federal laws. To ensure that you are paid properly and that no improper deductions are made, you must review your pay stubs promptly to identify and report all errors.

If you are classified as an exempt salaried Associate, you will receive a salary that is intended to compensate you for all hours you may work for the Company. This salary will be established at the time of hire or when you become classified as an exempt Associate. While it may be subject to review and modification from time to time, such as during salary review times, the salary will be a predetermined amount that will not be subject to deductions for variations in the quantity or quality of the work you perform.

Your salary may be reduced for certain types of deductions such as your portion of health, dental or life insurance premiums; state, federal or local taxes; social security; or voluntary contributions to a 401(k) or pension plan; garnishments; or otherwise, where allowed by applicable State or Federal law.

If you believe you have been subject to any improper deductions, you should immediately report the matter to your supervisor. If the supervisor is unavailable or if you believe it would be inappropriate to contact that person (or if you have not

received a prompt and fully acceptable reply), you should immediately contact Human Resources

2-9. Your Paycheck

You will be paid semi-monthly for all the time you have worked during the past pay period.

Your payroll stub itemizes deductions made from your gross earnings. By law, the Company is required to make deductions for Social Security, federal income tax and any other appropriate taxes. These required deductions also may include any courtordered garnishments. Your payroll stub will also differentiate between regular pay received and overtime pay received.

If you believe there is an error in your pay, bring the matter to the attention of your Manager immediately so the Company can resolve the matter quickly and amicably.

Your paycheck will be given only to you, unless you request that it be mailed, or authorize another individual to accept your check for you.

2-10. Direct Deposit

Adams Publishing Group strongly encourages Associates to use direct deposit. Authorization forms are available from the human resource department or payroll department for your region

2-11. Salary Advances

Adams Publishing Group does not permit salary advances on paychecks or against accrued paid time off.

2-12. Performance Reviews

Depending on your position and classification, Adams Publishing Group endeavors to review your performance on a regular basis. However, please understand that a positive performance evaluation does not guarantee an increase in salary, a promotion, or continued employment. Compensation increases and the terms and conditions of employment, including job assignments, transfers, promotions, and demotions, are determined by and at the discretion of management.

In addition to these formal performance evaluations, the Company encourages you and your supervisor to discuss your job performance on a frequent and ongoing basis.

Performance reviews are scheduled by your supervisor on an annual basis.

2-13. Poor Performance

Associates are expected to make every effort to learn their job and to always perform at a level satisfactory to the Company. Associates who do not meet the minimum performance criteria will be subject to discipline, up to and including termination.

2-14. Record Retention

The Company acknowledges its responsibility to preserve information relating to litigation, audits, and investigations. Failure on the part of Associates to follow this policy can result in possible civil and criminal sanctions against the Company and its Associates and possible disciplinary action against responsible individuals (up to and including termination of employment). Each Associate has an obligation to contact their regional human resources representative to inform them of a potential or actual litigation, external audit, investigation, or similar proceeding involving the Company that may have an impact on record retention protocols.

3-1. Benefits Overview

In addition to good working conditions and competitive pay, it is Adams Publishing Group's policy to provide a combination of supplemental benefits to all eligible

Associates. In keeping with this goal, each benefit program has been carefully devised. These benefits include paid-time-off benefits, such as PTO and holidays, and insurance and other plan benefits. We are constantly studying and evaluating our benefits programs and policies to better meet your present and future needs. These policies have been developed over the years and continue to be refined to keep up with changing times and needs.

The next few pages contain a brief outline of the benefits programs Adams Publishing Group provides for you and your family. Of course, the information presented here is intended to serve only as guidelines.

The descriptions of the insurance and other plan benefits merely highlight certain aspects of the applicable plans for your general information only. The details of those plans are spelled out in the official plan documents, which are available for review upon your request from the Human resources department. Additionally, the provisions of the plans, including eligibility and benefits provisions, are summarized in the summary plan descriptions ("SPDs") for the plans (which may be revised from time to time).

In the determination of benefits and all other matters under each plan, the terms of the official plan documents shall govern over the language of any descriptions of the plans, including the SPDs and this handbook.

Further, Adams Publishing Group (including the officers and administrators who are responsible for administering the plans) retains full discretionary authority to interpret the terms of the plans, as well as full discretionary authority about administrative matters arising in connection with the plans and all issues concerning benefit terms, eligibility, and entitlement.

While the Company intends to maintain these Associate benefits, it reserves the absolute right to modify, amend or terminate these benefits at any time and for any reason.

If you have any questions regarding your benefits, please contact the APG Human resources department.

3-2. Holidays

Full-time Associates will be paid for the following holidays:

New Year’s Day

Memorial Day

Independence Day

Labor Day

Thanksgiving Day

Christmas Day

When holidays fall or are celebrated on a regular workday, eligible Associates will receive one (1) day's pay at their regular straight-time rate. Eligible Associates who are called in to work on a holiday will receive one (1) day's pay at their regular straighttime rate, and an additional payment of straight-time for the actual time they work that day.

Holiday time and call-in pay are not considered “hours worked” for purposes of overtime unless otherwise required by applicable State law.

Associates must work the day before and day after a holiday to receive Holiday pay. Scheduled and approved time off the day before and after a holiday is the exception.

3-3. Floating Holidays

Adams Publishing Group offers (3) Floating Holidays to Associates working (30) hours or more per week for use throughout the year subject to manager approval and staffing levels.

Newly hired associates in the first year of employment working (30) hours or more per week will receive a prorated amount based on their month of hire as follows:

Floating Holidays are awarded on January 1 of each year.

Floating Holidays may be taken for the following:

● Birthday

● Friday after Thanksgiving

● Christmas Eve Day

● New Years Eve Day

● Juneteenth

● Martin Luther King Day

● Hanukkah

● Rosh Hashanna

● Yom Kippur

● Other days that are of cultural, religious, or personal significance

Unused Floating Holidays are not eligible for carry-over, nor is there a cash value for unused days.

Floating Holidays may not be used consecutively.

A minimum of (72) hours advance notice is required when requesting a Floating Holiday and may be requested in ADP. Final approval is subject to staffing levels.

3-4. Volunteer Days

Adams Publishing Group provides associates with (2) Volunteer days for use throughout the year to support activities that are important to associates.

This benefit is available to full-time associates working (30) or more hours per week.

Newly hired associates who work (30) hours or more per week will receive a prorated amount based on their month of hire as follows:

Volunteer Days are awarded on January 1 of each year.

Volunteer Days shall consist of up to 8 hours of paid time per Volunteer Day. Pay will be granted for time actually spent performing volunteer work. In accordance with applicable law, the hours of volunteer time will not be paid at overtime rate and will not count toward a weekly determination of whether hours are to be at overtime.

Unused Volunteer Days are not eligible for carryover, nor is there a cash out value for unused days.

Volunteer Days are limited to activities on behalf of charitable organizations classified by the IRS as 501(c)(3) and “municipalities” (including public schools).

By way of illustration, volunteer programs, initiatives, and activities eligible include activities that benefit the local community such as serving meals at a soup kitchen, helping to build a house, mentoring youth, leading a scout troop, assisting students with reading, math or the sciences and chaperoning field trips.

Programs, initiatives, and activities not eligible for paid volunteer time include activities where the primary purpose is the promotion of religious doctrine or tenets, activities intended to influence legislation or the outcome of any public elections, or to carry on any voter registration drive.

Volunteer activities performed on personal time (e.g., on vacation days, holidays weekends, days off, before or after regularly scheduled work hours) are not eligible for this program.

A minimum of (72) hours advance notice is required when requesting a Volunteer Day.

Associates may request a Volunteer Day in ADP. In addition, associates will submit a request form to their manager for approval. Final approval is subject to staffing levels and prohibitions.

3-5. Lactation Breaks

The Company will provide a reasonable amount of break time to accommodate an Associate desiring to express breast milk for the Associate's infant child, in accordance with and to the extent required by applicable law. The break time, if possible, must run concurrently with rest and meal periods already provided to the Associate. If the break time cannot run concurrently with rest and meal periods already provided to the Associate, the break time will be unpaid, subject to applicable law.

The Company will make reasonable efforts to provide Associates with the use of a room or location other than a toilet stall for the Associate to express milk in private. This location may be the Associate's private office, if applicable. Please consult your supervisor or your regional human resources representative if you have questions regarding this policy.

Please advise management if you need break time and an area for this purpose. Associates will not be discriminated against or retaliated against for exercising their rights under this policy.

3-6. Paid Time Off (PTO)

The Company knows how hard you work and recognizes the importance of providing you with time for rest and relaxation. We fully encourage you to get this rest by taking your paid time off. Time off under this policy includes extended time off, such as for a vacation, and incidental time due to sickness or to handle personal affairs. APG provides PTO to full-time Associates who average 30 hours or more of work per week. PTO hours are accrued each pay period based on hours worked and years of service.

Full-time Associates earn PTO based on 30, 37.50 and 40 hour work weeks. Associates will accrue PTO effective the first full day of employment as follows:

Only full-time Associates accrue PTO. Part-time Associates do not accrue paid time off unless it is part of a collective bargaining agreement. PTO should be taken during

the year received unless otherwise required by law. A maximum accrual of (160) hours of PTO is allowed at any time for each full-time Associate. PTO accrual will be halted when an Associate accrues this maximum. Once the accrual falls under (160) hours during a pay period, accrual will begin again. Accrued, unused paid time off up to (80) hours may be carried over to the following calendar year. State specific laws may affect the carry-over policy.

