i-1-a.2 duties and responsibilities

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Approved Training Manual’s Lesson Plans And Courseware STAR MARIANAS AIR, INC. Initial New Hire – Flight Crew Part I – Basic Indoctrination Section 1 – Operator Specific Module A.Duties and Responsibilities

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Page 1: I-1-A.2 Duties and Responsibilities

Approved Training Manual’sLesson Plans

AndCourseware

STAR MARIANAS AIR, INC.

Initial New Hire – Flight CrewPart I – Basic Indoctrination

Section 1 – Operator Specific ModuleA.Duties and Responsibilities

Page 2: I-1-A.2 Duties and Responsibilities

Complete Class Roster

Cell Phones OFF

Class programmed duration 30 Minutes

Before We Start

Page 3: I-1-A.2 Duties and Responsibilities

Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

Page 4: I-1-A.2 Duties and Responsibilities

Current copy of the Employee Handbook

Training Materials/Learning

Outcomes

Page 5: I-1-A.2 Duties and Responsibilities

Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

3-1144. OPERATOR-SPECIFIC TRAINING MODULES. The subject area of a basic indoctrination training curriculum segment referred to as “operator-specific” includes training modules that pertain to the operator’s methods of compliance with the regulations and safe operating practices. Examples of recommended training modules for the operator-specific subject area follow:

A. Duties and Responsibilities.

Company history, organization, and management structure Operational concepts, policies, and kind of operation Company forms, records, and administrative procedures Employee standards and rules of conduct Employee compensation, benefits, and contracts Authority and responsibilities of duty position Company-required equipment Company manual organization, revisions, and employee

responsibilities concerning manuals

Order 8900 Reference

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company history, organization and management structure.

2) Operational concepts, policies and kind of operation.

3) Company forms, records, and administrative procedures.

4) Employee standards and rules of conduct.

5) Employee compensation, benefits, and contracts.

6) Authority and responsibilities of duty position.

7) Company required equipment.

8) Company manual organization, revisions, and employee responsibilities concerning manuals.

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company History, Organization and Management Structure

History of Star Marianas Air

Business Location

SMA’s Goal

List of management & background

Employee Handbook Chapter 1

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company History, Organization and Management Structure

History of Star Marianas Air

Star Marianas Air, Inc was originally incorporated under the laws of the Commonwealth of the Northern Mariana Islands as Star Aviation Air, Inc. in August 8, 2007.

On 05/12/2008 Mr. Robert F. Christian and Mr. Alfred Yue acquired the stock and changed the company’s name to Star Marianas Air, Inc. Mr. Christian held 75% of the stock and Mr. Yue held 25%; both are US citizens.

SMA amended its articles and renamed the Corporation, Star Marianas Air, Inc. “STAR” is an acronym formed by using the first letters of the Islands in the Northern Mariana Islands beginning with the Island of Saipan (S) in the north and then south including Tinian (T), Aguijan (A) and Rota (R).

Chapter 1-Company Background

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company History, Organization and Management Structure

History of Star Marianas Air – cont’d

On August 8, 2008, the Federal Aviation Administration accepted the Company’s application to become an Air Carrier and issued the preliminary Certificate Number 1SMA230P.

On April 1, 2009, the Company received its Certificate 1SMA230M and Operations Specifications allowing operations to begin as an on-demand service provider, using three (3) single-engine Piper PA32-300 aircraft, for day and/or night, passenger and/or cargo operations, under visual flight rules between the Islands of the Northern Marianas and Guam.

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Chapter 1-Company Background

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company History, Organization and Management Structure

History of Star Marianas Air – cont’d

Initially, flights were primarily being chartered by the Tinian Dynasty Hotel and Casino (TDHC) to accommodate its staff and some of its customers. The flights chartered by the TDHC were used primarily as a supplement to their existing agreements with a ferry boat service which provided the majority of their customer transfers between Saipan and Tinian.

In February 2010 Robert Christian sold 50% of the Company’s shares to Shaun Christian and 25% of the shares to Paz Christian. Shaun took over as the President and Chief Operating Officer and Robert continues to act as the Director of Flight Operations and Chairman of the Board of Directors.

