United States

1
May, 2023
 Table of Contents
Welcome to Everise! ....................................................................................................................... 5

Overview............................................................................................................................................. 8

Our Employment Philosophy ....................................................................................................... 9

Everise Business Code of Conduct ........................................................................................... 13

Standards of Business Conduct .................................................................................................. 16

Protecting the Company’s Assets, Resources and Data ....................................................... 17

Accuracy of Books and Records and Public Disclosures ...................................................... 20

Duties to Stakeholders.................................................................................................................... 21

Communications and Media ....................................................................................................... 21

Conflicts of Interest and Personal Behavior .............................................................................. 23

Positive Work Environment ............................................................................................................ 25

Compliance with Laws, Rules, Regulations And Policies ........................................................ 28

Reporting Potential Code Violations ........................................................................................... 31

Disciplinary Action for Code Violations ...................................................................................... 32

Statement of Compliance ............................................................................................................ 32

Waivers............................................................................................................................................... 33

Amendments .................................................................................................................................... 33

Anti-Bribery and Corruption Policy......................................................................................... 35

Sustainability Policy ..................................................................................................................... 43

Outside Employment Policy ....................................................................................................... 45

Sanctions and Trade Controls Policy ...................................................................................... 48

Conflict of Interest Policy ............................................................................................................ 57

At-Work Policy ............................................................................................................................... 64

Cell Phone Policy ............................................................................................................................ 75

Electronic Monitoring and Recordings Policy....................................................................... 76

Chat Room Policy ........................................................................................................................... 78

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Drug-Free Workplace Policy ...................................................................................................... 80

Equal Employment Opportunity Policy .................................................................................. 87

Anti-Harassment, Discrimination, and Retaliation Prevention .................................... 89

The Genetic Information Nondiscrimination Act (GINA) .................................................. 91

Sexual Harassment Policy .......................................................................................................... 93

Discrimination on the Basis of Gender, Gender Identity or Transgender Status ...... 96

Creating a Respectful and Open Workplace Under the Natural Hair Act of 2020
Policy.................................................................................................................................................. 98

Diversity, Equity and Inclusion Policy ..................................................................................... 99

Human Rights Policy................................................................................................................... 101

Communication Devices & Workplace Tools Policy ........................................................ 105

Data Protection and Privacy Policy ....................................................................................... 111

Health Insurance Portability and Accountability Act - HIPAA ..................................... 121

Health, Safety & Environment Policy .................................................................................... 123

Search, Inspection & Investigation Policy ........................................................................... 129

Rewards And Recognition Policy ............................................................................................ 132

Taxable Income – Gifts and Cash/Gift Card Policy ........................................................... 136

Work-at-Home Policy ................................................................................................................ 137

Equipment Guidelines ................................................................................................................ 140

Headset Policy .............................................................................................................................. 142

Monitor Policy ............................................................................................................................... 144

Web Clock Acknowledgement ................................................................................................ 145

Compensation & Benefits Policy ............................................................................................ 146

Internal Job Posting (“IJP”) Policy ........................................................................................ 154

Promotion Policy .......................................................................................................................... 158

Time Off Policy .............................................................................................................................. 164

Company Paid Holidays ............................................................................................................ 184

Attendance and Absence Management.............................................................................. 185

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Accommodation Policy ............................................................................................................. 190

Rehire & Reinstatement Policy ................................................................................................ 193

Global Travel Policy..................................................................................................................... 195

Progressive Coaching Process ................................................................................................ 203

Employee Resources................................................................................................................... 205

Dispute Resolution ...................................................................................................................... 206

Whistleblower Policy and Procedure .................................................................................... 210

Enterprise Information Security Policy ................................................................................ 222

Employee Acceptable Use Policy ............................................................................................ 226

Confidentiality, Non-Solicitation and Non-Disparagement Policy ........................... 238

Separation and Termination Process ................................................................................... 241

Arbitration Statement & Agreement .................................................................................... 243

Acknowledgement of Employee Handbook........................................................................ 246

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 Welcome to Everise!

As an Everiser, you are now part of an award-winning, next-generation experience

company! As part of a growing team, you play a crucial role in helping some of the
world’s leading brands transform their customers into fans and products into passions.

OUR STORY

Everise was established in 2016 by founder and CEO, Sudhir Agarwal, with a vision to
disrupt the Business Process Outsourcing (BPO) industry by identifying companies
which showed potential in transforming elements of the customer experience.

WE ARE EVERISE

Globally, the Everise family is 15,000 people strong, across seven countries and creates
more than 500,000 daily customer experiences in 20 different languages. Our domain
expertise lies in making complex support simple in connected industries such as Health
& Wellness, Connected Health, Smart Home, Tech & Software, Travel & Hospitality, Media
& Communications, Financial Services, and Logistics & Supply Chain. This allows us to
nurture innovation and deliver immersive experiences for the brands of tomorrow.

OUR PURPOSE

At Everise, we believe that to truly transform customers into fans and products into
passions, we need to start with our purpose and people. As Everisers, our purpose is to
elevate experience for our customers and fellow employees. We do this by being
champions of customer happiness, being people-focused, celebrating diversity,
incubating innovation, and accelerating your development. Ultimately, we aim to
ensure that a future exists where technology is powered by people and is for the benefit
of people.

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OUR VALUES

We Are People-First

Be recognized for your hard work and achievement. We have a sharp eye for potential,
and we reward our people through recognition programs, performance awards, and
celebrations. We ensure a supportive work environment with initiatives that push
personal growth and career advancement.

We Incubate Innovation

Be creative and elevate yourself by working with amazing companies. Through our
Experience Labs and advanced digital products, we are a globally enabled workforce,
focused on embracing new technologies and fresh ideas to transform how we work.

We Celebrate Diversity

Be yourself and feel at home with our multicultural team. Supporting over 20 languages
in our locations, we encourage diversity at all levels through community service
programs, Everise Cares initiatives, Employee Resource Groups, and our E-Talk forums.

We Accelerate Your Growth

• Everise University

As a progressive global experience company, we have developed our very own

learning platform and resource. This allows our people to benefit from a large
pool of knowledge that’s accessible anytime.

• Everise Accelerator Training

A week of instructor-led classroom training to teach foundational skills to

Supervisors and ensure consistent coaching and management processes
across all global sites.

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• Everise Career Development

We pair promising employees with department leaders who provide career

coaching and skills development. This powerful mentor relationship increases
your readiness for career advancement. Coming soon to more sites.

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 Overview

Welcome to Everise, a dynamic and rewarding place to work!

This handbook has been written to serve as a guide for our U.S.-based employees and
to present an overview of the Company's policies and practices in one reference
source. This handbook supersedes all prior handbooks, written documents, or oral
representations regarding its subject matter. There are several things that are
important to keep in mind about this handbook. First, it contains only general
information and guidelines. It is not intended to be comprehensive or to address all
the possible applications of, or exceptions to, the general policies and procedures
described. If you have any questions concerning eligibility for a particular benefit or
the applicability of a policy or practice, you should address your specific questions to
your supervisor or the Human Resources Department (“HR”). You can access a copy of
the Employee Handbook on Workday from the internet and we encourage you to check
it from time-to-time to review any updates which may occur.

