Employee Handbook

WA L L

G O L D FI N G ER

Employee Handbook Policies and Procedures

Revised January 2008

Distributed for the employees of WallGoldfinger, Inc. for internal use only.

TABLE OF CONTENTS I.

WallGoldfinger, Inc.

A Purpose 5

7 Belknap Street Suite 3 Northfield, VT 05663

II.

USA

Copyright ©2008 WallGoldfinger, Inc. Publisher: WallGoldfinger, Inc. Content created by Carol Edwards

The content of this guide is furnished for informational use only. Additional revised sections

B

Equal Employment Opportunity 7

C

Harassment 8

D Harassment by Non-Employees 11

Editorial content revised by Bill Miller

Design, photography and layout by Thor Goodrich

EMPLOYEE RELATIONS A Open Door 7

www.wallgoldfinger.com

Art Director: Chuck Weaver

INTRODUCTION

E III.

Requests for Accommodation 11

EMPLOYMENT A Orientation 13 B

Employee Classification 13

employee mailboxes.

C

Hours of Operation, and Rest and Meal Periods 14

This volume was produced entirely on an Apple

D Flextime Scheduling 14

will be updated quarterly and distrubuted in

Macintosh PowerPC G5 computer with Adobe®

E

Attendance 14

CLC-1180 printer

F

Non-Disclosure 15

Printed and bound inhouse by Carol Edwards and

G Performance Evaluations 16

InDesign® CS3 software and output to a Canon®

Thor Goodrich Second revised edition January 2008

H Tracking Time 16 I

Direct Deposit Options and Pay Advances 17

J

Payroll and Pay Deductions 18

K

Overtime 18

L

Shop Meetings 19

M Dress 19 N Workplace Violence 19

ii | CONTENTS

IV.

V.

SAFETY

P

A

Machine and Tool Safety Manual 21

Q Training 36

B

Safety Communication and Training 21

C

Safety Committee 21

A

Employee Personnel Files 39

D

Injury Reporting 22

B

Computer, Internet, Telephone Use Policy 39

E

Employee Responsibility 22

C

Conflict of Interest 40

F

Eye Protection Policy 22

D

Use of Phone and Mail Systems 42

EMPLOYEE BENEFITS

E

Use of Equipment 42

A

Leave Policy 25

F

Return of Property 42

B

Procedure for Requesting Time Off 25

G No Smoking 42

C

Vacation Leave 25

H

Visitors in the Workplace 42

D

Holidays 26

I

No Solicitation 43

E

Parental, Medical, Family Care, and Short-Term Family Leave 27

J

Recycling 43

K

Emergency Closings 43

F

Sick Leave 31 L

Travel Expense Reimbursement 44

VI.

Shop Use 35

MISCELLANEOUS

G Bereavement Leave 31 M WallGoldfinger Van Use 45 H

Jury Duty 31

I

Military Leave 32

J

Voting and Attendence at Town Meetings 32

K

Personal Leave 32

L

Insurance 32

VII. TERMINATION OF EMPLOYMENT A

Resignation 47

B

Involuntary Termination 47

C

Exit Interview 47

D

References for Future Employment 47

M Employee Assistance Program 34 N

401(K) 34

VIII. ACKNOWLEDGMENT

O Employee Purchases 34

CONTENTS

| iii

SECTION I. A

Introduction Purpose This Employee Handbook is intended to help you feel comfortable in your job and assist you in finding satisfaction in your job performance. We hope you find your work satisfying and rewarding. We look forward to a successful working relationship.

All employees are expected to carry out the performance of their duties in a professional, respectful, and competent manner. This handbook is intended to outline employment expectations for employees of WallGoldfinger. Questions regarding specific content of the handbook or about a particular policy or procedure should be directed to your immediate supervisor or the Vice President of Finance.

The WallGoldfinger Management Team retains the authority to lead the organization as it deems appropriate and necessary to accomplish the overall goals of the organization. The provisions of this Handbook are subject and subordinate to all applicable employment laws and regulations. WallGoldfinger may add to the policies in this Handbook or revoke or modify them at any time as it deems necessary based on operational or other needs. The information in this Handbook is presented solely for informational purposes. It is intended as a general guide for the day-to-day handling of employment-related matters. This Handbook, and its provisions, does not constitute a contract or a contractual commitment of continued employment.

Unless covered by a separately negotiated agreement, each employee of WallGoldfinger is considered to be in an “at will” employment status. This simply means that you can leave your employment at any time, with or without cause, and with or without prior notice. Likewise, WallGoldfinger may discharge any employee, with or without cause, and with or without notice, at any time for any lawful reason.

No circumstances arising out of your employment, including any written or verbal statements by your supervisor or co-workers, will alter the “at will” employment relationship.

Please read the contents of this Handbook carefully. During the course of your employment, you will want to refer back to it when you have a question.

You are responsible for becoming fully familiar with the policies contained in this Employee Handbook, and for maintaining awareness of any policy changes occurring after the effective date of this Handbook.

INTRODUCTION

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SECTION II. A

Employee Relations Open Door In order to maintain a productive and respectful work environment, WallGoldfinger encourages open communication among all employees. It is hoped that employees will feel free to identify issues of concern, and make suggestions and recommendations about work conditions and operations. Employees are also welcome to discuss issues of concern privately with their supervisor or with any member of the management team including the President, Production Manager, Director of Design Engineering, and Vice-President of Finance. If possible, such meetings should be scheduled in advance or at a time convenient to those involved.

If an employee has a work-related or interpersonal problem or concern with another co-worker, they are encouraged to first try working through the problem directly with the employee involved. If this is unsuccessful, employees are encouraged to bring the matter to the attention of their supervisor or directly to a member of the management team.

B

Equal Employment Opportunity WallGoldfinger provides employment opportunities without regard to race, color, religion, national origin, gender, gender identity, marital status, sexual orientation, ancestry, place of birth, age, or physical or mental disability, or any other basis protected by state or federal law.

This policy of equal opportunities applies to all terms and conditions of employment, including, but not limited to: recruitment, hiring, training, professional development, promotion, transfer, termination, layoff, recall or rehire, leaves of absence, compensation and benefits, and all other conditions and privileges of employment.

Management is primarily responsible for assuring that equal employment opportunity policies are implemented, but all employees are asked to share in that responsibility. Any employee determined to be involved in discriminatory practices will be subject to disciplinary actions, up to and including termination of employment.

If you perceive any discriminatory action or practice, please report them in accordance with the harassment policy below.

EMPLOYEE RELATIONS

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C

Harassment It is against these policies and illegal under state and federal law, for any employee, male or female, to sexually harass another employee. It is also a violation of this policy for an employee to engage in any other unlawful harassment based on those categories set forth in the Equal Employment Opportunity policy above. WallGoldfinger is committed to providing a workplace free from this unlawful conduct.

What is Sexual Harassment?

Sexual harassment is a form of sex discrimination and means unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when: a. submission to that conduct is made either explicitly or implicitly a term or condition of employment; b. submission to or rejection of such conduct by an individual is used as a component of the basis for employment decisions affecting that individual; or c. the conduct has the purpose or effect of substantially interfering with an individual’s work performance or creating an intimidating, hostile, or offensive working environment.