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Chapter 1-Company Background

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company History, Organization and Management Structure

History of Star Marianas Air – cont’d

In March of 2010 Tinian Dynasty Hotel and Casino ceased operations of it passenger ferry boat service between Saipan and Tinian and has relied on Star Marianas Air to transport its customers between the islands

In April 2010, demand sharply increased as a result of the suspension of passenger ferry boat service and an increase in passengers visiting the TDHC facility.

On April 1, 2012 Paz Christian became the President of Star Marianas Air, Inc. and Shaun Christian took over as the Executive Vice President. Robert Christian continues as the Chairman of the Board of Directors.

Chapter 1-Company Background

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company History, Organization and Management Structure

Business Location

SMA has the following places of business:

The corporate headquarters is located at:

Hangar One, West Tinian International Airport Tinian MP 96952

Mailing address for Tinian:

PO Box 520461Tinian MP 96952

Mailing address for Saipan

PO Box 504820Saipan MP 96950

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company History, Organization and Management Structure

Business Location – cont’d

SMA has the following places of business:

There are check-in counters at three locations;

(1) the main terminal in Tinian,

(2) the Commuter Terminal in Saipan, and

(3) the Rota International Airport

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company History, Organization and Management Structure

Star Marianas Air’s Goal

Star Marianas Air, Inc. is a certificated air carrier. You were employed to perform functions that may include: piloting the airline’s aircraft, providing customer services, performing aircraft maintenance, or performing accounting functions or other support functions.

SMA has as its primary goal the provision of “RESPONSIBLE” air transportation between Tinian and Saipan. We are at all times fully committed to everyone’s safety.

You have been invited to join our company because we believe you can make a valuable contribution to the attainment of our goals. You are choosing to work with us because you feel the benefits, compensation and working condition package we offer is a fair exchange for your services.

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company History, Organization and Management Structure

Star Marianas Air’s Goal – cont’d

Therefore, please read, ask questions, and make sure you understand the information contained within the SMA Employee Handbook before signing the Employee Handbook Acknowledgment.

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company History, Organization and Management Structure

Organizational Chart

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

1) Company History, Organization and Management Structure

List of Management & Background

Robert F. Christian – Chairman of the Board/ Director of Operations

Paz L. Christian – President/ Chief Financial Officer

Shaun Christian – Executive Vice President

James E. Bell – Chief Pilot

Manuel Gabor – Director of Maintenance

Alma Canlas – Admin. Manager

Rowena Advincula – Accounting Manager

Joy Gustafson – Director of Customer Service

Donna Cabrera/ Randy Advincula – Dispatch Managers

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Pacific Island Aviation, Inc

1988 – 2006

Saipan

Tinian

Rota

Guam

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Tbilisi, GeorgiaCaucasus Airlines

Baku, Azerbaijan

Yerevan, Armenia

Sochi, Russia

Mineral Vody, Russia

D’neproprotrosk , Ukraine

Batumi, Georgia

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Iraq – 2005 through 2007Sulaimaniyah International Airport

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Bangalore, India 2006Falcon JetUniversity of North Dakota and BVU

1st undergraduate degree program with an aviation component

2007 - 2008

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Nigeria 2007

Albarka Air

Flight Attendants?

Maintenance staff?

Pilots?

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Safety Policy

Business Ethics policy and code of conduct

Drug and alcohol policy

Equal Opportunity employer

Harassment in the work place policy

Anti bribery and anti-boycott policies and procedures

The Family and Medical Leave Act policy

Computer Use Policy

Occupational Health and Safety Administration (OSHA)

Policy Statements

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Safety Statement

Safety is the first priority in all our activities. We are committed to implementing, developing and improving strategies, management systems and processes to ensure that all our aviation activities uphold the highest level of safety performance and meet national and international standards.