If you are unable to access the handbook via the internet, please see your Human
Resources Department for assistance.

This handbook does not create an employment contract. Your status as an “at-will”
employee may not be changed except in writing signed by an authorized Everise
officer. Therefore, other than the Arbitration Statement and Agreement, and Web Clock
Acknowledgement contained in this handbook, the Company reserves the right to add,
change, or alter conditions of employment, benefits, wages, policies, and all other
working conditions in its sole discretion. No manager or representative of Everise has
the authority to enter into any agreement for employment for any specified period of
time.

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 Our Employment Philosophy

At Everise, it is important that employees represent professional values and principles

and perform at the highest level of personal integrity. We will do our best to provide an
open, honest, and supportive work environment, and we ask that our s contribute the
same energy and dedication to maintaining a respectful, clean, and professional
workplace. Everise pledges to treat employees fairly and in a dignified manner,
providing them with a quality work environment, fair compensation, the right to be
heard, and opportunities to learn and grow within our organization.

1. At-Will Employment

• Employment is at will (unless state law dictates otherwise) and is subject to

termination by the employee or by the Company, with or without cause, and with
or without notice, at any time. Nothing in this handbook or any Company policy
shall be interpreted to conflict with, or to eliminate or modify in any way, the
employment-at-will status of employees.

• The employment-at-will policy may not be modified by any officer or employee

and shall not be modified in any publication or document.

2. Starting Employment – Introductory Period

• As a new employee, it is normal that it will take time before you are fully familiar
with fixed the people, procedures, and responsibilities of your assignment. For
this reason, the first six (6) months of employment are considered an
introductory period to allow you to acclimate to your new environment, as well
as provide an opportunity for both the Company and you to confirm both sides
have made a good employment decision. Your performance and acclimation
are monitored closely to ensure you are provided the appropriate coaching and
support for a successful transition.

• Completion of this introductory period does not change or alter the “at will”
employment relationship between you and the Company. You continue to have
the right to terminate your employment at any time, with or without cause or
notice, and the Company has the same right. There is no guarantee of
employment during or after the introductory period.

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3. Employee Records

• The Company complies with applicable laws regarding access to personnel

records. All employee information and records are the sole property of the
Company.

• For purposes of this policy, the personnel file includes records related to
performance and training as well as other records used for hiring, promotion
and disciplinary decisions. It will not include any reference checks, medical
records, or investigation files.

• The Human Resources Department maintains an employment record in

Workday for every employee. It is important that this record be up to date.
Please notify your Human Resources Department of any changes in your
address, telephone number, marital status, and number of dependents,
educational progress, and any other data which is maintained or should be
maintained in your employment records. Most of this information may be
updated directly in our Human Resources Information System by utilizing
employee self-service through one of our designated Company computer
kiosks or the Internet at: Workday.

• An employee who needs assistance using Workday should contact their

supervisor or Human Resources Department.

• Only active (currently employed and working) employees may review their
records by scheduling an appointment with their Human Resources
Department. A representative of the Human Resources Department must be
present during the review.

• An employee's supervisor or manager who has an employment related need to

know personal information may inspect certain documents related to an
employee over whom they have supervisory responsibility.

• Managers are not permitted to remove any documents from the employee file.

4. FLSA Classification of Employees

Everise employees are classified as follows:

• FT – Regular Full-Time Employee: An employee whose actual worked hours are

equal to or greater than 30 hours per week. Regular full-time employees are
eligible for the Company benefits, including, but not limited to paid holidays, sick

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 days, vacation days, and insurance benefits. Periodically, an analysis is
performed to validate the 30-hours-per-week requirement for full-time status.
Employees falling below this average may have their status changed to regular
part-time and be offered COBRA benefits.

• PT – Regular Part-Time Employee: An employee whose actual worked hours are

less than 30 hours per week. Regular part-time employees are not eligible for
standard Company benefits. Periodically, an analysis is performed to validate
that the 30-hours-per-week requirement for full-time status is not satisfied.

• Temporary/Seasonal Employee: An employee who works for a period of time or

on a specific project not to exceed 180 days during a 12-month period.
Temporary/seasonal employees are not eligible for any Company benefits.

• Exempt or Salaried Employee: An employee is classified as exempt based on the

type of work performed and wage-and-hour law requirements. Exempt
employees are not eligible for overtime.

• Non-Exempt or Hourly Employee: An employee in a position classified Non-

Exempt is entitled to overtime when approved in advance by their supervisor.

• Full-time / Part-time Determination - Employee work hours will be audited

periodically to determine if the employee is meeting the definition of their
currently assigned classification. If the employee is no longer meeting the
definition of their currently assigned classification, the employee will be
contacted by their supervisor or Human Resources and guided through a
process of re-classification which may affect eligibility for various benefit
programs.

5. Recording Hours Worked for Non-Exempt Employees

• The Company wants all non-exempt employees to be paid accurately and in a

timely manner for work hours they have completed. Non-exempt employees
must log in and out at the start and end of each shift. Non-exempt employees
are also required to log out and in at the start and end of meal breaks.

• Hours registered through the employee timekeeping system will be used to

calculate pay. Therefore, it is critical that all employees log in and out to assure
timely and accurate payment for work completed. All non-exempt employees
must log in and out prior to commencing any work duties, including, but not
limited to, computer or software system boot up. We recognize that errors may
occur, so any corrections to timecards or timesheets must be initiated by the
affected employee and approved by their supervisor.
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• Non-exempt employees must submit their hours to their supervisor in Workday
daily. Non-exempt employees are responsible for reviewing their hours worked
as recorded in Workday to ensure they reflect an accurate record of all hours
worked. Any discrepancies should be immediately communicated to the
employee’s supervisor for correction or clarification.

• At no time should any employee log in or out for another employee or ask
another employee to log in or out for them. Doing so is grounds for disciplinary
action, up to and including immediate termination of all involved.

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 Everise Business Code of Conduct

Summary Of the Code’s Principles

Protecting Company’s Assets, Resources and Data

• We often have sensitive confidential information about Everise, other

companies, our clients and investors, and our directors, officers and
employees; preserving the integrity of this information is vital to our business
and reputation and is necessary to meet our obligations under data
protection laws.
• Electronic communications relating to business activities may not be
conducted through electronic communication systems that have not been
specifically approved for business activities, including (among others)
personal email accounts, personal text messaging, nonapproved chat
forums, and social media.

Accuracy of Books and Records and Public Disclosures

• We should take care that our books and records are accurate and that all
our business transactions are properly authorized.

Duties to Stakeholders

• A company’s reputation is everything and we should act responsibly in

dealings with our customers, clients, investors, suppliers, other stakeholders
and competitors.

