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EMPLOYEE HANDBOOK - NORTH AMERICA January 2017 Beyond A Job Innovation Group Business Process Solutions for Auto, Property, Towing and Roadside Assistance

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Page 1: Innovation Group - HRadvocate Portal · PDF file2 Innovation Group Employee Handbook We are excited to distribute the 2017 Innovation Group, North America Employee Handbook. This

EMPLOYEE HANDBOOK - NORTH AMERICA

January 2017

Beyond A Job

Innovation Group Business Process Solutions for Auto, Property, Towing and Roadside Assistance

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Innovation Group Employee Handbook

We are excited to distribute the 2017 Innovation Group, North America Employee Handbook. This

Employee Handbook of Innovation Group, North America, also known throughout this handbook as “the

Company”, was developed to provide you with information about your employment with Innovation

Group and benefits available to eligible employees. Employees should familiarize themselves with the

contents of this Handbook, for it will answer many questions about employment with Innovation Group,

North America.

This handbook is not intended as an exhaustive compilation of the Company’s expectations, but rather it

provides information on certain policies and benefits which are currently in effect. Additionally, the

Handbook is accessible on Innovation Group, North America Employee Self Service portal:

www.innovation-group.web4inc.com/hradvocate_innovation/HRMS_modules/Login.aspx

Employees may login using first initial and last name as username and last four digits of SSN as preset

password. These documents have been placed on this secure portal for your reference and can be easily

updated by the Company. In connection with our ongoing efforts to enhance communication within the

organization, we plan to utilize our on-line tools to communicate with our employees as needed. For that

reason, employees are encouraged to periodically visit their Employee Self Service portal.

The Company reserves the exclusive right to, at any time, add to, modify, revoke, suspend, terminate or

change any of the plans, rules, policies and procedures set forth in this Handbook without notice and

regardless of whether the Handbook itself is modified. This Handbook may not reflect changes

immediately as they occur. Consult with your supervisor if you have any questions or need for

clarification.

Please review and retain a copy of the Handbook for future reference. A copy may be printed directly

from the Employee Self-Serve portal. If you still have questions about any of the Company’s policies,

programs, and benefits after reading this handbook please contact Human Resources via email to

[email protected]

At Innovation Group, we have a deep respect and appreciation for our customers. We strive to serve

their needs and exceed their expectations; every individual plays an important role in helping ensure

Innovation Group’s success.

We look to the future with confidence, and we hope that your employment with Innovation Group, North

America will bring professional satisfaction and growth throughout the coming years. Thank you for

being part of our team. Working together, Innovation Group, North America will continue to grow as a

place at which we are proud to work and our customers and clients are proud to partner with.

Sincerely,

Kim Edwards

Chief People Officer/ EVP Human Resources

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CO N T E N T

Welcome………………………………………………………………………………………………………… ..................... 6

Beyond A Job…………………………………………………………………………………………………………. ........... 6

Our Culture…………………………………………………………………………………………………………….. ........... 6

Innovation Group…………………………………………………………………………………………………………… ... 6

Our Identity…………………………………………………………………………………………………………….. ........... 6

Our Mission……………………………………………………………………………………………………………. ........... 6

Basic Policy Statement……………………………………………………………………………………………………. ... 6

Our Vision……………………………………………………………………………………………………………… ........... 6

Our Values……………………………………………………………………………………………………………… .......... 6

Our People……………………………………………………………………………………………………………… .......... 7

Valuing Diversity & Inclusion In the Workplace………………………………………………………………… ........... 7

Open Door Policy-Solving Problems ………………………………………………………………..................... ………7

Equal Employment Opportunity & Affirmative Action Statement………………………………………………….. .. 7

Business Ethics & Compliance…………………………………………………………………………………………... .. 8

Communities……………………………………………………………………………………………………………. ......... 8

EMPLOYMENT GUIDELINES & PRACTICES………………………………………………….. .......... 8

Nature of Employment………………………………………………………………………………………………… ......... 8

Employment of Relatives……………………………………………………………………………………………... ......... 8

Employee Referral Bonus Program…………………………………………………………………………………. ........ 8

Employment Classification…………………………………………………………………………………………… ......... 9

Performance Appraisals………………………………………………………………………………………………. ......... 9

Internal Job Posting Program for Growth & Advancement……………………………………………………. ......... .9

PROFESSIONAL STANDARDS & PRACTICES…………………………………………………... ..... 10

Personnel & Medical Records………………………………………………………………………………………… ...... 10

Access to Personnel Files……………………………………………………………………………………………... ..... 10

Protection of Confidential Information & Privacy…………………………………………………………………. ..... 10

Conflicts of Interest……………………………………………………………………………………………………… .... 11

Gifts………………………………………………………………………………………………………………………… ..... 11

Non-Compete……………………………………………………………………………………………………………... .... 11

Communication…………………………………………………………………………………………………………… .... 11

Outsider Request for Information……………………………………………………………………………………... .... 12

Product Development……………………………………………………………………………………………………. .... 12

Client Sites…………………………………………………………………………………………………………………. ... 12

Professional Conduct……………………………………………………………………………………………………….. 12

Employment Verification……………………………………………………………………………………………….. ..... 12

Complaint Resolution…………………………………………………………………………………………………… ..... 12

Employee Suggestions…………………………………………………………………………………………………. ..... 12

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Solicitation & Distribution……………………………………………………………………………………………… ..... 13

Bulletin Board Policy……………………………………………………………………………………………………. ..... 13

Termination of Employment Voluntary………………………………………………………………………………. .... 13

Service Date………………………………………………………………………………………………………………. ..... 13

SPECIFIC POLICIES………………………………………………………………………………….. .... 13

Anti-Harassment – Including Sexual Harassment………………………………………………………………….. .... 13

Reporting & Investigating Harassment……………………………………………………………………………….. ... 14

Substance Free Workplace……………………………………………………………………………………………… ... 14

Pre-Employment Drug Testing………………………………………………………………………………………….. .. 15

Work Related Accidents or Illness……………………………………………………………………………………... .. 15

Workplace Threats & Violence………………………………………………………………………………………….. ... 15

Health & Safety……………………………………………………………………………………………………………..... 16

Visitors………………………………………………………………………………………………………………………. .. 16

Building Security…………………………………………………………………………………………………………... .. 16

Fire Arms Weapon-Free Workplace……………………………………………………………………………………. ... 16

Clean Desk Policy…………………………………………………………………………………………………………. ... 17

Desk Privacy & Searches………………………………………………………………………………………………… .. 17

Use of Company Property……………………………………………………………………………………………….. ... 17

Computer Terminals & Software………………………………………………………………………………………….. 17

Lost, Stolen or Damaged Equipment………………………………………………………………………………….. ... 18

Return of Company Property……………………………………………………………………………………………. .. 18

Smoking & Tobacco Free………………………………………………………………………………………………… .. 18

Dress Code…………………………………………………………………………………………………………………. ... 18

Attendance/Tardiness…………………………………………………………………………………………………….. .. 18

Food & Drinks at Your Workstation……………………………………………………………………………………. ... 19

Monitoring & Recording………………………………………………………………………………………………….. .. 19

Weather Facility Closing…………………………………………………………………………………………………. ... 19

Breaks & Meal Periods…………………………………………………………………………………………………… ... 19

Nursing Mothers…………………………………………………………………………………………………………… .. 19

E-Mail & Chat……………………………………………………………………………………………………………….. .. 19

Voice Mail…………………………………………………………………………………………………………………… ... 20

Internet Use…………………………………………………………………………………………………………………. .. 20

Social Media………………………………………………………………………………………………………………… .. 21

LEAVE OF ABSENCE & ACCOMODATIONS……………………………………………………… ... 21

Americans with Disabilities Act………………………………………………………………………………………… ... 21

Family and Medical Leave (FMLA)……………………………………………………………………………………… .. 22

Family Military Leave…………………………………………………………………………………………………….. .... 23

Military Duty Leave……………………………………………………………………………………………………….. ... 23

Non-FMLA Leave of Absence…………………………………………………………………………………………… ... 23

Other Leaves of Absence………………………………………………………………………………………………… .. 23

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Jury Duty Leave……………………………………………………………………………………………………………. .. 23

Bereavement Leave……………………………………………………………………………………………………… ... .24

Time Off to Vote……………………………………………………………………………………………………………. .. 24

Crime Victim or Domestic Violence Leave……………………………………………………………………………. .. 24

Paid Sick Leave……………………………………………………………………………………………………………. ... 24

EMPLOYEE BENEFITS……………………………………………………………………………….. .. 25

Insurance Benefits………………………………………………………………………………………………………… .. 25

Better Life Employee Assistance Program (EAP)…………………………………………………………………… ... 25

Company’s 401K Savings Plan…………………………………………………………………………………………. ... 25

Company Holidays……………………………………………………………………………………………................. ... 25

Holiday Pay………………………………………………………………………………………………………………… ... 26

Holiday Rate………………………………………………………………………………………………………………... ... 26

Paid Time Off (PTO)………………………………………………………………………………………………………. ... 26

DISCIPLINARY PROCEDURES……………………………………………………………………… .. 27

Rules of Conduct………………………………………………………………………………………………………….. ... 27

Serious Misconduct………………………………………………………………………………………………………. ... 28

Separation Procedures & Policy……………………………………………………………………………………….. ... 29

PAYROLL PROCEDURES & POLICY………………………………………………………………. ... 29

Direct Deposit……………………………………………………………………………………………………………… ... 29

Time Clock…………………………………………………………………………………………………………………..... 29

Overtime……………………………………………………………………………………………………………………..... 29

Wage Discrepancies…………………………………………………………………………………………………….... ... 29

Cash Advances & Pay Checks…………………………………………………………………………………………..... 29

POLICIES FOR INDIVIDUALS WITH SPECIFIC FUNCTIONS……………………………………... 30

Company Issued Cell Phone…………………………………………………………………………………………….. .. 30

Bring Your Own Device (BYOD)………………………………………………………………………………………… .. 30

Telecommuter/Remote Workers………………………………………………………………………………………… .. 31

Company Issued Credit Cards…………………………………………………………………………………………... .. 31

Travel & Expense Policy………………………………………………………………………………………………….. .. 32

ACKNOWLEDGEMENT……………………………………………………………………………….. . 37

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W E L C O M E T O INNOVATION G R O U P

We are both excited and pleased to welcome you to the Innovation Group family servicing our North America

Region. As an Employee of Innovation Group, you have joined a team of professionals who proudly demonstrate

their commitment to providing superior customer service and delivery of services to our customers throughout

the United States, Canada, Germany, France, Spain, UK, India, Poland, Belgium Nederland’s , Australia and

South Africa. Where we put millions of lives back on track!

BEYOND A JOB

Every day Innovation Group employees’ across the globe help people recover from unexpected events whether it

be a flat tire on the way to work, water damage from a hot water tank leak or auto body repair from an accident.

Innovation Group helps put their life back on track. It takes empathy, it takes going above and beyond, it takes

building the right relationships and it takes people who don’t just want a job… they want to make a difference.

OUR CULTURE

We foster a diverse work environment. We embrace a spirit of innovation and encourage our employees to take

initiative to do the right things smarter, to work together to do things better and to communicate and collaborate

so we excel.

INNOVATION GROUP

Innovation Group is one of the leading solution providers to the global insurance industry through the development of a flexible combination of specialized business process outsourcing, supply chain management, and technology solutions. Our partnerships give clients access to proven, leading-edge technology, world-class insurance expertise and global delivery capabilities. Innovation is not static, and neither is our business. With a network of global offices and world class outsourcing operations we deliver solutions to our clients that generate measurable, sustainable business results and cost savings, while providing better service to customers. We operate in the world's largest insurance markets with a high proportion of our clients having international operations. Our team across the world has extensive insurance experience and they are ably supported by our partners.

OUR IDENTITY

Innovation Group, North America provides business process solutions for Auto, Property, Towing and Roadside Assistance in the United States and Canada. The solutions help our clients improve their customers experience, reduce internal process costs, and improve claims cost accuracy.

OUR MISSION

Providing effective, efficient, end-to-end solutions, focused on profit and process improvements that maximize the customer experience through process and technology innovation and using experts in their fields to drive the cycle to resolution. BASIC POLICY STATEMENT

Innovation Group (the “Company” or Innovation Group) conducts its business in strict compliance with both the letter and spirit of the law and in full adherence with the highest principles of business integrity and ethics. All Employees have the responsibility to conduct their dealings with customers, competitors, suppliers, and fellow Employees in a fair and honest manner consistent with the contents of this handbook. The following Corporate Objectives are guiding principles of Innovation Group in the conduct of its business.

OUR VISION

To enable efficiencies to improve revenue generation, customer service, and profitability for our clients.

OUR VALUES

We act with integrity. We respect our clients, colleagues, suppliers and employees. We are reliable. Our solutions are innovative and sustainable.