PTO requests for five or more full days off consecutively must be submitted at least (2) weeks in advance of your requested time off. This does not apply to emergency situations. Every effort will be made to grant your request, consistent with our operating schedule. However, if too many people request the same period off, the Company reserves the right to choose who may take time off during that period. Individuals with the longest length of service generally will be given preference.

If you will be out of work due to illness or due to any other emergency for which notice could not be provided, you must call in and notify your supervisor as early as possible, but at least by the start of your workday. If you must leave a message, it should include a phone number to contact you regarding job-related information, should that be required.

Paid time off may be used only in half-day increments or more for exempt Associates. Non-exempt Associates (hourly) may use paid time off in increments of one hour or more, up to a maximum per day equal to regularly scheduled hours.

Up to 100% of accrued, unused paid time off is paid out upon separation. The Company does not allow advancement of un-accrued paid time off.

PTO cannot be used if an associate resigns in order not to work out their notice. They are expected to work their notice period unless the company agrees to waive the notice.

3-7. Insurance Programs

Full-time Associates may participate in the Company's insurance programs. Under these plans, eligible Associates will receive an offer of comprehensive health and other insurance coverage for themselves and their families, as well as other benefits, for costs outlined in the Associate contribution description. Upon becoming eligible to participate in these plans, you will receive summary plan descriptions (SPDs) describing the benefits in greater detail. Please refer to the SPDs for detailed plan information. Of course, feel free to speak to Human Resources if you have any further questions.

3-8. Workers Compensation and Workers’ Comp Leave

The State you work in regulates the provision of worker’s compensation benefits for injuries and illnesses arising out of and occurring during one’s employment. These State worker’s compensation benefits are the sole source of benefits for these occurrences and the benefits are governed by the State.

Associates on worker’s compensation leave and still on the payroll must make the necessary Associate contribution to maintain their benefits. In most cases, an Associate must be off more than seven days to be eligible for workers compensation benefits. The Company will pay Associates who provide appropriate medical information, and an accident report filed within 24 hours of the accident sick leave for up to seven days. If the Associate is paid for the waiting period retroactively, the Company must be reimbursed.

3-9. Jury Duty Leave

The Company realizes that it is the obligation of all U.S. citizens to serve on a jury when summoned to do so. All Associates will be allowed time off to perform such civic service as required by law. Associates are expected, however, to notify their supervisor of a notice for jury duty promptly upon receipt of the notice and to provide verification of their service.

Associates also are expected to keep management informed of the expected length of jury duty service and to report to work for the major portion of the day if excused by the court. If the required absence presents a serious conflict for management, Associates may be asked to try to postpone or waive jury duty.

Associates on jury duty leave will be paid for their jury duty service which takes place during the Associate’s regularly scheduled work hours, offset by any amounts received by the Associate as jury fees against the compensation due, providing the Associate presents proof of jury service from the court upon return to work. The Associate may keep any funds reimbursed for travel and/or parking. This provision will be subject to and may be modified pursuant to applicable State law.

3-10. Bereavement Leave

We know the death of a close relative is a time when you wish to be with the rest of your family. Full-time Associates may request time off up to three (3) days with pay to assist in attending to your obligations and commitments. Part-time Associates may also request bereavement leave, but their time off is without pay. For the purposes of this policy, a close relative includes a spouse, domestic partner, children, stepchildren (and their spouses), parents or stepparents, grandparents, grandchildren, brothers, and sisters (and their spouses), mother-in-law, father-in- law or any other relation required by applicable law. Paid leave days may only be taken on regularly

scheduled, workdays after the day of death or later for the Celebration of Life. You must inform your supervisor prior to commencing bereavement leave. In administering this policy, the Company may require verification of death.

3-11. Voting Leave

Adams Publishing Group believes in the importance of every citizen exercising his or her right to vote. In the event an Associate does not have sufficient time outside of working hours to vote in a public local, state and/or national election, the Associate may take off the time necessary, or as required by state law, to vote during their regular work schedule without penalty or deduction from pay. Where possible, your supervisor should be notified prior to Election Day so that work functions can be covered during this time.

3-12. School Conference and Activities Leave

Adams Publishing Group will provide Associates with up to sixteen (16) hours of leave during any 12-month period to attend school conferences or school-related activities related to the Associate's child (including conferences related to a pre-kindergarten program or childcare services), provided the conferences or school- related activities cannot be scheduled during non-working hours. When leave cannot be scheduled during non-work hours and the need for leave is foreseeable, the Associate must provide reasonable prior notice of the leave and make a reasonable effort to schedule the leave so as not to unduly disrupt the Company's operations. Leave under this policy is unpaid. However, an Associate may substitute accrued paid time off for leave under this policy. This provision will be subject to and may be modified pursuant to applicable state law.

3-13. Short-Term and Long-Term Disability

Full-time Associates are eligible to participate in the Company’s Short-Term and Long-Term Disability plans, subject to all terms and conditions of the agreement between the Company and the insurance carrier.

This is solely a monetary benefit and not a leave of absence. Associates who will be out of work must also request a formal leave of absence. See the Leave of Absence sections of this handbook for more information.

3-14. Retirement Plan

Eligible Associates (as defined by the applicable Plan terms) are able to participate in the Company's retirement plan. Plan participants may make pre- or post-tax contributions to a retirement account subject to and in accordance with

plan terms and applicable law. The Adams Publishing Group 401k plan has an auto-enrollment. Contact human resources if you do not wish to participate for instructions to opt out of the plan.

Upon becoming eligible to participate in this plan, you will receive an SPD describing the plan in greater detail. Please refer to the SPD for detailed plan information. Of course, feel free to speak to a Transamerica representative at 800755-5801 if you have any further questions.

Adams Publishing Group has fifteen days (15) from the 15th and last day of the month to deposit 401(k) Associate contributions to Transamerica.

4-1. Family and Medical Leave

1. The Leave Policy

Associates may be entitled to a leave of absence under the Family and Medical Leave Act (FMLA). This policy provides Associates information concerning FMLA entitlements and obligations Associates may have during such leaves. If Associates have any questions concerning FMLA leave, they should contact their supervisor or APG human resources representative.

2. Eligibility

FMLA leave is available to “eligible Associates.” To be an “eligible Associate,” an Associate must: 1) have been employed by a covered Company* for at least 12 months (which need not be consecutive); 2) have been employed by the Company for at least 1,250 hours of service during the 12-month period immediately preceding the commencement of the leave; and 3) be employed at a worksite where 50 or more Associates are located within 75 miles of the worksite.

*Note a covered Company is one that has employed 50 or more Associates for at least 20 workweeks in the current or preceding calendar year.

3. Entitlements

The FMLA provides eligible Associates with a right to leave, applicable health insurance benefits and, with some limited exceptions, job restoration. The FMLA also entitles Associates to certain written notices concerning their potential eligibility for and designation of FMLA leave.

(a). Basic FMLA Leave Entitlement:

The FMLA provides eligible Associates up to 12 workweeks of unpaid leave for certain family and medical reasons during a 12-month period. The 12-month period is determined based on a rolling 12-month period measured backward

from the date an Associate uses his/her FMLA leave. Leave may be taken for anyone, or for a combination, of the following reasons:

• To care for the Associate’s child after birth or placement for adoption or foster care.

• To care for the Associate’s spouse, son, daughter, or parent (but not inlaw) who has a serious health condition.

• For the Associate’s own serious health condition (including any period of incapacity due to pregnancy, prenatal medical care, or childbirth) that makes the Associate unable to perform one or more of the essential functions of the Associate’s job; and/or

• Because of any qualifying exigency arising out of the fact that an Associate’s spouse, son, daughter or parent is a covered military member on covered active duty or called to covered active-duty status (or has been notified of an impending call or order to covered active duty) in the Reserves component of the Armed Forces in support of contingency operations or Regular Armed Forces for deployment to a foreign country. This leave also is available for family members of active-duty service members.

A serious health condition is an illness, injury, impairment or physical or mental condition that involves either an overnight stay in a medical care facility, or continuing treatment by a health care provider for a condition that either prevents the Associate from performing the functions of the Associate’s job or prevents the qualified family member from participating in school or other daily activities. Subject to certain conditions, the continuing treatment requirement may be met by a period of incapacity of more than 3 consecutive calendar days combined with at least two visits to a health care provider or one visit and a regimen of continuing treatment, or incapacity due to pregnancy, or incapacity due to a chronic condition. Other conditions may meet the definition of continuing treatment.

Qualifying exigencies may include attending certain military events, arranging for alternative childcare, addressing certain financial and legal arrangements, attending certain counseling sessions, caring for the parents of the military member on covered active duty and attending post-deployment reintegration briefings.

(b). Additional Military Family Leave Entitlement (Injured Service member Leave)

In addition to the basic FMLA leave entitlement discussed above, an eligible Associate who is the spouse, son, daughter, parent or next of kin of a covered service member is entitled to take up 26 weeks of leave during a single 12month period to care for the service member with a serious injury or illness. Leave to care for a service member shall only be available during a single 12month period and, when combined with other FMLA-qualifying leave, may not exceed 26 weeks during the single 12-month period. The single 12-month period begins on the first day an eligible Associate takes leave to care for the injured service member.

A “covered service member” is a current member of the Armed Forces, including a member of the National Guard or Reserves, who is undergoing medical treatment, recuperation, or therapy, is otherwise in outpatient status or is on the temporary retired list, for a serious injury or illness. These individuals are referred to in this policy as “current members of the Armed Forces.”