Examples of sexual harassment include, but are not limited to the following, when such acts or behavior come within one of the above definitions: • Either explicitly or implicitly conditioning any term of employment (e.g., continued employment, wages, evaluation, advancement, assigned duties or shifts) on the provision of sexual favors; • Touching or grabbing a sexual part of an employee’s body; • Touching or grabbing any part of an employee’s body after that person has indicated, or it is known, that such physical contact was unwelcome; • Continuing to ask an employee to socialize on-or off-duty when that person has indicated s/he is not interested; • Displaying or transmitting sexually suggestive pictures, objects, cartoons, or posters if it is known or should be known that the behavior is unwelcome; • Continuing to write sexually suggestive notes or letters if it is known or should be known that the person does not welcome such behavior; • Referring to or calling a person a sexualized name if it is known or should be

8 | EMPLOYEE RELATIONS

known that the person does not welcome such behavior; • Regularly telling sexual jokes or using sexually vulgar or explicit language in the presence of a person if it is known or should be known that the person does not welcome such behavior; • Retaliation of any kind for having filed or supported a complaint of sexual harassment (e.g., ostracizing the person, pressuring the person to drop or not support the complaint, adversely altering that person’s duties or work environment, etc.); • Derogatory or provoking remarks about or relating to an employee’s sex or sexual orientation; • Harassing acts or behavior directed against a person on the basis of his or her sex or sexual orientation; • Off-duty conduct which falls within the above definition and affects the work environment.

What WallGoldfinger will do if it learns of possible harassment In the event that a complaint of unlawful harassment is received, or we otherwise have reason to believe that unlawful harassment is occurring, we will take all necessary steps to ensure that the matter is promptly investigated and addressed.

We are committed, and required by law, to take action if we learn of potential unlawful harassment, even if the aggrieved employee does not wish to formally file a complaint. Everyone in a management or supervisory position is responsible for promptly responding to, and reporting, any complaint or suspected acts of unlawful harassment. All such complaints or suspected acts should be reported to a member of the Management Team including the President, Production Manager, Director of Project Management, and Vice President of Finance. Failure by a supervisor to appropriately report or address such harassment complaints or suspected acts shall be considered to be in violation of this policy.

Care will be taken to protect the identity of the person with the complaint and of the accused party or parties, except as may be reasonably necessary to successfully complete the investigation. It shall be a violation of this policy for any employee who learns of the investigation or complaint to take any retaliatory action, which affects the working environment of any person involved in this investigation.

If the allegation of unlawful harassment is found to be credible, WallGoldfinger will take appropriate corrective action. The complaining person and the accused person will be informed of the results of the investigation and what actions will be

EMPLOYEE RELATIONS

| 9

taken to ensure that the harassment will cease and that no retaliation will occur. Any employee, supervisor, or agent who has been found by the employer to have harassed another employee will be subject to sanctions appropriate to the circumstances, ranging from a verbal warning up to and including dismissal.

If the allegation is not found to be credible, the person with the complaint and the accused person shall be so informed, with appropriate instruction provided to each, including the right of the complainant to contact any of the state or federal agencies identified in this policy notice.

What employees should do if they believe they have been harassed?

Any employee who believes that she or he has been the target of sexual or any other form of unlawful harassment, or who believes she or he has been subjected to retaliation for having brought or supported a complaint of such harassment, is encouraged to directly inform the offending person or persons that such conduct is offensive and must stop. If the employee does not wish to communicate directly with the alleged harasser or harassers, or if direct communication has been ineffective, then the person with the complaint is encouraged to report the situation as soon as possible to their supervisor or a member of the Management Team including the President, Production Manager, Director of Project Management, and Vice President of Finance. It is helpful to an investigation if the employee keeps a diary of events and the names of people who witnessed or were told of the harassment, if possible.

If the complainant is dissatisfied with the final result, or is otherwise interested in doing so, she or he may file a complaint by writing or calling one of the following state or federal agencies: • Vermont Attorney General’s Office, Civil Rights Unit, 109 State Street, Montpelier, VT 05609, tel: (802) 828-3171 (voice/TDD). Complaints must be filed within 300 days of the adverse action. • Equal Employment Opportunity Commission, 1 Congress Street, Boston, MA 02114, tel: (617) 565-3200 (voice), (617) 565-3204 (TDD). Complaints must be filed within 300 days of the adverse action.

Either of these agencies can conduct impartial investigations, facilitate conciliation, and if it finds that there is probable cause or reasonable grounds to believe unlawful harassment occurred, it may take the case to court. Although employees are encouraged to file their complaint of harassment through the WallGoldfinger complaint process, an employee is not required to do so before filing a charge with these agencies.

10 | EMPLOYEE RELATIONS

Where can I get copies of this policy?

A copy of this policy will be provided to every employee, and extra copies are available from the Vice President of Finance.

D

Harassment by Non-Employees Any unlawful harassing or otherwise discriminatory behavior by customers, vendors, or any other third parties should be reported to your supervisor or member of the Management Team as soon as possible so that appropriate corrective action may be taken.

E

Requests for Accommodation WallGoldfinger prohibits discrimination against any qualified employee or job applicant with respect to any terms, privileges or conditions of employment because of a personĂ­s physical or mental disability.

If a potential or current employee believes that they will need an accommodation for a disability in order to perform the essential functions of their job, they must inform their supervisor or a member of the Management Team of that need and suggest a reasonable accommodation that will allow them to carry out the affected duties and responsibilities. Reasonable accommodations will be made for qualifying individuals with a disability of which we are aware in accordance with state and federal laws.

EMPLOYEE RELATIONS

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SECTION III. A

Employment Orientation The first ninety (90) days of employment with WallGoldfinger is considered to be an orientation period. During this time, employees are expected to become accustomed to their job expectations and responsibilities and are encouraged to determine whether the position meets their own expectations. Completing this period does not signify or imply a change in employment status and employees remain in an “at will” employment relationship.

There may be a waiting period before new employees are eligible for certain benefits. Any questions regarding benefits should be directed to your supervisor.

B

Employee Classification Regular full-time employees are those who are not in a temporary status and who are regularly scheduled to work WallGoldfingerís full-time schedule. Generally, they are eligible for WallGoldfingerís benefit package, subject to the terms, conditions, and limitations of each benefit program.

Regular part-time employees are those who are not assigned to a temporary status and who are regularly scheduled to work less than the full-time work schedule, but at least 20 hours per week. Regular part-time employees are eligible for some benefits subject to the terms, conditions and limitations of each benefit program.

Part-time employees are those who are not assigned to a temporary or introductory status and who are regularly scheduled to work less than 20 hours per week.

Part-time employees are not eligible for benefits except those required by law (such as Social Security and workersí compensation insurance).

Temporary employees are those who are hired as interim replacements, to temporarily supplement the work force, or to assist in the completion of a specific project. Employment assignments in this category are of a limited duration.

Employment beyond any initially stated period does not in any way imply a change in at-will or temporary employment status. Temporary employees retain that status unless and until notified of a change. Temporary employees are not eligible for benefits except those required by law.

Non-exempt employees are entitled to overtime pay of time and one-half their regular rate for hours worked over 40 in a workweek or as otherwise provided for in these policies.

EMPLOYMENT

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Exempt employees are not eligible for overtime pay requirements. An employeeís exempt or non-exempt classification may be changed only by written notification from WallGoldfinger management.

C

Hours Of Operation, And Rest And Meal Periods The normal work schedule for all shop employees is Monday–Friday, 8 hours between 7:00am–5:00pm. The normal work schedule for administrative staff is Monday–Friday, 8:00am–5:00pm.

Staffing needs and operational demands may necessitate variations in starting and ending time, as well as variations in the total hours that may be scheduled each day and week.

WallGoldfinger provides all regular full or part-time employees with one paid rest period of 20 minutes in length; for shop employees, this break starts at 9:30am, and other employees may take the break as work permits. Rest periods may need to be rescheduled or adjusted as necessary based on the operational needs of the organization. During such paid rest periods, employees must not be absent from their work station beyond the allotted rest period time.