OUR PEOPLE

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To maintain an organization of highly skilled, knowledgeable and empowered customer-oriented individuals in the countries of our operations, committed to the shared values and goals of Innovation Group.

VALUING DIVERSITY & INCLUSION IN THE WORKPLACE

We believe that a diverse work force best serves the interests of our employees, our customers and the communities in which we do business. Innovation Group recognizes that diversity is a business objective and that an inclusive workplace results in a better experience for our customers and employees. Innovation Group intends to create a work environment that fosters respect for the different experiences that each employee brings to his or her job. We believe that our differences make us stronger. The Company demonstrates its commitment to inclusion through:

Recruitment, hiring and development of employees;

Serving the needs of our customers; and

The Company’s mission and business strategy

Recruitment/hiring/promotions/training of minorities, females and protected Veterans OPEN DOOR POLICY—SOLVING PROBLEMS

The Company is committed to an Open Door Policy to answer any work related questions, problems or concerns

you may have. If you have a concern you would like to bring to the Company’s attention, follow these steps:

Talk it over with your immediate manager, if this issue doesn’t directly involve this individual.

If you and your manager cannot resolve the issue to your satisfaction, or your manager is part of the problem, you should feel comfortable discussing your concerns with the next level of management.

If you are not satisfied with the response given by your managers or if you do not feel comfortable in bringing your concerns to the attention of your mangers, please contact Human Resources.

Guidance will be provided as to alternative ways that such issues may be resolved.

The most important relationship you will develop at Innovation Group will be between you and your manager.

However, should you need support from someone other than your manager; the entire management team is

committed to trying to resolve your individual concerns in a timely and appropriate manner.

EQUAL EMPLOYMENT OPPORTUNITY STATEMENT & AFFIRMATIVE ACTION POLICY

Innovation Group maintains a continuing policy of nondiscrimination in employment. It is our policy to provide equal opportunity in all phases of the employment process and in compliance with applicable federal, state and local laws and regulations. This policy of nondiscrimination shall include, but not be limited to, the following employment decisions and practices: hiring; upgrading; promotions; demotions or transfers; layoffs; recalls; terminations; rate of pay or other forms of compensation; section for training, including apprenticeship; and recruitment or recruitment advertising. Employees and applicants of Innovation Group will not be subjected to any form of retaliation, harassment or discrimination for exercising rights protected by, or because of their participation in, an investigation or compliance review related to Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act, the Americans with Disabilities Act, Executive Order 11246, Section 503 of the Rehabilitation Act of 1973, the Vietnam Era Veterans’ Readjustment Assistance Act of 1974, the Veterans Employment Opportunities Act of 1998, or any other federal or state nondiscrimination law, rule, or regulation. Innovation Group is committed (1) to recruit, hire, train and promote persons and (2) to insure that all employment and personnel actions such as compensation, benefits, transfers, promotions, layoffs, return from layoff and company sponsored training, education and activity will be administered without regard to sex, age, race, color, national original, religion, sexual orientation, disability, veteran status or any other status or condition protected by applicable law, except where a bona fide occupational qualification applies. The success of this Policy requires cooperation between management and employees. All violations of the Company's Equal Employment Opportunity Policy should be reported immediately to the employee's immediate supervisor. If the employee's immediate supervisor is involved in this Policy's violation or is unresponsive, it should be reported directly to the next level management or Innovation Group senior management committee or Human Resources via email to [email protected] Innovation Group also maintains affirmative action programs to implement our equal employment opportunity policy. Employees or applicants who wish to review appropriate portions of these programs may request via email to [email protected]. BUSINESS ETHICS AND COMPLIANCE

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To adhere to the highest standards of integrity in all of our dealings with customers, suppliers, Employees and the general public. All Employees are required to sign off on Innovation Group’s code of business conduct as outlined in our Integrity Program. Please see Human Resources.

COMMUNITIES

To participate in our communities with the same principles that guide us with our people and our customers and to be mindful of the differing social, economic and environmental aspirations of the countries and communities where we are guests.

EMPLOYMENT GUIDELINES AND PRACTICES

NATURE OF EMPLOYMENT

Innovation Group adheres to the policy of employment-at-will, which enables either the employee or the employer to terminate the employment relationship at any time, with or without cause and in compliance with applicable governing regulations. The policy of employment-at-will may not be be modified.

EMPLOYMENT OF RELATIVES

Innovation Group is sensitive to the perception of conflicts of interest or the perception of favoritism as a result of

nepotism. Therefore, the Company prohibits Employees who are related from working in situations where one

family member may appear to have influence over the other’s employment, including an influence over

compensation and performance management. Family members must not directly report to another family

member.

For the purpose of this policy, a relative is defined as an employee’s spouse, common-law spouse, parent, parent-in- law, step-parent, brother, sister, brother-in-law, sister-in-law, step-brother, step-sister, child, child-in-law, step-child, grandparent, grandchild, aunt, uncle, or cousin, regardless of where they reside, and any other relative or person who lives with you in the same household. An employee who is in a personal relationship or plans to marry another employee should notify his/her supervisor immediately to allow steps to be taken to eliminate any conflicts, appearances of favoritism or adversely affecting the Company... Any questions regarding this policy should be directed to Human Resources. Any variance from this policy requires approval from a company officer.

EMPLOYEE REFERRAL BONUS

Employees' eligibility to receive a referral bonus is based on employment status at the time the person referred has completed three (3) months of regular full-time or part-time employment.

If an Employee refers a qualified candidate, and that individual is hired as either a full-time or a part-time Employee and successfully completes three months of employment, the referring Employee will receive a referral fee according to the following schedule:

Full Time positions $350.00 after successful completion of 90 days and is in good standing

Part Time positions $175.00 after successful completion of 90 days and is in good standing To be eligible for receipt of the referral fee, Employees making a candidate referral must be on the active payroll and in good standing at the time of the referred candidate successfully completes the 3-month period. Referring Employee must be listed on the employment application. The following positions are ineligible from participating in the employee referral bonus program: Human Resource department employees, managers to whom a candidate will report or that have the authority to recommend hiring, individuals directly involved in the hiring decision of the referred candidate and relatives of employees that are being referred.

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EMPLOYMENT CLASSIFICATION

Innovation Group classifies Employees in the following categories:

Regular Full-time Employees – A regular full-time Employee is hired for an indefinite period and

regularly scheduled to work at least 30 hours per week. There is not however, any guarantee of an on-going specific work schedule. These Employees are eligible for participation in all Employee benefits as provided by Innovation Group’s policy.

Regular Part-time Employees – A regular part-time employee is scheduled to regularly work less than 30 hours a week (whether working on a regularly-scheduled basis or not). Part-time employees are not guaranteed a weekly work schedule and receive no benefits other than those required by law. These employees will be able to participate in the Company’s Safe Harbor 401(k) Retirement Savings Plan.

Temporary Employees – A temporary employee is hired to fill short-term needs or as a temporary to hire as business needs change. Temporary Employees receive no benefits other than those required by law.

Exempt vs. Non-Exempt Employees: Exempt Employee: An exempt employee is paid a salary and is not eligible for overtime pay. Non-Exempt Employee: A non-exempt employee is paid on an hourly basis. A non-exempt employee is compensated for overtime when the employee works, at the supervisor's request and approval, more than 40 hours per week, unless otherwise required by state law. To be eligible for overtime, an employee must actually work 40 hours per week – for that purpose, any paid or unpaid time off, is not included in the calculation. For example: an employee works 36 actual hours in the office, Monday – Thursday, and then takes Friday off as a planned PTO day of 8 hours. No overtime would be paid because actual hours worked was less than 40. All Innovation Group employees are scheduled to work a set number of hours each week. As a general rule, hours worked beyond an employee’s regular schedule and based on business needs are not considered towards scheduled hours to determine full time or part time status. However, Innovation Group will analyze hours worked on a quarterly basis to determine if any changes should be made to scheduled hours. PERFORMANCE APPRAISALS

The performance review is a vital tool that will aid in the review of work performance and the encouragement of high performance work practices among employees in the organization. The appraisal is not only a tool to evaluate but also to develop. It helps in the assessment of training needs and in identifying areas of future development. A well-defined performance appraisal system serves the following objectives:

Identifying and linking employee goals to overall organizational goals

Sharing the organization’s expectations from employees

Motivating high performers

Generating performance data that would aid in various initiatives such as compensation, training needs, reward and recognition and career progression.

Full and part time employees who are employed prior to July 1 should receive an annual performance appraisal. Employees are typically reviewed on some or all of the following factors: quality of work, supervision required, attendance, teamwork, performance, compliance with Company policies and any assigned performance goals. INTERNAL JOB POSTING PROGRAM FOR GROWTH AND ADVANCEMENT

Innovation Group believes that its greatest potential for growth, profit, continuity, and good will is based upon the talents and efforts of its Employees. The achievement of this potential is the direct result of the collective efforts of all Employees. Innovation Group fosters a “promote from within” philosophy through the professional growth and skills development of all Innovation Group Employees. We are building career opportunities; most open positions are posted internally first. To apply for an internal position, employees must be in good standing and have been in their current position for at least 6 months. Managers may determine when there is a need for training, but Employees bear the final responsibility for their own personal and professional development. Innovation Group expects that Employees will work to the fullest extent of their abilities and inform managers when they feel training would be beneficial as they set goals on reviews and in going over quarterly objectives.

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PROFESSIONAL STANDARDS AND PRACTICES

Innovation Group has established a set of standards to protect the property and professional standing of the Company. Your employment with us depends upon your adherence to these standards, which are described below.

PERSONNEL AND MEDICAL RECORDS

Personnel and medical files are solely the property of Innovation Group and are extremely confidential. Information contained in personnel and medical files is released only in accordance with applicable law. It is your responsibility to notify Human Resources of any changes in your home address, telephone number, marital status, number of dependents, education, etc. Keeping this information up-to-date will help you to avoid problems concerning taxes, Employee benefits and other important matters.

ACCESS TO EMPLOYEE PERSONNEL FILES The Company has adopted the following principles to avoid unnecessary or inadvertent disclosure of confidential personal/employment information.

The Company will request, use and retain only personal information about employees that is required for business or legal reasons.

The Company will take reasonable measures to protect and preserve the confidential personal/employment information in its records and files.

The Company will limit the internal availability of confidential personal/employment information to those Company employees with a need-to-know purpose.

The Company will not, except in specific circumstances, release confidential personal/employment information to outside sources without the employee’s written approval. Exceptions include simple employment verifications and where disclosure is required by law (e.g. to respond to a subpoena).

While employed with Innovation Group, you may inspect your own personnel file during regular business hours by scheduling time with Human Resources. Please send your request to [email protected]. An employee does not have access to information concerning references, criminal/internal investigations or other official business conducted by the Company relating to the employee unless otherwise required by law. NOTE: Personnel files are Company property; therefore, they will not be released unless requested by law, necessary to defend the Company in litigation or other proceedings, or in compliance with a lawfully issued subpoena or court/agency order.

PROTECTION OF CONFIDENTIAL INFORMATION & PRIVACY POLICY

Any Confidential Information which Innovation Group may disclose to Employees shall be treated by Employee as confidential. Employees shall not directly or indirectly disclose, communicate or in any way divulge to any person or entity any Confidential Information. Employees are to protect against unauthorized disclosure of Confidential Information. Confidential Information shall mean all information, whether oral, electronic or written, of a confidential nature, including without limitation, proprietary, technical, marketing, operational or performance information, cost knowhow, business pricing policies or data programs, data systems, inventions, trade secrets, research or development materials, information marked ‘confidential’ or non-written information described as confidential, or any information which by its nature or by the circumstances in which it is disclosed or provided might otherwise reasonably be supposed to be confidential.

You must keep confidential all information acquired, developed, or shared as a result of the business process, including pricing, financial data, employee lists, research and development information, marketing and sales program, potential or existing contract relationships, and any other confidentiality or proprietary data pertaining to a Company customer. You must never use a customer’s confidential information to compete or to interfere with the customer’s business. You must store confidential customer information securely and share it only with those employees who have a business need to know. You should also refrain from discussing sensitive customer information in public places or “quasi-public” places within Innovation Group properties, such as an elevator or break room You must protect information pertaining to Innovation Group’s competitive position or business strategies, payment, and reimbursement information, and information relating to negotiations with employees or third parties,

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and share it only with employees who have a business need to know such information. You also must exercise care to maintain and manage intellectual property rights, including patents, trademarks, copyrights and software to preserve and protect their value. You must maintain all health information in a confidential manner, which prevents unauthorized or inadvertent disclosure to third parties. Various state laws impose criminal and civil penalties on individuals who misuse or disclose individually identifiable health information without explicit consent by the patient. HIPAA (Health Insurance Portability and Accountability Act) is federal legislation that governs the use of confidential health information and provides for both civil monetary penalties up to $25,000 per person, per year and federal criminal penalties for violations of patient confidentiality. Innovation Group may subject an employee who violates the privacy and confidentiality of information to disciplinary action, up to and including separation of employment. Upon termination of Employee’s employment with Innovation Group, Employee shall return to Innovation Group any and all Confidential Information which Employee received in any way during his or her employment, together with any and all copies thereof, as well as any and all documents, materials and/or property of Innovation Group relating in any way to Innovation Group’s business, together with any and all copies thereof. Employee shall not retain in any copies, notes, abstracts, or other summaries of the foregoing.