Our commitment is to: Develop and embed a safety culture in all our aviation activities that recognizes the importance and value of effective aviation safety management and acknowledges at all times that safety is paramount;

Clearly define for all staff their accountabilities and responsibilities for the development and delivery of aviation safety strategy and performance;

Minimize the risks associated with aircraft operations to a point that is as low as reasonably practicable/achievable;

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2) Operational Concepts, Policies and Kind of Operation

Safety Statement – cont’d

Our commitment is to: (cont’d)

Ensure that externally supplied systems and services that impact upon the safety of our operations meet appropriate safety standards;

Actively develop and improve our safety processes to conform to world-class standards;

Comply with and, wherever possible, exceed legislative and regulatory requirements and standards;

Ensure that all staff are provided with adequate and appropriate aviation safety information and training, are competent in safety matters and are only allocated tasks commensurate with their skills;

Ensure that sufficient skilled and trained resources are available to implement safety strategy and policy;

Establish and measure our safety performance against realistic objectives and/or targets;

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Safety Statement – cont’d

Our commitment is to: (cont’d)

Achieve the highest levels of safety standards and performance in all our aviation activities;

Continually improve our safety performance;

Conduct safety and management reviews and ensure that relevant action is taken; and

Ensure that the application of effective aviation safety management systems is integral to all our aviation activities, with the objective of achieving the highest levels of safety standards and performance.

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct

General

SMA is committed to conducting its business with honesty and integrity and applying the highest standard of ethics in all dealings with employees, customers, suppliers and the community. SMA will strictly comply with all applicable legislation, regulations and rules relating to the organizations and locations in which it carries out business.

All employees are required to comply with the Business Ethics Policy and Code of Conduct and any applicable policies, procedures and legislation. Breaching the requirements set out in these documents may result in disciplinary action, up to and including dismissal. The Policy also applies to contractors, consultants and secondees while they are engaged by SMA.

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct – cont’d

General – cont’d

Employees are encouraged to actively participate in applying this policy within the workplace and to raise any issues or concerns in relation to compliance with the Policy or related legislation. All issues raised will be treated seriously and confidentiality will be maintained where legally possible.

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct – cont’d

Values

Star Marianas Air, Inc.’s principles and standards set out in the Code of Business Ethics are based on the following values:

HonestyHonestyTo be honest and truthful in all of our dealings with one another and our customers, communities, suppliers and shareholders.

IntegrityIntegrity To say what we mean and deliver what we promise.

RespectRespect To treat one another with dignity and fairness.

TrustTrust To build confidence through open communication and teamwork.

ResponsibilResponsibilityity

To raise any concerns in the workplace, including any violations of policies, rules, regulation and procedures.

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A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct – cont’d

Principles and Standards

The Code of Business Ethics sets out the principles and standards Star Marianas Air, Inc. has adopted to guide our actions in all business conduct and practices.

1. Ensure that all dealings with employees, customers, communities and shareholders are conducted with honesty and integrity.

All interactions between employees will be based on honesty, fairness and respect.

All dealings with customers will be based on accurate and complete information, comply with applicable legislative requirements and be conducted in a fair and ethical manner.

SMA will be responsible in its actions and supportive of the communities within which it operates.

We will not tolerate harassment or discrimination of any kind - especially involving race, color, religion, gender, age, national origin, disability, and veteran or marital status

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Section 1 - Operator Specific

A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct – cont’d

Principles and Standards – cont’d

2. Conduct all business in accordance with applicable laws and regulations.

Star Marianas Air, Inc. will conduct its business in strict compliance with all applicable legislation, regulations and rules.

All employees are required to comply with applicable legal requirements and seek clarification in areas where they are unsure of their obligations

3. Work safely and protect the environment

Each of us is responsible for compliance with environmental, health, and safety laws and regulations. Star Marianas Air, Inc. is committed to providing a drug-free, safe and healthy work environment, and to observe environmentally sound business practices.

Observe posted warnings and regulations. Report immediately to the appropriate management any accident or injury sustained on the job, or any environmental or safety concern you may have.

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A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct – cont’d

Principles and Standards – cont’d.

4. Bid and negotiate contracts in an ethical manner and comply with legislative and contractual requirements.

All employees involved in the bidding and contract negotiation process will be responsible for understanding legislative and contractual requirements and carrying out the process in compliance with these requirements. All information, documentation, statements supplied to customers must be truthful and accurate. The submission of false information or documentation to customers will not be tolerated and could result in legal action. Once awarded, all contracts must be performed in accordance with the specifications and requirements.

5. Always keep accurate and complete records All payments and financial transactions must be properly authorized, disclosed, recorded and completed, in accordance with company policies and accepted accounting principles.

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2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct – cont’d

Principles and Standards – cont’d.

Incomplete, misleading or false recording of information will result in disciplinary action. Never rationalize or misrepresent facts.

