CONTENTS

1.0 INTRODUCTION ................................................................................................................... 3

1.1 The Purpose of the Handbook ...................................................................................................... 3
2.0 TERMS AND CONDITIONS OF EMPLOYMENT ............................................................ 3
2.1 Employee Relations ........................................................................................................................ 3
2.2 Employment Categories ................................................................................................................. 4
2.3 At-Will Employment......................................................................................................................... 4
2.4 Non-Disclosure of Confidential and Proprietary Information .................................................... 5
2.5 Equal Employment Opportunity .................................................................................................... 6
2.6 Native American Preference.......................................................................................................... 6
2.7 Veteran Preference ......................................................................................................................... 7
2.8 Employment of Relatives ............................................................................................................... 7
2.9 Americans with Disabilities Act (ADA) ......................................................................................... 7
2.10 Immigration Law Compliance ...................................................................................................... 8
2.11 Conflict of Interest ......................................................................................................................... 8
2.12 Employment Applications ............................................................................................................ 8
2.13 Job Posting and Recruitment ...................................................................................................... 8
2.14 Employment Reference and Background Checks ................................................................... 9
2.15 Employee Orientation ................................................................................................................... 9
2.16 Outside Employment .................................................................................................................... 9
2.17 Work Schedules ............................................................................................................................ 9
2.18 Overtime ....................................................................................................................................... 10
2.19 Timekeeping ................................................................................................................................ 10
2.20 Meal Periods ................................................................................................................................ 11
2.21 Paydays ........................................................................................................................................ 11
2.22 Administrative Pay Corrections................................................................................................. 11
2.23 Pay Deductions ........................................................................................................................... 11
2.24 Direct Deposit .............................................................................................................................. 12
2.25 Telecommuting ............................................................................................................................ 12
2.26 Access to Personnel Files ......................................................................................................... 13
2.27 Personnel Data Changes........................................................................................................... 14
2.28 Resignation .................................................................................................................................. 14
2.29 Employment Termination ........................................................................................................... 14
2.30 Return of Property....................................................................................................................... 15
3.0 EMPLOYEE BENEFITS PROGRAM ............................................................................... 15
3.1 Introduction to Employee Benefits .............................................................................................. 15
3.2 Paid Time Off (PTO) Donation .................................................................................................... 16
3.3 Holidays .......................................................................................................................................... 16
3.4 Workers’ Compensation Insurance ............................................................................................ 16
 3.5 OCONUS Employee Benefits...................................................................................................... 16
3.6 Training and Development........................................................................................................... 17
3.7 Employee Referral Bonus Program............................................................................................ 17
4.0 LEAVE TIME ........................................................................................................................ 17
4.1 Paid Time Off (PTO) ..................................................................................................................... 17
4.2 Maximum Time Accumulate ........................................................................................................ 19
4.3 PTO Taken Due to Illness ............................................................................................................ 20
4.4 Family and Medical Leave Act (FMLA) ...................................................................................... 20
4.5 Personal Leave/Non-FMLA ......................................................................................................... 21
4.6 Bereavement Leave ...................................................................................................................... 21
4.7 Jury Duty Leave............................................................................................................................. 21
4.8 Witness Duty Leave ...................................................................................................................... 22
4.9 Military Leave ................................................................................................................................. 22
4.10 Elections / Voting ........................................................................................................................ 23
4.11 Inclement Weather / Liberal Leave .......................................................................................... 23
5.0 ACCEPTABLE AND EXPECTED BEHAVIOR .............................................................. 23
5.1 Attendance and Punctuality ......................................................................................................... 23
5.2 Drug and Alcohol Use................................................................................................................... 23
5.3 Workplace Violence Prevention .................................................................................................. 24
5.4 Smoking .......................................................................................................................................... 25
5.5 Personal Appearance ................................................................................................................... 25
5.6 Standard of Conduct for Language ............................................................................................ 25
5.7 Code of Conduct ........................................................................................................................... 26
5.8 Ethics .............................................................................................................................................. 27
5.9 Sexual and Other Unlawful Harassment ................................................................................... 27
5.10 Problem Resolution .................................................................................................................... 29
6.0 SAFE WORK ENVIRONMENT ......................................................................................... 30
6.1 Safety .............................................................................................................................................. 30
6.2 Workplace Security ....................................................................................................................... 30
7.0 MISCELLANEOUS ............................................................................................................. 31
7.1 Access Card ................................................................................................................................... 31
7.2 Solicitation, Distributions, and Use of Bulletin Boards............................................................. 31
7.3 Business Travel Expense ............................................................................................................ 31
7.4 Company Related Purchase Expense Reimbursement .......................................................... 33
7.5 Company Owned, Rented or Personal Vehicle Use................................................................ 33
7.6 Use of Phones and Mail System................................................................................................. 34
7.7 Mobile Phone and Mobile Phone Policy .................................................................................... 34
7.8 Electronic Mail and Computer Services ..................................................................................... 34
7.9 Internal Investigations and Searches ......................................................................................... 38
 7.10 Emergency Closings................................................................................................................... 38
7.11 Emergencies ................................................................................................................................ 39
8.0 EMPLOYEE RESPONSIBILITIES ................................................................................... 39
8.1 Gift Policy ....................................................................................................................................... 39
8.2 Internal Investigations and Searches ......................................................................................... 39
8.3 Corrective Discipline and Discharge .......................................................................................... 39
8.4 Solicitation ...................................................................................................................................... 40
8.5 Employee Conflict Resolution ..................................................................................................... 40
9.0 EMPLOYEE ACKNOWLEDGEMENT FORM ................................................................ 42
Welcome to Waseyabek Federal Services, LLC!
Please allow me to be the first to wish you a successful and rewarding work experience
with Waseyabek Federal Services, LLC (WFS). It’s an exciting time for us as we
experience rapid growth in the federal sector. As we expand into new markets and new
geographical locations, we remain committed to economic diversification and revenue
generation to support the Nottawaseppi Huron Band of the Potawatomi (NHBP) Tribal
economy and Tribal members.
Each WFS employee contributes directly to the success of the entire organization and
accordingly, I have high expectations for individual performance and measurable
results. In return, I am committed to delivering strong, responsive, and direct
leadership to unify the team, foster great relationships, and responsibly allocate
resources. In short, we will succeed together.
This employee handbook was designed to provide you with a set of guidelines and
expectations as you begin your journey with us. Please familiarize yourself with its
contents and feel free to ask your Supervisor or Human Resources Representative if
you have questions.
Thank you for placing your trust in WFS to further your career goals. I look forward to
working with you.

Sincerely,

Deidra Mitchell
President

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1.0 INTRODUCTION
1.1 The Purpose of the Handbook
This Employee Handbook contains general information and guidelines. It is not
intended to be comprehensive or to address all the possible applications of, or
exceptions to, the general policies, procedures, and programs of Waséyabek Federal
Services (WFS). For that reason, if questions arise concerning eligibility for a
particular benefit, or the personal applicability of a policy or practice, please address
your specific questions to your Supervisor or the Human Resources Department.
Policies set forth in this handbook are not intended to create a contract, nor are they
to be construed to constitute contractual obligations of any kind or a contract of
employment between WFS and any of its employees. Absent any separate
agreement to the contrary as authorized by Section 2.3, all employment with WFS is
at-will.
WFS reserves the right to withdraw or change the policies, procedures, benefits, and
working conditions described in this handbook at any time, for any reason, and
without prior notice. WFS will make every effort to notify employees when an official
change of policy or procedure has been made but employees are responsible for their
own up-to-date knowledge about Company policies, procedures, benefits, and
working conditions. A copy of the employee handbook with any current updates will
be available from your Supervisor or in the Employee Portal section of the website
www.wfedservices.com
This employee handbook and information in it should be treated as confidential. No
portion of the employee handbook should be disclosed to others except WFS
employees and others affiliated with WFS whose knowledge of the information is
required in the normal course of business.

2.0 TERMS AND CONDITIONS OF EMPLOYMENT

2.1 Employee Relations
WFS strives to achieve the highest level of working conditions. If employees have
concerns about work conditions or compensation, they are strongly encouraged to voice
these concerns openly and directly to their Supervisor. Our experience has shown that
when employees deal openly and directly with Supervisors, the work environment can
be excellent, communications can be clear, and attitudes can remain positive. We
believe that WFS demonstrates its commitment to employees by its actions in
responding to employee concerns.

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2.2 Employment Categories
It is the intent of WFS to clarify the definitions of employment classifications so
employees understand their employment status and benefit eligibility. These
classifications do not guarantee employment for any specified period of time.
Accordingly, the right to terminate the employment relationship at will at any time is
retained by both the employee and WFS.

Each employee is designated as either non-exempt or exempt from federal wage and
hour laws. Non-Exempt employees are entitled to overtime pay under the specific
provisions of federal law. Exempt employees are excluded from specific provisions of
federal wage and hour law. An employee's exempt or non-exempt classification may be
changed only upon written notification by WFS management. Each employee will be
told their employment classification at the time of employment.

In addition to the above categories, each employee belongs to one of the following
employment categories:

Regular Salaried Full-Time employees are those who are regularly scheduled
to work a full-time schedule, working a minimum of 40 hours per week.
Generally, these employees are eligible for the benefit package, subject to the
terms, conditions, and limitations of each benefit program.

Full-Time employees are those who work less than a regular (40) hour work
week.

Part-Time Hourly Part-time employees must work a consistent 30 hours per

week to be eligible for benefits.

Service Contract Act (SCA) employees work full or part time, are paid on an
hourly basis, and receive health and welfare compensation in lieu of participation
in legally mandated benefit programs, based upon contractual obligations.

Casual employees have established an employment relationship and work on an

intermittent and/or unpredictable basis. This category includes interns.