Covered service members also include a veteran who is discharged or released from military services under condition other than dishonorable at any time during the five years preceding the date the eligible Associate takes FMLA leave to care for the covered veteran, and who is undergoing medical treatment, recuperation or therapy for a serious injury or illness. These individuals are referred to in this policy as “covered veterans.”

The FMLA definitions of a “serious injury or illness” for current Armed Forces members and covered veterans are distinct from the FMLA definition of “serious health condition” applicable to FMLA leave to care for a covered family member.

(c).Intermittent

Leave and Reduced Leave Schedules

FMLA leave usually will be taken for a period of consecutive days, weeks, or months. However, Associates also are entitled to take FMLA leave intermittently or on a reduced leave schedule when medically necessary due to a serious health condition of the Associate or covered family member, or the serious injury or illness of a covered service member.

(d). No Work While on Leave

The taking of another job while on family/medical leave or any other authorized leave of absence is grounds for immediate dismissal, to the extent permitted by law.

(e). Protection of Group Health Insurance Benefits

During FMLA leave, eligible Associates are entitled to receive group health plan

coverage (if applicable) on the same terms and conditions as if they had continued to work.

(f). Restoration of Employment and Benefits

At the end of FMLA leave, subject to some exceptions including situations where job restoration of “key Associates” will cause the Company substantial and grievous economic injury, Associates generally have a right to return to the same or equivalent positions with equivalent pay, benefits, and other employment terms. The Company will notify Associates if they qualify as “key Associates,” if it intends to deny reinstatement, and of their rights in such instances. Use of FMLA leave will not result in the loss of any employment benefit that accrued prior to the start of an eligible Associate’s FMLA leave.

(g). Notice of Eligibility for, and Designation of, FMLA Leave

Associates requesting FMLA leave are entitled to receive written notice from the Company telling them whether they are eligible for FMLA leave and, if not eligible, the reasons why they are not eligible. When eligible for FMLA leave, Associates are entitled to receive written notice of 1) their rights and responsibilities in connection with such leave; 2) the Company’s designation of leave as FMLA-qualifying or non-qualifying, and if not FMLA-qualifying, the reasons why; and 3) the amount of leave, if known, that will be counted against the Associate’s leave entitlement.

The Company may retroactively designate leave as FMLA leave with appropriate written notice to Associates, provided the Company’s failure to designate leave as FMLA-qualifying at an earlier date did not cause harm or injury to the Associate. In all cases where leaves qualify for FMLA protection, the Company and Associate can mutually agree that leave be retroactively designated as FMLA leave.

4.

Associate FMLA Leave Obligations

(a). Provide Notice of the Need for Leave

Associates who take FMLA leave must timely notify the Company of their need for FMLA leave. The following describes the content and timing of such Associate notices.

(b). Content of Associate Notice

To trigger FMLA leave protections, Associates must inform their supervisor or APG human resources representative of the need for FMLA-qualifying leave and the anticipated timing and duration of the leave, if known. Associates may do this by either requesting FMLA leave specifically or explaining the reasons for

leave to allow the Company to determine that the leave is FMLA-qualifying. For example, Associates might explain that:

• A medical condition renders them unable to perform the functions of their job.

• They are pregnant or have been hospitalized overnight.

• They or a covered family member are under the continuing care of a health care provider.

• The leave is due to a qualifying exigency cause by a covered military member being on active duty or called to active-duty status; or

• If the leave is for a family member, that the condition renders the family member unable to perform daily activities or that the family member is a covered service member with a serious injury or illness.

Calling in “sick,” without providing the reasons for the needed leave, will not be considered sufficient notice for FMLA leave under this policy. Associates must respond to the Company’s questions to determine if absences are potentially FMLA-qualifying.

If Associates fail to explain the reasons for FMLA leave, the leave may be denied. When Associates seek leave due to FMLA-qualifying reasons for which the Company has previously provided FMLA-protected leave, they must specifically reference the qualifying reason for the leave or the need for FMLA leave.

(c).Timing of Associate Notice

Associates must provide 30 days’ advance notice of the need to take FMLA leave when the need is foreseeable. When 30 days’ notice is not possible, or the approximate timing of the need for leave is not foreseeable, Associates must provide the Company notice of the need for leave as soon as practicable under the facts and circumstances of the case. Associates who fail to give 30 days’ notice for foreseeable leave without a reasonable excuse for the delay or otherwise fail to satisfy FMLA notice obligations may have FMLA leave delayed or denied.

(d). Cooperate in the Scheduling of Planned Medical Treatment (Including Accepting Transfers to Alternative Positions) and Intermittent Leave or Reduced Leave Schedules

When planning medical treatment, Associates must consult with the Company and make a reasonable effort to schedule treatment so as not to unduly disrupt the Company’s operations, subject to the approval of an Associate’s health care provider. Associates must consult with the Company prior to the scheduling of treatment to work out a treatment schedule that best suits the needs of both

the Company and the Associates, subject to the approval of an Associate’s health care provider. If Associates providing notice of the need to take FMLA leave on an intermittent basis for planned medical treatment neglect to fulfill this obligation, the Company may require Associates to attempt to make such arrangements, subject to the approval of the Associate’s health care provider.

When Associates take intermittent or reduced work schedule leave for foreseeable planned medical treatment for the Associate or a family member, including during a period of recovery from a serious health condition or to care for a covered service member, the Company may temporarily transfer Associates, during the period that the intermittent or reduced leave schedules are required, to alternative positions with equivalent pay and benefits for which the Associates are qualified and which better accommodate recurring periods of leave.

When Associates seek intermittent leave or a reduced leave schedule for reasons unrelated to the planning of medical treatment, upon request, Associates must advise the Company of the reason why such leave is medically necessary. In such instances, the Company and Associate shall attempt to work out a leave schedule that meets the Associate’s needs without unduly disrupting the Company’s operations, subject to the approval of the Associate’s health care provider.

(e). Submit Medical Certifications Supporting Need for FMLA Leave (Unrelated to Requests for Military Family Leave)

Depending on the nature of FMLA leave sought, Associates may be required to submit medical certifications supporting their need for FMLA-qualifying leave. As described below, there generally are three types of FMLA medical certifications: an initial certification, a recertification, and a return to work/fitness for duty certification.

It is the Associate’s responsibility to provide the Company with timely, complete, and sufficient medical certifications. Whenever the Company requests Associates to provide FMLA medical certifications, Associates must provide the requested certifications within 15 calendar days after the Company’s request, unless it is not practicable to do so despite an Associate’s diligent, good faith efforts. The Company shall inform Associates if submitted medical certifications are incomplete or insufficient and provide Associates at least seven calendar days to cure deficiencies. The Company will deny FMLA leave to Associates who fail to timely cure deficiencies or otherwise fail to timely submit requested

medical certifications.

With the Associate’s permission, the Company (through individuals other than an Associate’s direct supervisor) may contact the Associate’s health care provider to authenticate or clarify completed and sufficient medical certifications. If Associates choose not to provide the Company with authorization allowing it to clarify or authenticate certifications with health care providers, the Company may deny FMLA leave if certifications are unclear. Whenever the Company deems it appropriate to do so, it may waive its right to receive timely, complete and/or sufficient FMLA medical certifications.

5. Initial Medical Certifications

Associates requesting leave because of their own, or a covered relation’s, serious health condition, or to care for a covered service member, must supply medical certification supporting the need for such leave from their health care provider or, if applicable, the health care provider of their covered family or service member. If Associates provide at least 30 days’ notice of medical leave, they should submit the medical certification before leave begins. A new initial medical certification will be required on an annual basis for serious medical conditions lasting beyond a single leave year.

If the Company has reason to doubt initial medical certifications, it may require Associates to obtain a second opinion at the Company’s expense. If the opinions of the initial and second health care providers differ, the Company may, at its expense, require Associates to obtain a third, final and binding certification from a health care provider designated or approved jointly by the Company and the Associate.

(a). Medical Recertifications

Depending on the circumstances and duration of FMLA leave, the Company may require Associates to provide recertification of medical conditions giving rise to the need for leave. The Company will notify Associates if recertification is required and will give Associates at least 15 calendar days to provide medical recertification.

(b). Return to Work/Fitness for Duty Medical Certifications

Unless notified that providing such certifications is not necessary, Associates returning to work from FMLA leaves that were taken because of their own serious health conditions that made them unable to perform their jobs must provide

the Company medical certification confirming they are able to return to work and the Associates’ ability to perform the essential functions of the Associates’ position, with or without reasonable accommodation. The Company may delay and/or deny job restoration until Associates provide return to work/fitness for duty certifications.

6. Submit Certifications Supporting Need for Military Family Leave

Upon request, the first time Associates seek leave due to qualifying exigencies arising out of the active duty or call to active-duty status of a covered military member, the Company may require Associates to provide: 1) a copy of the covered military member’s active-duty orders or other documentation issued by the military indicating the covered military member is on active duty or call to active-duty status and the dates of the covered military member’s active-duty service; and 2) a certification from the Associate setting forth information concerning the nature of the qualifying exigency for which leave is requested. Associates shall provide a copy of new active-duty orders or other documentation issued by the military for leaves arising out of qualifying exigencies arising out of a different active duty or call to active-duty status of the same or a different covered military member. When leave is taken to care for a covered service member with a serious injury or illness, the Company may require Associates to obtain certifications completed by an authorized health care provider of the covered service member. In addition, and in accordance with the FMLA regulations, the Company may request that the certification submitted by Associates set forth additional information provided by the Associate and/or the covered service member confirming entitlement to such leave.