6. Avoid illegal and questionable gifts or favors. Always comply with rules and regulations of customers and government agencies in relation to their policies on accepting gifts, entertainment and gratuities. Never use gifts or entertainment to gain advantage or favorable treatment in dealings with customers or suppliers. Kickbacks and bribes are never acceptable and may be against the law.

Where it is appropriate to offer entertainment, gifts or promotional material, they should only be of nominal value. The courtesies must never be lavish or extravagant under the circumstances Next --

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2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct – cont’d

Principles and Standards – cont’d.

Never accept gifts or entertainment that are offered by suppliers and intended to influence business decisions or gain competitive advantage. Any gifts accepted must only be of nominal value and acceptance should foster goodwill and successful business relations. Acceptance of such courtesies should not be frequent or reflect a pattern or the appearance of a pattern of frequent acceptance of courtesies from the same entities or persons.

The employee accepting the courtesies should feel comfortable about discussing the courtesies with his or her manager or coworker, or having the courtesies known by the public.

7. Follow the law and use common sense in political contributions and activities.

The company encourages its employees to become involved in civic affairs and to participate in the political process. Employees must understand however that their involvement and participation must be on an individual basis on their own time and at their own expense.

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Business Ethics Policy & Code of Conduct – cont’d.

Principles and Standards – cont’d.

Know the laws that govern political contributions and activities and ensure that you comply.

8. Strictly adhere to all antitrust laws Antitrust is a blanket term for laws that protect the free enterprise system and promote open and fair competition. These laws deal with agreements and practices “in restraint of trade” such as price fixing and boycotting suppliers or customers. They also bar pricing intended to run competitor out of business; disparaging, misrepresenting, or harassing a competitor; stealing trade secrets; bribery; and kickbacks. Antitrust laws are vigorously enforced.

These laws also apply to international operations and transactions related to imports into and exports from the countries in which we do business. Employees involved in any dealings with competitors are expected to know about antitrust laws and to consult with the Legal Department prior to negotiating with or entering into any arrangement with a competitor.

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A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct – cont’d

Principles and Standards – cont’d.

9. Be sensitive to the conduct of international business.

The Company is committed to conduct its activities free from the unfair influence of bribery. Corruption erodes confidence in the marketplace. Star Marianas Air, Inc. depends on trust and transparency in the transaction of business.

10. Exercise care and judgment in utilizing corporate resources.

Avoid conflicts of interest and avoid any relationships or interactions that may influence your objectivity and fairness in performing your role.

Do not undertake outside employment with competitors, customers or suppliers unless you have a signed authorization from Star Marianas Air, Inc. to do so.

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2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct – cont’d

Principles and Standards – cont’d.

11. Do not engage in speculative or insider trading.

Do not trade in securities, property or assets based on information acquired through your employment with Star Marianas Air, Inc. It is against the law for employees to buy or sell Company stock based on material, non-public (“insider”) information about or involving the Company.

Understand that this guidance also applies to the securities of other companies (suppliers vendors subcontractors, etc.) for which you receive information in the course of your employment at Star Marianas Air, Inc.

12. Protect proprietary information.

Proprietary Company information may not be disclosed to anyone without proper authorization.

Keep proprietary documents protected and secure.

In the course of normal business activities, suppliers, customers, and competitors may sometimes divulge to you information that is proprietary to their business. Respect these confidences

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Business Ethics Policy & Code of Conduct – cont.

Responsibilities

The Chief Executive Officer has overall responsibility for ensuring that the company operates in accordance with the principles and standards set out in the Business Ethics Policy and Code of Conduct and ensuring that any breaches are appropriately dealt with. An Ethics Officer will be appointed by the Chief Executive Officer to oversee compliance with this policy. The Ethics Officer will report directly to the Executive Office and the Board of Directors.

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Section 1 - Operator Specific

A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct – cont.

Responsibilities – cont’d

Managers and Team leaders are responsible for ensuring that each person under his or her supervision receives and understands the Business Ethics Policy and Code of Conduct. Managers and Supervisors are also responsible for modeling appropriate behavior and for creating a positive working environment that fosters and encourages ethical conduct. All members of management must be careful in words and conduct to avoid placing, or seeming to place, pressure on subordinates that could cause them to deviate from acceptable ethical behavior.