2.3 At-Will Employment

WFS maintains an employment-at-will policy. During the term of employment,
employees are free to leave WFS at any time for any reason, and WFS reserves a
similar right. Thus, either the employee or WFS will have the right to terminate
employment at any time, with or without advance notice and with or without cause.
This is called “employment-at-will,” and no person other than an authorized
representative has the authority to alter this agreement, to enter into an agreement for
employment for a specified period of time, or to make any agreement contrary to this

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policy. Furthermore, any such agreement must be in writing and must be signed by an
authorized representative of WFS.

Notwithstanding this policy, as a courtesy, both the employee and WFS should give the
other as long a notice of employment separation as the circumstances and general
professional courtesy permit.

WFS requires the execution of an Employee Acknowledgment Form reflecting receipt,

understanding and agreement of this employee handbook by employees in all positions.

2.4 Non-Disclosure of Confidential and Proprietary Information

While a variety of information handled may seem routine, it could be proprietary and
should not leave the Company in written, verbal or any other form. Examples include,
but are not limited to, technical know-how, future business plans, computer passwords
or access codes, customer or employee lists, financial information, personal information
about employees, organization charts, details of sales proposals, pricing of items and
other information can, if disclosed, affect WFS competitive edge. As a condition of
employment, all WFS employees and consultants conducting work on behalf of WFS are
required to sign a confidentiality, proprietary information and assignment agreement in
order to protect WFS and its customers.

We expect all employees to exercise prudence and good judgment when handling
company confidential, proprietary, or sensitive information. These guidelines include
but are not limited to:

• Restrict the distribution of confidential, proprietary or sensitive information only to

those within the Company with the need to know or who have a legitimate use
for it.
• Only authorized WFS executives may provide confidential information to the
public.
• Adherence to all Company security procedures.
• Protect all client or government classified materials in accordance with Company
and industrial security procedures.
• Mark and handle Company confidential and sensitive documents accordingly.
• Clear all work areas at night or when unattended.
• Maintain the privacy and confidentiality of computer access codes and passwords.
Use computing resources only for purposes authorized by WFS.
• Protect computer data, documents and storage media in your possession.
• File sensitive material in locked cabinets.

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Additionally, restrictions are imposed on the acceptance, protection and control of
classified documents according to the federal laws and regulations. Breach of security
must be reported to the Corporate Security Officer or any other Facility and/or Client
Security Officer as deemed appropriate.

2.5 Equal Employment Opportunity

It is the policy of WFS to select, place, train, and promote the best qualified
individuals based upon such job-related factors as work, quality, attitude, and
experience. Factors not relevant to WFS in measuring its applicants or its employees
include age, race, religion, creed, sex, color, handicap, national origin, marital status,
sexual orientation, ancestry, physical appearance, or any other factor protected
under applicable law.
The policy of Equal Employment Opportunity applies to all policies and procedures
relating to recruitment and hiring, promotions, compensation, benefits, termination
and all other terms and conditions of employment.

Any employees with questions or concerns about any type of discrimination in the
workplace are encouraged to bring these issues to the attention of their Supervisor or
a member of the Human Resources Department. Employees may raise concerns and
make reports without fear of retaliation. Anyone found to be engaging in any type of
unlawful discrimination or retaliation will be subject to disciplinary action, up to and
including termination of employment.

2.6 Native American Preference

Federal law permits Native American Corporations to practice preferential hiring of
Native Americans under certain conditions. WFS is 100% tribally-owned by the
Nottawaseppi Huron Band of Potawatomi and accordingly, has established Board-
sanctioned hiring goals. It is the responsibility of the applicant to identify their Tribal
affiliation at the time of application.

Native American Hiring Preference will be applied based on the following:

• Individual meets the minimum qualifications
• Enrolled members of the Nottawaseppi Huron Band of the Potawatomi (NHBP)
• Parents or Spouses of NHBP Tribal members; or
• Enrolled members of another federally recognized Indian Tribe
WFS Native American preference practices do not diminish WFS commitment to anti-
discrimination and equal-opportunity-policy adherence. Each manager is expected to
make every effort to identify, hire, train, and promote qualified candidates, and to
ensure equal opportunity.

The legal authority for Indian Preference can be found in Title 25, United States Code
(USC) 472, 472a., and 47; Title 25, Code of Federal Regulations, Part 5 and the

6
Constitution and laws of the Band.

2.7 Veteran Preference

Former military personnel or their spouse that have been verified as a “veteran” under
Michigan Civil Service Commission Rule 3-8; will receive an interview if they meet the
minimum competency factors of the position. The veterans’ preference laws do not
guarantee the veteran a job. Positions are filled with the best qualified candidate as
determine by the hiring manager.

2.8 Employment of Relatives

In keeping with WFS commitment to participate in preferential hiring of Tribal Members,
as permitted by law, the instance may arise where qualified relatives may work for
WFS, or one of its subsidiaries. However, where one relative would supervise another,
or where bona fide business reasons exist, WFS may elect to avoid hiring relatives in
close personal relationships.

If relationships develop during the course of employment, neither employee should be

in a position to participate in making recommendations or decisions specifically affecting
the appointment, retention, work assignments, promotions, demotion, salary, or
working conditions of the other. In the event a conflict of interest is determined, an
attempt will be made to relocate one of the employees within the organization. If that
cannot be arranged, the employees will be asked to choose which of them should leave
WFS employment. That employee will have three (3) months to find other
employment. Exceptions to this Employment of Relative policy must be reviewed and
approved by the CEO & President.

Please see “Employment of Relatives” policy for full details.

2.9 Americans with Disabilities Act (ADA)

WFS is committed to complying with all applicable provisions of the Americans with
Disabilities Act (“ADA”) and Americans with Disabilities Act Amendments Act
(“ADAAA”). It is WFS policy to hire qualified candidates without regard to an
individual’s disability or perceived disability so long as the employee can perform the
essential functions of the job. Further, WFS does not discriminate against qualified
individuals with regard to advancement, discharge, compensation, training or other
terms, conditions, and privileges of employment.

Consistent with this policy of nondiscrimination, WFS will provide reasonable

accommodations to a qualified individual with a disability, as defined by the ADA and
ADAAA, who has made WFS Human Resources Department aware of his or her
disability; provided that such accommodation does not constitute an undue hardship
on the Company. If requested, the employee is responsible for providing medical
documentation regarding the disability.

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2.10 Immigration Law Compliance
WFS is committed to employing only United States citizens and aliens who are
authorized to work in the United States. WFS will not unlawfully discriminate on the
basis of citizenship or national origin.
In compliance with the Immigration Reform and Control Act of 1986 and subsequent
amendments, each new employee, as a condition of employment, must complete the
Employment Eligibility Verification Form I-9 and present documentation establishing
identity and employment eligibility. Former employees who are rehired must also
complete the I-9 form. All I-9 forms are verified with E-Verify. E-Verify is an
Internet-based system that allows businesses to determine the eligibility of their
employees to work in the United States.

2.11 Conflict of Interest

WFS recognizes and respects that employees have a right to engage in personal and
political activities outside of work. However, employees have an obligation to conduct
business within guidelines that prohibit actual, potential, or perceived conflicts of
interest. A conflict of interest is defined as a situation where an employee may have,
or may appear to have, competing professional or personal obligations, or personal or
financial interests that would make it difficult to fairly fulfill his/her duties. A conflict
depends upon the situation and not on the character or actions of the individual.
All potential conflicts of interest must be fully disclosed to the Human Resources
Director in order that Executive Management may determine actions necessary, if
any, to resolve the situation.

Please see “Conflict of Interest” policy for full details.

2.12 Employment Applications

WFS relies upon the accuracy of information contained in the employment application,
as well as the accuracy of other data presented throughout the hiring process and
employment. Any misrepresentations, falsifications, or material omissions in any of this
information or data may result in WFS exclusion of the individual from further
consideration for employment or, if the person has been hired, termination of
employment.

2.13 Job Posting and Recruitment

WFS will post all open positions on the Company website www.wfedservices.com for
interested and qualified applicants to apply. WFS requires all potential employees to
have training, education, and/or experience relevant to the position being sought, as
evidenced by applications, resumes, other supporting materials, and references.

8
2.14 Employment Reference and Background Checks
To ensure that individuals who join WFS are well qualified and have a strong
potential to be productive and successful, it is the policy of WFS to check the
employment references of all applicants. All new hires are subject to a background
check.
The Human Resources Department will be the only agent authorized by WFS to give
employment references or employment verification for past and present WFS
employees and will respond in writing only to those reference check inquiries that are
submitted in writing.
Please see the “Employment Reference Checks/Verification” policy for full details.

2.15 Employee Orientation

Each new employee will be given a general orientation to the Company's benefit
plans, general policies and procedures, and individual job duties and responsibilities.
The responsibility for new employee orientation is shared by the Human Resources
Department and the new employee's Supervisor.

2.16 Outside Employment

Employees are not permitted to engage in outside employment or activities where such
is competitive or detrimental to WFS interest, or where such activities would constitute
a conflict of interest. Employees must make the President aware of any outside
employment activities. Failure to do so may be grounds for discipline, up to and
including termination.

2.17 Work Schedules

Supervisors will advise employees of the times work schedules normally begin and end.
Staffing needs and operational demands may necessitate variations in starting and
ending times, as well as variations in the total hours that may be scheduled each day
and week.

If an employee is unable to show up for work, the employee must call his/her
Supervisor in advance, absent extenuating circumstances, and inform them of the
situation. If the employee is going to be absent due to illness, they are required to call
their immediate Supervisor.

This policy is subject to specific contract stipulations. Please check with your
Supervisor for additional requirements that may be imposed by your
customer.

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2.18 Overtime
When operating requirements or other needs cannot be met during regular working
hours, employees may be scheduled to work overtime hours. When possible, advance
notification of these mandatory assignments will be provided. Overtime assignments
will be distributed as equitably as practical to all employees qualified to perform the
required work. Overtime work performed without the Supervisor’s prior authorization is
grounds for discipline, up to and including discharge.