7.Miscellaneous provisions

(a). Reporting Changes to Anticipated Return Date & Periodically Concerning Intent to Return

to Work

Associates must contact their supervisor or their regional human resources representative periodically in accordance with the instructions noted on the Eligibility Notice regarding their status and intention to return to work at the end of the FMLA leave period. If an Associate’s anticipated return to work date changes and it becomes necessary for the Associate to take leave than originally anticipated, the Associate must provide the Company with reasonable notice (i.e., within two business days) of the Associate’s changed circumstances and new return to work date. If Associates give the Company unequivocal notice of their intent not to return to work, they will be considered to

have voluntarily resigned and the Company’s obligation to maintain applicable health benefits (subject to COBRA requirements) and to restore their positions will cease.

(b). Substitute Paid Leave for Unpaid FMLA Leave

Associates must (unless the Company specifically informs Associates otherwise) use any accrued paid time off while taking unpaid FMLA leave. The substitution of paid time for unpaid FMLA leave time does not extend the length of FMLA leaves and the paid time will run concurrently with an Associate’s FMLA entitlement.

Leaves of absence taken in connection with a disability leave plan or workers’ compensation injury/ illness shall run concurrently with any FMLA leave entitlement. Upon written request, the Company will allow Associates to use accrued paid time off to supplement any paid disability benefits.

(c). Pay Associate’s Share of Health Insurance Premiums

During FMLA leave, Associates are entitled to continued group health plan coverage (if applicable) under the same conditions as if they had continued to work. Unless the Company notifies Associates of other arrangements, whenever Associates are receiving pay from the Company during FMLA leave, the Company will deduct the Associate portion of the group health plan premium from the Associate’s paycheck in the same manner as if the Associate was actively working.

If FMLA leave is unpaid, Associates must pay their portion of the group health premium through a ‘’pay- as-you-go’’ method. Associates should contact their immediate supervisor to make these arrangements.

The Company’s obligation to maintain health care coverage ceases if an Associate’s premium payment is more than 30 days late. If an Associate’s payment is more than 15 days late, the Company will send a letter notifying the Associate that coverage will be dropped on a specified date unless the copayment is received before that date. If Associates do not return to work within 30 calendar days at the end of the leave period (unless Associates cannot return to work because of a serious health condition or other circumstances beyond their control), they will be required to reimburse the Company for the cost of the premiums the Company paid for maintaining coverage during their unpaid FMLA leave.

(d). Exemption for Highly Compensated Associates

The Company may choose not to return highly compensated Associates

(highest paid 10% of Associates at a worksite or within 75 miles of that worksite) to their former or equivalent positions following a leave if restoration of employment will cause substantial economic injury to the Company. (The Company on a case-by-case basis will make this fact-specific determination.) The Company will notify you if you qualify as a “highly compensated” Associate, if the Company intends to deny reinstatement, and of your rights in such instances.

(e). Questions and/or Complaints about FMLA Leave

If you have questions regarding this FMLA policy, please contact your supervisor or your regional human resources representative. The Company is committed to complying with the FMLA and, whenever necessary, shall interpret and apply this policy in a manner consistent with the FMLA.

The FMLA makes it unlawful for employers to: 1) interfere with, restrain, or deny the exercise of any right provided under FMLA; or 2) discharge or discriminate against any person for opposing any practice made unlawful by FMLA or involvement in any proceeding under or relating to FMLA. If Associates believe their FMLA rights have been violated, they should contact the Human resources department for Adams Publishing immediately. The Company will investigate any FMLA complaints and take prompt and appropriate remedial action to address and/or remedy any FMLA violation. Associates also may file FMLA complaints with the United States Department of Labor or may bring private lawsuits alleging FMLA violations.

(f). Coordination of FMLA Leave with Other Leave Policies

The FMLA does not affect any federal, state or local law prohibiting discrimination, or supersede any State or local law that provides greater family or medical leave rights. For additional information concerning leave entitlements and obligations that might arise when FMLA leave is either not available or exhausted, please consult the Company’s other leave policies in your Company handbook as applicable or contact your supervisor or their regional human resources representative.

If an Associate exhausts his or her leave available under FMLA for his/her own serious health condition and needs additional leave for medical reasons, he/she should contact the Human resources department to determine whether a reasonable accommodation may be available.

If you are called into active military service or enlist in the uniformed services, you will be eligible to receive an unpaid military leave of absence. To be eligible for military leave, you must provide management with advance notice of your service obligations unless you are prevented from providing such notice by military necessity or it is otherwise impossible or unreasonable for you to provide such notice. Provided your absence does not exceed applicable statutory limitations, you will retain reemployment rights and accrue seniority and benefits in accordance with applicable federal and state laws. Please ask management for further information about your eligibility for Military Leave.

If you are required to attend yearly Reserves or National Guard duty, you can apply for an unpaid temporary military leave of absence not to exceed the number of days allowed by law (including travel). You should give management as much advance notice of your need for military leave as possible so that the company can maintain proper coverage while you are away.

4-3. Sick Leave

See section 3-4. Paid time off (PTO) or human resources for state specific policies.

5-1. Standards of Conduct

Adams Publishing Group endeavors to maintain a positive work environment. Each Associate plays a role in fostering this environment. Accordingly, we all must abide by certain rules of conduct, based on honesty, common sense, and fair play.

General Standards of Conduct

Because everyone may not have the same idea about proper workplace conduct, it is helpful to adopt and enforce rules all can follow. Unacceptable conduct may subject the offender to disciplinary action, up to and including discharge, in the Company’s sole discretion. The following are examples of some, but not all, conduct which can be considered unacceptable:

1. Obtaining employment based on false or misleading information.

2. Stealing, removing or defacing Adams Publishing Group property or a coworker’s property, and/or disclosure of confidential business information. This includes unauthorized downloading and removing company files.

3. Falsifying any company records including completing another Associate’s time records or falsifying the Associate’s own time records.

4. Violation of safety rules and policies.

5. The unlawful or unauthorized use, abuse, solicitation, distribution, theft, possession, transfer, purchase, or sale of drugs, drug paraphernalia or alcohol by an individual anywhere on Company premises, while on Company business (whether or not on Company premises), or while representing the Company, reporting to work, or remaining on duty after using drugs or alcohol in any amount that (in the sole opinion of the Company) adversely affects the Associate’s ability to perform the functions of the job. Please refer to your state handbook for specific policy (if any) for additional information.

6. Fighting, threatening, or disrupting the work of others or other violations of Adams Publishing Group’s Workplace Violence Policy.

7. Failure to follow lawful instructions of a supervisor.

8. Failure to perform assigned job duties.

9. Violation of the Punctuality and Attendance Policy, including but not limited to irregular attendance, habitual lateness, unexcused absences, not reporting absences as required and no call no show

10. Gambling on Company property.

11. Willful or careless destruction or damage to Company assets or to the equipment or possessions of another Associate.

12. Performing work of a personal nature or performing work for other organizations during working time.

13. Violation of the Solicitation and Distribution Policy.

14. Violation of Adams Publishing Group’s Harassment or Equal Employment Opportunity Policies.

General Standards of Conduct

15. Violation of the Communication and Computer Systems Policy.

16. Unsatisfactory job performance.

17. Plagiarism.

18. Sleeping on the job.

19. Bringing firearms or other weapons on Company property, offices and or buildings, subject to applicable state law.

20.Unauthorized use of the Company’s intellectual property.

21. Conduct while off the job that reflects poorly on the Company may result in suspension or termination. Such conduct includes but is not limited to harassment, threats, arrests or convictions for criminal conduct which impacts the Associate’s ability to perform safely and effectively his or her job or which impacts the public image of the Company, and or inappropriate posts concerning the Company, managers/ supervisors, fellow Associates, or customers.

22. Any other violation of Company policy.

Obviously, not every type of misconduct can be listed, and the list above is only intended to provide examples of unacceptable conduct which will generally result in disciplinary measures. Note that all Associates are employed at will, (where permitted and subject to applicable law) and Adams Publishing Group reserves the right to impose whatever discipline it chooses, or none, in a particular instance. The Company will deal with each situation individually and nothing in this handbook should be construed as a promise of specific treatment in each situation. However, Adams Publishing Group will endeavor to utilize progressive discipline, but reserves the right in its sole discretion to discharge an Associate at any time for any reason. The observance of these rules will help to ensure that our workplace remains a safe and desirable place to work.

5-2. Punctuality and Attendance

You were hired to perform an important function at Adams Publishing Group. As with any group effort, operating effectively takes cooperation and commitment from everyone. Therefore, your attendance and punctuality are very important. Unnecessary absences and lateness are expensive, disruptive and place an unfair

burden on your fellow Associates and your Supervisors. We expect excellent attendance from every Associate. Regular and prompt attendance is an expectation of all Associates. Excessive absenteeism or tardiness will result in disciplinary action up to and including discharge.

General Standards of Conduct

We do recognize, however, that there are times when absences and tardiness cannot be avoided. In such cases, you are expected to notify your supervisor as early as possible, but no later than the start of your workday. Asking another Associate, friend or relative to give this notice is improper and constitutes grounds for disciplinary action.

Associates must call in to their supervisor, stating the nature of the reason for the absence or tardiness, and the expected duration of the absence, for every day that the Associate is absent.

Any absence from work because of incarceration will be unexcused and subject to discipline up to and including termination.