Employees who improperly use or disclose trade secrets or confidential business information will be

subject to disciplinary action, up to and including termination of employment and legal action, even if they do not

actually benefit from the disclosure of such information.

CONFLICTS OF INTEREST

Each Employee has a responsibility at all times to promote Innovation Group’s best interests. This is an obligation to Innovation Group’s clients/customers, Employees, shareholders and all others concerned with, or dependent upon, the welfare and progress of Innovation Group. A conflict of interest occurs when an Employee's judgment in acting for Innovation Group is adversely affected. Examples of conflicts of interest include but are not limited to:

Accepting gratuities from other companies or individuals who do business with Innovation Group or seek to do

business with it

Rendering services to competitors

Using or permitting others to use Innovation Group documents, equipment, confidential information or trade secrets

Benefiting personally from any purchases or sales by Innovation Group (excluding sales/ commissions)

If you have, or feel you have, encountered a situation that might be regarded as a conflict of interest, you must immediately consult your manager and Human Resources. Engagement in any business practices that compromise Innovation Group in any way may result in the immediate termination of any and all Employees involved in such activity, and may be grounds for legal action against those Employee. GIFTS To avoid potential conflicts of interest, Innovation Group employees should ensure that all gifts accepted from business clients are reasonable and do not exceed $150.00 in value per gift. If you have any questions regarding the acceptability of a gift you receive, contact our supervisor, or the designated office contract. NON-COMPETE Employee shall not directly or indirectly own, be employed by or work on behalf of any firm engaged in a business substantially similar to and competitive with Innovation Group.

COMMUNICATION Effective communication among everyone at Innovation Group is vital to the success of the Company. You have access to every level of Innovation Group management, and we encourage you to inform management of your concerns about any aspect of your work. You and your manager are both responsible for maintaining open and professional communication channels. If you have a complaint or disagreement involving the work environment, you should first address the matter with your supervisor. If you have

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an issue that cannot be resolved after a frank and open discussion with your supervisor, you are entitled to review the matter with either your supervisor’s immediate manager or with human resources. All efforts will be made to resolve a problem at the earliest stages. No written record of an employee’s use of this process will be retained in the employee’s personnel file unless the employee specifically requests as such.

OUTSIDER REQUEST FOR INFORMATION Employees must be careful about the information they give out. If someone outside Innovation Group asks you questions, either directly or through another person, do not attempt to answer them unless you are certain you are authorized to do so. If you are not authorized, refer the person to the appropriate source within the company. For example, if security analysts or investors approach you, you should refer them to a senior person in the Finance Department. Similarly, unless you have been authorized to talk to reporters, or to anyone else writing about or otherwise covering the Company or the industry, direct the person to a senior person in the Marketing Department. If you do not know what functional area the questioner should be referred to, ask your manager or Human Resources.

PRODUCT DEVELOPMENT Innovation Group was built on the ingenuity of its Employees and this ingenuity continues to be the foundation for our growth. You have an opportunity to contribute to the Company’s growth through improvements in existing methods or products, through technological discoveries, or through specific inventions related to the Company’s business. Any such developments for which you are responsible while working at Innovation Group will remain the property of the Company and/or its clients.

CLIENT SITES

Innovation Group has established certain policies and procedures to maintain a productive business environment for its Employees. However, many Employees spend a large part of their time at client sites. If you work at a client site, you are responsible for following the worksite practices of that client. Examples of such practices include no-smoking regulations, dress codes and security procedures. For more information, consult your manager.

PROFESSIONAL CONDUCT

Each Innovation Group Employee is expected to display a high level of professionalism, a strong desire to achieve, and the ability to work as a team player. Professionalism, communication skills, reliability, honesty, and integrity are the expectations of each Innovation Group Employee. Any conduct that interferes with Company operations, brings discredit to the Company, or offends clients or fellow Employees is unacceptable and may result in disciplinary action up to and including separation of employment.

EMPLOYMENT VERIFICATION All credit and employment references must be directed via email: [email protected]. Innovation Group will give only the following information about you to banks, credit card companies, mortgage institutions, and other similar inquiring parties:

Verification of your employment with Innovation Group

Your title

Your dates of employment

Other information, such as salary information, will only be provided with your written request and authorization.

COMPLAINT RESOLUTION

We all recognize that the accumulation of unspoken, unanswered problems can result in dissatisfaction and can impact the working relationship. Innovation Group maintains an “Open Door Policy”, if you have a concern or issue, it is to everyone's advantage to bring it out in the open. If you have a concern or complaint, please review it with your manager or Human Resources as soon as possible. It is the policy of Innovation Group that all Employee issues and concerns be given full consideration. There will be no discrimination or retaliation against any Employee because he/she presents a legitimate concern or issue.

EMPLOYEE SUGGESTIONS

Innovation Group welcomes suggestions and questions from Employees. These may be questions on policy or working conditions, or they may be suggestions on ways to reduce costs or improve efficiencies. We greatly encourage suggestions, since we believe the individual working on a particular task can best recommend ways to increase quality and product and productivity. Employee suggestions can be submitted directly to your supervisor

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or via email to [email protected].

SOLICITATION AND DISTRIBUTION Persons not employed by Innovation Group may not, at any time, solicit or distribute literature or other printed material on Innovation Group property for any purpose. For purposes of this policy, Innovation Group property also refers to any Innovation Group owned or leased property, including parking lots and sidewalks where applicable. Solicitation by an Employee of another Employee is prohibited while either person is on working time. Trespassing, soliciting, or distribution of literature by non-Employees on Innovation Group premises is prohibited. [email protected].

BULLETIN BOARD POLICY Innovation Group communicates important information about work and your job on Company bulletin boards. Pease review them frequently to keep up with current activities and information. The bulletin boards are for Company information only. Employees may not post materials on these boards and may not remove materials. It is also against Company policy to write on or any way deface postings on the Company bulletin boards. The Company will remove any postings or material that does not comply with this policy.

TERMINATION OF EMPLOYMENT VOLUNTARY If you wish to voluntarily terminate your employment with the Company, you are requested to notify your supervisor in writing at least two weeks in advance of the intended termination date. There may be times when the supervisor will ask you to leave work on the day you give notice. An exit interview may be scheduled prior to the last day of employment with a member of Human Resources. Upon termination, employees must return all company property in their possession, including but not limited to, office keys, credit cards, laptops, mobile devices, phones, etc. The Company will seek to recover the company property by use of all legal means available. The terminating employee’s immediate supervisor is responsible for ensuring that the employee returns all Company property, completes/submits all expense reports, and filling out all applicable paper work. Health insurance benefits for terminating employees will generally cease on the date described in the governing Plan documents and Summary Plan descriptions. Unless released for gross misconduct, terminated employees and their covered dependents may, however, elect continued medical, dental, and vision insurance coverage after that date, in accordance with the Consolidated Omnibus Budget Reconciliation Act of 1985 (COBRA). If you wish to retire there are various age and service requirements that affect the retirement benefits and programs for which an employee may be eligible. You are requested to notify Human Resources via email: [email protected] at least 90 days prior to your planned retirement to discuss the attainment of specific criteria, and to allow for proper processing. The retiring employee’s immediate supervisor is responsible for ensuring that the employee returns all Company property. All terminating employees can expect final payment of wages on the next regular pay date following termination date or sooner, if required by state law.

SERVICE DATE POLICY Under the Company’s Service Date Policy, if you voluntarily leave the Company, or lose your employment due to a “layoff” (terminated solely by reason of a reduction in the Company's work force), and are re-employed by the Company within six months, your original service date will be adjusted to reflect the difference in dates of employment with Innovation Group.

SPECIFIC POLICIES

ANTI-HARRASSMENT - INCLUDING SEXUAL HARRASSMENT Innovation Group is committed to maintaining a work environment free of all types of employment discrimination or harassment. In keeping with this commitment, Innovation Group will not tolerate harassment of any of its Employees by anyone, including any supervisor, co-worker, vendor, client, or customer of Innovation Group.

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The type of workplace harassment which is prohibited consists of any type of, including but not limited to, unwelcome conduct, whether verbal, physical, visual, or through our information systems, that is based upon a person's protected “status”, such as sex, color, race, ancestry, religion, national origin, age, disability, marital

status, veteran status, citizenship status, or any other protected group status.

This definition specifically includes sexual harassment. The Company will not tolerate any type of harassing conduct of any nature by any person that may affect tangible job benefits, that interferes unreasonably with another individual's work performance, or that creates an intimidating, hostile, or offensive working environment.

Sexual harassment in the workplace deserves further clarification. Any type of unwelcome sexual advances, requests for sexual favors, and any other conduct of a physical, verbal, or visual nature which is based on sex may constitute sexual harassment when: Submission to such conduct is made a term or condition of employment

Submission to or rejection of such conduct is used as the basis for employment decisions affecting an individual

Such conduct has the purpose or effect of interfering with an individual’s work performance, or creating an intimidating, hostile, or offensive work environment

Prohibited conduct which may constitute sexual harassment may include explicit sexual propositions or simply sexual innuendo, suggestive comments, sexually oriented “kidding” or “teasing,” “practical jokes,” jokes about gender-specific traits, foul or obscene language or gestures, display of foul or obscene printed or visual material, and any type of physical contact between two individuals such as patting, pinching, or brushing against another’s body. This prohibited conduct can occur in the workplace or away from the workplace at Company social or business functions, business trips, or meetings.

REPORTING AND INVESTIGATING HARASSMENT

All Innovation Group Employees are individually and collectively responsible to help ensure that harassment of any type or nature does not exist is not condoned in the workplace. If you feel that you have experienced or witnessed any type of workplace harassment, you are to notify your supervisor immediately.

All Employees are encouraged to raise any complaints or questions about harassment to their manager, the designated location contact or a Human Resource representative. The Company forbids retaliation against any Employee who reports any type of harassment, including sexual harassment, or who assists in making a harassment complaint, or who cooperates in a harassment investigation. If an Employee believes he/she has been harassed on the basis of sex or other protected class status, they should feel free to tell the harasser to stop the offending behavior. In addition, Employees who believe they have been harassed by a company Employee, vendor, consultant, customer, client, or contractor should contact their manager and Human Resources. The Company will promptly investigate all such complaints thoroughly and promptly and take appropriate action based upon the circumstances. Any Employee found to have engaged in inappropriate behavior, including illegally harassing behavior, will be subject to serious disciplinary action up to and including termination of employment. To the fullest extent practicable, the Company will keep the complaints and the terms of their resolution confidential. If, however, an investigation confirms that any Employee has been involved in any conduct or action in violation of this policy or has engaged in inappropriate conduct regardless of whether it violates this policy or is unlawful, the Company will take appropriate immediate disciplinary action, up to and including termination of employment. Any manager who becomes aware of inappropriate conduct must immediately notify Human Resources. Failure to do so will result in disciplinary actions for the manager. If you have any questions regarding this policy, or its meaning or application, please contact any member of your management team or human resources.

SUBSTANCE FREE WORKPLACE

All Employees are expected to work in a condition fit to perform their duties. All Employees are entitled to a substance free workplace, and any infraction of this policy will not be tolerated. Violation of this policy will result in disciplinary action, up to and including termination of employment. Employees who work under any degree of drug or alcohol influence endanger themselves and our Employees. If an Employee shows

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noticeable impairment to two or more objective persons including one member of management, they will not be permitted to work. If management has a reasonable suspicion that you are under the influence of drugs or alcohol, we reserve the right to require the employee to submit to a drug and alcohol test. Refusal to take a drug and alcohol test will be interpreted as if there were a positive result to the test. Innovation Group acknowledges that certain states’ laws supersede the language of this policy. In such cases, state law shall apply. Alcohol and illegal or controlled drugs are not to be brought on Company premises, under any circumstances. Alcoholic beverages may not be consumed during lunch or meal breaks. Buying or selling of illegal or prescription drugs on Company property is cause for immediate termination of employment. Any suspected violations may be reported to law enforcement. You may use physician- prescribed medications does not adversely affect job performance, your safety, or the safety of others. In such instances, Innovation Group may request medical documentation. The distribution, transfer, purchase, or sale of physician-prescribed medications between Employees is strictly prohibited. Innovation Group will require an Employee to take a drug test immediately following any workplace accident. Refusal to take a drug test will be interpreted as if there were a positive result to the test. Innovation Group acknowledges that certain states’ laws supersede the language of this policy. In such cases, state law shall apply.