Communications and Media

• In this digital era, be careful in your written communications made over

company information systems, such as email, as this is a permanent record.
• You must ensure that your online activities, including your use of social
media, are appropriate and reflect well on Everise.
• The Code does not prohibit an employee from engaging in such
communications that are intended to address employee concerns involving
terms and conditions of employment.

Conflicts of Interest and Personal Behavior

• Everise is a global brand and as a representative of the company your

personal behavior must be consistent with our values.

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 • Be cognizant that you face a risk that your personal interests may conflict
with or appear to conflict with the interests of the company.

Positive Work Environment

• We value diversity and we should all do our part to maintain a respectful work
environment where everyone feels safe, included and productive.
• Our success is dependent on establishing a workplace culture free from
discrimination, violence and harassment.

Compliance with Laws, Rules, Regulations And Policies

• We operate in many jurisdictions and are subject to different laws, rules and
regulations; you need to be aware of the laws that apply to your activities so
that you can comply with them; ignorance of the law is no excuse.
• The company has corporate policies that you must be familiar with, as they
govern your activities, business practices and other conduct while at Everise.

Frequently Asked Questions

Why do we have a code?

The Code serves as a guide for how you should conduct yourself as a member of the
Everise team. Preserving our corporate culture and ensuring compliance with legal
and regulatory duties is vital to the organization and following the Code helps us do
that.

Who must follow the code?

The Code applies to all directors, officers, employees and temporary workers of Everise
Holdings Pte. Ltd. and its direct and indirect subsidiaries.

What are your responsibilities?

You have two responsibilities. First, you must follow every aspect of the Code and certify
your commitment each year. Second, if you suspect someone may be violating the
Code or the policies referred to herein, you have an obligation to report it. To make a
report, follow the section of the Code: “Reporting Potential Code Violations.”

How will I know if there is a problem?

The Code attempts to deal with the most common issues that you may encounter, but
it cannot address every question that may arise. When you’re not sure what to do, ask
yourself the following questions:

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 • Is it illegal?

• Does it feel like the wrong thing to do?

• Would you feel uncomfortable if others knew about it?

• Will it have the potential to create a negative perception of you or the

company?

• Do you have a personal interest that has the potential to conflict with the
company’s interest?

If you answer “yes” to any of these questions your proposed conduct may violate the
Code and you should ask for help.

How should I ask for help?

If you have questions about the Code, any policies or guidelines referred to herein, or
about the best course of action to take in a particular situation, you should seek
guidance from your supervisor or a member of the Everise Legal Department by
emailing [email protected].

What if I would like to make an anonymous report?

You may make an anonymous report by contacting the company’s reporting hotline,
which is operated by an independent third-party and is available 24 hours a day, 7
days a week. The Reporting Hotline phone numbers by jurisdiction are set forth on
Schedule A. If you choose to make an anonymous report, your anonymity will be
protected to the fullest extent possible as permitted by law. Keep in mind, however, that
maintaining your anonymity may limit the company’s ability to investigate your
concerns.

What are the consequences for violating the code?

Violations of the Code or the policies and guidelines incorporated by reference herein,
can vary in its consequences. If you’re an employee, it could result in a reprimand or
other disciplinary action, including the termination of your employment with the
company for cause. If you’re a member of an Everise Board of Directors, a violation may
necessitate your resignation. Certain violations of the Code also contravene applicable
15
laws and therefore can have severe consequences outside of Everise. Depending on
your actions, failing to comply with the Code could lead to civil or criminal prosecution,
which could result in substantial fines, penalties and/or imprisonment.

Introduction
This Code of Business Conduct and Ethics (“the Code”) applies to all directors, officers,
employees and temporary workers1 (collectively, “you” or “employee”) of Everise, Inc.
and its affiliates and any other controlled affiliate of Everise (collectively, “we,” “us,”
“our,” “Everise” or the “company”)

Standards of Business Conduct

Everise seeks to foster and maintain a reputation for honesty, openness, trust, integrity
and professionalism. The confidence and trust placed in Everise by our clients and
investors is something we value greatly and endeavor to protect. In many respects, our
reputation is our most vital business asset. Accordingly, all our activities should be
conducted with honesty and integrity and in compliance with applicable legal and
regulatory requirements.

We have adopted the Code and related policies and procedures to preserve our
culture and to ensure compliance with legal and regulatory requirements applicable
to our activities. We expect and require that you meet the letter and spirit of the Code
(and related policies and procedures). This Code incorporates by reference the
following corporate policies and programs, which may be included in the Employee
Handbook relevant to your jurisdiction or provided to you separately, and should be
read in conjunction with the Code:

• Records Retention Policy

• Anti-Bribery and Corruption Policy

• Sanctions and Trade Controls Policy

• Data Protection Policy and Data Protection Program

• Confidentiality and Non-Disclosure Policy

• Enterprise Information Security Policy

1For purposes of the Code, “temporary workers” include non-full-time employees and consultants and contractors etc. that work on our
premises. The business group retaining a temporary worker is responsible for ensuring that the temporary worker certifies their
commitment to comply with the Code.
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 • Positive Work Environment Policy; Financial Authority Matrix

• Travel and Entertainment Expense Policy

• Whistleblower Policy

Protecting the Company’s Assets, Resources and Data

The company’s assets are to be used for legitimate business purposes only.
The company’s assets are for business, not personal use. The company’s assets span
many categories. Assets can be physical, tangible goods, such as office supplies,
furniture, computers or intangible items, such as intellectual property. You have a
responsibility to safeguard the company’s assets from loss, damage, theft, misuse and
waste. If you become aware of loss, damage, theft, misuse or waste of our assets, or
have questions about your proper use of them, you should speak with your supervisor.
The company’s name (including its corporate letterhead and logo), facilities and
relationships are valuable assets and must only be used for authorized company
business.

If you use the company’s assets for personal benefit or are otherwise wasteful with the
company’s assets, you may be in breach of your duty to the company. You have a
responsibility not to abuse company resources for reimbursement. Any requests for
reimbursement for authorized company expenses must be for legitimate business
expenses. If you are unsure whether a certain expense is legitimate, you should speak
with your supervisor or refer to the company’s Travel and Entertainment Expense Policy
in the Employee Handbook.

Confidential information must be protected at all times.

We must protect confidential information in our possession, both information about us
and information about other companies and our clients and investors. Confidential
information includes, but is not limited to, material non-public information, all
confidential memos, notes, lists, records and other documents in your possession, in
hard and soft copy. All of these are to be delivered to the company promptly after your
employment ceases or at any time upon the company’s request, and your obligation
to protect this information continues after you leave the company. You must protect
hard and soft copies of confidential information that are removed from the office ( e.g.,
to be worked with at home or at external meetings).

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It is important to use discretion when discussing company business. This includes
respecting information barrier protocols and discussing company business only with
those individuals at the company that have a “need to know” the information.
Additionally, be careful not to discuss company business in public places such as
elevators, restaurants, and public transportation or when using your phone or email
outside of the office. You should also be careful not to leave confidential information in
unattended conference rooms or in public places where others can access it. While
employed by Everise, if you become aware of confidential information about the
company or another entity that you know or suspect has been inadvertently disclosed,
seek guidance from a member of the Legal Department before using or acting upon
this information.