Excessiveabsenteeism,definedasunexcusedabsencesof(3)ormoredays,willbe groundsfordisciplinaryactionuptoandincludingtermination.

Unreported absences, “no call – no shows” of three consecutive workdays generally will be considered a voluntary resignation of your employment with the Company.

5-3. Inclement Weather/Company Closings

The Company’s success is dependent on each Associate being at work during scheduled work hours. The Company recognizes, however, that occasionally weather conditions may affect travel to work. If an Associate is late or absent from work due to inclement weather or difficult travel conditions, the Associate should personally contact his or her direct supervisor immediately so that the work may be covered. An Associate will be paid only for the time he or she works on inclement weather days. If an Associate is unable to get to work or must leave early due to inclement weather, he or she may choose to use PTO to compensate for the lost time.

Company or office location closings may occur on occasion for various reasons, including inclement weather, power outages, mechanical failures, and other reasons. If an Associate believes the Company may be closed, he or she should first contact the Company office or his or her supervisor before failing to arrive at work. During such closings, Associates will be paid for their regularly scheduled hours.

5-4. Use of Communication and Computer Systems

Adams Publishing Group’s communication and computer systems are intended for

business purposes and may be used only during working time; however limited personal usage is permitted if it does not hinder performance of job duties or violate any other Company policy. This includes voice mail, e-mail, and Internet systems. Associates have no legitimate expectation of privacy regarding their use of Company systems. Adams Publishing Group may access the voice mail and e-mail systems and obtain the communications within the systems, including past voice mail and e-mail messages, without notice to users of the system, in the ordinary course of business when the Company deems it appropriate or necessary to do so. The reasons for which the Company may obtain such access include but are not limited to: maintaining the system; preventing or investigating allegations of system abuse or misuse; assuring compliance with software copyright laws; complying with legal and regulatory requests for information; and ensuring that Company operations continue appropriately during an Associate’s absence.

General Standards of Conduct

Further, Adams Publishing Group may review Internet usage to ensure that such use with Company property, or communications sent via the Internet with Company property, are appropriate. The reasons for which the Company may review Associates’ use of the Internet with Company property include but are not limited to: maintaining the system; preventing or investigating allegations of system abuse or misuse; assuring compliance with software copyright laws; complying with legal and regulatory requests for information; and ensuring that Company operations continue appropriately during an Associate’s absence.

The Company may store electronic communications for a period after the communication is created. From time to time, the Company may determine those electronic communications must be deleted as part of its routine record retention and destruction policy.

The Company’s policies prohibiting harassment, in their entirety, apply to the use of Company’s communication and computer systems. No one may use any Company communication or computer system in a manner that may be construed by others as harassing or offensive based on race, national origin, sex, sexual orientation, age, disability, religious beliefs, or any other characteristic protected by federal, state or local law at any time.

Since the Company’s communication and computer systems are intended for business use, these systems may not be used to solicit for religious or political causes or outside organizations during work hours or on company machines.

Further, since the Company’s communication and computer systems are intended for

business use, all Associates, upon request, must inform management of any private access codes or passwords.

General Standards of Conduct

Unauthorized duplication of copyrighted computer software violates the law and is strictly prohibited.

No Associate may access, or attempt to obtain access to, another Associate’s computer systems without appropriate authorization.

Violators of this policy may be subject to disciplinary action, up to and including discharge.

5-5. Social Media Guidelines

Social media is an increasingly important tool for listening to and reaching our communities. Best practices, policies, and ethics around how our journalists should use various platforms are constantly evolving.

Truth, transparency, consistency, and objectivity are the foundation for all that we do, and social media is no exception.

As a company, we embrace the idea that a journalist’s personality should be reflected through their social media activity. It’s important that our communities get to know the people behind the byline. Journalists should be careful in what they reveal about their private lives, especially opinions and political persuasions, however. APG journalists should follow these guidelines related to social media use for professional and personal use:

Assume anything you post on social media platforms is public. Remember that the comments you make will reflect on you, and possibly your employer, whether you intend it to or not.

Avoid making your journalistic integrity a target. Do not share rumors, questionable reports, or anonymous allegations. Journalists must refrain from making racist, sexist, or political statements. In addition, journalists, and all Associates of APG must comply with our EEO policies at all times. If engaging in social media for the purposes of reporting, always identify yourself as a journalist, disclosing your news organization. Columnists and opinion writers/editors are not constrained by the same restrictions on social media opinion postings as their job is to offer commentary if it is based on fact. Many of our journalists wear multiple hats, and often are the only staff-based opinion voices expressed at a news organization. In those situations, they should weigh more carefully what they choose to post through social media, so they don’t compromise their position as an objective reporter.

Do not represent yourself as a spokesperson for APG or post internal documents or company information obtained by you as an Associate of APG.

General Standards of Conduct

When liking, following, or sharing from other social media accounts, remember that balance is an important tenet of our professional integrity. Best practice is to share content that represents various sides of an issue and refrain from spreading rumors, anonymous allegations, or questionable reports. As we participate on social networking sites, even for personal use, we must preserve our news organizations’ reputation for fairness and impartiality. Anything we say (or write, or post) potentially reflects upon our news organization, even if it’s said on a personal platform.

Adams Publishing Group respects the right of any Associate to maintain a blog or web page or to participate in a social networking, Twitter, or similar site, including but not limited to Facebook and LinkedIn. However, to protect Company interests and ensure Associates focus on their job duties, Associates must adhere to the following rules:

Associates may not post on a personal blog or web page or participate on a social network, Twitter, or similar site for personal reasons during the Associate’s working time or at any time with Company equipment or property. The Company understands that the use of social media is a part of some Associate’s work responsibility and that they will participate in social media for work purposes.

All rules regarding confidential and proprietary business information apply in full to blogs, web pages, social networking, Twitter, and similar sites. Any information that cannot be disclosed through a conversation, a note or an e-mail likewise cannot be disclosed in a blog, web page, social networking, Twitter, or similar site.

Whether an Associate is posting something on his or her own blog, web page, social networking, Twitter, or similar site or on someone else’s, if the Associate mentions the Company and expresses either a political opinion or an opinion regarding the Company’s actions, the poster must include a disclaimer. The post should specifically state that the opinion expressed is his/her opinion and not the Company’s position. This is necessary for clarification, and to preserve the Company’s goodwill in the marketplace; it is not intended to infringe on Associates’ freedom of expression or freedom of association.

Any conduct that is impermissible under the law if expressed in any other form or forum is impermissible if expressed through a blog, web page, social networking, Twitter, or similar site. For example, posted material that is discriminatory, obscene, defamatory, libelous, or threatening is forbidden. Company policies apply equally to

Associate social media usage on their own time when it comes to post or messages which negatively impact the Company, other Associates, or other implicates the Company’s policy prohibiting discrimination or harassment on the basis of race, color, religion, gender, age, national origin, veteran status, marital status, disability or sexual orientation or other protected status under applicable laws. Associates should review their Associate Handbook for further guidance.

General Standards of Conduct

Adams Publishing Group encourages all Associates to keep in mind the speed and way information posted on a blog, web page, and/or social networking site is received and often misunderstood by readers. Associates must use their best judgment. Associates with any questions should review the guidelines above and/or consult with their manager. Failure to follow these guidelines may result in discipline, up to and including discharge.

Nothing in this statement is intended to interfere with, restrain, or prevent concerted activity as protected by the National Labor Relations Act. Such activity includes Associate communications regarding wages, hours, or other terms or conditions of employment. APG Associates have the right to engage in or refrain from such activities.

5-6. Generative Artificial Intelligence (AI) Policy

With the increasing popularity of generative AI, it has become necessary to outline the proper use of such tools while working at Adams Publishing Group. While we remain committed to adopting new technologies to aid our mission, we also understand the risks and limitations of generative AI chatbots and want to ensure responsible use. Our goal is to protect employees, clients, suppliers, customers, and the company from harm and to reinforce our commitment to responsible and ethical journalism.

Some examples of what could be created using an AI chatbot include:

Emails and letters

Blog posts, reports, and other publications

Sales and advertising copy

Policies and job descriptions

Spreadsheet calculations

Foreign language translations

Coding development or debugging

Document or information sorting

Outlines or summaries of internal or external information

There are, however, risks in using this technology, including uncertainty about who owns the AI created content and security/privacy concerns with inputting proprietary company

information or sensitive information about an employee, client, customer, etc., when interacting with the chatbot. Additionally, the accuracy of the content created by these technologies cannot be relied upon, as the information may be outdated, misleading or in some cases fabricated

General Standards of Conduct

AI is best used as a tool to supplement, and not replace, human judgment. Associates should understand that when AI is incorporated in their work, they are responsible for that work.

The use of generative AI chatbots will be allowed while performing work for Adams Publishing Group. Company email addresses, credentials, or phone numbers can be used to create an account with these technologies. No proprietary company data may be submitted (copied, typed, etc.) onto these platforms.

Employees wishing to use generative AI chatbots should discuss the parameters of their use with their [manager/director/etc.]. Managers may verbally approve, deny, or modify those parameters as best meets company policy, legal requirements, or other business needs. All AI chatbot-generated content must be properly cited, as must the use of AI chatbot generated content when used as a resource for company work, except for general correspondence such as email.

All AI-generated content must be reviewed for accuracy before relying on it for work purposes. If a reliable source cannot be found to verify factual information generated by the chatbot, that information cannot be used for work purposes.