All full-time regular employees are allowed one unpaid meal period of up to 60 minutes each workday. Supervisors will schedule or adjust meal periods as necessary to accommodate operating requirements. Employees are relieved of all active responsibilities and restrictions during meal periods and are not compensated for that time.

D

Flextime Scheduling Employees may request the opportunity to vary their work schedules. Flextime scheduling will be granted on an individual basis with consideration to departmental needs and company considerations. Flextime scheduling should represent a regular but adjusted schedule.

E

Attendance Regular attendance is considered an essential requirement of your employment.

Employees are expected to be in direct contact with or reachable by, their supervisor during the work day. Individual work schedules will be determined based on the operational needs of the organization.

On occasion, operational needs may require a longer than normal workday.

Employees will be expected to stay if necessary. Should an employee need to work additional hours to complete their duties, the additional hours must be approved in advance by their supervisor or the Manager.

14 | EMPLOYMENT

Unapproved absences or excessive tardiness may result in discipline, up to and possibly including termination. Except in extraordinary circumstances, an unapproved absence of three consecutive days without communication with their supervisor is considered job abandonment and will be considered a voluntary resignation of your position.

F

Non-Disclosure The protection of confidential business information and trade secrets is vital to the interests and the success of WallGoldfinger. Confidential information is to be discussed with no one outside the organization and only discussed within the organization on a “need to know” basis. In addition, employees have a responsibility to avoid unnecessary disclosure of non-confidential internal information about WallGoldfinger, our employees, and members. This responsibility is not intended to impede normal business communications and relationships, but is intended to alert employees about their obligation to use discretion to safeguard internal business affairs. Any employee who violates this policy is subject to discipline, up to and including termination of employment even if he or she does not actually benefit from disclosed information. Employees may be required to sign a separate confidentiality agreement.

Such confidential information includes, but is not limited to, the following examples: • Compensation data • Customer lists • Customer preferences • Employee information • Financial information • Marketing strategies • New materials research • Pending projects and proposals • Proprietary production processes • Research and development strategies • Technological data • Technological prototypes

EMPLOYMENT

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G

Performance Evaluations All employees are expected to carry out the performance of their duties in a professional, respectful, and competent manner. Working with your supervisor and knowing what is expected are the best ways of avoiding conflict and performance problems.

Employee job performance is evaluated on a continuing basis; however, a more formal evaluation process may take place periodically.

The primary reason for evaluations is to keep employees informed of their achievements, to offer guidance for defining and reaching performance goals, to reinforce good work habits, to acknowledge individual contributions, and to develop new goals.

Evaluations provide an opportunity for the employee and supervisor to have a clear understanding and agreement regarding performance. If necessary, specific performance improvement goals shall be established and recorded.

Corrective Action There are times, however, when performance or other behavior must be addressed in a more formal manner. Poor performance or behavior that does not meet expectations will be addressed and documented on an ongoing basis as appropriate. WallGoldfinger reserves the right to take corrective action which may include verbal or written warnings, suspension with or without pay, and possible dismissal. Employees may be suspended with or without pay in order to investigate any allegations of misconduct, violations of law, or WallGoldfinger policy. The specific circumstances in any particular situation will determine what action is taken up to and including termination of employment, however this does not alter the at-will nature of the employment relationship and both the employee and WallGoldfinger have the right to terminate the employment relationship at any time, with or without notice.

H

Tracking Time Time Clock Accurately recording time worked is the responsibility of every employee.

WallGoldfinger is required to keep an accurate record of time worked in order to properly calculate employee pay and benefits. Time worked is all the time actually spent on the job performing assigned duties. WallGoldfinger has a time clock for tracking the hours worked of all nonexempt employees. All nonexempt employees must use the time clock for accurately recording time worked at WallGoldfinger; time worked off-site must be documented and approved by your immediate supervisor.

We also use various software programs to allocate time to jobs. They are the basis of our job cost analysis system. We use “TimeLogger� for allocating your time to jobs and maintaining accuracy is critical.

16 | EMPLOYMENT

Nonexempt employees must accurately record the time they begin and end their work, as well as the beginning and ending time of each meal period. They should also record the beginning and ending time of any split shift or departure from work for personal reasons. Overtime work must always be approved before it is performed. Time will be paid to the nearest quarter hour as shown by the time clock stamp.

If you are a non-exempt employee and you must travel for your work at WallGoldfinger, you will be paid for a normal (8-hour) day plus time spent traveling (if the travel time plus time worked exceeds 8 hours). If overtime is required and is approved by your immediate supervisor, you will also be paid overtime if the total amount of hours worked exceeds 40 for the workweek.

You may not alter, falsify, or tamper with time records, or record time on another employeeĂ­s time record. It is your responsibility to sign your time record to certify the accuracy of all time recorded. If corrections or modifications are made to the time record, both you and your supervisor must verify the accuracy of the changes by initialing the time record.

Time Sheet All exempt employees must complete a daily time sheet recording all hours actually worked. It is your responsibility to deliver an accurate, completed time sheet to the time sheet slot next to the time clock by 10:00 PM of the day worked, or if working at home, to notify finance staff of time worked before they start work the next morning. If you pencil in time, in or out, by hand, the time sheet must be checked and initialed by the immediate supervisor.

I

Direct Deposit Options And Pay Advances You may have your paychecks electronically deposited in your bank account (direct deposit). See Finance Department for details.

You may submit a written request for a pay advance in the event of a personal emergency or hardship. You should discuss the nature of the need with the Vice-President of Finance. The supervisor will evaluate the request and, in his sole discretion, determine whether or not an advance can be granted. There is no specific limit on the amount of such an advance. However, it is rare for an advance to be greater than the following paycheck. Requests for advances greater than your regular paycheck must be approved by a member of the Management team.

You must sign a promissory note in the Finance Department to repay the advance. Interest will be charged to offset the cost of our administrative tasks associated with the advance.

EMPLOYMENT

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J

Payroll and Pay Deductions All employees are paid biweekly for time worked in the two weeks ending several days before the pay date.

WallGoldfinger must make certain deductions from your gross earnings. Among these are applicable Federal and State income taxes and Social Security contributions.

WallGoldfinger offers programs and benefits beyond those required by law. Eligible employees may voluntarily authorize deductions from their pay checks to cover the costs of participation in these programs.

Pay deductions may also be taken by WallGoldfinger as a means for you to repay a debt or obligation to WallGoldfinger. If you have questions concerning why deductions were made from your paycheck or how they were calculated, please discuss them with your supervisor or the Finance Department. In addition to statutory deductions (taxes, Social Security, child support), pay deductions may be taken for the following reasons: • to repay a pay advance; • to repay a tool or material purchase; • to repay a loan from your 401(k) account; or • to pay for voluntary benefits that you may enroll in.

It is WallGoldfingerís policy and obligation to pay all employees the proper amount owed for all time worked, including overtime. Employees must notify their immediate supervisor or the Manager as soon as possible if it is believed that an error has occurred in calculating their correct wages, overtime pay, or if any improper deductions have been made. WallGoldfinger will investigate all claims of inaccurate payments and take corrective action as is necessary to resolve any errors.

K

Overtime Occasionally WallGoldfinger may need you to work overtime. Overtime work for non-exempt employees must receive the immediate supervisorís prior authorization.

Overtime assignments will be distributed as equitably as practical to all employees qualified to perform the required work, subject to the production needs of the company.

Overtime compensation is paid to all nonexempt employees in accordance with federal and state wage and hour requirements. Overtime pay is based on actual hours worked. Time off on sick leave, vacation leave, or any leave of absence will not be considered hours worked for purposes of performing overtime calculations. Paid holiday time is considered hours worked for this purpose. Any errors in overtime pay must be

18 | EMPLOYMENT

reported to the Finance Department as soon as possible so that the matter can be investigated and corrective action taken as necessary.