PRE-EMPLOYMENT DRUG TESTING

Drug testing will be conducted within ninety (90) days of an employee’s first date of employment for employees based in the Carrollton, TX office and assigned to Driven Solutions (United States Auto Club). Continued employment is contingent upon a satisfactory result of the drug test. At any subsequent time you appear to be working under the influence of alcohol, illegal drugs, or a controlled substance, you may be referred for a health evaluation or an additional chemical screening.

WORK RELATED ACCIDENTS OR ILLNESSES

If you are injured during working hours, our first concern is to ensure that you receive appropriate medical attention. As soon as possible, you should report the accident to your manager and Human Resources who will complete an Incident Report. If you are unable to report the accident due to the extent of your injuries, any other Employee who discovers or observes the accident is responsible for reporting the event to the appropriate manager and Human Resources. The Company requires that every accident, injury, or sudden illness that occurs in an Innovation Group facility be reported to your supervisor no matter how minor it may appear. It is important for your well-being that injuries and accidents are reported immediately, no later than 24 hours after the incident. Failure to do so could result in delay or denial of the accident or health benefits, such as workers compensation or group insurance All Employees who sustain an injury or illness that occurs in the course and scope of their job must immediately submit to a drug and alcohol test, unless state law specifies otherwise. Human Resources will file a worker’s compensation claim for all reported injuries and illnesses.

If you witness a workplace accident, you MUST report the accident to a supervisor, manager or Human Resources. Please take note of the facts leading up to the incident. Your information will assist in any investigation.

WORKPLACE THREATS AND VIOLENCE

Nothing is more important to Innovation Group than the safety and security of its Employees. Threats, threatening behavior, or acts of violence against Employees, clients, visitors, guests, or other individuals by anyone will not be tolerated. Violations of this policy will be subject to disciplinary action that may include dismissal, arrest, and prosecution. Any person who makes threats, exhibits threatening behavior, or engages in violent acts on Company property shall be removed from the premises as quickly as safety permits, and shall remain off Company premises pending the outcome of an investigation. Upon completion of the investigation, Innovation Group will initiate an appropriate response. This response may include, but is not limited to, suspension and/or termination of any business relationship, reassignment of job duties, suspension, or termination of employment, and/or criminal prosecution of the person or persons involved.

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All company personnel are responsible for notifying a manager and Human Resources of any threats that they have witnessed, received, or have been told that another person has witnessed or received. Even without an actual threat, personnel should also report any behavior they have witnessed which they regard as threatening or violent, when that behavior is job related or might be carried out on a company controlled site, or is connected to Company employment. Employees are responsible for making this report regardless of the relationship between the individual who initiated the threat or threatening behavior and the person or persons who were threatened or were the focus of the threatening behavior. Any manager who becomes aware of threatening behavior must immediately notify Human Resources. All individuals who apply for or obtain a protective or restraining order which lists Company locations as being protected areas, must provide to their manager and Human Resources a copy of the petition and declarations used to seek the order, a copy of any temporary protective or restraining order that is granted, and a copy of any protective or restraining order that is made permanent. Innovation Group understands the sensitivity of the information requested and has developed confidentiality procedures that recognize and respect the privacy of the reporting Employee.

HEALTH AND SAFETY

Innovation Group has a continual objective of providing Employees with a safe and healthy environment. The safety of our Employees is of primary concern. It is important that any potentially unsafe conditions are reported immediately and that each Employee recognizes that health and safety is a responsibility that is shared by all. Employees are expected to follow safe work practices and help create safe working conditions at all times.

VISITORS

Only persons who have business with the Company or its employees are welcome to visit the Company’s facilities. To ensure safety and security, your supervisor must approve all tours or access to the Company’s facilities. All suppliers and visitors must register with the receptionist, human resources, or designated member of management at their destination building. Visitors may be required to present valid identification. If there is no receptionist, the employee meeting the visitor(s) is responsible for escorting the visitor to the person(s) who are scheduled to meet with the visitor. All visitors must wear a Company issued visitor badge while on Company premises.

BUILDING SECURITY

We are committed to continually providing a safe and secure work environment. To that end, we have established the following rules:

No Employee, under any circumstances, should let anyone they do not know into the building. This includes vendors and delivery people. Family and/or friends are not permitted into any areas of the building. Allowing others into the building jeopardizes the security and safety of everyone. Therefore, this policy is strictly enforced and violations of the policy are subject to disciplinary action, up to and including termination of employment. We encourage Employees who would feel more comfortable to buddy up when they leave the building at night. Your cooperation and adherence to these procedures are appreciated and will allow us to have a safe and secure work environment. Employees must adhere to client policies when at remote site locations.

FIREARMS, WEAPONS-FREE WORKPLACE

To ensure that the Company maintains a workplace safe and free of violence for all employees, the company prohibits the possession or use of perilous weapons on company property. A license to carry the weapon on company property does not supersede company policy. Any employee in violation of this policy will be subject to prompt disciplinary action, up to and including termination. All company employees are subject to this provision, including contract and temporary employees, visitors and customers on company property. “Company property” is defined as all company-owned or leased buildings and surrounding areas such as sidewalks, walkways, driveways and parking lots under the company’s ownership or control. This policy applies to all company-owned or leased vehicles and all vehicles that come onto company property.

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“Dangerous weapons” include, but not limited to, firearms, explosives, knives and other weapons that might be considered dangerous or that could cause harm. Employees are responsible for making sure that any item possessed by the employee is not prohibited by this policy. Innovation Group reserves the right at any time and at its discretion to search all company-owned or leased vehicles and all vehicles, packages, containers, briefcases, purses, lockers, desk, enclosures and persons entering its property, for the purpose of determining whether any weapons has been brought onto its property or premises in violation of this policy. Employees who fail or refuse to promptly permit a search under this policy will be subject to discipline up to and including termination.

CLEAN DESK POLICY

In order to maintain a culture of security, trust and positive image for clients and visitors all employees at Innovation Group are expected to maintain a clean and clutter free work area. Anytime an employee leaves the workstation for an extended period of time, sensitive working papers are expected to be placed in locked drawers. At the end of work day the employee is expected to tidy their desk and secure all office papers. Any employee found to be in violation of this policy may be subject to disciplinary action.

DESK PRIVACY/SEARCH POLICY

It is the policy of Innovation Group, when deemed necessary by management, for authorized persons to search and inspect both company property and personal items brought onto Company property. Refusal to cooperate in a search, inspection, or investigation may result in a disciplinary action up to and including termination.

USE OF COMPANY PROPERTY

In an effort to promote an efficient and productive work environment, Innovation Group supplies its Employees with a variety of items designed to facilitate quality work in a pleasant environment. For instance, Employees are provided with such items and conveniences as computers, voicemail, e-mail, Internet access, desks, Employee Identification card and file cabinets. It is important for Employees to remember; however, that these items are Company property and are being furnished to Employees for job related purposes. Employees are expected to use these items in the course of their work, and should not use them for personal reasons. Employees should not, for example, store personal or confidential objects in their desks, file cabinets, or computers. Innovation Group reserves the right to access and inspect, with or without prior announcement, all of its property, including offices, desks, and file cabinets. In addition, Innovation Group has the right to access and review all computer related communications, including electronic mail, voicemail, internet access, computer files, and information stored on discs, as well as any faxes or mail sent to or from Employees at Innovation Group’s address. Employees are expected to exercise care in their use of Company property and to use such property for authorized purposes only. Negligence in the care or use of Company property, unauthorized removal of company property from the premises or conversion of Company property to personal use may be cause for disciplinary action up to and including termination of employment. The Company does not guarantee the privacy of any data, information, documents, messages, or the like stored in Company assets and Employees have no expectations of privacy with respect thereto. Phones, fax, and copy machines are for company use only. Should the procedures for use of company communication equipment not be observed, reprimands up to and including termination could result.

COMPUTER TERMINALS AND SOFTWARE

Unless you have been authorized to do so, do not attempt to make hardware repairs or modifications on

company computer terminals.

Only software approved by the IT department or upper management is to be loaded onto company owned

computer equipment. This includes screen savers, games, graphics packages or any other non-standard

software. Passwords will be assigned by the IT department.

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Only programs or applications you have been authorized to use should be opened on your computer terminal.

You are not authorized to use any programs other than that intended to perform your work duties. No games,

sound events, graphic applications are to be used by any Employee. Cell phones, tablets and blackberry devises

are not to be used unless on a designated break.

LOST, STOLEN OR DAMAGED EQUIPMENT

It is the employee/borrower’s responsibility to safeguard equipment and return it to the Company in working condition at the end of employment, end of loan, or use. Employees must notify their manager immediately when equipment/property is LOST, STOLEN, DAMMAGED OR DESTROYED. Employee manager will determine if all or part of the loss will be the financial responsibility of the employee, waived or covered by the company. Replacements and costs should be made within 10 days from date of loss. Additional payment arrangements may be discussed and approved by manager. This applies to any and all Company equipment provided to an employee such examples include but not limited to; computers, printers, mobile devices, headsets, and employee badges are a few examples covered under this policy.

RETURN OF COMPANY PROPERTY

Company property issued to an Employee must be returned at the time the Employee terminates employment with the Company or earlier, if management requests its return. Under appropriate circumstances, an Employee may be liable for the cost of damaged or unreturned property. Employees are expected to return company-owned equipment in the condition in which it was issued. Failure to return company equipment following separation of employment may result in legal action.

SMOKING & TOBACCO FREE

The policy of the Company is dedicated to promoting good health among Employees by prohibiting smoking in all facilities. Smoking of any kind, including e-cigarettes, use of tobacco (dip, chew) is only allowed in the designated area outside of the confines of each facility at designated break times only. Employees should adhere to client site policies.

DRESS CODE

Dress, grooming, and personal cleanliness standards contribute to the morale of all employees and affect the business image Innovation Group presents to customers and visitors. When representing the Company, employees are expected to present a clean, neat and tasteful appearance. Employees should dress and groom themselves according to the requirements of their position and accepted social stands. If the employee’s supervisor feels the employee’s personal appearance is inappropriate, the employee may be asked to leave the workplace until he or she is properly dressed or groomed. Under such circumstance, the employee will not be compensated for the time away from work.

Reasonable accommodation may be made to a person with a disability or religious/moral beliefs.

ATTENDANCE/TARDINESS

To maintain a productive and quality work environment, the Company expects all Employees to arrive to work on time and ready to work every day. An absence is defined as any non-appearance at work during scheduled hours, including but not limited to tardiness or failure to complete a scheduled workday for any reason excluding approved time off.

If you’re unable to report for work on time for any reason, tell your supervisor as far in advance of your scheduled start time as you can. If it’s an emergency, tell your supervisor as soon as it’s practical. Tell your supervisor why you’ll be absent and when you expect return to work. Each day you’re out, you must notify your supervisor unless you have a doctor’s note excusing multiple and consecutive days.

Employees who fail to call or report to work for three (3) consecutive shifts will conclude that you’ve abandoned the job and voluntarily resigned.

Employees working in the call center will be subject to progressive disciplinary steps based on occurrences. Call center supervisors will provide details specific to their business unit.

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FOOD AND DRINKS AT YOUR STATION

Food and drinks are allowed at your work station or training center so long as they do not distract from the quality

of your conversation with a customer or class discussions. Drinks must be in a closed container at all times.

Chewing gum is not permitted when taking a calls on the call center floor. In some offices food and drinks may be

prohibited due to landlord or client restrictions. Employees should check with on-site management.

MONITORING AND RECORDING Phone calls, chat, email and audio recordings may be monitored and recorded by authorized personnel at Innovation Group. Such activity may be the result of real-time in service-observance monitoring, call recording, side by side monitoring, or screen capture. Any information obtained through such activity may be used to protect our customers, employees and company against unethical practices or collect facts to resolve customer complaints by monitoring, recording and supervising the quality of work being performed. Employees should not have any expectation of personal privacy in anything created, sent, received, communicated or stored on or by means of the email system, chat, the Internet, the telephone, voicemail system, computer or other device. This policy applies to all employees, contactors, consultants, temporaries, visitors, and other workers at Innovation Group or persons on the premises.

WEATHER FACILITY CLOSING

Innovation Group offices will remain open during extreme weather conditions. In the event of extreme weather conditions, it is expected that all Employees will make every effort possible to arrange for childcare and transportation in order to report to work as soon as possible. Despite the office remaining open during inclement weather, individual safety concerns should not be sacrificed. Should you decide that your regular arrival to the office will be delayed or should you choose to leave early as a result of bad weather when the office is open, contact your manager with as much advance notice as possible. Innovation Group must function even when other businesses or facilities are unable to. Should you not report to work in weather related event, the attendance procedure and policy will be enacted and occurrences appropriate to the lost time will be applied to the Employee. Any exceptions to be considered by Management. If Innovation Group offices will remain open for business, employees will be required to use PTO to account for their absences.