As generative AI chatbots may produce content that is plagiarized from its knowledge base, including copyrighted works, no text generated or partially generated from a chatbot will be eligible to have an Adams Publishing Group copyright, trademark, or patent at this time.

Any violation of this policy will result in disciplinary action, up to and including termination.

Associates must use generative AI chatbots in accordance with all Adams Publishing Group’s conduct and anti- discrimination policies. These technologies must not be used to create content that is inappropriate, discriminatory, or otherwise harmful to others or the company. Such use will result in disciplinary action, up to and including termination.

Adams Publishing Group’s Computer Use Policy and relevant monitoring policies still apply when using generative AI chatbots with company equipment.

5-7. Personal and Company-Provided Portable Communication Devices

Company-provided portable communication devices (PCDs), including cell phones and personal digital assistants, should be used primarily for business purposes with some limitations on personal use. Associates have no reasonable expectation of privacy regarding the use of such devices, and all use is subject to monitoring, to the maximum

extent permitted by applicable law. This includes as permitted the right to monitor personal communications as necessary.

General Standards of Conduct

Some Associates may be authorized to use their own PCD for business purposes. These Associates should work with the IT department to configure their PCD for business use. Communications sent via a personal PCD also may be subject to monitoring if sent through the Company’s networks and the PCD must be provided for inspection and review upon request.

All conversations, text messages and e-mails must be professional. When sending a text message or using a PCD for business purposes, whether it is a Companyprovided or personal device, Associates must comply with applicable Company guidelines, including policies on harassment based on sex or other protected status, discrimination, workplace violence, conduct, confidentiality, equipment use and operation of vehicles. Using a Company-issued PCD to send or receive personal text messages must, also, comply with applicable Company guidelines, including policies on harassment, discrimination, conduct, confidentiality, equipment use and operation of vehicles.

If an Associate who uses a personal PCD for business resigns or is terminated, the Associate will be required to submit the device to the IT department for removal of Company information on or before his or her last day of work. At that time, the IT department will remove all Company information (such as contacts, e-mails, and photographs) from the PCD before returning it to the Associate.

Associates may not use their personal PCD for business unless they agree to submit the device to the IT department on or before their last day of work for removal of Company information. This is the only way currently possible to ensure that all Company information is removed from the device at the time of termination. The removal of Company information is crucial to ensure compliance with the Company’s confidentiality and proprietary information policies and objectives.

Please note that whether Associates use their personal PCD or a Company-issued device, the Company’s electronic communications policies, including but not limited to, proper use of communications and computer systems, remain in effect.

5-8. Camera Phones/Recording Devices

Due to the potential for issues such as invasion of privacy, sexual and/or other prohibited harassment, and loss of productivity, no Associate may use a camera phone function on any phone on company property or while performing work for the

Company.

General Standards of Conduct

The use of tape recorders, dictaphones or other types of voice recording devices anywhere on Company property, including to record conversations or activities of other Associates or management, or while performing work for the Company, is also strictly prohibited, unless the device was provided to you by the Company and is used solely for legitimate business purposes.

5-9. Inspections

Adams Publishing Group reserves the right to require Associates while on Company property, or on client property, to agree to the inspection of their persons, personal possessions and property, personal vehicles parked on Company or client property, and work areas. This includes lockers, vehicles, desks, cabinets, workstations, packages, handbags, briefcases and other personal possessions or places of concealment, as well as personal mail sent to the Company or to its clients. Associates are expected to cooperate in the conduct of any search or inspection. The purpose of this policy is to advise Associates that they should have no expectation of privacy in the areas described in this policy. The Company maintains this policy as a security measure to maintain a safe work environment.

5-10. Smoking

The use of tobacco products and electronic cigarettes is prohibited in Company enclosed workplaces and in all Company vehicles. An Associate’s two regularly scheduled work breaks may be used for tobacco and electronic cigarette use outside of the enclosed workplace in designated locations.

5-11. Personal Visits and Telephone Calls

Disruptions during working time can lead to errors and delays. Therefore, we ask that personal telephone calls be kept to a minimum, and only be made or received after working time, or during lunch or break times.

For safety and security reasons, an Associate must accompany all personal guests anywhere in our facilities other than the reception areas. Family members may visit the workplace accompanied by the associate and on a limited basis.

5-12. Solicitation and Distribution

To avoid distractions, solicitation by an Associate of another Associate is prohibited while either Associate is on working time. “Working time” is the time an Associate is engaged, or should be engaged, in performing his/ her work tasks for Adams Publishing Group. Solicitation of any kind by non-Associates on Company premises is

always prohibited.

Distribution of advertising material, handbills, printed or written literature of any kind in working areas of the Company is always prohibited. Distribution of literature by non-Associates on Company premises is always prohibited. Nothing in this policy is intended to interfere with, restrain, or prevent concerted activity as protected by the National Labor Relations Act. Such activity includes Associate communications regarding wages, hours, or other terms or conditions of employment. AGP Associates have the right to engage in or refrain from such activities, but it may not be during work time.

5-13 Bulletin Boards

General Standards of Conduct

Important notices and items of general interest are continually posted on our bulletin board. Make it a practice to review bulletin boards frequently. This will assist you in keeping up with what is current at Adams Publishing Group. To avoid confusion, please do not post or remove any material from any bulletin board. Bulletin boards are for work related postings only. Any postings which have not received management approval prior to posting are subject to removal.

5-14. Confidential Company Information

During work, an Associate may become aware of confidential information about Adams Publishing Group’s business, including but not limited to information regarding Company finances, pricing, products and new product development, trade secrets, strategic plans, software and computer programs, marketing strategies, suppliers, customers and potential customers. An Associate also may become aware of similar confidential information belonging to the Company’s clients. It is extremely important that all such information remains confidential, and particularly not be disclosed to our competitors or our customers’ competitors. Any Associate who improperly copies, removes (whether physically or electronically), uses or discloses confidential information to anyone outside of the Company may be subject to disciplinary action up to and including discharge. Associates may be required to sign an agreement reiterating these obligations.

5-15 Conflict of Interest and Business Ethics

It is Adams Publishing Group’s policy that all Associates avoid any conflict between their personal interests and those of the Company. The purpose of this policy is to ensure that the Company’s honesty and integrity, and therefore its reputation, are not compromised. The fundamental principle guiding this policy is that no Associate should have, or appear to have, personal interests or relationships that actually or

potentially conflict with the best interests of the Company.

It is not possible to give an exhaustive list of situations that might involve violations of this policy. However, the situations that would constitute a conflict in most cases include but are not limited to:

General Standards of Conduct

1. Holding an interest in or accepting free or discounted goods from any organization that does, or is seeking to do, business with the Company, by any Associate who is in a position to directly or indirectly influence either the Company’s decision to do business, or the terms upon which business would be done with such organization.

2. Holding any interest in an organization that competes with the Company.

3. Being employed by (including as a consultant) any organization which does, or is seeking to do, business with the Company or which competes with the Company.

4. Profiting personally, e.g., through commissions, loans, expense reimbursements or other payments, from any organization seeking to do business with the Company.

5. Performing work for any other organization while on Company time.

6. Running for or holding a political office at the local, state or federal level.

A conflict of interest would also exist when a member of an Associate’s immediate family is involved in situations such as those above.

This policy is not intended to prohibit the acceptance of modest courtesies, openly given and accepted as part of the usual business amenities, for example, occasional business-related meals or promotional items of nominal or minor value.

It is your responsibility to report any actual or potential conflict that may exist between you (and your immediate family) and the Company.

5-16. Use of Facilities, Equipment and Property, Including Intellectual Property

Equipment essential in accomplishing job duties is often expensive and may be difficult to replace. When using property, Associates are expected to exercise care, perform required maintenance, and follow all operating instructions, safety standards and guidelines.

Please notify your supervisor if any equipment, machines, or tools appear to be damaged, defective, or in need of repair. Prompt reporting of loss, damages, defects, and the need for repairs could prevent deterioration of equipment and possible injury to Associates or others. The Supervisor can answer any questions about an

Associate’s responsibility for maintenance and care of equipment used on the job. Associates also are prohibited from any unauthorized use of the Company’s intellectual property, such as audio and video tapes, print materials and software. Improper, careless, negligent, destructive, or unsafe use or operation of equipment can result in discipline, up to and including discharge.

General Standards of Conduct

Further, the Company is not responsible for any damage to Associates’ personal belongings unless the Associate’s Supervisor provided advance approval for the Associate to bring the personal property to work.

Coupons, inserts and advertising information

No Associate is to remove coupons or inserts from the workplace except in copies of the newspaper authorized by a supervisor or use an advertiser’s information for personal use prior to distribution of the newspaper. No Associate is to attempt to use advertising information, coupons or inserts prior to the publication date of such material.

5-17. Health and Safety

The health and safety of Associates and others on Company property are of critical concern to Adams Publishing Group. The Company intends to comply with all health and safety laws applicable to our business. To this end, we must rely upon Associates to ensure that work areas are kept safe and free of hazardous conditions. Associates are required to be conscientious about workplace safety, including proper operating methods, and recognize dangerous conditions or hazards. Any unsafe conditions or potential hazards should be reported to management immediately, even if the problem appears to be corrected. Any suspicion of a concealed danger present on the Company’s premises, or in a product, facility, piece of equipment, process, or business practice for which the Company is responsible should be brought to the attention of management immediately

The Company strives to maintain a safe work environment in accordance with the Occupational Safety and Health Act of 1970. No Associate will be retaliated against for reporting a suspected safety hazard to Company management. In addition, any deliberate or ongoing safety violations will be addressed through corrective action up and including termination of employment.