L

Shop Meetings Shop meetings are held as necessary, depending on the amount of business to be covered during the meeting. You are required to attend these meetings, and you may bring topics concerning the business for discussion.

M

Dress WallGoldfinger expects all its employees to dress in an appropriately professional manner for each position. For initial contact with customers, WallGoldfinger administrative employees should always wear at least a dress slacks, dress shirt, or similar dress for women; after the initial contact, dressing to match the customerĂ­s dress may be appropriate, but employees should always strive to dress more formally than customers or other outside contacts. Shop employees should dress with safety in mind.

All employees should dress with consideration for fellow employees and for visitors. No clothing with inappropriate phrases or pictures is permitted. Any questions regarding appropriate dress or appearance should be directed to your supervisor.

N

Workplace Violence All employees, members, and vendors should be treated with courtesy and respect at all times. Employees are expected to refrain from conduct that may be threatening or dangerous to others.

All threats of (or actual) violence, both direct and indirect, are prohibited and should be reported as soon as possible to your immediate supervisor or to a member of the Management Team. If appropriate, threats of violence will be reported directly to law enforcement. When reporting a threat of violence, you should be as specific and detailed as possible. WallGoldfinger will promptly and thoroughly investigate all reports of threats of (or actual) violence and take action as appropriate.

EMPLOYMENT

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SECTION IV.

Safety To assist in providing a safe and healthful work environment for employees, customers, and visitors, WallGoldfinger has established a workplace safety program.

This program is a top priority for WallGoldfinger and its management. The supervisor of each division has a responsibility for implementing, administering, monitoring, enforcing and evaluating the safety program in conjunction with the Safety Committee. Maintaining a safe work place is the responsibility of all employees and depends on the continued alertness and personal commitment of all.

A

Machine and Tool Safety Manual WallGoldfinger provides a Machine and Tool Safety Manual to all employees.

Please refer to it for general safety standards and specific information on operating and using machines and tools. All employees are required to read this Manual, and to sign and turn-in the employee acknowledgement that they have received it.

B

Safety Communication and Training WallGoldfinger provides information to employees about workplace safety and health issues through regular internal communication channels such as supervisoremployee meetings, bulletin board postings, memos, email or other written communications.

Employees and supervisors receive periodic workplace safety training. The training covers potential safety and health hazards and safe work practices and procedures to eliminate or minimize hazards.

Some of the best safety improvement ideas come from employees. Those with ideas, concerns, or suggestions for improved safety in the workplace are encouraged to raise them with their supervisor, or with another supervisor or manager, or bring them to the attention of the Safety Committee or the owner. Reports and concerns about workplace safety issues may be made anonymously if the employee wishes.

Retaliation against any employee reporting concerns about workplace safety is prohibited. Any such retaliation may result in disciplinary action, up to and including termination of employment

C

Safety Committee WallGoldfinger has instituted a Safety Committee which is comprised of both management and employees of the company. The purpose of the Safety Committee

SAFETY

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is to create, communicate, and implement safe practice standards for the business. This includes establishing policy, and rules throughout the company.

D

Injury Reporting In the case of accidents that result in injury, regardless of how insignificant the injury may appear, employees should immediately notify the appropriate supervisor. A VT state form, First Report of Injury, must be filed within 24 hours; this form is available in the Finance Department, which is responsible for coordinating Workersí Compensation records. Except in the case of emergency treatment, this form must be completed before medical attention is obtained. Such reports are necessary to comply with laws and initiate insurance and Workersí Compensation benefits procedures.

Injuries sustained while working with WallGoldfinger tools or resources on personal projects are not within the scope of employment and will not be covered by Workersí Compensation. All such injuries, however, must be reported to the appropriate supervisor or member of the Management Team.

E

Employee Responsibility Each employee is expected to obey safety rules and standards and to exercise caution in all work activities as well as using WallGoldfinger tools or resources for personal projects. Employees must immediately report any unsafe condition to the appropriate supervisor. Use of safe work practices and procedures, personal protective equipment and prompt reporting of unsafe conditions or injuries are part of the review process which determines if employees are compliant. Employees who violate safety standards, who cause hazardous or dangerous situations, or who fail to report or (where appropriate) remedy such situations, including while working on personal projects, may be subject to disciplinary action, up to and including termination of employment.

F

Eye Protection Policy WallGoldfinger has a mandatory use of eye protection policy. All employees are required to wear eye protection that meets the ANSI Z87.1-1989 standard.

The policy requires all WallGoldfinger employees and visitors to wear eye protection in the following designated areas: • Finish Department • Woodworking Department, including the reassembly area • Veneer Department • CNC Department • Shipping & Receiving Department

22 | SAFETY

All employees and any visitors are required to wear eye protection full-time when in a designated area. Any employee operating equipment or using tools will be required to wear ANSI approved eye protection. Subcontractors are required to wear ANSI approved eye protection while working anywhere on the premises.

All administrative employees (employees that donít work in the shop) and visitors are required to wear eye protection when entering or passing through any “designated area.” Visitors include salespeople, consultants, or any other nonemployee. For practical purposes regular prescription eye glasses will qualify as suitable eye protection for conditions other than operating equipment or using tools. Individuals that do not wear prescription eye glasses must wear ANSI approved eye protection.

Face shields are required wherever there’s a severe danger of impact or chemical splash. Face shields are considered secondary protection and should always be used in conjunction with the primary protection of safety glasses.

Employees will be responsible for maintaining their eye protection in a clean and sanitary manor. Cleaning may be accomplished by using warm water with a mild soapy detergent then rinsing with clean water and drying of the frame and lenses with a clean dry paper towel. When safety glasses become too scratched for clear vision or become broken or damaged in any way please discard them and get a new pair.

WallGoldfinger provides ANSI approved eye protection at no cost to all employees and visitors. WallGoldfinger will reimburse production employees for reasonably priced prescription safety glasses. When selecting safety glasses always confirm that they meet the ANSI specification. (Most safety glasses available today meet the ANSI specification.)

SAFETY

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SECTION V. A

Employee Benefits Leave Policy Leave is defined as any absence that occurs during an employee’s regularly scheduled work hours or on a legal holiday that is approved by the immediate supervisor.

Leave is granted to regular or introductory employees in accordance with the policies outlined herein on the basis of the work requirements of the organization and, whenever possible, the personal needs of the employee. This section sets forth the current policies on leave and, like all other aspects of this Handbook is subject to change. When that occurs, affected employees will be given appropriate notice.

The President may make exceptions to leave policies based upon operational needs.

B

Procedure For Requesting Time Off Requests for permission to schedule vacation, personal, medical, or other kinds of leave shall be approved in advance by the employee’s immediate supervisor.

C

Vacation Leave Vacation time off with pay is available to regular full-time and part-time employees to provide opportunities for rest, relaxation, and personal pursuits.

Once you enter a regular full- or part-time employment classification, you begin to accrue paid vacation time according to the following schedule. Regular part-time employees accrue vacation leave proportionately to their standard work week The amount of paid vacation time you receive each year increases with the length of your employment as shown: Length of service

Hours earned per year

Allowed carryover

Allowed borrowing

0–5 year

80 (3.08/pay period)

80

40

6–10 years

120 (4.62/pay period)

80

40

11+ years

160 (6.15/pay period)

80

40

Your length of eligible service is calculated on the basis of a “benefit year.” This is the 12-month period that begins when you start to accrue vacation time. Your benefit year may be extended for significant leaves of absence, except military leave; military leave has no effect on this calculation. (See individual leave of absence policies for more information.)