Overtime compensation is paid to all employees in positions classified as non-Exempt;

in accordance with federal and state wage and hour restrictions. Overtime pay is based
on actual hours worked beyond 40 hours in a work week. Time off on holidays, sick
leave, vacation leave or any leave of absence is not considered hours worked for
purposes of performing overtime calculations.

Please see the “Overtime” policy for full details.

2.19 Timekeeping
Accurately recording time worked is the responsibility of every employee. Federal laws
require WFS to keep an accurate record of time worked in order to calculate employee
pay and benefits. In addition, the electronic employee timesheet is the basis for billing
our customers for approved contract work.

Each employee is required to record daily his or her hours worked that are billable to a
customer. For payroll purposes, each employee is also required to record on their
timesheet all hours payable for each day of work. The basic rules for recording daily
hours are:

• Exempt positions - these positions are paid for each full day of work and total
hours paid each day is limited to 8 hours. Each employee should account for no
more and no less than 8 hours of billable and non-billable (indirect labor, paid
time off, holiday and other leave available) hours on the timesheet (see policy
statement at the end of this section).
• Non-Exempt positions - these positions are paid by the hour and total hours
paid equals total hours worked plus any available leave balances used.

As addressed in Section 3.3 Employment Categories, Exempt employees are not paid
overtime while Non-Exempt employees (including SCA positions) are paid overtime for
all hours worked in excess of 40 hours per calendar week.

For more information, refer to the WFS website in the Employee Portal and access
Timesheet Instructions.

Non-Exempt employees are to gain approval of overtime before it is performed.

10
Altering, falsifying, tampering with time records, or recording time on another
employee's time record may result in disciplinary action, up to and including termination
of employment.

It is the employees’ responsibility to sign their time records to certify the accuracy of all
time recorded. The Supervisor will review and approve the time record before
submitting it for payroll processing.

This policy is subject to specific contract stipulations. Please check with your
Supervisor for additional requirements that may be imposed by your
customer.

2.20 Meal Periods

All full-time Non-Exempt employees are provided with one uninterrupted meal period of
60 minutes in length each workday. Supervisors will schedule meal periods to
accommodate operating requirements. Employees will be relieved of all active
responsibilities and restrictions during meal periods and will not be compensated for
that time.

This policy is subject to specific contract stipulations. Please check with your
Supervisor for additional requirements that may be imposed by your
customer.

2.21 Paydays
All employees are paid bi-weekly every other Friday. Each paycheck will include
earnings for all regular hours of work performed through the end of the previous payroll
period.

2.22 Administrative Pay Corrections

WFS takes all reasonable steps to ensure that employees receive the correct amount of
pay in each paycheck and that employees are paid promptly on the scheduled payday.

In the unlikely event there is an error in the amount of pay, the employee should
promptly bring the discrepancy to the attention of your Supervisor so corrections can be
made as quickly as possible.

2.23 Pay Deductions

The law requires WFS make certain deductions from every employee's compensation.
Among these are applicable federal, state and local income taxes. WFS must also
deduct Social Security taxes on each employee's earnings up to a specified limit that is
called the Social Security "wage base." WFS matches the amount of Social Security
taxes paid by each employee.

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WFS offers programs and benefits beyond those required by law. Eligible employees
may voluntarily authorize deductions from their paychecks to cover the costs of
participation in these programs by expressly authorizing such deductions in writing.

Any employee who believes they have been subjected to an improper salary deduction
must promptly report the matter to the Controller. Complaints need not be in writing
and will be promptly investigated. All employees are expected to cooperate in any
investigation under this policy and to provide appropriate information or documentation.
Complaints will be kept confidential to the extent possible, consistent with the need for
a thorough investigation and consultation for resolution.

WFS will promptly reimburse the employee for any improper deduction. WFS prohibits
retaliation in any manner against anyone who brings a complaint under this policy or
assists in the investigation of any complaint. If you believe you may have been
retaliated against for these reasons, please notify the Human Resources Department.

Garnishments are pay deductions taken by WFS, usually to help pay off a debt or
obligation. Employees will be asked to sign authorizations for such deductions, as may
be required by applicable law.

If you have questions concerning why deductions were made from your paycheck or
how they were calculated, your Supervisor can assist in having your questions
answered.

2.24 Direct Deposit

WFS offers direct deposit as a benefit to you. Direct deposit will result in your
compensation being deposited directly into your financial institution, provided they
accept this type of transaction. If you do not participate in the direct deposit program,
your physical paycheck will be sent to your mailing address on a scheduled payday. See
the Human Resources Department for the required forms to participate in the direct
deposit program.

2.25 Telecommuting
The practice of working at home or at a site near the home instead of physically
traveling to a central workplace may be offered, when it would benefit both the
organization and the coworker. Coworkers who believe telecommuting can enhance
their ability to get the job done should submit a written request to their managers,
describing the benefit to WFS and themselves, explaining how they would be
accountable and responsible, what equipment is necessary, and how communication
barriers will be overcome. The decision to approve a telecommuting arrangement will
be based on factors such as position and job duties, performance history, related work
skills, and the impact on the organization, all at the sole discretion of management. To
be eligible, in addition to the stated factors above, employees also must meet the
following minimum criteria:

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 • Must be an Exempt employee – this policy is primarily for our Exempt workforce;
however, telecommuting for non-Exempt employees will be considered on a case-
by-case basis.
• Employee must have VPN capabilities and access to telephone during pre-
established working hours. The ability to communicate and transmit documents
and information electronically via e-mail, phone, or fax is essential to effective
telecommuting.
• Employee will bear the costs associated with establishing an office away from the
central workplace.
• Employee is not permitted to perform child care, adult care, or similar personal
duties during working hours.
• Telecommuting does not adversely affect the organization, departmental
assignments/projects, customer relations, or other work units.
• There is adequate and suitable work available for the employee to perform at
home with no supervision.
• The position is appropriate for a telecommuting arrangement.
• The employee has maintained a good work record prior to making his/her
request to telecommute, to include, no excessive or unexcused absences and no
corrective action within the last six months of employment.
• The employee remains obligated to comply with all company rules, practices, and
instructions.
• Employees also must check with their WFS Program Supervisor to determine if
there are contract-specific procedures for requesting telecommuting
arrangements.

The Employee’s compensation, benefits, work status, work responsibilities, and the
amount of time they are expected to work per day or per pay period will not change
due to participation in the telecommuting program (unless otherwise agreed upon in
writing). Telecommuting is a privilege, not a right; WFS has the right to refuse to make
telecommuting available to any employee and to terminate a telecommuting
arrangement at any time and for any reason.

An employee’s shift to telecommuting does not affect his classification as an

“at will employee.”

Please see the “Work Schedules and Telecommuting” policy for full details.

2.26 Access to Personnel Files

WFS maintains a personnel file on each employee. The personnel file includes such
information as the employee's job application, resume, records of training,
documentation of performance appraisals and salary adjustments, and other
employment records.

13
Personnel files are the property of WFS and access to the information they contain is
restricted. Generally, only Supervisors and management personnel of WFS who have a
legitimate reason to review information in a file are allowed to do so.

Employees who wish to review their own file should contact the Human Resources
Department. With reasonable advance notice, employees may review their own
personnel files in WFS offices and in the presence of an individual appointed by WFS to
maintain the files. Pre-employment reference information will not be made available.
Any medical information related to compliance with the Americans with Disabilities Act
is kept separate from an employee’s personnel file.

2.27 Personnel Data Changes

It is the responsibility of each employee to promptly notify the WFS Human Resources
Representative (or designee) of any change in personal data. Notification should be
made in writing via email. Personal mailing address, telephone number, number and
names of dependents, individuals to be contacted in case of emergency, educational
accomplishments and other such status changes should be accurate at all times.

2.28 Resignation
Resignation is a voluntary act initiated by the employee to terminate employment.
Although advance notice is not required, as a courtesy, WFS requests at least two
weeks' written notice of resignation from Non-Exempt employees and three weeks'
notice from Exempt employees. Prior to an employee’s departure, an exit interview will
be scheduled to discuss the reasons for resignation and the implications on benefits.

2.29 Employment Termination

Termination of employment is an inevitable part of personnel activity within any
organization, and many of the reasons for termination are routine. Below are examples
of some of the most common circumstances under which employment is terminated:

Resignation - voluntary employment termination initiated by an employee.

Discharge - involuntary employment termination initiated by the organization.

Layoff - involuntary employment termination initiated by the organization for

non-disciplinary reasons.

Retirement - voluntary employment termination initiated by the employee

meeting age, length of service, and any other criteria for retirement from the
organization.

WFS will generally schedule exit interviews at the time of employment termination. The
exit interview will afford an opportunity to discuss such issues as employee benefits,

14
conversion privileges, repayment of outstanding debts to WFS, or return of WFS-owned
property. Suggestions, complaints and questions can also be voiced.

Since employment with WFS is based on mutual consent, both the employee and WFS
have the right to terminate employment at will, with or without cause, at any time.
Employees will receive their final pay in accordance with applicable state law.

Employee benefits will be affected by employment termination. All accrued, vested

benefits that are due and payable at termination will be paid. Some benefits may be
continued at the employee's expense if the employee so chooses. The employee will be
notified in writing of the benefits that may be continued and of the terms, conditions
and limitations of such continuance.

2.30 Return of Property

Employees are responsible for all property, materials, or written information issued to
them or in their possession or control. Employees must return all WFS property
immediately upon request or upon termination of employment. Where permitted by
applicable laws, WFS may withhold from the employee's check or final paycheck the
cost of any items not returned. WFS also may take all action deemed appropriate to
recover or protect its property.

3.0 EMPLOYEE BENEFITS PROGRAM

3.1 Introduction to Employee Benefits
Eligible employees at WFS are provided a wide range of benefits. A number of the
programs (such as Social Security, worker’s compensation, state disability and
unemployment insurance) cover all employees in the manner prescribed by law.