Personal data held by or on behalf of the company must be used in compliance with
data protection laws.
The company collects personal data regarding individuals both inside and outside the
organization where we have the lawful basis for doing so. This is necessary to effectively
and efficiently administer and manage the operation of our business. Personal data
includes, among other things, sensitive personal, medical and financial information. We
should take all reasonable steps to only hold personal data for as long as we have a
need to retain it.

Collection and use of personal data are subject to various legal and regulatory
requirements. You must take all reasonable steps to ensure that personal data is kept
confidential and accessed only by those individuals at the company that have a need
to know this information to carry out their duties. In addition, if it is necessary to the
conduct of business to disclose personal data to a third-party (e.g., so that a third-
party may provide services to the company or acquire an asset or business of the
company) then you must ensure that such transfer complies with applicable legal and
regulatory requirements. This may include ensuring the third-party is subject to a
written agreement which contains confidentiality obligations and, where relevant, other
obligations which must be included under the data protection laws of certain
jurisdictions in which we operate or have clients or investors. In all other cases, you
may only disclose personal data pursuant to a legal or regulatory requirement.

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In the ordinary course, the company transfers personal data between jurisdictions in
which the company operates, including the United States, Bermuda, Ireland,
Guatemala, Colombia, and the Asian Pacific Region (“APAC”). If you transfer personal
data outside these areas, then you must ensure that it is permissible for you to do so
(e.g., consent has been given by the individual or an appropriate data transfer
agreement has been signed). In addition, you should ensure that the personal data is
protected in a manner that is consistent with how personal data is protected by the
company within these jurisdictions, and in any event in compliance with all applicable
data protection laws.

You are responsible for ensuring that you understand and comply with our data
protection/privacy policies. For more information about compliance with data
protection laws, refer to the company’s Data Protection and Privacy Policy in the
Employee Handbook.

Intellectual property belongs to the company.

During the course of your employment, you may be involved in the creation,
development or invention of intellectual property such as concepts, methods,
processes, inventions, confidential information and trade secrets, know-how, physical
products, ideas, plans, programs, software, applications, code, works of authorship,
trademarks, service marks and designs, alone or jointly with others, including but not
limited to the improvement of existing intellectual property belonging to the company.
All such intellectual property and the rights therein shall be owned by the company
and your moral rights to such intellectual property, if any, will be waived. You are
responsible for cooperating with the company and providing all necessary assistance,
including the preparation and execution of any necessary documentation such as
assignments and applications to register rights before relevant government authorities
on behalf of the company, to ensure that all intellectual property and related rights
become or are recognized as the exclusive property of the company.

The documents of the company must be preserved.

It is critical that you help preserve our business records, follow the guidelines set forth
in any document retention policies and comply with related legal and regulatory
requirements. If you are notified that your documents are relevant to an anticipated or
pending litigation, investigation or audit, you must follow the guidance set forth in a

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litigation hold memorandum or any similar notice you receive from legal counsel
regarding retention of documents.

Accuracy of Books and Records and Public Disclosures

Ensure that the books and records of the company are complete and accurate and
that all business transactions are properly authorized.

The books and records of the company must reflect all its transactions in order to
permit the preparation of accurate financial statements. Employees must never
conceal information from (i) an external auditor; (ii) an internal auditor; or (iii) an audit
committee of the company. In addition, it is unlawful for any person to fraudulently
influence, coerce, manipulate or mislead an external auditor of the company.

The company’s contracts and agreements govern our business relationships. Because
the laws governing contracts and agreements are numerous and complicated, we
have put in place policies and procedures to ensure that any contract entered into by
the company has the appropriate level of approval. As a result, employees who enter
into contracts or agreements on behalf of the company must have proper
authorization to do so and, prior to their execution, these documents must be reviewed
by legal counsel. If you are unsure whether you have proper authorization to enter into
a contract on behalf of the company, consult the Chief Legal Officer.

Ensure that the company provides full, true and plain public disclosure.
All employees who are responsible for the preparation of the company’s public
disclosures, or who provide information as part of this process, must ensure that public
disclosures of information are made honestly and accurately. Employees must be
aware of and report any of the following: (a) fraud or deliberate errors in the
preparation, maintenance, evaluation, review or audit of any financial statement or
financial record; (b) deficiencies in, or noncompliance with, internal accounting
controls; (c) misrepresentations or false statements in any public disclosure document,
such as annual and quarterly reports, prospectuses, information/proxy circulars and
press releases; or (d) deviations from full, true and plain reporting of the company’s
financial condition.

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Additionally, each person who is in a financial reporting oversight role, and their Family
Members, are prohibited from obtaining any tax or other services from the external
auditor, irrespective of whether the company or such person pays for the services.

Duties to Stakeholders

Deal fairly with the company’s stakeholders.

You must deal fairly with the company’s customers, clients, suppliers, communities in
which we operate, other stakeholders and competitors. To preserve our reputation and
relationship, do not engage in any illegal or unethical conduct.

Communications and Media

Use the company’s various forms of communication properly and appropriately.

All business matters that involve electronic, written communication must be
conducted by employees on the company’s email system or through other systems
provided and approved by the company. You must always use our e-mail, Internet,
telephones and other forms of communication appropriately and professionally. While
we appreciate the need for limited use of these tools for personal purposes, any such
use should not be excessive or detract from your work. As outlined in the summary of
the Code’s principles, electronic communications relating to business activities may
not be conducted through electronic communications system that have not been
specifically approved for business activities, including (among others) personal email
accounts, personal text messaging, non-approved chat forums and social media.

Employees should not email business information to their personal email accounts or
maintain a copy of business information on their personal computers or other non-
work electronic devices. When using company-provided technologies, such as
computers, cell phones and voicemail, you should not expect that the information you
send or receive is private. Your activity may be monitored to ensure these resources
are used appropriately and are in compliance with the company’s policies and laws
and regulations. The Code does not prohibit an employee from engaging in such
communications that are intended to address employee concerns involving terms and
21
conditions of employment. Please refer to the Data Protection and Privacy Policy in the
Employee Handbook.

Be cautious in your use of social media.

The company’s social media policy is that, unless you are expressly authorized, you are
strictly prohibited from commenting, or posting about, or otherwise discussing the
company, its customers and clients, its (and its clients’) investors, its employees, and
its securities, investments and other business matters on all social media forums,
including, but not limited to, social networks, chat rooms, wikis, virtual worlds and blogs
(collectively, “social media”). You are a representative of Everise when engaging in
online activities and you must ensure that your behavior online, including on social
media, is appropriate and consistent with our values. For further details on the
appropriate use of social media, you should refer to the Employee Handbook.