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Paid vacation time can be used in any increments. To take vacation, you are required to request and receive advance approval from your supervisor. Six weeks notice must be given for one week of vacation; twelve weeks notice must be given for two consecutive weeks of vacation; requests for more than two consecutive weeks shall be reviewed by the Management Team. Requests will be reviewed based on a number of factors, including business needs and staffing requirements. If necessary, you will be asked to take vacations on dates other than those requested.

Vacation time is paid at your base pay rate at the time of vacation. A “day” of vacation is 8 hours; it does not include overtime or any special forms of compensation like incentives, commissions, bonuses, or shift differentials. If your available vacation is not used by the end of the benefit year, you may carry over a maximum of 80 hours; Carryovers greater than 80 hours must receive Management Team approval. Any hours carried over into a subsequent benefit year must be used in the first 6 months of the year.

You may borrow vacation time in advance of accrual within your benefit year up to a maximum of 40 hours with your supervisor’s approval.

If your employment at WallGoldfinger is terminated, you will be paid for unused vacation time accrued through your last day of work. If you have borrowed vacation time, it will be deducted from your final paycheck.

D

Holidays WallGoldfinger will grant holiday time off to all employees on the holidays listed below.

• New Year’s Day ( January 1) • Presidents’ Day (third Monday in February) • Memorial Day (last Monday in May) • Independence Day ( July 4) • Labor Day (first Monday in September) • Thanksgiving (fourth Thursday in November) • Day after Thanksgiving • Christmas (December 25) WallGoldfinger will grant paid holiday time off to all regular full-time and parttime employees. Holiday pay will be calculated based on the employee’s straight-time

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pay rate (as of the date of the holiday) times 8 hours (pro-rated for part-time employees).

If a recognized holiday falls on a Saturday or Sunday, WallGoldfinger will designate a Thursday, Friday or Monday for the holiday. You will receive holiday pay with your next regular paycheck.

If a recognized holiday falls during your paid absence (e.g., vacation, sick leave), paid holiday time will be utilized instead of the paid time off benefit that would otherwise have applied.

If you work on a recognized holiday, you will either receive holiday pay plus wages at their normal rate, or you may take that holiday at a later date. You must have permission from your supervisor to work on a holiday.

Paid holidays will be counted as hours worked for the purposes of determining overtime.

E

Parental, Medical, Family Care, Short-Term Family Leave Introduction WallGoldfinger provides eligible employees with up to 16 weeks of unpaid leave during a 12-month period relating to the birth or adoption of a child, or 12 weeks of unpaid leave during a 12-month period relating to the serious health condition of the employee, or the care of a seriously ill dependent, and additional short-term family leave consistent with Vermont and federal law.

Definitions For purposes of this section, an “immediate family member” shall mean a spouse, a party to a civil union, domestic partner, son, daughter, stepchild, foster child, parent, parent-in-law, a ward of the employee who lives in the employee’s home, or other close family member who resides in the employee’s home.

For purposes of this section, a “serious health condition” shall mean an illness, injury, impairment, or condition that includes any period of incapacity connected with an inpatient hospital stay or any period of incapacity involving continuing treatment by a health care provider.

For purposes of this section, “emergency” means circumstances where the required notice could have a significant adverse impact on the family member or the employee.

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Parental, Medical and Family Care Leave Eligibility In order to be eligible for leave under this policy, an employee must have been employed for at least one year and have worked at least 1,250 hours during the previous 12-month period.

Only one 12-week leave during each 12-month period (16 weeks for parental leave) is provided, even if more than one qualifying event has occurred. Additional leave beyond the 12-week period may be taken only with the approval of the Management Team.

Parental Leave An eligible employee shall be entitled to take 16 weeks of unpaid parental leave during the employee’s pregnancy and within one year following the birth or adoption of a child or the initial placement of a child under 18 years of age with the employee for the purpose of adoption or foster care of a child.

Parental leave may be taken intermittently or on a reduced schedule only with the approval of the Department Head. Although accrued leave can be used to supplement the work week, exempt employees who work a reduced schedule due to intermittent leave, shall be paid only for the hours they actually work during the work week. If intermittent or reduced schedule leave is used, the employee must give due consideration to potential disruption to his or her department due to his or her absence and the employee may be required to temporarily transfer to an available alternative position of equivalent pay and benefits which better accommodates recurring periods of leave.

Medical and Family Care Leave An eligible employee shall be entitled to take 12 weeks of unpaid medical leave if the employee is unable to work because of a serious health condition. An employee shall be entitled to take unpaid family medical care leave in order to care for an immediate family member with a serious health condition. Medical leave may be taken intermittently or by reducing the normal weekly or daily work schedule.

Notice From Employee And Certification From Physician An employee must provide reasonable notice to his or her Department Head of intent to take leave under this policy. In the case of parental leave, reasonable notice shall mean notice at least six weeks prior to the leave. In the case of medical leave, an employee must give at least 30 days prior notice of a leave which is foreseeable. In cases of emergency, the employee shall notify the Department Head as soon as practicable. All

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notices must include the date the leave is expected to commence and the estimated duration of the leave. A form shall be available from the Finance Department for this purpose.

An employee may be required to provide certification from the attending health care provider for the employee or the employee’s immediate family member supporting the need for medical leave and the estimated duration of the leave.

WallGoldfinger may require that the employee submit to a further examination to confirm the medical need for the leave under this policy.

After receipt of the notice from the employee and information from the treating physician, WallGoldfinger will confirm with the employee whether the requirements for leave under this section have been met and whether the leave taken by the employee shall be counted toward the 12 week period provided by this section.

Use of Accrued Paid Leave An employee may use available accrued leave time, including sick, vacation and personal leave. The use of accrued paid leave shall not extend the 12-week leave period provided by this section.

Continuation of Employee Benefits An employee shall continue to receive health care benefits including medical, dental and life during such leave under the same terms and conditions as if the employee was working. Should the employee elect not to return to work after the expiration of the leave period, the employee shall pay WallGoldfinger the cost of the insurance coverage during the leave period. If a returning employee exhausts their accrued leave and can no longer utilize paid time off, the cost of the employee’s contribution to WallGoldfinger’s benefit programs will be recouped by WallGoldfinger upon the employee’s return to work.

Return to Work An employee who wishes to return to work prior to the originally scheduled date shall give reasonable notice of his or her intent to return to work.

Except for an employee returning from caring for a family member, employees returning to work after a medical leave may be required to provide certification from the health care provider that he or she is able to perform all the essential functions of his or her employment. Consistent with other existing policies, WallGoldfinger may require that the employee complete a return to work examination with WallGoldfinger’s medical examiner or other health care provider designated by WallGoldfinger.

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An employee who fails to return to employment at the end of the leave period and who has not been granted a leave extension by WallGoldfinger will be subject to disciplinary action including termination.

All qualified returning employees shall be entitled to return to the same position or a position of like seniority, status and pay.

Short-term Family Leave In addition to the leave provided above, an employee shall also be entitled to take unpaid leave not to exceed 4 hours in any 30-day period and not to exceed 24 hours in any 12-month period for any of the following purposes: a. to participate in preschool or school activities directly related to the academic educational advancement of the employee’s child, stepchild, foster child, ward who lives with the employee, such as a parent-teacher conference. An employee may use available paid vacation or personal time for this leave at his/her discretion. b. to attend or to accompany the employee’s child, stepchild, foster child, parent, spouse, civil union partner, domestic partner or parent-in-law or ward who lives with the employee or the employee to routine medical or dental appointments.