BREAKS AND MEAL PERIODS

Employees are entitled to one (1) paid 15-min rest break for every four (4) hours of consecutive work time. Employees who work more than six (6) hours during a shift are required to take a 30 minute unpaid meal period. Your rest break and meal period schedule will be determined by the Staffing and Scheduling Department and will be based on business needs and applicable state law. Employees may not take breaks or meal periods within the first or last hour of their shift. Employees on their unpaid 30 minute meal period are required to clock out during this time and free to leave their workstation. Performing any work while off-the-clock is strictly prohibited.

NURSING MOTHERS

Non-exempt employees who are nursing mothers are permitted to take reasonable unpaid (Lactation Breaks) as frequently as needed to express breast milk for their children for one year after each child’s birth. The Company will designate locations (which will not be restrooms) for Lactation Breaks that are shielded from view and free from intrusion by coworkers and the public while being used for Lactation Breaks. The company will comply with all applicable state or local laws providing protection for Lactation Breaks. Questions about Lactation Breaks should be directed to Human Resources at [email protected]

E-MAIL & CHAT POLICY

Use of electronic mail, commonly called “e-mail” is provided by the Company and is to be used for company purposes. Any personal use of e-mail must be kept to a minimum and must not interfere with the needs of our business or an Employee’s job duties. E-mail use, chat use and e-mail files are not confidential. Activity may be monitored at any time and without notice to you. Please keep in mind that the Company has access to your e-mail messages. While the concept of a business need and a respect for legitimate confidentiality will guide our actions, we reserve the right to access your e-mail at any time we deem appropriate in order to protect the Company. Remember as well that even though you may “delete” messages, the messages may be preserved for an extended period of

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time. Upon termination, no e-mails related to company business are to be deleted. Access to all electronic files, including e-mail files, may be provided to third parties, as the Company deems appropriate. E-mail use is specifically prohibited in the following situations:

Any communication that violates state or federal law.

Any communication that may be viewed as libelous, harassing or threatening

Any communication that could damage the Company’s reputation or potentially put you and the Company at risk for legal proceedings by any party

Communication of Company proprietary information, or the release of any information that may be considered confidential or a trade secret Harassing, threatening, discriminatory, profane, sexually explicit, or other inappropriate messages are not to be transmitted or stored. If you receive such a message, it is your responsibility to advise Human Resources immediately

VOICEMAIL

Voicemail is a resource provided by the Company and is the property of the Company. It is provided solely for business purposes. Harassing, threatening, discriminatory, sexually explicit, or other inappropriate messages are not to be transmitted or stored. Employees are responsible for protecting access to voicemail. Sharing use is discouraged. Employees may be held responsible for misuse that occurs through unauthorized access. Please keep in mind that the Company has access to your voicemail. While the concept of a business need and a respect for legitimate confidentiality will guide our actions, we reserve the right to access your voicemail at any time we deem appropriate for protection needs. Use and access can be monitored and tracked by management at any time and without notice to you. Remember that even though messages may appear to be “deleted”, procedures by the Company to guard against data loss may preserve material for extended periods of time. Access to voicemail and voicemail records may also be provided to third parties, as the Company deems appropriate. Violations of this policy may result in disciplinary action, up to and including termination of employment.

INTERNET USE

When using the Company’s Internet connection, you are a representative of the Company. Any personal use of the connection must be kept to a minimum and must not interfere with the needs of the business or your job duties. Improper use of the connection may be grounds for disciplinary action, up to and including termination of employment. Prohibited uses include, but are not limited to:

Any activity that is contrary to state or federal law, including distributing or obtaining copyrighted software or information without proper authorization from the copyright holder.

Any activity that could damage the Company’s reputation or potentially put you and the Company at risk for legal proceedings by any party. For example, libelous or harassing communications or unfair competitive practices are strictly prohibited

Any activity that could be construed as hostile to another Company or institution. For example, Employees may not make attempts to gain unauthorized access to another Company’s systems and/or information

Any display, transmittal, and/or downloading of sexually-explicit images, messages, ethnic slurs, racial

epithets, etc. that may be construed as offensive to others.

Communication of Company proprietary information please remember that Internet access is a privilege that

may be withdrawn at any time. In addition, accounts based on the Company’s connection are not confidential and communications, including mail and/or files, may be inspected by the Company at any time, and Internet activity may be monitored at the discretion of the Company.

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SOCIAL MEDIA

Innovation Group understands that social media has become an important tool in everyday life, both personally and professionally. While the Company takes no position on your decision to partake in social networking or other social media activities, we would like to remind you that the Company’s policies on confidentiality, anti-harassment, ethics and company loyalty extend to all forms of communication. The intent of this policy is not to restrict the flow of useful and appropriate information, but to ensure that the Company and its employees are participating in social media in a manner that is consistent with Innovation Group’s values; honesty, fairness and respect. In general, employees who participate in social media are free to publish information about themselves without censorship by the Company. However, every employee is responsible for protecting the reputation of the Company and must avoid posting comments or information about the Company, fellow employees, clients, customers or other business partners what would be in conflict with applicable policies, including but not limited to the Company’s Code of conduct and Anti-Discrimination and Harassment Policy. Unless specifically instructed, employees are not authorized and therefore restricted to speak on behalf of Innovation Group. Employees may not publicly discuss clients, products, employees or any work-related matters, whether confidential or not, outside company-authorized communications. This includes protecting confidential and proprietary information of Innovation Group, such as trade secrets and client information, and refraining from the use of derogatory or defamatory language about the Company, its employees, customers and/or clients. If you become aware of any such conduct while participating in social media activities, please report the incident to your supervisor or Human Resources immediately. Please note that the Social Media Policy applies to all multi-media, social networking websites, blogs, wikis, etc. used for both professional and personal use. This includes, but is not limited to, Facebook, LinkedIn, Twitter, and YouTube. Employees should not be using social media sites that are not affiliated with Innovation Group during business hours. Innovation Group is dedicated to protecting itself from the unauthorized disclosure of information and these guidelines apply to all executive officers, board members, management and staff. The Company reserves the right to monitor comments or discussions about the Company, its employees, clients and the industry, including products and competitors, posted on the Internet by anyone, including employees and non-employees. Violation of this policy may result in disciplinary action, up to and including separation of employment.

LEAVE OF ABSENCE & ACCOMODATIONS

AMERICANS WITH DISABILITIES ACT The Americans with Disabilities Act (ADA) and the Americans with Disabilities Amendments Act, known as the ADAA, are federal laws that require employers with 15 or more employees to not discriminate against applicants and individuals with disabilities and, when needed, to provide reasonable accommodations to applicants and employees who are qualified for a job, with or without reasonable accommodations, so that they may perform the essential job duties of the position. It is the policy of Innovation Group to comply with all federal and state laws concerning the employment of persons with disabilities and act in accordance with regulations and guidance issued by the Equal Employment Opportunity Commission (EEOC). Furthermore, it is our company policy not to discriminate against qualified individuals with disabilities in regard to application procedures, hiring, advancement, discharge, compensation, training or other terms, conditions and privileges of employment. Through an interactive process, when an individual with a disability is requesting accommodation and can be reasonably accommodated without creating an undue hardship or causing a direct threat to workplace safety, Innovation Group will reasonably accommodate qualified individuals with a disability so that they can perform the essential functions of a job unless the accommodation creates an undue hardship for the Company. Questions or requests for accommodation should be directed to Human Resources. For the purposes of this policy, “disability” means a physical or mental impairment that substantially limits one or more major life activities of the individual, a record of such an impairment or being regarded as having such an impairment. Individuals who are currently using illegal drugs are excluded from coverage under the company ADA policy. Employees who need to request an accommodation under this policy should make such request to [email protected] and a member of the human resources team will schedule a meeting to

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discuss requested accommodations.

FAMILY AND MEDICAL LEAVE (FMLA)

Employees who have worked for Innovation Group for at least twelve months and at least 1,250 hours

during the previous twelve months may take up to twelve weeks of unpaid leave in a twelve month period

under the Family Medical Leave Act (FMLA). As individual state laws may provide additional benefits, please

contact Human Resources via email: [email protected] for further information. The relevant

twelve month period will be calculated by measuring forward from the date an Employee’s first FMLA leave

begins. Unpaid leave will be granted for the following reasons:

The birth of the Employee’s newborn child

Placement with an Employee of a child for adoption or foster care

To care for the Employee’s spouse, child, or parent with a serious health condition

The serious health condition of the Employee

In some instances approved leave may be taken intermittently or on a reduced leave schedule. Upon the birth or placement of a child, intermittent leave or working a reduced number of hours is not permitted unless both the Employee and Innovation Group agree. If both spouses are employed by Innovation Group, the leave period will be limited to a combined total of twelve (12) weeks during any twelve (12) month period. For birth, adoption, or foster care placement, leave availability expires twelve (12) months after the birth or placement of the Employee’s child. In the case of leave for serious health conditions, the approved leave may be taken intermittently or on a reduced- hours basis only if such leave is medically necessary. If intermittent or reduced leave is taken, the Employee may, in some circumstances, be temporarily transferred to another position with equivalent pay and benefits. Employees needing intermittent or reduced schedule leaves must attempt to schedule their leave so as not to disrupt Innovation Group operations. Intermittent leave is tracked using time calculation based on weekly scheduled hours.

During an approved leave of absence under FMLA Innovation Group will continue to pay its portion of health insurance premiums and the Employee must continue to pay his/her share of the premium. Failure of the Employee to pay his/her share of the health insurance premium may result in loss of coverage. If the Employee does not return to work after the expiration of the unpaid leave, the Employee may be required to reimburse Innovation Group for payment of health insurance premiums during the unpaid leave as provided by law. During unpaid leave, the Employee shall not accrue employment benefits, such as accrued sick time. Employment benefits accrued by the Employee up to the day on which the unpaid leave begins will not be lost. Employees are required to use a minimum of 40 hours PTO during the first and/or second week of leave. Employees may request to use more PTO if available. Workers comp leave runs concurrently with FMLA. Employees who take leave pursuant to this policy will, in general, be reinstated to the same or equivalent position upon return from leave, unless the Company's circumstances have so changed as to make it impossible or unreasonable to do so. Applications for family and medical unpaid leaves of absence must be submitted in writing to Human Resources via email: [email protected]. Applications should be submitted at least thirty days before the leave is to commence, or as soon as possible if thirty days’ notice is not possible. Employees who fail to give appropriate notice may be denied leave. Appropriate forms, including medical certification for a medical leave, must be submitted to Human Resources. If an Employee requires a leave of absence and is eligible for FMLA, the leave must be designated as FMLA. He/she is responsible to make the request to Human Resources. You may also contact your manager or Human Resources for more detailed information on this policy.

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FAMILY MILITARY LEAVE

FMLA also extends to cover employees with family members in the military to take leave under two circumstances: (1) leave due to a qualifying exigency, and (2) service member caregiver leave. The requirements for each are described in detail below.

Qualified Exigency: up to 12 weeks of unpaid leave in any 12-month period for a qualifying exigency arising out of a covered employee’s spouse, son, daughter, or parent’s covered active duty or notification of an impending call or order to covered active duty in the armed forces.

Caregiver Leave: up to 26 weeks of leave during any single 12-month period if the employee is the spouse son, daughter, parent, or next of kin caring for a covered military service member or veteran recovering from an injury or illness.

Please contact Human Resources via email: [email protected] for more information on family military leave. MILITARY DUTY LEAVE

Innovation Group complies with all applicable laws that afford protection rights to employees serving duty with the Military, the Reserve and the National Guard. When an employee receives orders for training, temporary military duty, or active duty, he or she should notify his/her supervisor and Human Resources detailing the duration of the required service as far in advance as reasonable under the circumstances. Military duty leave will be unpaid. Employees may choose to use PTO time to supplement the leave. Upon your return from military service you may be eligible for reinstatement as provided in the Uniformed Services Employment and Reemployment Rights Act. You must contact Human Resources via email: [email protected] to determine your re-employment eligibility.

NON-FMLA LEAVE OF ABSENCE

Innovation Group may, in some circumstances, grant an unpaid leave of absence as a reasonable accommodation to employees who do not qualify for FMLA. Employees are expected to comply with HR inquiries regarding medical certification in a prompt manner and provide any verification data requested in the same fashion. Failure to provide certification in a timely manner may result in disciplinary action, up to and including separation of employment. During such leaves of absence, the Company will permit benefits continuation to a maximum of 8 calendar weeks on the same basis as active employees. Employees should establish in advance a contribution payment schedule with HR prior to commencement of leave. 401(k) contributions will be suspended during periods of unpaid leave and reinstated upon return to active status. Following 8 weeks of unpaid leave, your benefits will be discontinued and you will be offered coverage under the provisions of the Consolidated Omnibus Budget Reconciliation Act (COBRA). Upon returning to work from a leave of absence beyond 8 weeks, benefits will be reinstated at the level of coverage you had prior to the LOA on the first of the month following the return to work date.

OTHER LEAVES OF ABSENCE

Please contact Human Resources via email: [email protected] for eligibility of any state sponsored leave of absences.