Provided is a general description of the benefits to which you may be entitled as an

employee of WFS. This general explanation is not intended to / does not provide you
with all the details of these benefits. This handbook does not change or otherwise
interpret the terms of the official plan documents. Your benefits can be determined
only by referring to the full text of the official plan documents, which are available for
your examination from the Human Resources Department. To the extent that any of
the information contained in this Handbook is inconsistent with the official plan
documents, the provisions of the official documents will govern in all cases. Please
note that nothing contained in the benefit plans described herein shall be held or
construed to create a promise of future benefits, or a binding contract between the
Company and its employees or their dependents, for benefits or for any other
purpose.

WFS reserves the right, in its sole and absolute discretion, to amend, modify, or
terminate, in whole or in part, any or all of the provisions of the benefit plans
described herein. Further, the Company reserves the exclusive right, power and

15
authority, in its sole and absolute discretion, to administer, apply and interpret the
benefit plans described herein, and to decide all matters arising in connection with
the operation and administration of such plans.

Benefits eligibility is dependent upon a variety of factors, including employee

classification. Your Supervisor can identify the programs for which you are eligible.
Some benefit programs require contributions from the employee, but many are fully
paid by WFS.

The following benefit programs are available to eligible employees:

• Bereavement Leave • Medical/Rx Insurance

• Life Insurance • Dental Insurance
• Paid Time Off (PTO) • Section 125 Flexible Spending
• Disability Insurance Account
• Paid Holidays • 401(k)

Service Contract Act (SCA) Employees are provided a Health & Welfare fringe
benefit rate to purchase Health & Welfare benefits. The Health & Welfare benefit rate is
subject to change annually.

All benefits are subject to change or termination at any time, in WFS sole discretion.
Any summary of benefits contained in this handbook is not determinative of the
benefits actually available, and coverage and eligibility requirements are those set forth
in the official insurance documents and summary plan descriptions.

3.2 Paid Time Off (PTO) Donation

WFS allows employees to donate vested PTO to co-workers in need. If a situation
develops that is emergent in nature, the employee is to notify their Program
Supervisor/Supervisor who will in turn notify the Human Resources Department of the
need to request and receive donated PTO. Service Contract Act employees may
not participate in leave donations.

3.3 Holidays
WFS recognizes ten (10) holidays as Company paid time off. They are:

• New Year’s Day • Labor Day

• Martin Luther King, Jr. Day • Columbus Day
• President’s Day • Veteran’s Day
• Memorial Day • Thanksgiving Day
• Independence Day • Christmas Day

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To be eligible for holiday pay an employee must be in an active status, work the day
before and or day after the holiday, or be on an approved PTO day. Employees in an
unpaid leave status: Family Medical Leave, Long or Short Term Disability are not
entitled to holiday pay. Full–time salaried employees will receive 8 hours of holiday pay
for each of the above listed stated holidays; however, all employees paid on an hourly
basis will receive holiday pay, based on the number of hours paid in the week prior to
the holiday as shown in the following schedule:

Part Time Service Contract Employees may or may not be subject to holiday pay. This
will vary by contract and hours worked before and after the holiday.

Hours Hours Hours

Worked Hours of Worked Hours of Worked Hours of
Week Prior Holiday Pay Week Prior Holiday Pay Week Prior Holiday Pay
to Holiday to Holiday to Holiday
0 - 1.5 0 14 - 16.5 3 29 - 31.5 6
2 - 3.5 0.5 17 - 18.5 3.5 32 - 33.5 6.5
4 - 6.5 1 19 - 21.5 4 34 - 36.5 7
7 - 8.5 1.5 22 - 23.5 4.5 37 - 38.5 7.5
9 - 11.5 2 24 - 26.5 5 39 - 40.5 8
12 - 13.5 2.5 27 - 28.5 5.5

Absences for religious holidays not observed as official Company holidays may be taken
as PTO.

3.4 Workers’ Compensation Insurance

WFS provides a comprehensive workers' compensation insurance program at no cost to
employees. This program covers any injury or illness sustained in the course of
employment that requires medical, surgical, or hospital treatment. Subject to
applicable legal requirements, workers' compensation insurance provides benefits after
a short waiting period or, if the employee is hospitalized, immediately. Employees who
sustain work-related injuries or illnesses must inform their Supervisor immediately. No
matter how minor an on-the-job injury may appear, it is important that it be reported
immediately. Following an illness, accident, or injury sustained while working, the
Human Resources Department will provide you with a claim form to complete for
processing by the insurance carrier. Failure to report an injury can result in a loss of
benefits.

3.5 OCONUS Employee Benefits

WFS may at times have employees working overseas or Outside the Contiguous
United States (OCONUS). We understand the importance of applicable benefit
coverage while out of the United States and have a policy to address location-
specific benefit needs.

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Please see the “OCONUS Benefits” policy for full details.

3.6 Training and Development

Your ongoing growth and development are important to WFS. Therefore, we
encourage employees to take advantage of WFS supported training and development
opportunities including: professional conferences, seminars, workshops, certification
courses and in-house training sessions. You are expected to work with your Supervisor
to determine mutually agreeable training and development. Once you have completed
training, you must submit your training certificate to your Supervisor and/or Human
Resources to ensure a record of your training is maintained in your personnel file. If
you voluntarily separate from WFS within one year of completing a company paid
training opportunity, you will be required to reimburse a portion of WFS investment in
this training. The only exception to reimbursement is for fees spent on professional
conferences. The reimbursement will be 100% of the total cost if separation occurs
within 6 months of completing the training. It will be 75% of the total if separation
occurs between 6 months and 12 months of completing the training.

3.7 Employee Referral Bonus Program

WFS encourages its employees to refer qualified candidates for employment. Any
active WFS or Subsidiary employee who recommends a successful candidate will receive
a Referral Bonus of $500.00 An enterprise email to all WFS and Subsidiary employees
identifying the position, labor category, clearance level and maximum amount to be
awarded will be sent by WFS Vice President of Human Resources. Payment will be
made in two parts; $250.00 after new hire completes 30 days of employment and
$250.00 after the new hire has completed 90 days of employment.

The vacancy announcement will be posted on the website of the company seeking the
candidate. The Referral Bonus amount will be listed in the posting.

Employees interested in referring a qualified candidate should complete an Employee

Owner Referral Bonus Request along with the candidate’s resume and submit both to
the WFS Human Resources department for consideration.

Referral bonuses will be paid to the active employee through the payroll department.

4.0 LEAVE TIME

4.1 Paid Time Off (PTO)
Employees are eligible to earn PTO according to their employment classification and
tenure. Calculated from the leave date, PTO is paid at the employee’s rate of pay at

17
the time the PTO is taken. Employees may not go into a negative leave status.
Employees may only use PTO that has been accrued.

The amount of PTO you accrue each year is based on your length of service and
accrues according to the Accrual Schedule chart for full-time employment, below. PTO
is accrued per pay period and is available for use immediately. You will not accrue PTO
time while you are on an unpaid leave of absence or long-term disability. Accrual
information is calculated and updated at the end of each pay period.

Full-Time – Exempt & Non Exempt (not including Service Contract Act
employees)

Years of Accrued per Pay Annual Accrual

Service Days Accrued Period (Hours) (Hours)

0 – 2 years 10 3.08 80
3 - 7 years 15 4.62 120
8+ years 20 6.16 160

PTO can only be used as it is earned. In order to ensure operational continuity, all PTO
must be scheduled in advance.

Exempt employees may take PTO in 1 hour increments, hourly employees may take
PTO in 30 minute increments.

Upon separation of employment, the employee will be paid for unused PTO time that
has been earned through the last day of work. Upon separation, employees will not
receive an amount greater than the number of hours accrued by such employee during
his or her last year of service. i.e., an employee with 8 years of service will receive
payment for no more than 160 hours.

Part & Casual-Time – Hourly (not including Service Contract Act employees)

• Leave date through 2 years of service (24 months): accrue at the rate of .038
hours per hour paid.
• Beginning with year 3 through year 7 (25 months to 84 months): accrue at the
rate of .058 hours per hour paid.
• Beginning with year 8 (85 months): accrue at the rate of .077 hours per hour
paid.

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PTO does not accrue when the employee is in an “unpaid” status of employment, such
as an unpaid leave of absence, with the exception of a military training leave of
absence.

PTO can only be used as it is earned. In order to ensure operational continuity, all PTO
must be scheduled in advance.

Upon separation of employment, the employee will be paid for unused PTO time that
has been earned through the last day of work. Payout of PTO hours earned cannot
exceed an amount equal to one year’s PTO accrual.

Service Contract Act Employees (SCA) Full, Part & Casual- Time

• Service Contract employees do not accrue vacation benefits per pay period.
Rather, vacation benefits vest on the service contract employee’s Anniversary
Date.

• This benefit will vest once a year on your Anniversary Date as defined by the
Service Contract Act regulations.

• *Two (2) weeks paid vacation after one (1) year of service with a contractor or
successor; three (3) weeks after eight (8) years, and four (4) weeks after 15
years.

• *Amount of vested hours will vary based on Wage Determination (WD) minimum
requirement for the county in which employee works.

• Anniversary Date: For service contract employees covered under the Service
Contract Act of 1965, its regulations and the DOL Wage Determinations,
“Anniversary Date” means each one-year period beginning with the date on
which the service contract employee first began work at a particular government
work site as a service contract employee and remained in continuous service on
the contract (or its successor contract) at the same contract site.

4.2 Maximum Time Accumulate

Employees are expected to use all PTO in the year it is earned. However, employees
may elect to carry over a maximum of 40 hours or 5 days of earned PTO from one
year to the next, with the approval of their Supervisor. Any unused PTO time will be
lost and will not be paid as compensation to the employees. This encourages you to
use your PTO and allows the company to manage its financial obligations responsibly.
Any exceptions will be made per signed agreement.