All employees are responsible for adhering to the principles set out in the Ethics Policy and Code of Conduct and reporting any breaches of this policy to management or to the Ethics Officer.

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Business Ethics Policy & Code of Conduct – cont.

Education

Star Marianas Air, Inc. will ensure that all employees are aware of and understand the company’s Business Ethics Policy and Code of Conduct and their personal obligations for compliance in this area.

The Human Resource area will be responsible for ensuring that education of ethical issues is incorporated into induction programs and other training and development activities across the organization.

Inquiries and Reporting Incidents

Employees are encouraged to direct all inquiries and report any violations of the Policy, Code of Conduct or applicable legislation to their immediate Manager or the Human Resource Manager. Reports may also be made independently to the Ethics Officer.

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2) Operational Concepts, Policies and Kind of Operation

Business Ethics Policy & Code of Conduct – cont.

Inquiries and Reporting Incidents – cont’d

All inquiries will be treated seriously and no employee will be disadvantaged for raising a concern. Confidentiality will be applied, except where disclosure is required by law.

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2) Operational Concepts, Policies and Kind of Operation

Drug and Alcohol Policy

It is the Company’s policy to maintain a drug-free work place.

The use, sale, manufacture, distribution, purchase, possession, dispensing, or being under the influence of alcohol, illegal drugs, or non-prescribed controlled substances on Company property, while on Company business, or while operating Company-owned or leased equipment is strictly prohibited.

Employees found to be in violation of this policy will be subject to termination of employment.

APPENDIX B of the Employee Handbook contains SMA’s Substance Abuse Policy and Alcohol Misuse and Prevention Program

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Equal Opportunity Employer

The Company is an equal opportunity employer complying with all federal laws concerning non-discrimination, and affirms its commitments to the principle of equal opportunity in all employee relations.

Our policy is to:

Recruit, hire and promote persons without discrimination with regard to race, religion, color, sex, age, or national origin.

 Employ and advance qualified physically and mentally handicapped individuals, disabled veterans, and veterans of the Vietnam era.

Actively seek and place qualified women and persons in minority groups in all lines of employment.

Ensure that all personnel decisions are in accordance with the principles of equal employment opportunity.

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Basic Indoctrination Training:

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A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Harassment in the Work Place Policy

Harassment and discrimination is prohibited.

Harassment and any form of discrimination violate company policy and are strictly prohibited.

All employees must be allowed to work in an environment free from harassment or discrimination. To accomplish this, the company must have the cooperation of all employees.

If an employee believes that harassment or discrimination has taken place, the employee must report it immediately to his or her supervisor.

If for any reason this would be inappropriate, or if not satisfied with the response, the employee is responsible for bringing the matter directly to the President of SMA.

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Harassment in the Work Place Policy – cont’d

Harassment may be difficult to recognize. It can consist of sexual favoritism, attempts to condition employment benefits on sexual concessions, or comments and/or conduct that creates a hostile or intimidating atmosphere.

If an employee feels that the conduct or statement of any other employee may constitute harassment, or may undermine the company’s commitment to equal employment opportunity, the employee must immediately notify the appropriate person, as explained above.

This is every employee’s responsibility.

All reports will be taken seriously and investigated.

The company will protect the confidentiality of those involved to the extent it can, consistent with the need to investigate and resolve the problem.

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Harassment in the Work Place Policy – cont’d Disciplinary action, including termination, will be taken against those who violate this policy, and against any others who condone such conduct.

No employee will be retaliated against for good faith efforts to comply with this policy.

Harassment is a form of employment discrimination that violates Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act of 1967, (ADEA), and the Americans with Disabilities Act of 1990, (ADA).

Additional references are available from the U.S. Equal Employment Opportunity Commission (EEOC) website at: http://www.eeoc.gov/laws/practices/harassment.cfm

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Anti Bribery Policy

General Scope

The Company will conduct every business transaction with integrity and will comply with the laws and regulations of each country in which it operates as well as the U.S. Foreign Corrupt Practices Act.

More specifically, it is prohibited for the Company, its officers, directors, employees or consultants, to offer or give money or anything of value, directly or indirectly through agents or intermediaries, to government officials (including officials or employees of any wholly or partially government-owned company), any political party or official thereof, or any person while knowing or being aware of a high probability that all or a portion of any payment will be offered, given or promised, directly or indirectly, to any of the above, to assist the Company in obtaining or retaining business.