An employee may use available paid vacation or personal time for this leave at his/her discretion. An employee may use sick time if the appointment cannot be scheduled outside of regular work hours. c. to accompany the employee’s parent, spouse, civil union partner, domestic partner or parent-in-law to other appointments for professional services related to their care and well-being. An employee may use available paid vacation or personal time for this leave at his/her discretion. An employee may use sick time if the appointment cannot be scheduled outside of regular work hours. d. to respond to a medical emergency involving the employee’s child, stepchild, foster child, parent, spouse, civil union partner, domestic partner or parent-inlaw or ward who lives with the employee or the employee. An employee may use available paid vacation or personal time for this leave at his/her discretion. An employee may use sick time if the appointment cannot be scheduled outside of regular work hours.

An employee may be required to take leave in a minimum of two-hour segments.

An employee shall make a reasonable attempt to schedule appointments for which leave may be taken under this subsection outside of regular work hours. In order to take leave under this section, an employee shall provide the Management Team with the earliest possible notice, but in no case later than seven days before the leave is to be

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taken, except in the case of an emergency.

F

Sick Leave Regular full-time employees are allowed 3 days sick leave at the beginning of each calendar year. Regular part-time employees accrue their 3 sick leave days in direct proportion to the number of hours worked. Unused sick leave days will accrue from year to year, to a maximum of 6 days. As in all other leave calculations, a “day” is 8 hours.

1. Sick leave may be used for employee illness, injury, counseling or disability.

Any consecutive use of medical leave for more than three full-time days, pro-rated for part-time employees, may require certification by an attending physician.

2. Sick leave may be used for medical and dental appointments which cannot be scheduled for non-working hours, and for situations of serious illness or death in the immediate family (see Bereavement Leave, below).

3. Sick leave may not be used as vacation time. Upon termination of employment employees will not be paid for accumulated, but unused sick leave time.

G

Bereavement Leave If you wish to take time off due to the death of a significant other person in your life, you should notify your supervisor immediately.

Up to one day of paid bereavement leave, and up to three days total leave, will be allowed to regular full-time and part-time employees. Bereavement pay is calculated based on the base pay rate at the time of absence and will not include any special forms of compensation, such as incentives, commissions, bonuses, or shift differentials.

Bereavement leave will normally be approved in the absence of unusual operating requirements. Any employee may, with the supervisor’s approval, use any available paid leave for additional time off as necessary.

H

Jury Duty WallGoldfinger encourages employees to fulfill their civic responsibilities by serving jury duty when required. Regular full-time and part-time employees who have completed a minimum of 180 calendar days of service will be paid for up to one week of jury duty leave over any two year period.

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Jury duty pay will be calculated on your base pay rate times 8 hours (pro-rated for part-time employees).

If you are required to serve jury duty beyond the period of paid jury duty leave, you may use any available paid time off (for example, vacation), or you may request an unpaid jury duty leave of absence.

You must show the jury duty summons to your supervisor as soon as possible, so that we may make arrangements to accommodate your absence. Employees are expected to report for work whenever the court schedule permits.

I

Military Leave Employees are entitled to a leave of absence in order to perform their service requirements as a member of the Reserve or National Guard military forces or are called or volunteer for active military duty. Employees must submit copies of their military orders to their Supervisor in order to qualify for military leave. Employees retain reemployment rights following completion of the military duty or training, according to applicable state and federal law. Employees who are members of the National Guard or on the Reserve List of any branch of the Federal Armed Forces, and who are requested to attend training camp will annually be allowed five (5) workdays paid military leave in addition to the employee’s normal vacation allotment. Payment for the first week of military leave shall be computed on the same basis as vacation pay. Additional military leave shall be without pay, or may be taken as vacation.

J

Voting And Attendence At Town Meetings Time off for voting will not be authorized, since adequate voting hours exist after working hours. You may use accrued vacation time for attending Town Meeting. You should notify your supervisors well in advance if you plan to attend. Time off will be granted with consideration to business needs.

K

Personal Leave If leave is required for reasons other than those described above, WallGoldfinger may provide a personal leave of absence without pay at the discretion of the Management Team.

L

Insurance Medical WallGoldfinger provides medical insurance to all regular full-time employees, and to regular part-time employees on a pro rata basis (for both premiums and any

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contributions towards medical expenses). You are eligible after one month of service, and coverage begins on the first day of the month following that one-month period. For more detailed information, please contact the Finance Department.

The specific form and terms of coverage may vary from year to year.

Dental WallGoldfinger provides dental insurance at shared cost to all regular full-time employees as a benefit of employment, and to regular part-time employees on a pro rata basis (for both premiums and any contributions towards dental expenses). For more detailed information, please contact the Finance Department. The specific form and terms of coverage may vary from year to year.

Life Insurance, Accidental Death and Dismemberment WallGoldfinger provides life insurance and AD&D insurance in the amount of $50,000 to all regular full-time employees. For more detailed information, please contact the Finance Department. The specific form and terms of coverage may vary from year to year.

Short-Term Disability Individual short-term disability insurance is provided for each regular full-time employee after one month of service, and ensures benefits after 7 days of disability for an illness, and immediately (0 days) for an accident. You must meet eligibility requirements of the insurer; underwriting rules determine the issuance date of the policy. The specific form and terms of coverage may vary from year to year.

Long-Term Disability Individual long-term disability insurance is provided for each regular full-time employee after one month of service and ensures benefits after 90 days of disability.

You must meet eligibility requirements of the insurer; underwriting rules determine the issuance date of the policy. The specific form and terms of coverage may vary from year to year.

Cafeteria/Flexible Spending Plan Regular full-time employees may choose benefits (generally medical and dental insurance premiums), and contribute a part of pretax salaries to an account for that purpose. This option allows employees to minimize the federal tax they must pay on specific allowed expenses.

The employee is solely responsible for ensuring such funds are spent or utilized in accordance with federal regulations.

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M

Employee Assistance Program WallGoldfinger provides an Employee Assistance Program (EAP) to all employees and their families to receive confidential and professional support for their personal problems. Employees and immediate family members are encouraged to use this voluntary program to improve their quality of life at home and in the work place.

All employees will be provided with contact information and instructions at the beginning of their employment.

N

401(K) WallGoldfinger provides access to a 401(k) tax-deferred retirement savings plan. Funds are invested in a family of mutual funds at your discretion with the advice on a quarterly basis of an outside professional. Employees may contribute up to the maximum allowed by IRS and Department of Labor regulations. Regular full-time employees are eligible after the first day of the calendar quarter following hire. WallGoldfinger may from time to time contribute either on a matching basis or on a profit-sharing basis, or may contribute nothing at its discretion.

O

Employee Purchases WallGoldfinger allows certain personal purchases using company accounts. These purchases include: • personal hand tools used in production • materials from inventory that cannot be purchased locally • materials from industrial suppliers that do not allow individual credit accounts • UPS/FedEx/postage All purchases from suppliers must be made through the purchasing agent using a WallGoldfinger purchase order and an Employee Purchase Request Form, signed by your supervisor. For personal UPS/FedEx/postage purchases please use the Transmittal-Personal Packages form.

WallGoldfinger values it credit relationships with vendors and suppliers. We use that credit relationship everyday to produce our products. Credit relationships include local and distant suppliers, banks and credit card companies. Please help us protect that relationship by respecting theseguidelines.

Materials From Inventory Each personal purchase from inventory must be documented on an Inventory Ticket,

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signed by the employee and supervisor. Supervisors will submit the inventory ticket to the accounting office. Materials may be purchased from inventory only if such use will not interfere with WallGoldfinger’s production needs.

Reimbursing The Company Personal purchases will be deducted from an employee’s paycheck over the next one or two pay periods, although hand tools may be deducted at $20 per pay period.