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4.3 PTO Taken Due to Illness
When an employee is ill and absence from work is required, the employee will be
excused and paid when proper notification is given and PTO accrual is sufficient, unless
such absences are considered by the Company to be excessive.

Absences or tardiness without good reason and/or without notice to the Company will
not be tolerated. Chronic unexcused absenteeism or tardiness, whether with or without
good reason, is considered by WFS as grounds for termination and will be considered
and weighed heavily when an employee is evaluated for salary increases.

Doctor or dental appointments should be scheduled in the early morning, late afternoon
or at the lunch hour, if at all possible, to maintain smooth office operations. The
Company realizes this is not always possible and will make every effort to accommodate
these appointments. However, employees are urged to make a strong effort to schedule
appointments at the requested times.

Due to the Family and Medical Leave Act (FMLA) reporting requirements, before
returning to work from an absence of three working days or more due to illness, an
employee must provide a physician's verification of the employee's illness and that he
or she may safely return to work. This physician's verification must also provide an
explanation of any work limitations or restrictions placed on the employee and the
period of time in which these limitations are in effect. This does not apply in cases
where the employee has been approved for intermittent leave under the FML.

4.4 Family and Medical Leave Act (FMLA)

WFS is committed to providing employees with all leave required by federal law and
applicable state law. This policy sets out the rights of eligible employees under federal
law.

Employees who have been employed for at least 12 months, and have worked at least
1,250 hours in the last 12 months, may be eligible for federal family and/or medical
leave. Eligible employees may take up to 12 weeks of unpaid leave for the following
reasons:

• The serious health condition of the employee;

• The serious health condition of the employee’s child, spouse, or parent;
• The birth, adoption, or foster care placement of a child; or
• Qualifying reasons arising out of a family member’s call to active service in the
military.

Eligible employees may take additional leave, not to exceed 26 weeks, to care for a
family member who becomes ill or injured, or who aggravates an existing illness or

20
injury, in the line of active duty in the military.

WFS will determine when employees are eligible for FMLA leave and whether a
particular leave qualifies as FMLA leave under federal law. WFS requires employees to
use all available accrued paid leave during any otherwise unpaid FMLA leave.

When the need for leave is foreseeable, employees must notify their Supervisor, or the
Human Resources Department, 30 days before the start of leave. In the event of an
emergency, notice must be provided as soon as possible.

During leave, employees are expected to comply with all applicable call-in procedures
unless they are medically unable to do so or it is unreasonable under the circumstances.

The use of FMLA leave will not be used as a negative factor in any employment
decision.

Please see the “FMLA” policy for full details.

4.5 Personal Leave/Non-FMLA

Under certain circumstances, WFS offers leaves of absence without pay (LWOP) to
employees for the purpose of taking time off from work duties to fulfill personal
obligations. Supervisor will have the authority to grant this type of leave on a case-by-
case basis following predetermined guidelines.

4.6 Bereavement Leave

If an employee suffers the death of a family member, or the family member of their
spouse, the employee will be allowed from one (for extended family members) to three
(for immediate family members) paid working days for personal use. Examples of
extended family members are cousin, second cousin, aunt and uncle. Examples of
immediate family members are husband, wife, mother, father, grandmother,
grandfather, son and daughter.

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 or
bonuses.

4.7 Jury Duty Leave

WFS encourages employees to fulfill their civic responsibilities by serving jury duty
when required. Full-time employees in an eligible classification may request up to two
weeks of paid jury duty leave over any one year period.

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Jury duty pay will be calculated on the employee's base pay rate times the number of
hours the employee would otherwise have worked on the day of absence, less the
amount received while serving jury duty.

Employees must show the jury duty summons to their Supervisor as soon as possible so
that the Supervisor may make arrangements to accommodate their absence. Employees
are expected to report for work whenever the court schedule permits. If jury duty is
concluded prior to 1:30 p.m. and the employee is in close proximity to the work place,
they are expected to report to work at that time.

WFS will continue to provide health insurance benefits for the full term of the jury duty
absence. PTO benefits will continue to accrue during unpaid jury duty leave.

4.8 Witness Duty Leave

WFS encourages employees to appear in court for witness duty when subpoenaed to do
so. If employees have been subpoenaed or otherwise requested to testify as witnesses
by WFS, they will receive pay for the entire period of witness duty.

If an employee is served with a subpoena to appear as a witness at a trial or arbitration

by a party other than WDC, employees will be granted a maximum of 16 hours of pay.
Employees will be paid at their base rate and are free to use certain remaining paid
leave benefits (such as PTO) to receive compensation for any period of witness duty
absence that would otherwise be unpaid.

The subpoena MUST be shown to the employee’s Supervisor immediately after it is

received so that operating requirements can be adjusted, where necessary, to
accommodate the employee’s absence. The employee is expected to report for work
whenever the court schedule permits.

4.9 Military Leave

A military leave of absence will be granted to employees who are absent from work
because of service in the U.S. uniformed services in accordance with the Uniformed
Services Employment and Reemployment Rights Act (USERRA). Advance notice of
military service is generally required, unless military necessity prevents such notice or it
is otherwise impossible or unreasonable. The leave will be unpaid. However,
employees may use any available accrued vacation time for the absence. Employees will
be reinstated upon return from military leave in accordance with applicable law.
Contact the Human Resources Department for more information or questions about
military leave.

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4.10 Elections / Voting
WFS encourages employees to participate in any and all elections for public office by
voting. WFS employees will be granted sufficient time-off to vote in all national, state,
and local elections. Employees are required to coordinate this time-off with their
Supervisor.

4.11 Inclement Weather / Liberal Leave

WFS will announce "Liberal Leave" is in effect when weather or other emergency
conditions may require the granting of PTO without prior approval to employees. This
policy is in place to eliminate confusion and make it clear to employees that they will be
charged PTO or leave-without-pay while absent from work. The official decision that
Liberal Leave is in effect will be made by President or designee.

5.0 ACCEPTABLE AND EXPECTED BEHAVIOR

5.1 Attendance and Punctuality
To maintain a safe and productive work environment, WFS expects employees to be
reliable and to be punctual in reporting for scheduled work. Absenteeism and tardiness
place a burden on other employees and on WFS. In the rare instances when
employees cannot avoid being late to work or are unable to work as scheduled, they
should notify their Supervisor as soon as possible in advance of the anticipated
tardiness or absence.

An employee absent due to illness must notify their Supervisor of their status and
estimated date of return on a daily basis. Absences due to illness in excess of three
days require a doctor's note.

Poor attendance and excessive tardiness are disruptive. Either may lead to disciplinary
action, up to and including termination of employment.

5.2 Drug and Alcohol Use

WFS wants to maintain a safe, healthy and productive work environment. Alcohol and
drug abuse can pose a serious threat to the health and safety of our employees.
Therefore, WFS is committed to eliminating drug and/or alcohol use and abuse in the
workplace.

Employees should report to work fit for duty and free of any adverse effects of illegal
drugs or alcohol. As used in this policy, references to “illegal drugs” include marijuana
even if the use of marijuana may be legal under the law of the state where an
employee works.

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WFS does not prohibit employees from the lawful use and possession of prescribed
medications. However, employees must consult with their doctor about the affect any
medication may have on their fitness for duty or on their ability to work safely. Any
employee who is taking legal prescription drugs which could affect his or her job
performance, or create a safety risk, must notify his/her Supervisor, or the Human
Resources Department, of the prescription drugs being taken and their anticipated side
effects.

Please see the “Drug and Alcohol Free Workplace” policy for full details.

5.3 Workplace Violence Prevention

WFS is committed to preventing workplace violence and to maintaining a safe work
environment. Given the increasing violence in society in general, WFS has adopted the
following guidelines to deal with intimidation, harassment, and other acts or threats of
violence that may occur during business hours or on its premises.

Workplace violence includes any conduct which reasonably makes a person feel unsafe,
threatened, harassed, intimidated, or assaulted during the course of their employment.
It is important to note that this policy prohibits physical violence against another
person, as well as verbal abuse, or any other behavior or act which threatens,
humiliates, or demeans another person. Damage to property and vandalism also are
prohibited.

All employees have a responsibility to report any act or threat of violence in the
workplace to management so that prompt and appropriate action can be taken. Any
violent act or threat of violence in the workplace, or off premises while on Company
business, will result in disciplinary action up to and including immediate discharge.

WFS prohibits employees from carrying or storing weapons in buildings or vehicles it

owns or leases. We also prohibit employees from carrying concealed weapons while
they are performing any duties within the course or scope of their employment.
However, this policy does not prevent employees from storing or keeping weapons in
their personal vehicles. We ask that employees store any weapons in their personal
vehicles out of plain sight, e.g., in a trunk or glove box. As used in this policy, a
weapon includes all firearms, knives with blades longer than four (4) inches, explosive
devices, Tasers, and stun guns.

WFS is committed to supporting victims of domestic violence and to maintaining a safe

workplace. Employees should promptly inform the Human Resources Department of
any protective or restraining order they have obtained which lists the employee or the
workplace as a protected area. We will work with employees to protect them, and their
workplace. Employees also are encouraged to report any safety concerns relating to
domestic violence.

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Please see the “Workplace Violence Prevention” policy for full details.

5.4 Smoking
In keeping with WFS intent to provide a safe and healthful work environment, smoking
is prohibited throughout the workplace. Smoking is only permitted in the established
smoking areas. This policy applies to employees, customers and visitors.

This policy is subject to specific contract stipulations. Please check with your Supervisor
for additional requirements that may be imposed by your customer.

5.5 Personal Appearance

The dress and appearance of employees will be appropriate to the employee’s position,
location and working hours. All employees are expected to dress and groom
themselves in such a manner as not to be offensive to the members served and must
reflect a professional, business-like appearance. The immediate Supervisor is
responsible for taking necessary action when an employee’s dress or grooming does not
meet the standards set.