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Anti Bribery Policy - cont’d

General Scope – cont’d

Additional reference about the U.S. Foreign Corrupt Practices Act is available from the U.S. Department of Justice website at: http://www.justice.gov/criminal/fraud/fcpa/

Limited Exceptions

Subject to the laws and regulations of each country in which the Company operates, the Company’s Business Ethics Policy and Code of Conduct, and the prior written approval of the Company’s legal counsel, who shall be competent in such matters, there may be certain limited exceptions to the general scope of this policy.

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Anti Bribery Policy - cont’d

Limited Exceptions – cont’d

These limited exceptions may include any facilitating or expediting payment to any government official, political party, or party official, “the purpose of which is to expedite or secure performance of a routine governmental action.” Examples of such “routine governmental action” may include actions ordinarily and commonly performed by a government official in:

• Granting permits, licenses, or other official documents to qualify a person to do business in a foreign country;

• Processing governmental papers such as visas and work orders;

• Providing police protection, mail pick-up and delivery, or scheduling inspections associated with contract performance or inspections related to transit of goods across country; or

• Providing phone service, power and water supply, loading and unloading cargo, or protecting perishable products or commodities from deterioration

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Anti Bribery Policy - cont’d

Limited Exceptions – cont’d

The term “routine governmental action” does not include any decision by a government official whether, or on what terms, to award new business to or continue business with a particular party, or any action taken by a government official involved in the decision-making process to encourage a decision to award new business or to continue business with a particular party

Action Required

Any director, officer, employee or consultant of the Company who receives a request, either in writing or orally, which is, or might be construed as, a request to take or agree to take any of the prohibited actions (or possible exceptions thereto) set forth above, will not respond to the request and will immediately refer the request to the Company’s legal counsel..

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Anti-Boycott Policy

General Scope of Policy

It is the policy of the Company to prohibit its officers, directors, employees and consultants from taking any action or making any agreement or statement which has the effect of furthering, supporting, participating in or cooperating with any boycott not sanctioned by the U.S. Government, provided that, in the event compliance with this paragraph would result in a material violation of local law by Company or any of its directors, officers, or employees, the Company’s Board of Directors shall promptly meet and discuss in good faith a proper course of action with respect to such violation.

Additional information regarding Antiboycott Compliance is available at the U.S. Department of Commerce Bureau of Industry and Security website at: http://www.bis.doc.gov/complianceandenforcement/antiboycottcompliance.htm

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Anti-Boycott Policy – cont’d

Prohibited Conduct

No director, officer, employee or consultant will take any action or make any agreement to:

• Refuse (or require any person to refuse) to do business with anyone, including an entity of a boycotted country or a blacklisted person, pursuant to an agreement with, a requirement of, or a request from or on behalf of an entity of a boycotting country;

• Discriminate against any individual or entity in employment or in commercial relationships on the basis of the race, religion, sex, national origin or nationality of such person or, where an entity, of its employees, officers, directors or owners;

• Furnish information with respect to the race, religion, sex, or national origin of any individual or entity or, where an entity, of any owner, officer, director, or employee of such entity;

• Furnish information about past, current, or prospective business relationships of anyone with a boycotted country, an entity of a boycotted country, or firms known or believed to be on a boycott list or “blacklist”; or

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A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Anti-Boycott Policy – cont’d

Prohibited Conduct – cont’d

No director, officer, employee or consultant will take any action or make any agreement to:

• Furnish information about the affiliation or other relationship of any person with an organization which supports a boycotted country.

Action Required

Any officer or employee of the Company who receives a request, whether in relation to a sanctioned or unsanctioned boycott, either in writing or orally, which is, or might be construed as, a request to take or agree to take any of the prohibited actions set forth above, will not respond to the request and will immediately refer the request to the Company’s legal counsel.