Employees must not use internet-based platforms including, but not limited to, blogs,
social networking sites, chat rooms, wikis, virtual worlds, or personal Web sites
(collectively, “social media”) to disparage2 the company, its associates, customers,
clients, vendors, business practices, or other employees of the company. Unless you
are expressly authorized, you are strictly prohibited from commenting, or posting about,
or otherwise discussing information that reveals the identity of the company’s clients
who have engaged the company for services. We encourage you to use good
judgment when communicating on internet-based platforms. You are a representative
of the company when engaging in online activities and you must ensure that your
behavior online, including on social media, is appropriate and consistent with our
values. Disparaging communications, as well as statements revealing our clients’ use
of our services, even if made on your own time using your own resources, may be
grounds for discipline up to and including immediate termination. For further details on
the appropriate use of social media, you should refer to the Employee Handbook. This
policy does not prohibit an employee from engaging in such communications that are
intended to address employee concerns involving the terms and conditions of
employment.

2
For purposes of this Code, the term “disparage” means to make statements that are
egregiously offensive, purposely malicious, knowingly false, publicly disparaging the company’s
services without relating the complaint to any labor controversy, or otherwise reasonably
calculated to harm the company’s reputation and reduce its income.
22
Conflicts of Interest and Personal Behavior

Exhibit personal behavior that reinforces a positive image of you and the company.
Your personal behavior, both inside and outside work, should reinforce a positive image
of you, the company and its business activities. It is essential to use good judgment in
all your personal and business dealings. You should refrain from engaging in activities
or making disparaging statements that maliciously hurt the company’s reputation, or
yours, and that could undermine the relationship of trust between you and the
company or the company and its clients. Employees who have acted inappropriately
may be subject to disciplinary action up to and including termination for cause.

Remember your duties to Everise when participating in outside personal interests;

obtain permission before pursuing business activities outside the scope of your role
with the company
The company encourages directors and employees to be active participants in their
community. While pursuing personal, political, not-for-profit activities or other like
activities, be mindful that your participation in any outside interest must not prevent
you from adequately discharging your duties to Everise. In addition, ensure that when
you are involved in these activities you are not seen to be speaking or acting on behalf
of the company without express authority.

“Outside Business Activities,” otherwise known as “OBAs” include any business activities
outside the scope of one’s role with the company, including any activity as an
employee, independent contractor, sole proprietor, officer, director, or partner of
another business organization, regardless of whether compensation is involved.
Employees must receive approval from their supervisor prior to accepting an OBA. If
the direct business unit supervisor has doubts or concerns regarding the approval, you
should consult with a member of the Legal Department or email
[email protected]. Directors of the company must advise the Chief Legal Officer
prior to taking on any OBAs. Prior approval is not required to serve on boards of charities
or small, private family holding companies that have no relation to the company. For
greater clarity, approval is not needed to serve on the board of a family holding
company which is an extension of one’s personal business affairs; however, it is needed
to serve on the board of a private operating business with significant operations. When
in doubt whether you need to obtain permission, consult with a member of the Legal
Department.
23
Avoid situations in which your personal interests’ conflict with the interests of the
company, its clients or investors in Client accounts.
A “conflict of interest” for this purpose occurs when a person’s private interest inclines
the person, consciously or unconsciously, or appears to incline the person to act in a
manner which is not in the commercial interests of the company. You may have a
conflict of interest if you are involved in any activity that prevents you from performing
your duties to the company properly, or that may create a situation that could affect
your ability to act objectively, effectively and in the best interests of the company,
including due to among other things, personal interests or receipt of benefits from our
relationships with companies, business partners, counterparties, service providers, and
other constituencies. Accordingly, you must place the company’s interest in any
business matter ahead of any personal interest. Remember that the company’s
interest includes the company’s obligations to its clients.

You may also have a conflict of interest or the appearance of a conflict of interest as a
result of a “close personal relationship” with another employee at Everise or a
counterparty with which Everise is engaging (e.g., a company employee’s spouse works
at an entity that is being considered as a service provider). To ensure that these
relationships are managed appropriately, and to deal with any possible conflicts of
interest in an appropriate and responsible manner, you are expected to disclose the
existence of such relationships to your Human Resources (“HR”) department.

For the purposes of the Code, a close personal relationship includes, but is not limited
to, relationships with a parent or parent equivalent (e.g., adoptive parent), close relative,
spouse, fiancée, common law, or anyone else with whom you are in, or have been in, a
romantic or intimate relationship.

The best way to judge whether you may have a conflict of interest is to ask yourself
whether a well-informed person would reasonably conclude that your interest, activity
or close personal relationship could in any way influence your decision or performance
in carrying out a duty on behalf of the company. To avoid conflicts of interest, identify
potential conflicts when they arise; contact the Legal Department if you are unsure
whether a specific interest or activity gives rise to a conflict situation or contact HR to
disclose any close personal relationship that may give rise to a conflict. In addition, if

24
you become aware of any conflict or potential conflict of another director, officer, or
employee, you should consult HR, and the Legal Department, as appropriate.

Do not take corporate opportunities as your own personal opportunities.

You are prohibited from taking personal advantage of a business opportunity that you
become aware of through your work at Everise. You owe a duty to the company to
advance its commercial interests when the opportunity arises, and you must not
compete with the company in any way.

Positive Work Environment

Be committed to our respectful work environment free from discrimination,3 violence4

and harassment.5
We value diversity and we should all do our part to maintain our respectful work
environment where everyone feels safe, included and productive. The company does
not tolerate workplace discrimination, violence or harassment. All directors, officers and
employees must work to ensure that the company is a safe and respectful
environment where high value is placed on integrity, fairness and respect. For more
information on the company’s commitment to its positive work environment, refer to
the company’s Positive Work Environment Policy.

You have a duty to report discrimination, violence and harassment.

If you experience or become aware of what you believe to be discrimination, violence
or harassment, you are expected to report it in accordance with the “Reporting
Potential Code Violations” section of the Code and/or in accordance with the Positive
Work Environment Policy. Reports of discrimination, violence or harassment will be taken

3 “Discrimination” means the differential treatment of an individual or group based on prescribed characteristics protected by law.
Prescribed characteristics generally include age, color, race, religion, sex, gender, marital status, ancestry, sexual orientation, national
origin, disability. It does not matter whether the discrimination is intentional; it is the effect of the behavior that matters.
4“Violence” means an action (oral, written or physical) which causes, is intended to cause, could reasonably be interpreted as a threat
to cause, or is capable of causing death or bodily injury to oneself or others, or property damage.
5 For purposes of the Code, “harassment” means conduct which is known or ought reasonably to be known to be unwelcome and includes
conduct (e.g., comments and actions) which would be perceived by a reasonable person as being hostile, humiliating or abusive or cause
him/her torment. Harassment covers a wide range of conduct and includes sexual harassment, bullying and psychological harassment.
Harassment may occur in a variety of ways and may, in some circumstances, be unintentional, but regardless of intent, all harassment
negatively affects individual work performance and our workplace as a whole. This definition should not be interpreted so as to prohibit
U.S. employees from engaging in “protected concerted activity” under the federal law known as the National Labor Relations Act.