5.6 Standard of Conduct for Language

The purpose of this policy is not to restrict the rights of anyone, but to define and
protect the rights of all and ensure cooperation. The fact that inappropriate language
often occurs in conversations or that not everyone may be offended does not make it
right or acceptable. The use of profane, foul, obscene, insults, abusive or crude
language, inappropriate jokes, racial slurs, sexual comments, even if spoken in non-
English/foreign languages, or the making of verbal threats is considered disrespectful,
demeaning and abusive behavior. This abuse usually causes great anxiety and stress
for the recipient and may give the recipient reason to be concerned for his/her safety
and well-being. Vulgar and offensive language can cause real harm, crosses the
boundary of appropriate conduct and may even disrupt the entire workforce.

Inappropriate language infringes upon equal respect in working relationships and can
cause serious harm to productivity, efficiency and stability. This policy defines
violations against accepted standards of language and conduct in the workplace.

Those violations are defined as:

• Unwanted, deliberate, repeated, unsolicited profanity, cussing, swearing, vulgar,

insulting, abusive or crude language;
• The making of verbal threats, sexual comments, gestures, graphic materials,

25
 physical contacts, solicitations or sexual favors; or
• Those who engage in unwelcome name-calling, obscene language, racial slurs, or
other abusive behavior, including intimidation by way of obscene or threatening
gestures.

Consistent with this policy, WFS will not tolerate any employee’s language, whether
intentional or unintentional, that results in harassment, discrimination or creation of an
offensive work environment for anyone because of his or her sex, race, creed, national
origin, disability, age, veteran’s status or sexual orientation.

Any employee with concerns about offensive language in the workplace has an
obligation to report such violations immediately to the Human Resources Department or
any member of management. All complaints will be investigated promptly and where
necessary, immediate and appropriate action will be taken to stop and remedy any such
conduct. Any manager, Supervisor, agent or employee found in violation of this policy
will be subject to disciplinary action that may include counseling sessions, verbal
warning, written reprimand, suspension or termination, depending upon the severity of
the event. We want to continue building and maintaining an atmosphere where
employees can discuss their differences with Supervisors and exchange ideas with co-
workers openly, honestly and respectfully.

Please see the “Code of Conduct” policy for more information.

5.7 Code of Conduct

To ensure orderly operations and provide the best possible work environment, WFS
expects employees to follow rules of conduct that will protect the interests and safety of
all employees and the organization. As a general policy statement, WFS is committed
to providing an environment that supports honesty, integrity, respect, trust,
responsibility, and citizenship of every employee, customer, vendor and business
associate.

WFS operates in federal contracting; employees are expected to, in the course of
conducting federal-related business, to meet the current and any future requirements
established by the Federal Acquisition Regulations (FAR) for awardees of federal
government contracts.

WFS reserves the right, in its sole discretion, to determine what constitutes improper
behavior and the level of discipline appropriate in any given circumstance.

Please see the “Code of Conduct” policy for more information.

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5.8 Ethics
WFS employees will maintain the highest ethical standards in the conduct of WFS
affairs. The intent of this policy is that each employee with conduct WFS business with
integrity and comply with all applicable laws that in a manner that excludes
considerations for personal advantage or gain.

Please see the “Ethics” policy for more information.

5.9 Sexual and Other Unlawful Harassment

It is the intent of WFS to exclude harassment in all forms from all of its workplaces and
working relationships. All employees have the right to work in an environment free of
discrimination and any form of harassment, based on race, color, religion, age, sex,
national origin, disability or marital status.

To help ensure that no employee feels him/herself to be subject to harassment, WFS

prohibits any offensive physical, written, or spoken conduct regarding any of these
items, including conduct of a sexual nature, off-color jokes, racial, ethnic, or religious
slurs or innuendoes.

Offensive conduct of a sexual nature, may constitute harassment when engaged in by

someone employed by WFS in a position to influence employment decisions when (1)
submission to such conduct is made, either expressly or implicitly, a condition of the
recipient's continued employment; or (2) submission to or rejection of such conduct by
the recipient is used as the basis for employment decisions affecting the recipient.

WFS also prohibits unwelcome physical, written or spoken conduct by either a

Supervisor or any fellow employee that substantially interferes with an individual's work
performance or creates what a reasonable person could consider to be an intimidating,
hostile, abusive or offensive working environment. Any such conduct to or by not only
fellow employees but also customers, vendors or visitors of WFS, customers off-
premises of WFS served by WFS, in any gathering sponsored by WFS or in which WFS
is officially participating, will be cause for immediate investigation upon report of such
offensive conduct or situations to the Human Resources Department, or the employee's
immediate Supervisor.

In addition, the same prohibition of discrimination or harassment applies to all

employees of WFS who act on behalf of WFS as vendors, contractors, consultants and
others who spend time on the premises of WFS clients.

Harassment is not always capable of precise definition. For example, what may be
unwelcome sexual harassment to one person could be nothing more than socializing,
teasing, locker room banter, or flirtation to another person. Therefore, WFS must treat

27
complaints seriously and advises all employees to guard against any conduct that tends
to cause discomfort or harassment to another employee, even though one might not
believe it to be offensive.

The following are examples of what may be considered sexual harassment, depending
on the facts and circumstances:
• Verbal Harassment: derogatory or vulgar comments regarding sex or
demands for sexual favors.
• Visual Harassment: distribution of written or graphic materials
containing sexually explicit or demeaning pictures or language.
• Physical Harassment: unwelcome or unsolicited sexual advances or
other physical conduct of a sexual nature, such as touching, pinching or
causing one to fear that they will be touched inappropriately.

If an employee believes that he/she is being subjected to any of these forms of

harassment or believes he/she is being discriminated against because other employees
are receiving favored treatment in exchange, for example, sexual favors, he/she has the
obligation to promptly bring this to the attention of the Human Resources Department
or other management personnel that the employee is comfortable with so the matter
may be reviewed. The very nature of harassment makes it virtually impossible to
detect unless the individual being harassed registers his/her discontent with the Human
Resource Department or other management personnel.

Any Supervisor or manager who becomes aware of possible sexual or other unlawful
harassment has the obligation to promptly advise the Human Resources Department,
who will handle the matter in a timely and discreet manner.

The Company prohibits retaliation against any individual who reports harassment in
good faith or participates in good faith an investigation. Retaliation against an
individual for reporting harassment or for participating in an investigation of a claim of
harassment is a serious violation of this policy and may subject the person found to
have retaliated to disciplinary action, up to and including discharge.

Employees will be asked to produce this information to a written statement. After a

complaint has been received from an employee, WFS will investigate the allegations. A
record of the complaint and the findings will become a part of the complaint
investigation record that will be maintained separately from the personnel files of those
involved.

It is understood that any person electing to utilize this complaint resolution procedure
will be treated courteously, and the investigation and resolution of the situation will be
handled as quickly as possible. The registering of a valid complaint will not be used or

28
held against the employee, nor will it have an adverse impact on the complaining
individual's employment status. WFS will urge all employees who are involved in the
investigation to respect the privacy of both the complaining employee and the alleged
harasser so as not to impair the careers or reputations of either. All parties must be
aware of the seriousness of such complaints and the damage that can be done to
everyone concerned.

Appropriate action will be taken consistent with the findings of this investigation. An
employee engaging in sexual or other form of unlawful harassment will be subject to
disciplinary action, up to and including discharge.

The complaining employee must understand that confidentiality of the complaint

involving the substance of the allegations cannot reasonably be expected due to the
very nature and process of the investigation of the complaint. Nonetheless, due to the
serious nature of harassment complaints, WFS will make an effort to restrict the
dissemination of the complaint to those having a need to know.

We urge all employees to report any improper behavior. Unless WFS knows of a
problem, it cannot take steps to resolve it.

WFS Employees can be assured that:

• Employees can raise concerns and make good-faith reports without fear of
retaliation.
• WFS will act promptly to quickly investigate all harassment complaints, and will
keep information confidential to the greatest extent possible when processing
complaints.
• Anyone engaging in sexual or other unlawful harassment will be subject to
disciplinary action, up to and including termination of employment.

Please see the “Discrimination and Harassment Prevention” policy for full details.

5.10 Problem Resolution

Whenever a group of people are required to work together for an extended period of
time, problems and misunderstandings can occur. In order to ensure prompt and
constructive problem solving, employees are encouraged to follow this procedure:

a. Discuss the problem with their immediate Supervisor.

b. If a resolution does not occur within thirty (30) days, the problem should be
submitted in writing to your Supervisor’s boss, with a copy sent to the Vice
President of Human Resources.

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 c. If a resolution is not initiated in step two within a reasonable time, the problem
should be presented in writing to the CEO, with a copy sent to the Vice President
of Human Resources. The CEO will take appropriate action, and their decision is
final and binding.

6.0 SAFE WORK ENVIRONMENT

6.1 Safety
WFS will make every reasonable effort to provide a safe work environment for
employees and visitors. Safety is important, and the success of our efforts depends on
the alertness and personal commitment of all staff.

Each employee is expected to obey safety rules and to exercise caution in all work
activities. Employees have an obligation to immediately report any unsafe condition to
the appropriate Supervisor. Employees who violate safety standards, who cause
hazardous or dangerous situations, or who fail to report or, where appropriate, remedy
such situations may be subject to disciplinary action, up to and including termination of
employment.

In the case of accidents that result in injury, regardless of how insignificant the injury
may appear, employees should immediately notify the appropriate Supervisor. Such
reports are necessary to comply with laws and initiate insurance and workers’
compensation benefits procedures.

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. Reports and concerns about workplace safety issues may
be made anonymously if the employee wishes. All reports can be made without fear of
retaliation.

6.2 Workplace Security

To provide for the safety and security of employees and the facilities at WFS, 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.

Employees share the responsibility of maintaining a safe and secure workplace. All
photo identification will be visible at all times.