JURY DUTY LEAVE

It is the Employee's responsibility to notify the Company as soon as a formal notice regarding jury duty is

received. A copy of the notice must be provided to your manager. While serving, a non-exempt Employee's

wages will continue as regular pay for up to a maximum of 1 week per calendar year for actual days served, (or

as otherwise mandated by local, state or federal law). Regular pay is calculated based upon the base pay that an

Employee would otherwise have earned had he/she worked on the day of the absence. Mandatory overtime will

not be reimbursed. Should jury service go beyond 5 days, the remaining time will be treated as time off without

pay. It is expected that the Employee will report to work when off for the day or excused early.

Extenuating circumstances will be individually reviewed by Human Resources and members of Management.

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BEREAVEMENT LEAVE

Innovation Group will provide up to three (3) paid workdays to full-time employees in the event of the death of a member of their immediate family. This paid time off will be based on the employee’s regularly scheduled work day and rate of pay, and will be paid only for days that the employee has been scheduled to work.

Immediate family for the purpose of this policy, is defined as your father, mother, step-parents, grandparents, spouse, children, stepchildren, brother or sister; your spouse’s father, mother, grandparents, brother or sister, and any relative living with you in the same household.

Upon your return, please provide HR a copy of the obituary/funeral notice.

TIME OFF TO VOTE

We believe that every employee should have the opportunity to vote in any state or federal election, general

primary or special primary. Any employee whose work schedule does not provide him or her with time off to vote

while polls are open, will be granted reasonable time off in order to vote, or in accordance with state law. Time off

to vote may be paid if required by state law. Employees must give their supervisor at least 3 days’ notice of their

need for leave in order to vote.

CRIME VICTIM OR DOMESTIC VIOLANCE LEAVE

Employees who are victims of crime or domestic violence or who have to care for an immediate family member may be eligible to take unpaid leave. Employees should contact human resources to determine eligibility.

PAID SICK LEAVE

All employees, both exempt and nonexempt shall be eligible to accrue and use paid sick time. Sick time accrues at the rate of one (1) hour for every thirty (30) hours worked per benefit year (Jan, 1 – Dec. 31), up to a maximum of 40 hours and up to a maximum of 56 hours for employees assigned to Driven Solutions as required under Executive Order 13706. Use of Sick Time Employees may use up to 40 or 56 (Driven Only) hours of accrued sick time per benefit year. Accrual of sick time begins on the employee’s first date of actual work, but employees may not use such earned sick time until 90 calendar days after their start date. Sick time is provided to allow employees to:

Care for the employee’s own physical or mental illness, injury, or other medical condition that requires home, preventative, or professional care;

Care for a child, parent, spouse, or parent of a spouse who is suffering from physical or mental illness, injury , or other medical condition that requires home, preventative or professional care;

Attend routine medical and dental appointments for themselves or for their child, parent, spouse, or parent of a spouse;

Address the psychological, physical, or legal effects of domestic violence; or travel to and from an appointment, a pharmacy, or other location related to the purpose for which the time was taken.

Use of sick time for other purposes is not allowed and may result in disciplinary action if abused. Sick time can only be used in full hour increments and 1-hour increment is the smallest increment allowed under this policy. Absence Notification Procedures If an employee needs to be absent, to be late or to leave work early (for purposes that are permissible), the employee must give advance notice to his or her supervisor, except in an emergency. If the absence is foreseeable (for example scheduled appointment), the employee must provide up to seven days’ advance notice, unless the employee learns of the need to use earned sick time within a shorter period of time. Documentation of Use of Sick Time The company will generally require an employee to submit a doctor’s note or other documentation to support the use of sick time if the absence:

Exceeds 24 consecutively scheduled work hours or three consecutive days on which the employee is scheduled to work;

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Occurs within two weeks prior to an employee’s final scheduled day of work (except in the case of temporary employees); or

Occurs after four unforeseeable and undocumented absences within a three month period. If an employee fails to timely comply with documentation requirements the Company may recoup the sick time paid from future wages unless otherwise prohibited by law. Carryover: Carryover of sick time is not allowed unless otherwise prohibited by local or State Law. Payout of Sick Time Sick time is not payable upon termination of employment.

EMPLOYEE BENEFITS

INSURANCE BENEFITS

Innovation Group offers insurance benefits to all regular full-time Employees. These benefits may change from time to time and are regulated accordingly to U.S. regulations respectively. While they are too lengthy to cover in this Handbook, specific coverage and details are available from Human Resources. To the extent anything in this Handbook may conflict with the insurance documents themselves, the insurance documents will control. Regular full-time exempt/salaried employees will be eligible to participate in health care and other benefits plans of the Company according to the terms in the offer letter. Insurance benefits may be discontinued if an Employee has been on a non-FMLA related leave of absence for more than 8 consecutive weeks. Under the terms of our insurance plan, employees are required to meet certain specific hours worked requirements. Plan requirements are subject to change. For additional Please contact Human Resources via email: [email protected] for more information.

BETTER LIFE EMPLOYEE ASSISTANCE PROGRAM (EAP)

Our Employee Assistance Program (EAP) is designed to help you and the members of your household with work and life services, legal services and life planning. The EAP can also help with such issues as:

Depression

Relationship Concerns

Child and elder care issues

Alcohol and substance abuse

Health problems

Defining goals

School stress/support EAP services are free, confidential and provide voluntary, short term counseling and information service. Employees can call 24/7 to speak with a clinician or schedule an appointment by calling 1-844-763-8543 or contact Human Resources via email: [email protected] for more information.

COMPANY’S 401K SAVINGS PLAN

The purpose of the Plan is to give you a simple, tax-effective way to save for retirement. The Plan can plan an important role in helping you build retirement savings for tomorrow while you save on taxes today. The Plan allows you to:

Save with pre-tax dollars

Use easy payroll deductions

Receive 100% match up to 4% contributions from the Company

Benefit from tax-deferred investment growth on your savings and the Company’s match

Invest in a range of professionally managed investment funds

Make loans or withdrawals in certain situations If you would like more information on this plan, please contact Human Resources at [email protected].

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COMPANY HOLIDAYS

All full-time Employees receive 10 paid holidays. The following holidays are observed in the U.S.: New Year’s Day, President’s Day, G o o d F r i d a y, Memorial Day, Independence Day, Labor Day, Thanksgiving Day, and the Friday after Thanksgiving Day, Christmas Eve, and Christmas Day. Part-time and temporary employees are not eligible for holiday pay.

HOLIDAY PAY

All newly hired employees are not eligible for Holiday pay until after completing of 90 days of service. This policy does not affect the time and a half paid to employees who work on a company-designated holiday. Full-time Employees regularly scheduled to start a shift on the weekday a holiday is being observed are eligible for 8-hours holiday pay. Holiday pay will be calculate based on the employee’s straight-time pay rate (as of the date of the holiday). Employees forfeit Holiday pay hours if they are absent, sick, late by more than one hour, or leave more than one hour before the end of the shift on the previously expected working day, on the holiday, or on the next expected working day.

HOLIDAY RATE

Employees working on a designated company holiday will receive compensation at a rate of time-and-a-half for all hours worked midnight to midnight on the holiday. Holiday rate does apply to part-time and temporary employees if scheduled to work.

PAID TIME OFF (PTO)

Paid Time off (PTO) is available to regular full-time employees to provide opportunities for rest, relaxation, and to pursue special interests . PTO is an inclusive paid time off program which encompasses personal time, vacation or other personal pursuits in a flexible plan. Employees hired as temporary or with part time status are not eligible for PTO. Employees who are converted to regular full-time status and/or become regular full-time employees will become eligible on the date of change and all previous time served will be credited within the PTO schedules below. If there is a break in service from the company of less than 30 days, service is considered “bridged” and the length of service is calculated utilizing the original date of hire for purposes of this policy. If the break in service is more than 30 days, the rehire date will be used to calculate PTO grants. The amount of PTO time employees will be granted in January of each new calendar year will be granted based on consecutive length of service shown in the following schedules below. For the purposes of this policy the PTO year is (January 1 – December 31st). All PTO should be taken by December 31st of each year however, a maximum of 40 hours may be carried over to the next year. Unless otherwise required by law, all time in excess of 40-hours on Dec. 31st is forfeited. PTO – Full-time Hourly Employees

Length of Employment Amount of PTO per Year

0-1 Prorated based on Hire date

Available 1st of month following 60 day waiting period

1-2 years 10 days

2-3 years 12 days

3-4 years 15 days

4-5 years 16 days

5-6 years 17 days

6-7 years 18 days

7-8 years 19 days

8-9 years 20 days

9-10 years 21 days

11-12 years 22 days

12-13 years 23 days

13-14 years 24 days

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15 + years 25 days

PTO – Full-time Salaried Employees

Length of Employment Amount of PTO per Year

0-5 Years – (*First Yr. Prorated)

15 days

January following 5 completed years

20 days

January following 15 completed years

25 days

Your supervisor reserves the right to decline PTO requests. Requests will be reviewed based on a number of factors, including business needs and staffing requirements. All time-off request must be submitted through ADP Workforce Now. The Company encourages everyone to take this time off each year for rest and recreation. PTO should be requested ideally a minimum of 2-weeks in advance unless extenuating circumstances exist. PTO may be taken in a minimum of 4 hour increments and must be approved by your supervisor in advance. PTO is not allowed to be cashed in for pay under any circumstances. Paid time off is granted, not earned or accrued. Accordingly, unless otherwise required by law, PTO time not taken when an employee leaves the Company for any reason will be forfeited and will not be paid. PTO or any other paid time off cannot be used in place of a resignation notice.

D I S C I P L I N A R Y PROCEDURES

RULES OF CONDUCT

Every organization involving people has to have rules of conduct to protect the interests of the members of the organization and to achieve established objectives. All employees are expected to meet our standards of work performance. Work performance encompasses many factors, including attendance, punctuality, personal conduct, job proficiency and general compliance with our policies and procedures. If an employee does not meet these standards, we may, under appropriate circumstances, take corrective action, other than immediate dismissal. Such action may include, but is not limited to, written warnings, verbal warnings and suspension. Please note that although we may choose to follow progressive discipline in some instances, we reserve the right to determine, at our sole discretion, the appropriate disciplinary action to be taken in any given circumstance. Any Employee whose conduct, actions or performance violates or conflicts with our policies may be terminated immediately, with or without notice and with or without warning. Infractions of the following rules may subject Employees to disciplinary action, including warnings and possible discharge and is NOT meant to be a complete list:

Irregular attendance, repeated tardiness

Failing to report to work for three (3) days (consecutive or otherwise) during any three (3) consecutive months without authorization

Inefficiency or negligence in performing job

Disruptive behavior, creating conflict with coworkers

Sleeping on the job

Taking unauthorized or extended breaks

Permitting avoidable waste of material or supplies, carelessness, poor workmanship

Using abusive or foul language

Violation of health, housekeeping or safety rules, including littering grounds or work areas

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Visiting, loitering, loafing during working time, or disturbing other Employees at work

Horseplay

Unauthorized solicitation of Innovation Group Employees or Client Employees on behalf of any merchant, club or individual society, organization, political party, or religious group during working time, whether for membership, subscription, or payment of money

Repeated failure to accurately input time

Posting, removing or defacing material from the bulletin board

SERIOUS MISCONDUCT

The Company has listed below a number of offenses that we consider to be serious enough to result in discipline, up to and including discharge, even for a single offense. Of course, not all circumstances can be reduced to a single list and the Company reserves the right to dispense discipline in its sole discretion based upon the facts of a particular situation. The action that will be taken in a particular case will depend on the circumstances involved, including the severity of the offense, the employee’s past record and other relevant factors. Termination decisions must be reviewed and approved by Human Resources prior to the actual termination. The following are NOT a complete list but are illustrative of those offenses for which even the first offense may lead to performance counseling and/or termination from the Company:

Violation of any of the above listed infractions after a previous warning

Deliberately refusing to obey the orders of a manager

Using obscene language

Any degree of rudeness to clients, customers, or fellow Employees

Unprofessional behavior, including threatening, intimidating or coercing another employee, customer or client

Creating a hostile work environment

Failure to cooperate during an investigation

Disobeying instructions, procedures and policies, whether through neglect or deliberate disobedience

Insubordination of any degree

Gambling on Innovation Group or Client property

Violation of the Travel & Expense Policy or Corporate Credit Card Policy

Hitting, pushing or otherwise striking another person or any other disorderly conduct while on Innovation Group or Client property or arising out of Innovation Group business relations

Willful falsification of Innovation Group or Client records

Willful damage to Innovation Group, Client or Employee property

Arriving at work under the influence of alcohol or illegal drugs, or use, sale or dispensing of drugs or alcohol on Innovation Group Company or Client premises, or otherwise reporting to work in a manner unfit to perform work duties

Refusing to be tested if there is reasonable cause to suspect substance influence

Walking off the job during working hours or leaving the company premises without informing supervisor

Smoking, electronic cigarettes and/or use of tobacco (dip, chew) in prohibited areas

Possession or use of firearms or other lethal weapons on company premises or in the course of performing company duties

Jeopardizing the health or safety of Employees through neglect of duty

Assaulting a visitor or fellow Employee on Company premises

Forging, altering, or deliberately falsifying any document, authorization, record or time sheet that is used by the Company

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Stealing property and/or the unauthorized use of property that belongs to the Company, visitors or fellow Employees

Conviction of a felony within the past seven (7) years

Engaging in unlawful or indecent conduct on Company property within or outside regular work hours

Refusal to allow package, purse, or pocket to be checked by authorized personnel

Making false accusations against another Employee, customer or client

Disclosure of confidential Company or Employee information

This list is intended to be representative of the types of activities that may result in disciplinary action. It is not exhaustive and it does not change the employment-at-will relationship between the Employee and the Company.