25
seriously and investigated. If you are found to be discriminating against, acting or
threatening to act violently towards, or harassing any individual at Everise, or if you
knowingly condone the discrimination of, violence towards, or harassment of another
individual, you will face corrective action up to and including termination without notice
and for cause.

We want to create a culture of reporting when it comes to discrimination, violence and

harassment, as reporting is essential for us as a company to stamp out these
behaviors. While we reserve the right to take corrective action if you knowingly make a
false accusation about an innocent party, you will not face retaliation for making a
good faith report or assisting in the investigation of a report.

Be committed to ensuring the health and safety of fellow directors, officers and
employees.
We all have the right to work in an environment that is safe and healthy. In this regard,
while at work you must:

a. comply strictly with all occupational, health and safety laws and internal
procedures;

b. not engage in nor condone illegal or dangerous behavior, including any acts
or threats of violence;

c. not possess, distribute or be under the influence of drugs while on company

premises or when conducting company business; and

d. not possess or use weapons or firearms or any type of combustible material

in the company’s facilities, or at company-sponsored functions.

If you or someone you know is in immediate danger of serious bodily harm, first call
local law enforcement authorities and then report the incident in accordance with the
“Reporting Potential Code Violations” section of the Code and/or in accordance with
the Positive Work Environment Policy in the Employee Handbook.

Human Rights and Modern Slavery

We are committed to conducting business in an ethical and responsible manner,
including by carrying out our activities in a manner that respects and supports the
protection of human rights through:

a. the elimination of discrimination in employment;

26
 b. the prohibition of child and forced labor; and

c. the eradication of harassment and physical or mental abuse in the workplace.

We strive to embed these standards into all our core business activities, including
training, communications, contracts and due diligence processes. These practices
extend to our interactions with our key suppliers and other business partners.

Environmental, Social and Governance (“ESG”) Management

Our ESG principles are embedded throughout our operations and are integral to
building resilient businesses and creating long-term value for our investors and other
stakeholders. These include:

1. Mitigate the impact of our operations on the environment.

a. Strive to minimize the environmental impact of our operations and

improve our efficient use of resources over time.
b. Support the goal of net zero greenhouse gas (GHG) emissions by
2050 or sooner.

2. Ensure the well-being and safety of employees.

a. Foster a positive work environment based on respect for human

rights, valuing diversity, and zero tolerance for workplace
discrimination, violence or harassment.
b. Operate with leading health and safety practices to support the
goal of zero serious safety incidents.

3. Uphold strong governance practices.

a. Operate to the highest ethical standards by conducting business

activities in accordance with our Code of Business Conduct and
Ethics.
b. Maintain strong stakeholder relationships through transparency
and active engagement.

4. Be good corporate citizens.

27
 a. Ensure the interests, safety and well-being of the communities in
which we operate are integrated into our business decisions.
b. Support philanthropy and volunteerism by our employees.

Compliance with Laws, Rules, Regulations and Policies

Know and comply with all laws, rules, regulations and policies applicable to your
position.
Our business is highly regulated, and the company is committed to compliance with
applicable laws, rules, regulations and policies. Each of us must recognize our personal
obligations as individuals, to understand and comply with the laws, rules, regulations
and policies that apply to us in the conduct of our duties.

Many of the company’s activities are governed by laws, rules, regulations and policies
that are subject to change. If you have questions about the applicability or
interpretation of certain laws, rules, regulations or policies relevant to your duties at
Everise, you should consult with a member of the Legal Department. In the event a local
law, custom or practice conflicts with the Code you must adhere to whichever is most
stringent. If you know of any of our practices that may be illegal, you have a duty to
report it. Ignorance of the law is not, in general, a defense to breaking the law. We expect
you to make every reasonable effort to become familiar with the laws, rules, regulations
and policies affecting your activities and to comply with them. If you have any doubts
as to the applicability or interpretation of any of the above, you should obtain advice
from the company’s Legal Department.

Do not give or receive bribes, including “facilitation payments.”

We value our reputation for conducting business with honesty and integrity. It is vital
for us to maintain this reputation as it generates confidence in our business by our
stakeholders, which ultimately means it is good for business. We do not pay bribes in
furtherance of our business, either directly or indirectly, and you are not permitted to
pay bribes on our behalf or authorize others to pay bribes on our behalf. This
commitment comes from the highest levels of management and you must meet this
standard. A bribe is anything of value that is offered, promised, given or received to
improperly influence a decision or to gain an improper or unfair advantage in
promoting, enhancing, obtaining or retaining business. Bribery may not always be in

28
the form of cash payments and may take many other forms, including gifts, travel,
hospitality, political contributions, charitable donations, lobbying payments,
sponsorships, employment opportunities, internships, and secondments. Facilitation
payments6 are also a form of bribe and are therefore not permitted. For further details,
refer to company’s Anti-Bribery and Corruption Policy.

Giving or receiving gifts/entertainment should be reasonable, and in certain cases

prohibited.
Gifts and entertainment given to or received from persons who have a business
relationship with the company are generally acceptable, if the gift or entertainment is
modest in value, appropriate to the business relationship, and does not create an
appearance of impropriety. No cash or cash equivalent payments should be given or
received, except in limited circumstances preapproved by the Legal Department.
Employees who do not comply with these requirements may be required to reimburse
the company for the value of any gifts or benefits they make or receive on behalf of the
company and may be subject to disciplinary action up to and including termination
for cause. For further details, refer to the company’s Anti-Bribery and Corruption Policy.

There may be restrictions on your political donations to candidates and political

parties.
In certain jurisdictions, political donations made on behalf of the company are
prohibited. Political donations made by individuals on their own behalf should comply
with local laws and regulations. In the U.S., various federal, state, and municipal laws
and regulations impose specific restrictions and rules with respect to political
contributions, both those made on behalf of the company or made by individuals on
their own behalf, which can carry significant penalties for the company for violations.
To ensure that we do not breach the law regarding political donations in any country,
all political donations, no matter how small, made on behalf of the company (directly
or indirectly) or by individuals and/or their family members must be approved in
advance by the applicable regional head or the Legal Department.

We must prevent the use of our operations for money laundering or any activity that
facilitates money laundering, the financing of terrorism, or other criminal activities.

6Facilitation payments are small payments made to secure or speed up routine actions or otherwise induce public officials or other third-
parties to perform routine functions they are otherwise obligated to perform, such as issuing permits, approving immigration documents
or releasing goods held in customs. This does not include legally required administrative fees or fees to fast-track services.
29
The company is strongly committed to preventing the use of its operations for money
laundering, the financing of terrorism, or other criminal activities, and will take
appropriate actions to comply with applicable anti-money laundering laws. Everise
has procedures for conducting anti-money laundering due diligence on investments
and divestments.

You should consider your rights and obligations when providing information to
governmental authorities.
During your employment at Everise you may be contacted by governmental authorities
(e.g., law enforcement, securities regulators, etc.) who are seeking confidential
information from you which you obtained through your association with Everise.