General Standards of Conduct

Periodically, the Company may issue rules and guidelines governing workplace safety and health. The Company may also issue rules and guidelines regarding the handling and disposal of hazardous substances and waste. All Associates should familiarize themselves with these rules and guidelines, as strict compliance will be expected. Any workplace injury, accident, or illness must be reported to the Associate’s Supervisor as soon as possible, regardless of the severity of the injury or accident.

5-18. Hiring Relatives/Associate Relationships

A familial relationship among Associates can create an actual or at least a potential conflict of interest in the employment setting, especially where one relative supervises another relative. To avoid this problem, Adams Publishing Group may refuse to hire or place a relative in a position where the potential for favoritism or conflict exists.

In other cases, such as personal relationships where a conflict or the potential for conflict arises, even if there is no supervisory relationship involved, the parties may be separated by reassignment or terminated from employment, at the discretion of the Company. Accordingly, all parties to any type of intimate personal relationship must inform management.

If two Associates marry, become related, or enter an intimate relationship, they may not remain in a reporting relationship or in positions where one individual may affect the compensation or other terms or conditions of employment of the other individual. The Company generally will attempt to identify other available positions, but if no alternate position is available, the Company retains the right to decide which Associate will remain with the Company.

For the purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship with the Associate is like that of persons who are related by blood or marriage.

5-19. Associate Dress and Personal Appearance

The Company is a professional organization, and as such, all its Associates should look and act professionally. You are expected to report to work well groomed, clean, and dressed according to the requirements of your position. At no time should an

Associate wear lewd or suggestive attire on Company property or while engaging in Company business.

General Standards of Conduct

All sales and office representatives are expected to dress business casual. When meeting with the public, more professional attire may be appropriate. However, some business assignments may not be appropriate for professional attire. Some Associates may be required to wear uniforms or safety equipment/clothing. Anyone working with or near heavy equipment, such as press, inserter, strapper, or forklift, should not wear loose-fitting clothing or jewelry that could get caught in machinery. Individuals with longer hair should keep it confined to prevent it from being caught in equipment. Also, proper footwear with no open toe must be worn while working with or near heavy equipment.

Please contact your supervisor for specific information regarding acceptable attire for your position. If you report to work dressed or groomed inappropriately, you may be prevented from working until you return to work well- groomed and wearing the proper attire.

5-20. Publicity/Statements to the Media

All media inquiries regarding the position of the Company as to any issues must be referred to your APG Regional President. Only your Regional President is authorized to make or approve public statements on behalf of the Company. No Associates, unless specifically designated by a Regional President, are authorized to make those statements on behalf of the Company. Any Associate wishing to write and/or publish an article, paper, or other publication on behalf of the Company must first obtain approval from his or her Regional President.

5-21. Fleet and Driver Policy

All Associates who operate company vehicles and or personal vehicles for company business are to read and follow the guidelines included in the Driving section of the APG Employee Safety Handbook.

The purpose of the policy is to ensure the safety of those individuals who drive company vehicles, or those who operate personal vehicles while conducting company business and to provide guidance on the proper use of these vehicles. Some of the guidelines follow and are presented here for emphasis. This section of the Associate’s handbook is not intended to replace the Driving section of the APG Employee Safety Handbook.

Driver Guidelines and Reporting Requirements

1. Company vehicles are to be driven by authorized Associates only, except in case of repair testing by a mechanic.

General Standards of Conduct

2. Any Associate who has a driver’s license expire, revoked or suspended shall immediately notify the Human Resources and Safety offices by 9 a.m. eastern time the next business day, and immediately discontinue operation of the company vehicle or personal vehicle for company business. Failure to do so may result in disciplinary action, including termination of employment.

3. All accidents in company vehicles, regardless of severity, must be reported to the police and to the company. Accidents are to be reported immediately (from the scene, during the same day, or as soon as practicable if immediate or same day reporting is not possible). Photographic documentation of the scene and all vehicles involved is fully expected unless this presents an additional safety risk, or interferes with medical treatment of others, or if you yourself have sustained serious injuries.

4. Accidents in personal vehicles while on company business* must follow these same accident procedures. Accidents involving the Associate’s personal injury must be reported to Human Resources for Worker’s Compensation purposes. Failing to stop after an accident and/or failure to report an accident may result in disciplinary action, up to and including termination of employment.

5. Drivers must report all ticket violations received during the operation of a company vehicle, or while driving a personal vehicle on company business*, within 72 hours to the office.

6. A driving record that fails to meet the criteria stated in this policy or is considered to be in violation of the intent of this policy will result in a loss of the privilege of driving a company vehicle. or to drive a personal vehicle on company business. Driving records reflect the safety performance of the driver. In most cases no distinction will be made as to whether the citation occurred on or off duty.

7. Associates who are approved to drive on Company business are required to inform their supervisor and the Publisher, or Business Manager of any change in their license status, insurability and or physical limitations or restrictions concerning their operating a motor vehicle. Failure to notify the Company as outlined above or driving on a suspended license or without insurance will result in discipline up to and including discharge. If an Associate who is required to drive in their work loses their driving privileges, the Associate may be terminated.

* Company business is defined as driving at the direction, or for the benefit, of employer. It does not include normal commuting to and from work.

Personal Insurance Requirements

General Standards of Conduct

Associates who operate a personal vehicle while conducting company business are required to maintain an automobile insurance policy without lapse of coverage and for at least the State Minimum Coverage amount or greater. You must provide proof of insurance coverage as requested. Inability or unwillingness to comply with this request may result in revocation of approved driver status and/or disciplinary action up to and including termination.

Driver Safety Rules

1. The use of a company vehicle while under the influence of intoxicants and other drugs, including prescription and OTC (over the counter) medications which could impair driving ability is forbidden and is sufficient cause for discipline, up to and including termination of employment.

2. Cell phone use while driving should be kept to a minimum. Drivers need to be aware that use of a cell phone creates a distraction from safe driving and associates should adjust their usage, accordingly, including pulling off the road to continue/finish the conversation if needed. Whenever possible, Drivers should complete calls while the vehicle is parked. Use of cell phones in a “hands free” mode via a headset or speaker while driving is mandatory. Attention to the road and safety should always take precedence over conducting business over the phone. Texting, emailing, and application use (other than for navigational aid) are not permitted. Any Associate who does so in a company vehicle or personal vehicle while on company business shall be terminated immediately.

3. No driver shall operate a company vehicle when his/her ability to do so safely has been impaired by illness, fatigue, injury, or prescription medication. This also includes operating commercial vehicles outside the allowable Hours of Service requirements. Operating beyond Hours of Service is in direct violation of federal and state regulation, as well as company policy and absolutely will not be tolerated.

4. All drivers and passengers operating or riding in a company vehicle, or a personal vehicle operated on company business must always wear seat belts in the method that they were always designed when the vehicle is not in Park, or Neutral with the brake set. Passengers are not permitted to ride unrestrained (use of factory installed seatbelt) in the cargo area of any vehicle, including the

bed area of pickup trucks. Any Associate who fails to do so in a company vehicle or personal vehicle while on company business shall be terminated immediately.

General Standards of Conduct

5. No unauthorized personnel are allowed to ride in, or operate company pool, maintenance, or delivery/ circulation vehicles. “Unauthorized personnel” is defined as anyone that is not an active APG Associate, excepting authorized professional service personnel who are in the act of providing service to company vehicles. See: Personal Use, Passengers, & Authorized Drivers of Company Vehicles for exceptions.

6. Drivers are responsible for the security of company vehicles assigned to them. The vehicle engine must be shut off, ignition keys removed, and vehicle doors locked whenever the vehicle is left unattended.

7. Headlights shall be used after sunset or during inclement weather or at any time when 500 feet ahead of the vehicle cannot be clearly seen.

8. All Federal, State and Local laws must be obeyed.

Drug Testing

Associates involved in disabling accidents, (a vehicle must be towed), or when bodily injury occurs may be required to report for mandatory drug testing within 12 hours of the incident. Failure to do so when directed by a supervisor, other company official or law enforcement will result in termination after 24 hours. Associates operating personal vehicles on company business are not exempted from testing. Only clearly defined “non-preventable accidents” are exempted from testing. Contact HR or Safety if there is any doubt.

Damage or Injury

Damage to Associate-owned personal autos, as well as injury to family members, friends, etc., will not be covered by the corporate coverage and therefore, is the sole responsibility of the Associate.

Mileage

Associates with a valid driver’s license who occasionally use their personal vehicle for company business will be reimbursed for mileage. Reimbursed mileage is defined as mileage driven over and above the Associate’s normal commuting mileage.

In addition, Associates driving on Company business may claim reimbursement for parking fees incurred and Associates driving Company vehicles may charge or claim reimbursement for gasoline and other expenses directly incurred for business

purposes.

General Standards of Conduct

All Company policies are applicable to Company vehicles including but not limited to Standards of Conduct, Substance Abuse, Workplace Violence, Harassment, Conflict of Interest, Security/Search etc.

Portable Communication Device Use While Driving

Adams Publishing Group prohibits any Associate from using a portable communication device (PCD), including cell phones or personal digital assistants, or tablets while driving on Company business. Associates who drive on Company business must abide by all state or local laws prohibiting or limiting portable communication device (PCD) use. Associates may use hands-free equipment to make or answer calls while driving without violating this policy as permitted by law. However, safety must always be your priority. We expect you to keep these calls brief. Further, even as use is permitted, Associates may choose to refrain from using any PCD while driving. Under no circumstances should Associates feel the need to place themselves at risk to fulfill business needs.