An employee’s balance, on all purchases, may not exceed $500. WG will assess Vermont state sales tax on all employee purchases (except shipping and postage).

Other important Credit issues: • All credit accounts with suppliers must be set up by the Finance Department.

• Employees may not use the company’s local store accounts for personal purchases. Local stores may be willing to give WallGoldfinger employees a discount.

• WallGoldfinger issues credit cards to the purchasing agent and some employees who travel on WallGoldfinger business. Employees may not use company cards for personal purchases. Credit card purchases will be reviewed and signed off by supervisors at the end of each month.

Payroll deductions may be made in accordance with the procedures listed above for payment of employee purchases. If an employee chooses to have a payroll deduction, he or she must clearly indicate on the purchase order or inventory ticket to “Deduct From Pay” your signature must also be present.

P

Shop Use Use of WallGoldfinger shop facility by full-time employees for personal projects is permitted with compliance to the following guidelines: • Employees are required to sign a release agreement before doing any personal work for any injuries incurred while working on personal projects.

• You must sign in and out of the log which is kept to record personal time worked in the shop.

• Non-employees are not permitted to be on the premises while you are working on personal projects without express approval. Such non-employees may be required to sign a release agreement prior to being permitted to be on the premises.

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• No personal projects should be done during lunch hour or before the work shift on scheduled work days.

• You are not permitted to run an ongoing business out of the WallGoldfinger shop.

• All personal work should cease by 10pm on any given day.

• All personal projects must be stored out of the way of WallGoldfinger production needs; all work areas used for personal projects must be cleaned up before the next work day begins.

• All safety precautions and guidelines must be followed while working on personal projects.

Q

Training WallGoldfinger may from time to time provide you with training to improve your performance on the job, or to improve general awareness of important topics. This training will be available depending on the overall budget for the year, and may cover such topics as First Aid, Sexual Harassment, or specific job-related issues. See your supervisor if you have suggestions for training that would help your job performance.

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SECTION VI. A

Miscellaneous Employee Personnel Files WallGoldfinger maintains a personnel file on each employee. The personnel file includes information such as the employee’s job application, resume, record of training, documentation of performance appraisals and salary increases, and other employment records.

Personnel files are the property of WallGoldfinger, and access to the information they contain is restricted. Generally, only supervisors and management personnel of WallGoldfinger who have a legitimate reason to review information in a file are allowed to do so. WallGoldfinger grants employees the right to view their individual file under the supervision of the Vice-President of Finance or designee subject to operational needs. Employees do not have the right to, add to, respond or make changes to their individual personnel file.

Employees who wish to review their own file should contact their supervisor.

B

Computer, Internet, Telephone Use Policy All electronic and telephonic communication and computer systems (including e-mail, voice mail, Intranet, Internet) and all communications and information transmitted by, received from, or stored in the WallGoldfinger’s systems are the property of WallGoldfinger, and as such are to be used solely for job-related purposes. The use of any software and business equipment (including but not limited to fax machines, printers, computers, telephones, and copy machines) for private purposes is strictly forbidden, unless expressly permitted by a member of the WallGoldfinger Management Team.

Employees using the Internet and phone systems represent WallGoldfinger in their communications. Communications during working hours will be for professional reasons. Employees are responsible for seeing that all systems are used in an effective, ethical, and lawful manner. The telephones, internet or email may be used to conduct official company business or to gain technical or analytical information.

Databases may be accessed for information as needed. E-mail may be used for business contacts during work hours and personal contacts during non-work hours.

The Internet or other WallGoldfinger systems and hardware should not be used for personal gain, advancement or to promote individual views. Solicitation of non-company business or any use of WallGoldfinger systems and hardware for

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personal gain is strictly prohibited. Use of the Internet must not disrupt the operation of the company network or the networks of other users. It must not interfere with your productivity, and games of any kind shall not be played during working hours.

To prevent computer viruses from being transmitted through the system, employees are prohibited from downloading and/or installing any unauthorized software.

All software downloads and/or installations must be approved in advance by the Vice President of Finance.

The entire e-mail system is backed up every night for disaster recovery purposes.

The backup media follow a standard WallGoldfinger retention cycle, and are not intended for long-term archive. Long-term document archive is the responsibility of individual users. Please discuss your long-term archival needs with the Management Team if you feel your position’s needs are not being met.

All messages created, sent, or retrieved over the Internet or via email are the property of the WallGoldfinger and should not be considered private. WallGoldfinger reserves the right to access, inspect, monitor, copy, disclose, or delete any documents, information, or messages transmitted or stored on WallGoldfinger computer or email system as deemed necessary and appropriate. Internet messages are public communication and are not private. All communication including text and images can be disclosed to law enforcement or other third parties without prior consent of the sender or the receiver.

Harassment of any kind is prohibited. Employees must not use the electronic communications system in any illegal, obscene, harassing or discriminatory way, and must not use it in any manner that is a violation of WallGoldfinger’s Harassment and Discrimination policies. Employees are not to transmit material in violation of any state or federal law or government regulation. Employees shall not disguise their identity when creating or transmitting messages or material on or from the WallGoldfinger’s equipment. All employees are required to report misuse of the systems to their supervisor or a member of the Management Team.

C

Conflict Of Interest All employees are expected to avoid activities that create an actual, or an appearance of a conflict of interest with their responsibilities to WallGoldfinger. WallGoldfinger also expects that its employees will observe the highest moral and ethical standards in business dealings on its behalf.

WallGoldfinger recognizes and respects each employee’s right to privacy and to engage in personal activities outside the scope of his or her employment. Each employee

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also has an obligation, however, to refrain from activities that conflict or interfere with the WallGoldfinger’s operations. We reserve the right to determine when an activity conflicts with WallGoldfinger interests and to take whatever action is necessary to resolve the conflict, up to and including termination of employment.

Employees who are aware of conflict of interest violations or suspected violations are obligated to report them to their Supervisor or the Management Team immediately. Those who fail to do so may be subject to discipline, up to and including termination of employment. The confidentiality of all employees reporting conflicts of interest will be protected to the extent possible.

An employee involved in any actual or potential conflict of interest should immediately and fully disclose the relevant circumstances to his/her immediate Supervisor or the Management Team so that a determination as to whether a potential or actual conflict exists. If WallGoldfinger determines that such a potential or actual conflict exists, appropriate corrective action will be taken based on the circumstances.

Employment of Family Members The employment of immediate family members or partners in an organization can lead to conflicts and problems with favoritism and employee morale.

WallGoldfinger prohibits any direct reporting relationship between immediate family members unless specifically authorized by the President.

Outside Employment Employees may hold outside jobs so long as the standards of your job at WallGoldfinger are met. All employees will be subject to performance standards applicable to their positions and will be subject to WallGoldfinger’s scheduling demands, regardless of existing outside work requirements.

If WallGoldfinger determines that your outside work interferes with performance or the ability to meet the requirements of WallGoldfinger as they are modified from time to time, you may be asked to terminate the outside employment if you wish to remain with WallGoldfinger.

Outside employment that constitutes a conflict of interest is prohibited.

You may not receive any income or material gain from individuals outside WallGoldfinger for materials produced or services rendered while performing a job that could otherwise be performed by WallGoldfinger. Employees may be required to enter into a non-compete agreement as a condition of employment.

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D

Use Of Phone And Mail Systems You may be required to reimburse WallGoldfinger for any charges resulting from your personal use of the telephone or postage systems.

To assure effective telephone communications, you should always use the approved greeting and speak in a courteous and professional manner. Please confirm information received from the caller, and hang up only after the caller has done so.