Whether you are able to respond to these questions or not, we strongly recommend
that, for your own protection, you do not speak with authorities without first seeking
legal advice on your obligations. In this situation, you may contact the Legal
Department to guide you on how to proceed.

Notwithstanding the foregoing, nothing in the Code prohibits or restricts you in any way
from providing information to a government authority pursuant to a subpoena or
applicable whistleblowing regulations. For further information, refer to the
Whistleblower Policy.

You have internal reporting obligations in the event you are convicted of a felony or
misdemeanor.
We are only as good as our people, and therefore our reputation as a leading global
alternative asset manager depends on the reputation of the individuals who serve the
company as a director, officer or employee. Our screening process at Everise is rigorous
and includes background checks so that we have the best information possible about
our prospective directors, officers and employees. Once at Everise, we expect you to
continue to adhere to these principles of openness, honesty and transparency. If at any
time while you are employed with the company you are convicted of a felony or
misdemeanor (or been subject to any similar conviction in any jurisdiction) or are
involved in any conduct that you think may be relevant to your reputation, you have an
obligation to report this information to the Legal Department or your supervisor so that
it may be appropriately documented internally.

30
Reporting Potential Code Violations

You are expected to make good faith reports.

Internal reporting is critical to the company’s success, and it is both expected and
valued. You are required to be proactive and promptly report any suspected violations
of the Code, or any illegal or unethical behavior or misconduct that you become aware
of or are involved with. When making a report, please include specific details and back-
up documentation where feasible in order to permit adequate investigation of the
concern or conduct reported. Vague, nonspecific or unsupported allegations are
inherently more difficult to pursue.

Employees are expected to report actual or potential misconduct or violations of the

Code to their supervisor in the first instance, since their supervisor is generally in the
best position to resolve the issue. Alternatively, you may contact the HR Department or
the Legal Department to report any actual or potential misconduct or Code violations,
or if you have any specific or general questions.

If you have questions about the Whistleblower Policy, contact the Legal Department.

In the event you do not want to report violations to your supervisor, HR, or the Legal
Department, you can always make a report through the company’s reporting hotline.
Our reporting hotline (the “Reporting Hotline”) is managed by an independent third-
party. The Reporting Hotline allows anyone to call anonymously (if they so choose) to
report suspected unethical, illegal or unsafe behavior in English and other languages.
The Reporting Hotline is available toll-free, 24 hours a day, 7 days a week. Refer to the
“Contact Information” section of the Code for the Reporting Hotline phone numbers by
jurisdiction. If you choose to make an anonymous report, your anonymity will be
protected to the fullest extent possible as permitted by law. If you have an HR-related
issue, the HR Department runs a ticketing platform that is suitable for addressing
interpersonal or other workplace issues that are not Code violations.

Reports will be kept confidential and will be dealt with appropriately.

The confidentiality of reported violations will be maintained to the fullest extent
possible, consistent with the need to conduct an adequate review and subject to
applicable law. You may wish to identify yourself to facilitate our investigation of any

31
report; however, you can make an anonymous report by calling the Reporting Hotline.
The party receiving the initial report must record its receipt, document how the situation
was dealt with and file a report, which will be retained for the record. The Chief Legal
Officer or the Chief People Officer, as appropriate, will report all illegal and unethical
conduct in violation of the Code to the appropriate Everise Board of Directors, or a
committee thereof as appropriate, and externally in accordance with applicable laws.

Everise prohibits retaliation against anyone who reports suspected violations of the
Code or any law or regulation.
No retribution or retaliation will be taken against any person who has filed a report
based on the reasonable good faith belief that a violation of the Code or any law or
regulation has occurred or may in the future occur; however, making a report does not
necessarily absolve you (if you are involved) or anyone else of the breach or suspected
breach of the Code. The company reserves the right to discipline you, up to and
including termination for cause, if you provide false information or make an accusation
you know to be untrue. This does not mean that the information that you provide has
to be correct, but it does mean that you must reasonably believe that the information
is truthful and demonstrates at least a possible violation of the Code. If you believe that
you have been unfairly or unlawfully retaliated against, you may file a report with your
supervisor, the HR team, or the Legal Department, or by calling the Reporting Hotline.

Disciplinary Action for Code Violations

Please note that we reserve the right to take disciplinary action for Code violations that
fits the nature and particular facts of the violation. This could include suspension or
immediate termination for cause and, if warranted, legal proceedings may be brought
against you.

Statement of Compliance
Upon starting at Everise, each director, officer, employee and temporary worker who is
subject to this Code will be provided with a copy of the Code and other policies
referenced herein and is required to be reviewed and signed. The acknowledgement is
maintained by the HR Department in your personnel file. On an annual basis, each
director, officer, employee and temporary worker who is subject to this Code will be
required to re-certify compliance with the Code via an acknowledgement of the
Employee Handbook.

32
Waivers
A waiver of the Code will be granted only in very exceptional circumstances. A Code
waiver for Everise employees, and must be approved by the Chief Legal Officer and the
Chief People Officer.

Amendments
The Board of Directors of Everise Holdings Pte. Ltd. reviews and approves each updated
edition of the Code and is ultimately responsible for monitoring compliance with the
Code.

33
 Legal Notice

The company reserves the right to modify, suspend or revoke the Code and any related
policies, procedures, and programs at any time. The company also reserves the right
to interpret and amend the Code and these policies in its sole discretion. Any
amendments to the Code will be disclosed and reported as required by applicable law.

Neither the Code, nor any of the policies referred to herein, confer any rights, privileges
or benefits on any employee, create an entitlement to continued employment with the
company, establish conditions of employment for the employee or create an express
or implied contract of any kind between employees and the company. In addition, the
Code does not modify the employment relationship between employees and the
company.

The Code is posted on Workday and included in each edition of the Employee
Handbook. The posted version of the Code may be more current and supersedes any
paper copies, should there be any discrepancy between paper copies and what is
posted.

August 1, 2022

Everise
600 North Pine Island Road, Suite 320 34
Plantation, FL 33324 weareeverise.com
 Anti-Bribery and Corruption Policy

I. Introduction

This Anti-Bribery and Corruption Policy (“Policy”) applies to all directors, officers and
employees (collectively, “you”) of Everise Holdings Pte. Ltd. and its wholly-owned
direct and indirect subsidiaries (collectively, “Everise,” “we,” “us,” “our” or the
“company”).

Everise Holdings Pte. Ltd. and its affiliates are committed to operating with the
highest ethical standards and this includes preventing bribery in our business
activities. This Policy sets forth key principles and standards, as well as key
supporting policies and procedures, with respect to addressing bribery risks in our
business, which should guide your conduct.

This Policy should be read in conjunction with the Code of Business Conduct and
Ethics (“the Code”), which serves as a guide for how you should conduct yourself as
a member of the Everise team.

II. Zero Tolerance Approach to Bribery

Do not give or receive bribes, including facilitation payments.