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

The Family and Medical Leave Act Policy

The FMLA entitles eligible employees of covered employers to take unpaid, job-protected leave for specified family and medical reasons with continuation of group health insurance coverage under the same terms and conditions as if the employee had not taken leave. Eligible employees are entitled to twelve workweeks of leave in a 12-month period for: the birth of a child and to care for the newborn child within one year of birth; the placement with the employee of a child for adoption or foster care and to care for the newly placed child within one year of placement; to care for the employee’s spouse, child, or parent who has a serious health condition; a serious health condition that makes the employee unable to perform the essential functions of his or her job;

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Section 1 - Operator Specific

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2) Operational Concepts, Policies and Kind of Operation

The Family and Medical Leave Act Policy – cont’d

any qualifying exigency arising out of the fact that the employee’s spouse, son, daughter, or parent is a covered military member on “covered active duty;” or Twenty-six workweeks of leave during a single 12-month period to care for a covered servicemember with a serious injury or illness who is the spouse, son, daughter, parent, or next of kin to the employee (military caregiver leave).

FMLA Amendments for Airline Flight Crew

The amendment provides that an airline flight attendant or flight crew member meets the hours of service requirement if, during the previous 12-month period, he or she:

(1) has worked or been paid for not less than 60 percent of the applicable total monthly guarantee (or its equivalent), and

(2) has worked or been paid for not less than 504 hours, not including personal commute time, or time spent on vacation, medical, or sick leave.

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2) Operational Concepts, Policies and Kind of Operation

The Family and Medical Leave Act Policy – cont’d

Additional information is available at the U.S. Department of Labor website for the Family and Medical Leave Act at: http://www.dol.gov/whd/fmla/

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Basic Indoctrination Training:

Section 1 - Operator Specific

A. Duties and Responsibilities

2) Operational Concepts, Policies and Kind of Operation

Computer Use Policy

Purpose

To remain competitive, better serve our customers and provide our employees with the best tools to do their jobs, Star Marianas Air, Inc. makes available to our workforce access to one or more forms of electronic media and services, including computers, e-mail, telephones, voicemail, fax machines, external electronic bulletin boards, wire services, online services, intranet, Internet and the World Wide Web.

Prohibited Communications

Electronic media cannot be used for knowingly transmitting, retrieving, or storing any communication that is:• Discriminatory or harassing;

• Derogatory to any individual or group;

• Obscene, sexually explicit or pornographic;

• Next --

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Computer Use Policy – cont’d

Prohibited Communications

Electronic media cannot be used for knowingly transmitting, retrieving, or storing any communication that is:

• Defamatory or threatening;

• In violation of any license governing the use of software; or

• Engaged in for any purpose that is illegal or contrary to Star Marianas Air’s policy or bus iness interests .

Personal Use

The computers, electronic media and services provided by Star Marianas Air, Inc. are primarily for business use to assist employees in the performance of their jobs.

Next --

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Computer Use Policy – cont’d

Personal Use (cont’d)

Limited, occasional, or incidental use of electronic media (sending or receiving) for personal, nonbusiness purposes is understandable and acceptable, and all such use should be done in a manner that does not negatively affect the systems' use for their business purposes. However, employees are expected to demonstrate a sense of responsibility and not abuse this privilege

Access to Employee Communication

Star Marianas Air does routinely gather logs for most electronic activities or monitor employee communications directly, e.g., telephone numbers dialed, sites accessed, call length, and time at which calls are made, for the following purposes:• Cost analysis;

• Resource allocation;

• Next --

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Computer Use Policy – cont’d

Access to Employee Communication – cont’d

• Optimum technical management of information resources; and

• Detecting patterns of use that indicate employees are violating company policies or engaging in illegal activity.

• Star Marianas Air, Inc. reserves the right, at its discretion, to review any employee's electronic files and messages to the extent necessary to ensure electronic media and services are being used in compliance with the law, this policy and other company policies.

• Employees should not assume electronic communications are completely private. Accordingly, if they have sensitive information to transmit, they should use other means.

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Computer Use Policy – cont’d

Software

To prevent computer viruses from being transmitted through the company's computer system, unauthorized downloading of any unauthorized software is strictly prohibited. Only software registered through Star Marianas Air may be downloaded. Employees should contact the system administrator if they have any questions.

Security and Appropriate Use

Employees must respect the confidentiality of other individuals' electronic communications. Except in cases in which explicit authorization has been granted by company management, employees are prohibited from engaging in, or attempting to engage in:

• Monitoring or intercepting the files or electronic communications of other employees or third parties;

• Hacking or obtaining access to systems or accounts they are not authorized to use;

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Computer Use Policy – cont’d

Security and Appropriate Use – cont’d

• Using other people's log-ins or passwords; and

• Breaching, testing, or monitoring computer or network security measures .