WallGoldfinger reserves the right to monitor any voicemail messages on its voicemail system at any time.

E

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

Please notify the supervisor if any equipment, machines, or tools appear to be damaged, defective, or in need of repair. Prompt reporting of damages, defects, and the need for repairs could prevent deterioration of equipment and possible injury to employees or others. The supervisor can answer any questions about an employee’s responsibility for maintenance and care of equipment used on the job.

F

Return Of Property Employees are responsible for all property, materials, or written information issued to them or in their possession or control. All WallGoldfinger property must be returned by employees on or before their last day of work.

G

No Smoking In keeping with WallGoldfinger intent to provide a safe and healthful work environment, smoking is prohibited throughout the workplace. Smoking may only take place in designated areas.This policy applies equally to all employees, customers, and visitors.

H

Visitors In The Workplace To provide for safety and security of employees and the facilities at WallGoldfinger, only authorized visitors are allowed in the workplace. Restricting unauthorized visitors helps maintain safety standards, protects against theft, ensures security of equipment, protects confidential information, safeguards employee welfare, and avoids potential distractions and disturbances.

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All visitors should enter WallGoldfinger at the reception area. Authorized visitors will receive directions or be escorted to their destination. Employees are responsible for the conduct and safety of their visitors, including wearing safety glasses. All visitors are required to sign in and out when they enter and leave WallGoldfinger.

If an unauthorized individual is observed on WallGoldfinger’s premises, employees should immediately notify their supervisor or, if necessary, direct the individual to the reception area.

I

No Solicitation In an effort to assure a productive and harmonious work environment, persons not employed by WallGoldfinger may not solicit or distribute literature in the workplace at any time for any purpose.

WallGoldfinger recognizes that you may have interests in events and organizations outside the workplace. However, you may not solicit or distribute literature concerning these activities during working time. (Working time does not include lunch periods, work breaks, or any other periods in which employees are not on duty.)

J

Recycling WallGoldfinger supports environmental awareness by encouraging recycling and waste management in its business practices and operating procedures. This support includes a commitment to the purchase, use and disposal of products and materials in a manner that will best utilize natural resources and minimize any negative impact on the earth’s environment.

K

Emergency Closings At times, emergencies such as severe weather, fires, power failures, or earthquakes, can disrupt company operations. In extreme cases, these circumstances may require the closing of WallGoldfinger’s work facility.

When operations are officially closed due to emergency conditions, the time off from scheduled work will be unpaid. However, with supervisory approval, you may use available paid leave time, such as unused vacation benefits. Employees in essential operations may be asked to work on a day when operations are officially closed. In these circumstances, employees who work will receive regular pay.

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L

Travel Expense Reimbursement WallGoldfingerwill reimburse for reasonable business travel expenses incurred while on assignment away from the normal work location. All business travel must be approved in advance by your immediate supervisor. Employees whose travel plans have been approved must make all travel arrangements through WallGoldfinger.

When approved, the actual costs of travel, meals, lodging and other expenses directly related to accomplishing business travel objectives will be reimbursed by WallGoldfinger. Employees are expected to limit expenses to reasonable amounts.

Expenses that generally will NOT be reimbursed include the following: • Travel in 1st class.

• Car rental fees for large cars.

• Taxi fares when there is a less expensive alternative.

• Mileage costs for use of personal cars when the WallGoldfinger van or less expensive transportation is available.

• Cost of accommodations in high-priced hotels.

• Cost of meals more lavish than would be eaten at the employee’s own expense.

• Tips exceeding 15% of the total cost of a meal or 10% of a taxi fare.

• Charges for telephone calls, fax and similar services not required for business purposes.

• Charges for more than one personal telephone call per day.

• Charges for laundry and valet services on trips of less than five days.

• Personal entertainment and personal care items.

Employees who are involved in an accident while traveling on business must promptly report the incident to their immediate supervisor. Vehicles owned, leased, or rented by WallGoldfinger may not be used for personal use without prior approval.

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Cash advances to cover reasonable anticipated expenses may be made after travel has been approved. You should submit a written request to your supervisor when travel advances are needed.

With prior approval, employees on business travel may be accompanied by family member or friend, when the presence of a companion will not interfere with successful completion of business travel, as long as time away from work is approved. Additional expenses arising from such non-business travel are your responsibility.

When travel is completed, employees should submit completed travel expense reports within 14 days. Reports should be accompanied by receipts for all individual expenses of ten dollars or more.

Employees should contact their supervisor for guidance and assistance on procedures related to travel arrangements, travel advances, expense reports, reimbursement for specific expenses, or any other business travel issue.

M

WallGoldfinger Van Use The company van is for Project Managers and Sales staff, in order to save money on renting cars. In addition to Project Managers and Sales staff, we expect that Shipping and Purchasing staff will have local uses for it when it is available. The Company van is not available for personal use.

Project Management (PM) support staff is responsible for scheduling and maintenance. For insurance purposes, we need name, Driver’s License Number, Date of Birth and Marital Status for regular drivers. PM support staff will schedule the van use. Authorized users can check its availability online.

For those who are authorized to use it, please use it as often as possible to avoid renting—drive carefully—and leave it at least as clean and orderly as you find it.

We will not reimburse personal mileage when the van was available.

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SECTION VII. A

Termination of Employment Resignation WallGoldfinger understands that it may become necessary for you to leave your employment. Employees are requested to provide at least four weeks notice of their last day of employment. WallGoldfinger reserves the right to provide a resigning employee with pay in lieu of continued employment through the requested notice period. Offers to resign accepted by WallGoldfinger, whether verbal or written, may not be rescinded without the express approval of the President.

Employees who give less than the requested notice will have their payout of any accrued, but unused vacation time reduced by a corresponding amount. Unused sick leave is not paid out to the employee upon termination of employment.

Employees who resign will be paid for all wages earned to date on the next regular payday.

B

Involuntary Termination Employees whose employment is terminated due to misconduct shall not be paid for any accrued, but unused vacation time upon their dismissal. Employees whose employment is terminated involuntarily for other reasons such as poor performance or a lay off, may be paid for their accrued, but unused vacation time with the approval of the President, up to 80 hours. The employee will be paid for all other wages earned to date within 72 hours of dismissal.

C

Exit Interview Upon termination of employment, employees or management may schedule an exit interview to discuss the employee’s reasons for leaving and any other impressions that they may have about their employment experience at WallGoldfinger.

D

References for Future Employment WallGoldfinger will respond to reference requests on former employees by confirming dates of employment and positions held unless specific approval is received from the President to release additional information. Requests for references should be referred to the previous employee’s immediate supervisor and to the Vice President of Finance.

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SECTION VIII.

Acknowledgment I have received a copy of the WallGoldfinger Employee Handbook. I have read it and understand the policies contained in it and my responsibility to follow all policies. I have had an opportunity to ask questions about and discuss the policies with my supervisor, Vice-President of Finance or other member of the Management Team.

I understand that this revised Employee Handbook is not a contract of employment, express or implied, between WallGoldfinger and me and that I should NOT view it in any manner to be a contract of employment.

I understand that this employee handbook takes precedence over, supersedes and revokes all previous versions of a handbook or employment policies. I also understand and agree that WallGoldfinger reserves the right to change or alter the policies at any time.

I also understand and agree that my employment is “at-will� for no definite period and that either I or WallGoldfinger, regardless of the time and manner of payment of my wages or salary, can terminate the employment relationship for any lawful reason, with or without cause, and with or without any previous notice.

It is my understanding that only the President has the authority to enter into an agreement with me for employment for any specified period of time or to make any agreement contrary to the foregoing.

Employee Signature

Date

Print Name

JANUARY 2008

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