To further maintain a safe and healthy environment all visitors will be escorted by a
WFS employee at all times. Visitors will report to the Corporate Office Reception area

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where they will be issued a visitor badge. All visitors will be escorted by a WFS
employee while on the premises.

If an unescorted person is observed by a WFS employee walking through the halls of

the facility, stop them and ask them for identification. You have the responsibility to
escort that individual to the Program/Project Manager in charge or the Corporate
Reception area immediately.

7.0 MISCELLANEOUS
7.1 Access Card
WFS will provide one (1) access card/ID badge to each employee. If the card is lost or
damaged, WFS will charge the employee no less than $25.00 for each additional
replacement card subject to the requirements imposed by our customers at each work
location.

7.2 Solicitation, Distributions, and Use of Bulletin Boards

No person, whether employee, client, sales representative, business visitor, supplier or
other person having business with the Company, is permitted on WFS premises for any
reason other than Company business. Solicitation and/or distribution of non-work-
related materials will not be permitted at any WFS facility.

Non-employees are not permitted to solicit or distribute literature on Company

premises. Bulletin boards are located in all WFS-owned work sites. Employees should
check them regularly to stay informed about policies, practices and events of interest as
well as for information regarding state and federal employment laws. WFS clients
maintain the bulletin boards at the respective work sites with the notices required by
federal law. Under no circumstances will WFS bulletin boards be used for solicitation or
posting of non-work-related materials.

7.3 Business Travel Expense

WFS reimburses employees for reasonable business travel and expenses while on
approved assignments away from the normal (local) work location. Employees whose
travel plans have been approved are responsible for making their own travel
arrangements. Employees must fly economy class unless they have a single segment of
travel that is over eight (8) hours or a total travel time in excess of fourteen (14) hours,
in which cases employees may fly business class. First class travel must be approved by
President.

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All travel arrangements, including air travel, rental cars and lodging can be made by the
business traveler directly through the airline or through known travel sites such as
Orbitz and Expedia, for example.

Direct billing for travel expenses is not authorized, unless approved in writing by the
Vice President of Human Resources (or his/her designate).

Travel Companions
With prior approval, a family member or friend may accompany employee travelers on
business travel. The presence of a companion is only accepted when it will not
interfere with successful completion of the preset business objectives. Generally,
employee travelers are also permitted to combine personal travel with business travel,
as long as time away from work is approved. Additional expenses arising from such
non-business travel are the responsibility of the employee traveler.

Corporate Credit Cards and Reimbursement

Corporate credit cards are for business travel expense only and the employee is
expected to turn in their monthly expense report within 14 days of receipt of credit card
statement from accounting. Misuse including any personal use of the corporate credit
card is a serious matter that may result in discipline up to and including termination of
employment. Expense reports must be completed accurately and honestly. Any
intentional or reckless charging of unauthorized costs is strictly prohibited and may
result in discipline up to and including termination of employment.

Failure to turn in expense report and supporting receipts will result in a payroll
deduction.

Travel and Reimbursement Forms

Travelers and all other employees needing reimbursement should use the standardized
expense forms supplied on the intranet that can be accessed with the following web
address: www.wfedservices.com

Company Hosted Business Meals

In those cases where an employee is on temporary travel (TDY) status and is involved
in hosting or participating in a business meal, each TDY employee is responsible for
payment of their portion of the meal’s costs. The TDY employee is responsible for
coordinating with the host of the business meal to ensure that the employee pays his or
her share of the business meal; the per diem rate for meals and incidentals for
employees on TDY reimburses the employee for that meal.

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The only portion of the costs of the business meal that should be submitted for
reimbursement will include the costs related to those who participated in the business
meal that were not on WFS TDY status.

Please see the “Travel and Expense Reimbursement” policy for more details.

7.4 Company Related Purchase Expense Reimbursement

Employees are authorized to purchase business necessity items at the lowest possible
cost to the Company or its clients, within budget guidelines and without compromising
quality. The reimbursement will be facilitated using the Request for Payment Form.
Some locations and/or contracts require written approval from the customer prior to the
purchase. On rare occasions when assistance is needed to purchase an item, the
Finance Department can be contacted to assist.

7.5 Company Owned, Rented or Personal Vehicle Use

Any employee driving a Company owned vehicle, personal vehicle or renting a
vehicle while on Company business shall have an acceptable driving record and
maintain the appropriate type of driver's license for the vehicle being driven as
required by the state or area in which the driver is located. Employees utilizing
Company vehicles at any time may be requested to provide a copy of their driving
record to WFS.

WFS expects any employee operating a Company owned or rented vehicle to operate it
in a safe and economical manner. Company-owned vehicles may be operated for
Company business, traveling to or from work and/or for approved personal uses.

Employees are prohibited from operating Company owned or rented vehicles when
under the influence of alcohol or illegal drugs.

All drivers of and passengers in any Company owned, rented or personal vehicle must
wear seatbelts and all other available active restraints. WFS prohibits the drivers of
Company owned, rented or personal vehicles from texting, checking email messages or
engaging in other distracting behavior while driving Company vehicles.

Any employee assigned a Company vehicle, or authorized to drive a Company vehicle,

must report any driving citation to the Human Resources Department within two
business days.

Please see the “Company Vehicle Use” policy for full details.

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7.6 Use of Phones and Mail System
Use of the Company phone system for personal business is discouraged. Any such
phone calls should be limited. Placing personal international calls using Company
resources is prohibited and may result in termination.

The use of WFS-paid postage for personal correspondence is not permitted.

7.7 Mobile Phone and Mobile Phone Policy

It is against WFS policy and procedures to text, email or use a handheld phone or
communication device while operating a company vehicle, driving a personal vehicle for
business use, driving a rental vehicle while on company business, or using a company-
issued communication device while driving. The use of handheld devices is prohibited
except in emergency situations. When essential calls must be made, employees must
pull off the road to a safe location. Employees bear sole responsibility for liability
incurred from traffic violations or accidents involving the use of a cellular phone or
other electronic device while driving.

Certain, designated individuals may participate in the company’s mobile phone plan and
will be provided a cellular device.

Employee will return the company issued cellular device upon termination of
employment.

7.8 Electronic Mail and Computer Services

Internet use, on WFS time, is authorized to conduct Company business. Internet use
brings the possibility of breaches to the security of confidential WFS information.
Internet use also creates the possibility of contamination to our system via viruses or
spyware. Spyware allows unauthorized people, outside WFS, potential access to
Company passwords and other confidential information.

Removing such programs from the WFS network requires IT staff to invest time and
attention that is better devoted to progress. For this reason, and to assure the use of
work time appropriately for work, we ask staff members to limit non-work-related
Internet use.

Additionally, under no circumstances may WFS computers or other electronic equipment

be used to obtain, view, or reach any pornographic, or otherwise immoral, unethical, or
non-business-related Internet sites. Doing so can lead to disciplinary action up to and
including termination of employment.

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1. Computers and Computer Services. WFS owns, or has a property interest
in, all of the computers, software, on-line accounts, e-mail services, computer
and e-mail files, and similar and related equipment and documentation employed
or stored in its offices, including services for Internet access (“Electronic
Facilities”), and any use of such information processing Electronic Facilities from
locations outside the Company.

2. Individuals Covered. This policy covers all employees of the Company, and
any persons whom employees authorize or give permission to use the Electronic
Facilities of the Company.

o Employees using their own personal computer from any location while
connected to the WFS network directly or through a VPN connection are
governed by this Policy; to the extent they utilize the Company’s
computers or Electronic Facilities, just as though they were working only
on the Company’s computers or Electronic Facilities.

3. Use of the Company’s Electronic Facilities. The Company supplies the

Electronic Facilities to the Company employees solely for the purpose of work-
related business. Accordingly, as a general rule, use of the Company resources
for other than normal business-related purposes is prohibited.

o As a limited exception to that general rule, authorized users may use the
Company’s Electronic Facilities for incidental personal purposes. Personal
use of the Electronic Facilities should be kept within reasonable bounds
pursuant to the spirit of this policy and should not interfere with an
employee’s work responsibilities. Personal use of the Electronic Facilities
is expected not to distract, annoy or harass co-workers. Any personal use
that poses a security risk, delays or threatens to delay, the timely
accomplishment of company business will be curtailed.
o Employees are absolutely prohibited from using the Company’s Electronic
Facilities to set up or operate a personal business.
o Non-business emails to associates, family or friends waste company time
and attention.
o Viewing pornography, or sending pornographic jokes or stories via email,
is considered sexual harassment and will be addressed according to our
sexual harassment policy.
o All employees are required to maintain the confidentiality of the
Company’s communications, business and materials.
o Employees may not communicate company or employee passwords or
pass codes to unauthorized third parties within or without the Company.

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4. Software. Various types of software are provided for the use of employees by
the Company. The proper use and licensing of software within the Company is
very important. Accordingly, there are several restrictions on employees with
respect to software and the Company’s Electronic Facilities, including:

o No employee may see, copy or otherwise transfer Company software to

others without authorization.
o No employee may install any software on the Company’s Electronic
Facilities without approval.
o The Company’s Electronic Facilities may not be used to download software
from the Internet, including games and screen savers. If an employee
believes software that is available on the Internet may be useful to the
Company’s employees, the employee should contact the IT Department to
discuss the software.
o An employee may not use his or her personal computer to download
software from the Internet in violation of applicable licensing requirements
with the intent of bringing such software to the Company for us in the
Company’s Electronic Facilities.
o The Company reserves the right to audit the software on all of its
Electronic Facilities, and remove any unauthorized software.

5. Copyrighted Materials. Certain materials on the Internet may be protected by

copyrights, including articles, images and software.

o Employees are prohibited from downloading copyrighted materials,

including text, image and multimedia materials, from the Internet.
Employees also are prohibited from downloading copyrighted software
from the Internet.
o Employees are prohibited from any trademark infringement with respect
to materials on the Internet, including infringement by linking or framing
material protected by a trademark, and infringement via news servers.