SEPERATION PROCEDURES AND POLICY

Innovation Group expects all Company property to be returned on the last day of employment. It is also expected that the Employee will take with them any personal belongings. Innovation Group will not be responsible for personal property left 5 business days following separation. Transitioning employees will be paid final wages on next regularly schedule payroll unless otherwise required by law to pay final wages at time of termination.

PAYROLL PROCEDURES & POLICY

DIRECT DEPOSIT

As a courtesy to our employees, we offer the option to have your pay check directly deposited into your bank account. Please note that all direct deposit accounts are pre-noted to authorize the account which can take up to ten (10) business days. We cannot guarantee that every direct deposit request will be authorized and are not responsible for errors, as we cannot control the banking systems that provide this service.

TIME CLOCK

Hourly non-exempt Employees are required to punch in and out of the time and attendance system in accordance with working hours. Employees are required to punch in and out for lunch breaks. Manager approval is needed to work outside of regularly scheduled shifts. Employees are responsible, prior to the close of each pay cycle, to ensure time cards are complete and report discrepancies immediately to the appropriate supervisor. Corrections after the current payroll cycle closes will be made the following pay cycle.

OVERTIME

If you’re non-exempt, you’re eligible for overtime pay (subject to provisions of the federal and state wage and hour laws and Innovation Group policy). A supervisor must approve overtime before you work overtime hours.

WAGE DISCREPANCIES

Occasionally, due to error or inadvertence, employees receive an overpayment or underpayment of their wages or other compensation. Employees are responsible for reviewing their pay stubs or direct deposit notifications upon receipt and notify their immediate supervisor and Human Resources payroll department of any over or under payments so the appropriate action can be taken to correct. Employee’s failure to timely repay an acknowledged overpayment or to follow the terms of a repayment agreement will be subject to discipline that may include termination of employment.

CASH ADVANCES AND PAY CHECKS

Cash advances are not provided and checks are not handed out early.

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POLICIES FOR INDIVIDUALS WITH SPECIFIC FUNTIONS

COMPANY ISSUED CELL PHONES

Employees issued a Company owned cellular telephone or any Company owned communication device shall have no expectation of privacy relating to any aspect of its use. Cellular telephones are provided (with supervisor approval) to individuals who are required to be in close contact with the company at all times. Individuals required to be in close contact will be provided a Company owned cellular telephone and will not be eligible to expense personal cellular cost in lieu of. Employees are responsible for reporting any lost, stolen or damaged devices within 24 hours to their immediate supervisor. Employees’ devices will be either replaced or repaired which ever option is most cost effective. Employees that have repeat incidents of lost, stolen or damaged cellular phones may be required to pay out-of-pocket for repairs or replacements. Upgrades will be determined at the discretion of the senior management and only allowed for valid business reasons. All Data contained on cellular telephones provided by the Company, shall be considered the intellectual property of the Company. Certain information regarding device/service usage is tracked for the purpose of managing cost and policy compliance. Usage of Company cellular telephones may be monitored at any time as needed to determine whether devices/services are being used in accordance with Company policies and financial controls. This includes, but is not limited to, e-Mails, telephone call records, including personal telephone calls, text messages, photographs, documents, downloads or any other function available on the device issued to them. Every aspect relating to the functionality of the device remains the sole property of the Company and may be reviewed or requested by the Company at any time. Employees should refrain from activities that consumes excess amounts of data and that are not work related. Some examples included but not limited to; gaming, downloads, Pandora, web surfing or using cell phone as hot spot. Devices provided per this policy remain the property of the Company. Employees must return cellular telephones to the Company at the end of employment, management request, or when no longer required to fulfill job requirements. Company owned cellular telephones and telephone numbers may not be purchased by employees and will remain the sole property of the Company. BRING YOUR OWN DEVICE (BYOD)

The use of personal devices is limited to certain employees and may be limited based on compatibility of technology. Employees must discuss using personal devices for company-related information with their supervisor and human resources department to obtain approval. Employees authorized to use personal devices under this policy will receive an agreed-on monthly stipend based on the position and estimated use of the device not to exceed $60 per month. Employees authorized to use personal devices under this policy should not expect any privacy except that which is governed by law. Innovation Group has the right, at any time, to monitor, request data usage and preserve any communications that use the company’s networks in any way, including data, voice mail, telephone logs, internet use and network traffic, to determine proper use. Management reserves the right to review or retain personal and company-related data on personal devices or to release the data to government agencies or third parties during an investigation or litigation. Furthermore, no employee may knowingly disable any network software or system identified as a monitory tool. Termination of employment Upon resignation or termination of employment, or at any time on request, the employee may be asked to produce the personal device for inspection. All company data or personal devices will be removed by IT upon termination of employment. Safety Employees are expected to follow applicable local, state and federal laws and regulations regarding the use of electronic devices (Company Issued or Personal) at all times. Employees whose job responsibilities include regular or occasional driving are expected to refrain from using company issued or personal devices while driving at all times. Innovation Group is not responsible for payment of fines incurred by individuals who violate local, City or State laws.

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TELECOMMUNTER/REMOTE WORKERS Employees should not work from home without approval of the Department Vice President and Human Resources. Prior to approving request either from the employee or manager of the employee, must ensure that the following conditions apply:

The employee agrees to work remotely and is not on any disciplinary documentation (Written, Final, PIP)

The employee must be quality certified

The nature of the work to be performed from primary residence is operationally feasible

Employee has a place at their residence free from distraction (e.g., children, TV, dogs)

Employee understands the Company will not be responsible for insuring Company or personnel items located at the residence

The position has tasks or job responsibilities which are portable and can be performed away from the main worksite

The overall quality and quantity of work performed in the primary residence can be sustained by the employee

It is cost-effective to allow the work to be performed at the employee’s primary residence

Presence is not a job requirement at the main site

Will not burden the team (or budget) unfairly

Performance is easily quantified and evaluated against specific targets

Employee already has internet access at residence, if not employee will be provided with company device upon request

Reasonable costs for office supplies that are difficult obtain from the corporate office (toner, paperclips, paper, folders and filing supplies will be reimbursed with manager prior approval). Office furniture, (e.g., desk, chair, file cabinet, computer, lighting, phone, internet) will not be reimbursed

Executive Management will provide the final approval based on funding available within its budget to support the additional expenses associated with the employee working from home

Employees working remote are subject to the same benefits and policies listed in the Company’s employee handbook. Company reserves the right to require the employee to attend meetings at the physical location as business needs arise. Commuting expenses from the employee’s residence to the office location will not be reimbursed. Employee understands that the Company can change, alter or terminate the ability to work remotely with or without notice. Employee understands that all Company property including any proprietary documents, files must be returned to the Company upon termination of employment.

COMPANY ISSUED CREDIT CARDS

The Company will issue company credit cards to certain employees for use in their jobs and this policy sets out the acceptable and unacceptable uses of such credit cards. Use of company-issued credit cards is a privilege, which the Company may withdraw in the event of serious or repeated abuse. Any credit card the Company issues to an employee must be used for business purposes only, in conjunction with the employee’s job duties. Employees with such credit cards shall not use them for any non-business, non-essential purpose, i.e., for any personal purchase or any other transaction that is not authorized or needed to carry out their job duties. Employees must pay for personal purchases (i.e., transactions for the benefit of anyone or anything other than the Company) with their own funds or personal credit cards. The Company will not regard expenses for one’s own business-related use, such as lodging and meals while on Company-approved business trips, as personal purchases, as long as such expenses are consistent with the Company’s travel and expense reimbursement policy. Deductions from Pay If any employee uses a Company credit card for personal purchases in violation of this policy, the cost of such purchase(s) will be considered an advance of future wages payable to that employee, and will be recovered in full from the employee’s next paycheck; any balance remaining will be deducted in full from subsequent paychecks

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until the wage advance is fully repaid. Such deductions may take the employee’s pay below minimum wage for the pay period(s) in question. If an employee uses a company credit card for any other type of unauthorized transaction in violation of this policy, i.e., incurs financial liability on the Company’s part that is not within the scope of the employee’s duties or the employee’s authorization to make business-related purchases, the cost of such purchase(s) or transaction will be the financial responsibility of that employee, and the employee will be expected to reimburse the Company via deductions from the employee’s pay until the unauthorized amount is fully repaid. Such deductions will be in the amount of the unauthorized purchase(s), but if a deduction for such amount would take the employee below the minimum wage for the workweek in question, the deductions will be in two or more equal installments that will not take the employee’s pay below minimum wage for any workweek involved. In addition to financial responsibility and liability for wage deductions, any purchases an employee makes with a Company credit card in violation of this policy will result in disciplinary action, up to and possibly including termination of employment, and criminal prosecution if applicable.

TRAVEL & EXPENSE REIMBURSEMENT POLICY

To be reimbursable, expenses must have a clear business purpose consistent with the image of a professional organization. Good judgment is expected before incurring any expense on behalf of the Company and employees are expected to use discretion and “do the right thing” if a situation arises that is not covered by this policy. This policy clearly defines the process required for travel and entertainment expense reimbursement to insure that expenses incurred are within Company good business standards, properly supported with required documentation, appropriately approved by management and reimbursed in a timely manner. Accuracy in reporting and documenting expenses is essential. Employee business expenses must meet record keeping requirements imposed by the Internal Revenue Service. The Company assumes no obligation to reimburse employees for expenses NOT in compliance of this policy or deemed not to be a necessary business expense. All expenses must be submitted for reimbursement within 30 days of travel or expense. Expenses submitted beyond 30 days will not be reimbursed. Responsibility The employee is responsible for complying with this Policy. The manager who approves and signs expense reports is responsible for accurately reviewing expense reports for compliance. The Company will reimburse employees for all reasonable and necessary expenses while traveling on authorized Company business or entertaining business clients. This Policy assumes no obligation to reimburse employees for expenses that are not in compliance with this Policy. The CFO must approve any deviation, if any, from this Policy by the employee. Enforcement Employees who do not comply with this Policy may be subject to delay or withholding of reimbursement and/or, disciplinary action, up to and including termination. Reservations All employees should use the services of Travel Incorporated accessible through the Concur Travel Site for air, rail, rental car and hotel reservations. Making reservations through any other resource would be outside of this policy and would require supervisor approval and reasonable explanation. Vendors or any non-employee who are traveling on behalf of Innovation Group should make travel arrangements through the designated travel agency and adhere to all expense guidelines contained within this document. Human Resources can assist with the booking of non-employees. Traveler Profiles All employees are responsible for the completion and updating of their individual travel profile accessible through Concur travel site. Traveler needing immediate assistance with domestic travel can call a client travel agent 24/7 at 1-855-890-5172. When calling a client travel agent our account is listed under Driven Solutions. Travelers needing immediate assistance with international travel should dial 1-813-371-1220. Frequent Flyer Programs

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Employees may retain frequent flyer program benefits for their personal use or for business-related upgrades. However, participation in these programs must not influence flight selection, resulting in incremental cost to the Company beyond the lowest available airfare as defined in this policy. The Company will not reimburse employees for program membership fees or other costs associated with these programs. Employees Traveling Together No more than six group employees are permitted to fly on the same aircraft. Where practical, not more than two Directors or two members of the Executive Team are permitted to fly on the same aircraft. Lost Baggage The airlines are ultimately responsible for the retrieval of and compensation for lost luggage. The Company will not reimburse travelers for personal items lost while traveling on business. Further, employees are responsible for the care of company property, such as laptops, when they are traveling. Lost or Stolen Airline Tickets The traveler should immediately report the lost or stolen ticket to Travel Incorporated travel agency by calling 1-855-890-5172. There is a charge for each time a lost ticket application is filed and you may be asked to pay this fee. Payment Procedures Air travel costs should be paid with your corporate American Express Card if one was issued. Personal credit cards are acceptable for travelers without AMEX Corporate Cards. If you do not have a credit card or you do not have the means to travel, speak to your supervisor so other arrangements can be made on your behalf. Air/Rail Travel Air travel reservations should be made in such a manner as to secure the best available fare. ALL AIR TRAVEL SHOULD BE IN COACH OR ECONOMY CLASS. Premium Economy class flights may be used for trips where the flight time is more than 4 hours if fare is not overly expensive. Good financial judgment must prevail. When traveling by air:

Employees are expected to use the lowest logical airfare available.