No e-mail or other electronic communications can be sent that attempt to hide the identity of the sender or represent the sender as someone else.

Electronic media and services should not be used in a manner that is likely to cause network congestion or significantly hamper the ability of other people to access and use the system.

Anyone obtaining electronic access to other companies' or individuals' materials must respect all copyrights and cannot copy, retrieve, modify or forward copyrighted materials except as permitted by the copyright owner.

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2) Operational Concepts, Policies and Kind of Operation

Computer Use Policy – cont’d

Encryption

Employees can use encryption software supplied to them by the systems administrator for purposes of safeguarding sensitive or confidential business information.

Employees who use encryption on files stored on a company computer must provide their supervisor with a sealed hard copy record (to be retained in a secure location) of all of the passwords and/or encryption keys necessary to access the files.

Participation in Online Forum

Star Marianas Air, Inc. recognizes that participation in some forums might be important to the performance of an employee's job. For instance, an employee might find the answer to a technical problem by consulting members of a news group devoted to the technical area.

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Computer Use Policy – cont’d

Violations

Any employee who abuses the privilege of their access to e-mail or the Internet in violation of this policy will be subject to corrective action, including possible termination of employment, legal action, and criminal liability

Employee Agreement on Use of E-mail and the Internet

By signing the Employee Handbook Acknowledgement the employee acknowledges the following:

• To having read, understood, and agree to comply with the foregoing policies, rules, and conditions governing the use of the Company's computer and telecommunications equipment and services.

• An employee has no expectation of privacy when using any of the telecommunication equipment or services.

• Next --

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Computer Use Policy – cont’d

Employee Agreement on Use of E-mail and the Internet – cont’d

By signing the Employee Handbook Acknowledgement the employee acknowledges the following:

• That a violation of this guideline on appropriate use of the e-mail and Internet systems may subject an employee to disciplinary action, including termination from employment, legal action and criminal liability.

• That an employee’s use of the e-mail and Internet may reflect on the image of Star Marianas Air, Inc. to our customers, competitors and suppliers and that I have responsibility to maintain a positive representation of the company.

• This policy can be amended at any time.

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Use of Company Vehicles and Ground Support Equipment

Company vehicles will be used whenever possible to conduct company business and/or errands. Any employee using a company vehicle must adhere to all applicable traffic rules and regulations. Star Marianas Air, Inc. is not liable for any violation incurred due to misuse of the company vehicle.

Employees who use company vehicles must be at least 25 years old and holds a current Driver’s License valid in the CNMI.

Employees who are assigned to use and/or operate company vehicles and ground support equipment may be subjected to Drug and Alcohol testing at the discretion of Star Marianas Air, Inc.

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Occupational Safety and Health Administration (OSHA)

SMA adheres to guidelines set by OSHA under the U.S. Department of Labor.

For current information employees are advised to visit the OSHA website at: https://www.osha.gov/index.html

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REVIEW

Type of Company: CorporationCorporation

Place of Incorporation: CNMICNMI

Headquarters: TinianTinian

Policies in Employee Handbook Chapter 2

Safety StatementSafety Statement

Equal Opportunity EmployerEqual Opportunity Employer

Drug and Alcohol PolicyDrug and Alcohol Policy

Harassment in the Workplace PolicyHarassment in the Workplace Policy

Business Ethics Policy and Code of ConductBusiness Ethics Policy and Code of Conduct

Anti Bribery PolicyAnti Bribery Policy

Anti-Boycott Policies and ProceduresAnti-Boycott Policies and Procedures

The Family and Medical Leave Act PolicyThe Family and Medical Leave Act Policy

Computer Use PolicyComputer Use Policy

Use of Company Vehicles and Ground Support Use of Company Vehicles and Ground Support EquipmentEquipment

OSHAOSHA

Basic Indoctrination Training:

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Written examination not required

Examination

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Student Fill-out Student Feedback Form Sign Training Record (if applicable)

Instructor Sign Class Roster Fill-out Instructor Feedback Form Sign Training Record (if applicable)

Completion of Paperwork

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