6. Internet Access. Employees are granted the privilege of accessing the

Internet via the Company’s Electronic Facilities. Internet usage is intended to be
primarily for work-related purposes. Any personal Internet access should be
incidental and brief in nature or during non-working hours.

o The Company’s Electronic Facilities may not be used to access or transmit

any content or material that could threaten or harm the business or
reputation of the Company.

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 o The Company is dedicated to providing a work environment that is free
from unlawful harassment. This applies to Internet usage as well.
Accordingly, employees are prohibited from using the Company’s
Electronic Facilities to harass, intimidate or threaten co-workers. The
Company’s Electronic Facilities also may not be used to transmit other
inappropriate material, such as material that is defamatory, discriminatory,
threatening, slanderous or libelous. Materials covered by this restriction
include documents, messages, jokes, images, cartoons, programs and
software.
o The Company’s Electronic Facilities may not be used to disclose any
confidential employee, company or medical information to unauthorized
third parties. Unauthorized messages or discussions regarding such
matters are strictly prohibited.
o Employees are prohibited from any hacking or cracking activities.
o Some Internet sites may request a user’s e-mail address. Employees
should not provide their e-mail addresses to such sites, unless the user
can reasonably trust that the site is legitimate and there is a reason for
the site to have the user’s e-mail address. Other Internet sites may be
able to detect a user’s e-mail address without the user’s knowledge.
Accordingly, employees should carefully consider the Internet sites they
visit.
7. Electronic Mail. Employees may be permitted access to the Company’s
internal intra-office electronic mail (e-mail) system and/or the privilege of
utilizing external Internet e-mail via the Company’s Electronic Facilities. All
transactions and/or communications made on or via the Company’s Electronic
Facilities, whether internal or external, are the property of the Company. Both
internal and external e-mail is intended primarily for business-related purposes.
If an employee is connected through VPN, all transmissions while connected are
monitored by the Company.

o Employees should consider all e-mail messages and attachments as

shared paper files. Employees should expect that anything in an
electronic file is always available for and subject to review by the
Company.
o The Company reserves the right and intends to exercise the right to
review audit, access and disclose all messages created, received or sent
over personal or Company e-mail systems for any purpose. The contents
of e-mail properly obtained for legitimate business purposes may be
disclosed within the Company without the permission of the employee.
o Attachments to e-mails are treated the same as e-mails and these rules
apply for attachments as well. These rules also apply to resending or
forwarding e-mails and attachments.

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 o Employee use of the Company’s Electronic Facilities for e-mail, both
internal and external, is subject to the following restrictions:

1. Employees shall not disclose confidential information to unauthorized

third parties.

2. Personal e-mail usage is a privilege of employment, not an

entitlement, and e-mail usage may be banned or limited in any
manner by the Company.

3. All personal e-mail usage, whether internal or external, should be

incidental and brief.

4. Care should be taken to assure that all personal e-mail is scanned for
viruses.

This policy is subject to specific contract stipulations. Please check with your
Supervisor for additional requirements that may be imposed by your
customer.

Please see the “Communication Equipment” policy for full details.

7.9 Internal Investigations and Searches

From time to time, WFS may conduct internal investigations pertaining to security,
auditing or work- related matters. Whenever necessary, in the Company's discretion,
work areas (i.e., desks, file cabinets, etc.) and personal belongings (i.e., brief cases,
handbags, etc.) may be subject to a search without notice. Employees are required to
cooperate fully with and assist in these investigations.

The Company will generally try to obtain an employee's consent before conducting a
search of work areas or personal belongings, but may not always be able to do so.
Internal investigations and searches will adhere to state and federal laws.

7.10 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 a work facility. When operations are officially closed due to emergency
conditions you are excused from work without loss of pay or charge to leave. In the
event that your facility or alternate work site is open and you elect not to report to work
Liberal Leave will be in effect and the time off from scheduled work will be treated as
PTO and charged accordingly.

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7.11 Emergencies
In case of general emergency, local procedures for evacuation, sheltering in place or
other responses should be followed. Local managers will provide direction for staff
meeting areas in case of evacuation.

In case of a critical emergency dial 911. For less critical cases, walk-in medical care is
available at a local medical treatment facility. Minor emergencies can be treated with a
first aid kit. All emergencies need to be reported to an immediate Supervisor who will
complete a report of the incident.

8.0 EMPLOYEE RESPONSIBILITIES

8.1 Gift Policy
WFS and its subsidiaries provide services to the federal government and must follow
the guidelines below when providing gifts in conjunction with a Federal contract:

• Business Gifts – Federal - Not to exceed $50.00 per gift per recipient per year.
However, Federal government procurement regulations prohibit any government
official accepting a gift with a value over $20, which includes meals and
incidentals. Any attempt to provide a government official with a “gift” exceeding
the $20 value will be considered offering a bribe and is not tolerated. All WFS
employees shall be required to comply with any Federal, state, or local laws, as
may be enacted, regarding the acceptance gifts or gratuities.

• Employee Gifts – Non-Federal - Any individual gift greater than $25 requires
prior approval from a company official authorized to approve expense reports.

8.2 Internal Investigations and Searches

From time to time, WFS may conduct internal investigations pertaining to security,
auditing or work- related matters. Whenever necessary, in the Company's discretion,
work areas (i.e., desks, file cabinets, etc.) and personal belongings (i.e., brief cases,
handbags, etc.) may be subject to a search without notice. Employees are required to
cooperate fully with and assist in these investigations.

The Company will generally try to obtain an employee's consent before conducting a
search of work areas or personal belongings, but may not always be able to do so.
Internal investigations and searches will adhere to state and federal laws.

8.3 Corrective Discipline and Discharge

Whenever people work together, certain standards of reasonable conduct need to be
established to maintain an orderly and efficient work atmosphere. Any unacceptable

39
behavior will result in discipline. Whenever WFS issues corrective discipline, that
discipline is designed to correct the performance problem and to make the employee
aware of the importance of adhering to WFS policies and procedures. Corrective
discipline may take the form of an oral warning, a written warning, and a suspension or
final warning, prior to discharge. However, depending on the facts and circumstances,
WFS reserves the right to skip any or all of these steps when it believes that action is in
the best interests of the Company. In no event is any employee guaranteed lesser
levels of corrective discipline before receiving more severe corrective discipline or
before discharge.

There are some types of conduct which are sufficiently serious that they may result in
an employee’s immediate discharge. It is not possible to list every infraction which may
result in immediate discharge. WFS provides the following list so employees understand
the type of behavior which can result in their discharge:

• Any violation of WFS Code of Conduct.

• Harassment of anyone in the course and scope of an employee’s employment.
• Reporting for work under the influence of alcohol or illegal drugs.
• Stealing or attempting to steal Company property or the property of another
employee, customer, vendor, business partner, or visitor.
• Falsifying information on any employment-records
• Fighting, threats, or intimidation of other employees.
• The use or possession of illegal drugs.
• The possession of weapons or explosives in violation of WFS workplace violence
policy.

Please see the “Corrective Discipline” policy for full details.

8.4 Solicitation
In an effort to ensure a productive and harmonious work environment, persons not
employed by WFS may not solicit or distribute literature during work hours or in any
place where work is being performed at any time for any purpose.

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

8.5 Employee Conflict Resolution

To provide for prompt and efficient evaluation of and response to conflicts or
grievances, WFS has established a conflict resolution procedure for all employees. It
will be the Company's policy to give full consideration to every employee's opinion.

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There will be no recrimination against anyone for presenting unresolved problems
between employees or between employees and their Supervisors.

Under this policy, a conflict is defined as any event, condition, rule, or practice where
the employee believes he/she has experienced a violation of civil rights, has been
treated unfairly, or has been caused any degree of unpleasantness or unhappiness
on the job. This covers a wide range of circumstances from the work place, the
environment, or policies or practices that interfere with or hinder performance. A
conflict may also deal with an attitude, a statement, or an opinion held by a manager
or a fellow employee.

Employees are encouraged to seek guidance from the Human Resources Department
with regard to the progressive steps involved in conflict resolution within WFS.

Please see the “Conflict Resolution” policy for full details.

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9.0 EMPLOYEE ACKNOWLEDGEMENT FORM
ACKNOWLEDGEMENT AGREEMENT OF WASEYABEK FEDERAL SERVICES, LLC
EMPLOYEE HANDBOOK

I have received a copy of the WFS Employee Handbook effective on the date shown on
this acknowledgement. The Policies and Procedures describe the current policies,
practices, and benefits of WFS.

I further understand the Handbook describes important information on employee

policies and procedures and I agree to consult with my Supervisor, or the management
of WFS, when I might have questions on employment, obligations or benefits.

I also understand business conditions constantly change. Therefore, the company has
the right to add, delete, modify or change any of the policies, practices, or benefits
described in the Employee Handbook at any time without prior notice to me or to any
WFS employee.

I understand my status is as an at-will-employee, for no definite period of time, unless

otherwise agreed to in writing. I understand my employment with the company is
entered into voluntarily and I am free to resign at any time. Similarly, the company is
free to conclude my employment relationship at any time, with or without cause.

I understand that no Supervisor or other official of the employer, except its Chief
Operating Officer & President, in writing, is authorized to change any of the policies or
procedures mentioned in the WFS employee handbook.

I acknowledge receiving the Employee Handbook in a hard copy, via email or on the
internet (www.wfedservices.com) and that I understand and agree to follow the policies
and procedures of Waséyabek Federal Services, LLC. Hard copies of the employee
handbook may be found in the office of each Program/Project Supervisor or in the
Human Resources Department.

Employee Signature Date

(Print Name)

PLEASE RETURN THIS ACKNOWLEDGEMENT TO THE HUMAN RESOURCES

DEPARTMENT

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