Since this policy does not require any Associate to use a PCD while driving, Associates who are charged with traffic violations resulting from the use of their PCDs while driving will be solely responsible for all liabilities that result from such actions. Texting and emailing while driving is prohibited in all circumstances. Additional resources and guidelines pertaining to driving company vehicles or driving personal vehicles for business purposes may be found in the APG Employee Safety Handbook.

5-22. Business Expense Reimbursement

Associates may be reimbursed for reasonable approved expenses incurred during business. These expenses must be approved by your supervisor, and may include air travel, hotels, motels, meals, cab fare, rental vehicles, or gas and car mileage for personal vehicles. All expenses incurred should be submitted to your supervisor along with the receipts in a timely manner.

Associates are expected to exercise restraint and good judgment when incurring expenses. You should contact your supervisor in advance if you have any questions about whether an expense will be reimbursed.

5-23. Employment and Income Verification

Adams Publishing Group will respond to employment and income verification requests through the human resource department. The Company will provide general information concerning the Associate such as date of hire, date of termination, and positions held. Requests for verification information must be in writing, and responses will be in writing. Please refer all requests for references to human resources for instructions. Most employment and income verifications take up to 24 hours to return. Associates shall not provide professional references.

5-24 Service Animals

General Standards of Conduct

No animals are permitted in the workplace except service animals. There must be a demonstrated need for a service animal to allow the animal in the building. Examples of service animals are guide dogs, signal dogs, or other animals individually trained to aid an individual with a disability. Emotional comfort animals are not considered service animals and are prohibited from our buildings.

5-25. If You Must Leave Us

Should you decide to leave the Company, we ask that you provide your supervisor with at least two (2) weeks advance notice of your departure. Your thoughtfulness will be appreciated. This does not mean that your last two weeks should be spent on PTO which is not considered a two week notice of your departure and does not allow staff ample time to prepare for staffing changes.

All Company property including, but not limited to, keys, security cards, parking passes, laptop computers, fax machines, uniforms, etc. must be returned at separation. Associates also must return all the Company’s Confidential Information upon separation. To the extent permitted by law, Associates will be required to repay the Company (through payroll deduction, if lawful) for any lost or damaged Company property. If an Associate quits shortly after the first of the month, the Associate is responsible for their benefits through the end of that month for their share of premiums.

As noted previously, all Associates are employed at-will (except those states that are not covered by at-will laws) and nothing in this handbook changes that status.

5-26. A Few Closing Words

This handbook is intended to give you a broad summary of things you should know about Adams Publishing Group. The information in this handbook is general in nature and, should questions arise, any member of management should be consulted for complete details. While we intend to continue the policies, rules and benefits

described in this handbook, Adams Publishing Group, in its sole discretion, may always amend, add to, delete from, or modify the provisions of this handbook and/or change its interpretation of any provision set forth in this handbook. Please do not hesitate to speak to management if you have any questions about the Company or its representative policies and practices.

General Standards of Conduct

Acknowledgement of Harassment Prevention and Complaint Procedure

It is Adams Publishing Group, LLC's policy to prohibit intentional and unintentional harassment of any individual by another person based on any protected classification including, but not limited to, race, color, national origin, disability, religion, marital status, veteran status, sexual orientation or age. The purpose of this policy is not to regulate our Associates' personal morality, but to ensure that in the workplace, no one harasses another individual.

You are to conduct yourself at all times in a manner that is respectful of others and their differences. If you are asked to stop doing or saying something that is making another uncomfortable, you are expected to stop what you are doing or saying.

Always remember what is acceptable, amusing, and inoffensive to some may be unwelcome, abusive, or offensive to others.

This policy applies to all Associates of the Company, including supervisors and non-supervisory Associates, and prohibits harassment of Associates in the workplace by any person, including non-Associates. This policy applies to Associates when off duty. Furthermore, this policy prohibits unlawful harassment in any form, including verbal, physical, electronic and/or visual harassment.

If you feel that you have been subjected to conduct which violates this policy, you should immediately report the matter. You may report harassment, unwelcome conduct, or retaliation by contacting any of the following in any order you feel most comfortable:

• Your manager or Supervisor

• Your Publisher or General Manager

• Your Business Manager or that person at your location responsible for human resources at your location or region

• Directly to the Human Resources Department

Associates may also contact the Human resources department at (443)-786-0119 if they are uncomfortable for any reason using the above procedure. Every report of perceived harassment will be fully investigated, and corrective action will be taken where appropriate. Violation of this policy will result in disciplinary action, up to and including discharge. All complaints will be kept confidential to the extent possible, but confidentiality cannot be guaranteed.

In addition, the Company will not allow any form of retaliation against individuals who report unwelcome conduct to management or who cooperate in the investigations of

such reports in accordance with this policy.

Associates who make complaints in bad faith may be subject to disciplinary action, up to and including discharge.

All Associates must cooperate with all investigations.

Associate’s Printed Name: Position:

Associate’s Signature: Date:

Receipt of Non-Harassment Policy

It is Adams Publishing Group, LLC’s policy to prohibit intentional and unintentional harassment of any individual by another person on the basis of any protected classification including, but not limited to, race, color, national origin, disability, religion, marital status, veteran status, sexual orientation or age. The purpose of this policy is not to regulate our Associates’ personal morality, but to ensure that in the workplace, no one harasses another individual.

If you feel that you have been subjected to conduct which violates this policy, you should immediately report the matter to your supervisor. If you are unable for any reason to contact this person, or if you have not received a satisfactory response within five (5) business days after reporting any incident of what you perceive to be harassment, please contact the next level Manager. Note: If your supervisor or next level Manager is the person toward whom the complaint is directed, you should contact any higher-level Manager in your reporting chain.

Associates may also contact the Vice President of Human Resources at 423-620-8771 if they are uncomfortable for any reason using the above procedure. Every report of perceived harassment will be fully investigated, and corrective action will be taken where appropriate. Violation of this policy will result in disciplinary action, up to and including discharge. All complaints will be kept confidential to the extent possible, but confidentiality cannot be guaranteed.

In addition, the Company will not allow any form of retaliation against individuals who report unwelcome conduct to management or who cooperate in the investigations of such reports in accordance with this policy.

Associates who make complaints in bad faith may be subject to disciplinary action, up to and including discharge.

All Associates must cooperate with all investigations.

Associate’s Printed Name: Position:

Associate’s Signature: Date:

Receipt of Sexual Harassment Policy

It is Adams Publishing Group, LLC’s policy to prohibit harassment of any employee by any Supervisor, employee, customer or vendor on the basis of sex or gender.

The purpose of this policy is not to regulate personal morality within the Company. It is to ensure that at the Company all Associates are free from sexual harassment.

While it is not easy to define precisely what types of conduct could constitute sexual harassment, examples of prohibited behavior include unwelcome sexual advances, requests for sexual favors, obscene gestures, displaying sexually graphic magazines, calendars or posters, sending sexually explicit emails, text messages and other verbal or physical conduct of a sexual nature, such as uninvited touching of a sexual nature or sexually related comments.

Depending upon the circumstances, improper conduct also can include sexual joking, vulgar or offensive conversation or jokes, commenting about an employee’s physical appearance, conversation about your own or someone else’s sex life, or teasing or other conduct directed toward a person because of his or her gender which is sufficiently severe or pervasive to create an unprofessional and hostile working environment.

If you feel that you have been subjected to conduct which violates this policy, you should immediately report the matter to your supervisor. If you are unable for any reason to contact this person, or if you have not received a satisfactory response within five (5) business days after reporting any incident of what you perceive to be harassment, please contact the next level Manager.

Note: If your supervisor or next level Manager is the person toward whom the complaint is directed, you should contact any higher-level Manager in your reporting chain. Associates may also contact the Vice President of Human Resources at 423-620-8771 if they are uncomfortable for any reason using the above procedure. Every report of perceived harassment will be fully investigated, and corrective action will be taken where appropriate. Violation of this policy will result in disciplinary action, up to and including discharge.

All complaints will be kept confidential to the extent possible, but confidentiality

cannot be guaranteed. In addition, the Company will not allow any form of retaliation against individuals who report unwelcome conduct to management or who cooperate in the investigations of such reports in accordance with this policy. Associates who make complaints in bad faith may be subject to disciplinary action, up to and including discharge. All Associates must cooperate with all investigations.

I have read and I understand Adams Publishing Group, LLC’s Sexual Harassment Policy.

Associate’s Printed Name: Position:

Associate’s Signature: Date: The signed original copy of this receipt should be given to management - it will be filed in your personnel file.

General Handbook Acknowledgment Form

I acknowledge that I have received a copy of the Adams Publishing Group’s Employee Handbook, and that I have an obligation to become familiar with its contents. I agree to conform to the rules, policies and procedures contained in the Employee Handbook. Furthermore, I understand that neither spoken nor written representations, including this Handbook, create any express or implied contract of employment between the Organization and me. I agree that my employment is voluntary or “at-will” * (some states do not apply as “at will” check with your locate human resources representative) so that I have the right to terminate my employment at any time with or without reason, and that the Organization has the same right.

I understand and agree that the provisions of this Handbook may be amended or revised at any time, without notice, at the Organization’s discretion, and that this Handbook is not an exhaustive statement of this Organization rules, policies or procedures.

Associate’s Printed Name: Position:

Associate’s Signature:

Date:

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