Book tickets as early as possible to take advantage of advance purchase discounts. Early booking discounts begin at 3 days prior to departure and increase incrementally at 7, 14, and 21 days.

Consider alternate airports (within 50 miles), one connection that does not exceed 90 minutes and departure/arrival times within 2 hours (before or after) the original times requested. Savings should be at least $150 to offset scheduling inconvenience.

Upgrades for Air Travel Upgrades for air travel are not reimbursable. If an employee wishes to upgrade, it is done at the employee’s expense. Upgrades may be approved when a medical condition requires it and documentation from the employees physician is presented to proper management level pre-approving the trip. Alcoholic Beverages

The employee is to refrain from consuming alcoholic beverages during business travel, entertaining clients or attending any business events. However, in the event an employee chooses to consume alcoholic beverages in connection with a business related meeting or event, the Company expects that employees will act responsibly and avoid excess consumption of any alcoholic beverage. If an employee has any concerns that he/she is not capable of safely driving after such events, the Company will reimburse the cost of alternative transportation to ensure that the employee does not place themselves or others in danger. An employee, who is arrested and convicted for Driving under the Influence while in the performance of company business, or when returning from a business meeting or event, is subject to disciplinary action up to and including termination. General Travel Requirements Necessity of Travel. The person authorizing the travel should consider the costs and benefits of every trip. Less expensive alternatives, such as participation by telephone or video/web conferencing, or the availability of local programs or training opportunities, should also be considered. Personal and Spousal Travel Expenses Individuals traveling on behalf of Innovation-Group may incorporate personal travel or business with company-related trips. Additional expenses incurred as a result of personal travel, including but not limited to extra nights,

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additional stopovers, meals, and transportation, are the sole responsibility of the individual and will not be reimbursed by Innovation-Group. Expenses for an employee’s family or friends will not be reimbursed by the Company. Expense Reports Expenses will be reimbursed based on Expense Report submitted through the company expense report software system (Concur) or use of paper expense reports available through the finance department. Expenses should be submitted for reimbursement within 30 days of completing the travel or incurring the expense. Generally, expenses submitted for reimbursement longer than 65 days after completing the travel or incurring the expense will not be accepted or reimbursed. Exceptions are considered on a case-by-case basis and require justification. Persistent or deliberate non-compliance may result in disciplinary action. Incomplete or Incorrect Expense Reports Expense reports that are incorrect, incomplete or do not have a necessary business reason will be returned to the employee and may be delayed or non-reimbursement of specific items. Receipts Itemized receipt is required for all expenses. Business meals and entertainment expenses must contain the client and/or employee names. Digital photos or scanned images of receipt are acceptable as long as they are legible. If receipt is lost or not available, an addendum explaining the expense, where there is no receipt and proof of payment must be submitted with the expense report. Cancellations when a trip is cancelled after the ticket has been issued, the Concur system will track unused tickets and automatically apply to the traveler’s next booking. Unused tickets must be used for business travel only. Using unused airline tickets for personal travel is a violation of policy and subject to disciplinary action, up-to and including possible termination of employment. Cancellations for trips booked outside the Concur system must be reported to your supervisor immediately so the proper reallocation of that ticket can be determined. Auto Travel/Car Rental Rental car reservations must be made through Concur travel site and preferred rental car vendors should be selected. Employees may rent a car to get to their destination when driving is more cost effective than airline or rail travel. Employees may rent a car at their destination when it is less expensive than other transportation modes such as personal mileage for long distance trips (100 miles or longer), taxis, airport limousines and airport shuttles or when entertaining customers. Whenever multiple employees are traveling together, every effort to rideshare or carpool must be made. Employees must reserve a car in the compact or intermediate rental car category. At the time of rental, inspect the car and be sure that any damage found is noted on the contract before the vehicle is accepted. Employees may book a car rental class of service one level higher when:

The traveler can be upgraded at no extra cost

Two or more company employees are traveling together

Entertaining customers

Cars in the authorized category are not available

Transporting excess baggage such as trade show booth displays Guidelines to follow when renting vehicles:

Decline the refueling option and return the vehicle to the rental company with a full tank of gas

Return rentals to the original rental location if possible to avoid costly drop-off charges

Use the company’s corporate AMEX card for all vehicle rentals is preferred but not required. Insurance should not be purchased from the rental company. If the AMEX card is used for renting, then please use the car rental insurance that is offered by Amex as one of its benefits. However, Innovation Group has its own Automobile insurance (Company’s Auto Insurance), and should the coverage of AMEX not be sufficient, the Company’s Auto Insurance will trigger as back up policy. The Certificate of Insurance for the Auto rentals is circulated annually in an email by the Company’s Legal Dept. in June or July every year. Should you miss this email, please contact Human Resources or the Legal Dept., for a copy of this Certificate of Insurance of the Company’s Auto Policy.

Should a rental car accident occur, employees should immediately contact the rental Car Company, local authorities (as required), immediate supervisor and Human Resources.

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Rental Car Gas Gasoline for use in rental cars is reimbursable with proper documentation. Make sure to log this expense as AUTO RENTAL & GAS. Cell Phone Use While Driving Use of a cell phone while driving is not recommended in any situation and employees are expected to refrain from using their phone while driving. Employees must adhere to local or state laws regarding cell phone use while driving. Citations issued for violating local or state laws is not reimbursable. Otherwise where legally permissible, employees are strongly encouraged to pull off to the side of the road and safely stop the vehicle before placing or accepting a call. If acceptance of a call is unavoidable and pulling over is not an option, employees are expected to keep the call short. Taxi / Shuttle / Parking Fees The use of airport shuttles and taxis upon arrival at the employee’s destination is the preferred mode of transportation. Make sure to ask for a receipt if one is not offered. This documentation aids in the expense-tracking process. Business Use of Personal Vehicle Employees may use their personal vehicle for business purposes if it is less expensive than renting a car, taking a taxi, or using alternate transportation. Personal vehicles may also be used when transporting company goods for delivery or entertaining clients. It is the personal responsibility of the vehicle owner to carry adequate insurance coverage for their protection and for the protection of any passengers. Mileage is reimbursed at the rate established by the IRS. This mileage allowance is in lieu of actual expenses for gasoline, oil, repairs, tags, insurance, and depreciation. Therefore, actual expenses for those items will not be reimbursed when your personal vehicle is used for business. The Company will NOT reimburse and employee for any repairs resulting from business travel. To be reimbursed for the use of your personal vehicle for business, employees must list on the expense report:

Date and purpose of the trip

Locations traveled to and from

Mileage Lodging / Hotel Hotel reservations should be made in such a manner as to secure the best available rate. Employees are required, whenever possible, to use properties in the Moderate category. Hotel rooms should be guaranteed for late arrival and cancellations should be made before the time limit shown on the itinerary (usually between 4:00 pm – 6:00 pm local time of the property) to avoid “no show” charges. The recommended limit for nightly spend is between $129.00 - $149.00 US dollars. In case of cancellation:

Employees are responsible for cancelling the reservation

Employees will be held responsible and will not be reimbursed for "no-show" charges unless there is sufficient proof that the billing is in error or circumstances were beyond the traveler’s control.

Employees should request and record the cancellation number in case of billing disputes

Meals Employees are reminded to act with maturity, consideration and responsibility in exercising prudent business judgment over the necessity and validity of subsistence expenses as they are being incurred. Below are meal guidelines understanding that in some markets meal(s) will cost more.

Breakfast- Employees may reclaim the cost of breakfast where they are working away from their normal place of work and this requires being away from home overnight. It is expected that this will normally be covered as part of the hotel room booking. Where it is not included in the hotel booking, the reclaimable guideline is limited to $10 US dollars.

Lunches and daily incidentals – All lunches, snacks and incidental drinks are not allowed to be reclaimed as these are considered to be part of the normal working however, managers can make exceptions.

Evening meal – Employees may claim for an evening meal where they are working away from their normal place of work and this requires being away from home overnight. Claims must be fully supported by receipts with a limited guideline of $30 US dollars.

Meals attended solely by employees that are “in=town” are not reimbursable unless approved in advance by a member of the Regional Executive team.

Tips must be limited to 18% of the cost of the meal and only provided where it is customary to offer such

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gratuities. Anything above this level will not be reimbursed. Client Entertaining or Department Events Business meals are defined as meal expenses incurred when a client is present or another company employee is present. All employees are reminded to exercise common sense and restraints whilst incurring this cost – “if you wouldn’t spend your own money, would the Company? Where business entertaining costs will exceed $125.00 US dollars per head approval by a member of the Regional Executive team will be required in advance. The following documentation is required by the IRS, and must be recorded on the expense report:

Names of individuals present, their titles and company name

Name and location of where the meal or event took place

Exact amount and date of the expense Parking/Tolls/Mileage Parking and toll expenses, including charges for hotel parking, incurred by employees traveling on Company business will be reimbursed. On-airport parking is permitted for short business trips. For extended trips, employees should use off-airport facilities. Non Reimbursable Travel Expenses The company will generally not reimburse employees for the following expenses:

Sweatpants, Sweatshirts

In room movie rentals or at theatre

Personal bar bills

Parking tickets, traffic citations or speeding tickets

No replacement or reimbursement of personal property lost, stolen or damaged (sun glasses, briefcase, cell phone etc.) This is typically covered by most homeowner’s policies

Insurance costs for luggage via air or ground level

Automobile repairs

Upgrade for air, hotel, or vehicle rental

Personal care items, cosmetics, nail or hair salon expenses etc.

Health club fees

Spouse’s/ partner expenses if accompanying Innovation Group employee on a trip

Kennel fees

Political or charitable contributions

Childcare expenses

Personal or over the counter medications

Laundry and/or dry cleaning charges (unless claimant spends 3 or more days and nights out of town)

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A C K N O W L E D G M E NT O F RECEIPT OF INNOVATION

GROUP

E M P L O Y E E H A N D B OO K

This handbook is presented to provide you with information about your employment with Innovation Group. It has been prepared as a guide and reference only. This Employee handbook is not a contract. Innovation Group reserves the right to revise, discontinue, suspend, or modify any of the policies contained in this handbook at any time and in its sole discretion. I acknowledge that I have received a copy of the Innovation Group, North America Employee Handbook outlining the policies and procedures of Innovation Group. I have read the Table of Contents, and I know what kind of information I can find in the handbook. I acknowledge that it is my responsibility to read and understand the information contained in this handbook and to abide by the policies and procedures of the Company, both now and in the future. I also understand that Innovation Group has the right to revise, discontinue, suspend or modify any of the policies contained in this handbook at any time and that all such changes will be binding upon all Employees. If I have any questions, I understand that I should contact my manager or Human Resources. I understand and confirm my electronic signature of acknowledgment is proof of my acknowledgment. AS A CONDITION OF MY EMPLOYMENT AND CONTINUED EMPLOYMENT AT INNOVATION GROUP, I AGREE TO FOLLOW THE POLICIES AND PROCEDURES OF THE COMPANY. I UNDERSTAND THAT UNLESS OTHERWISE AGREED IN WRITING SIGNED BY AN OFFICER OF THE COMPANY AND SUBJECT TO APPLICABLE LAW, ALL INNOVATION GROUP EMPLOYEES ARE EMPLOYED ON AN AT-WILL BASIS. THIS MEANS THAT EMPLOYMENT IS NOT GUARANTEED FOR ANY SPECIFIC DURATION, AND INNOVATION GROUP RETAINS THE RIGHT TO TERMINATE AN INDIVIDUAL’S EMPLOYMENT AT ANY TIME, WITH OR WITHOUT CAUSE. NO ORAL REPRESENATIONS MADE BY AN INNOVATION GROUP EMPLOYEE WITH RESPECT TO CONTINUED EMPLOYMENT CAN ALTER THIS RELATIONSHIP, LIKEWISE, NO STATEMENT MADE IN THIS HANDBOOK IS INTENDED TO ALTER THE AT-WILL NATURE OF EMPLOYMENT WITH INNOVATION GROUP OR TO CREATE ANY CONTRACT WITH RESPECT TO THE TERMS OR CONDITIONS OF MY EMPLOYMENT. Note to Employees: As of its issue date, this handbook replaces all previously distributed editions. Any policy contained in any previous handbook which does not appear in this edition, or is different from the information provided in this edition is invalid. This handbook is the property of Innovation Group. All information contained within this handbook is for Innovation Group and its employees only.

Employee Signature Date January 2017 Edition Innovation Group is an equal opportunity employer. It is the Company’s policy to provide equal employment opportunity (EEO) to all qualified persons without regard to race, sex (including pregnancy, childbirth and related medical conditions), religion, color, age, national origin, disability, citizenship, sexual orientation, genetic information, gender identity or any other characteristic protected by the applicable federal, state, or local law. The Company provides equal opportunities in employment, promotions, wages, benefits and all other privileges, terms and conditions of employment.