We have, over many years, built a reputation for conducting business with honesty
and integrity. It is vital for us to maintain this reputation as it generates confidence
in our business from our customers, clients, investors, investees, and others – which
ultimately means it is good for business.

We do not pay bribes in furtherance of our business and expect that you will not do
so on our behalf. We have a zero-tolerance approach towards bribery. This
commitment comes from the highest levels of management, and you must meet
this standard.

Everise
600 North Pine Island Road, Suite 320 35
Plantation, FL 33324 weareeverise.com
 A bribe is anything of value that is offered, promised, given or received to improperly
influence a decision or to gain an improper or unfair advantage in promoting,
enhancing, obtaining or retaining business. Bribery may not always be in the form
of cash payments and may take many other forms, including:

• Gifts, travel, entertainment and hospitality;

• Political contributions and charitable donations;

• Employment opportunities, directorships, internships or secondments;

• Procurement and service contracts;

• Phony jobs or “consulting” relationships;

• Excessive discounts or rebates; or

• Non-arm’s length loans, forgiveness of debt or other transactions.

Facilitation payments are also a form of bribe and are, therefore, not permitted.
Facilitation payments are small payments made to secure or speed up routine
actions or otherwise induce public officials or other third-parties to perform routine
functions they are otherwise obligated to perform, such as issuing permits,
approving immigration documents or releasing goods held in customs. This does
not include official, legally permitted statutory or administrative fees formally
imposed and codified by government agencies for expedited service.

III. Dealing with Public Officials

Interactions with public officials require enhanced scrutiny and sensitivity.

A public official is any person who is employed by or is acting in an official capacity
for a government, a department, agency or instrumentality of a government, or a
public international organization. This includes elected or appointed persons who
hold legislative, administrative or judicial positions, such as politicians, bureaucrats,
civil servants, and judges. It also includes candidates for political office, political
party officials and persons who perform public functions, such as professionals
working for public pension plans, public health agencies, water authorities, planning
officials and agents of public international organizations, such as the United Nations
or World Bank. A public official may also include employees of government-owned
or controlled businesses, including sovereign wealth funds and state-owned utility
companies. For example, if a government has an interest in a utility and exercises

Everise
600 North Pine Island Road, Suite 320 36
Plantation, FL 33324 weareeverise.com
 control over the activities of that utility, then the utility’s officials are likely to be
considered public officials. Third-parties acting at the direction of these individuals
and entities should also be considered public officials.

There is increased sensitivity and scrutiny of dealings with public officials because
this has traditionally been an area where bribery activity is more likely to occur. Be
cognizant of these risks in your dealings and interactions with public officials and
consider how your actions may be viewed. For example, payments, gifts or
employment to close relatives of public officials have been treated by enforcement
authorities as direct payments to the public officials and, therefore, may constitute
violations of law.

Hiring public officials or persons referred by public officials requires enhanced

scrutiny.
Hiring public officials or applicants related to, or referred by, public officials could be
seen as a bribe in certain situations and should be subject to enhanced review to
ensure that the related risks are appropriately mitigated. Consult your Human
Resources team for procedures related to identifying and mitigating these risks.

In practice, situations can be complex and this Policy does not cover every
circumstance that you may encounter. When in doubt, please contact the
company’s Legal and Regulatory Group for assistance.

IV. Third Parties

Third Parties are not permitted to pay bribes on our behalf.

The company may be scrutinized and/or prosecuted for failing to detect and
prevent bribery by a person associated with it. This includes any individual or entity
that performs services for or on behalf of the company. Employees should avoid
doing business with third-parties who do not have a zero tolerance approach to
bribery.

This means due diligence should be undertaken on contractors, joint venture

partners, agents and other third-parties to establish their anti-bribery credentials,

Everise
600 North Pine Island Road, Suite 320 37
Plantation, FL 33324 weareeverise.com
 where warranted by the assessed level of risk. This due diligence could include
meeting with them to better assess their business practices and anti-bribery and
corruption policies/controls, and making inquiries into their reputation and past
conduct. Other risk mitigation strategies, such as including anti-bribery language
in agreements, should also be implemented, as appropriate.

Please refer to the company’s Third-Party Due Diligence Procedures for further
details.

V. Gifts, Meals and Entertainment

The giving or receiving of gifts, meals and entertainment should be proportionate

and reasonable for the circumstances, for legitimate purposes only, and not with a
view to improperly inducing a third-party to misuse their position, as a quid pro quo
for official action or with linkage to an official decision.

Gifts (e.g. merchandise, event tickets) given to or received from persons who have
a business relationship with the company are generally acceptable, if the gift is
reasonable in value, infrequent, appropriate to the business relationship, and does
not create an appearance of impropriety. No cash payments should be given or
received.

Meals and entertainment (e.g. sporting events or the theatre, concerts, rounds of
golf) given to or received from persons who have a business relationship with the
company are generally acceptable, but again only if the meal or entertainment is
reasonable in value, appropriate to the business relationship, infrequent, does not
create an appearance of impropriety, is otherwise in accordance with applicable
laws and regulations, and if a representative from the sponsoring organization (the
party paying for the meal or entertainment) is present at the event. For the
avoidance of doubt, if a representative from the sponsoring organization is NOT
present at the event, the meal or entertainment would be considered a gift. Also,
be aware that many jurisdictions have laws restricting meals and entertainment
given to public officials or their close relatives that must be followed.

Everise
600 North Pine Island Road, Suite 320 38
Plantation, FL 33324 weareeverise.com
 Gifts, meals and entertainment that are repetitive, no matter how small, may be
perceived to be an attempt to create an obligation to the giver and should not be
provided. Gifts or entertainment given close in time to when a decision impacting
Brookfield’s business is being made (including by a private business partner) may
be perceived as a bribe in return for a favorable decision and should also not be
provided. Employees should not pay for gifts, meals and entertainment personally
to avoid having to report or seek approval.

Travel (e.g. for due diligence or site visit) and related items given or received should
follow the same principles as for gifts, meals and entertainment. When travel or
related items are given, payment should be made directly to the provider (as
opposed to providing a reimbursement to the individual), whenever possible. Under
no circumstances should cash or per diem reimbursements be provided.

To help ensure that our practices are reasonable, appropriate and otherwise in
accordance with applicable regulatory requirements, certain gifts, meals and
entertainment must be logged and/or pre-approved.

If you are in doubt as to whether proposed gifts, meals or entertainment to be given

or received are appropriate, please consult the company’s Legal Department for
assistance.

VI. Charitable Donations

Do not solicit or offer donations to clients, suppliers, vendors, public officials or

others in a manner which communicates that a donation is a prerequisite for future
business or that the offer of a donation is intended to obtain or retain business and
a business advantage.

We encourage our directors, officers and employees to contribute personal time

and resources to charities and not-for-profit organizations. However, unless
approved, you are prohibited from using the company’s name, resources or
business contacts for solicitation of donations. Charitable donations made by

Everise
600 North Pine Island Road, Suite 320 39
Plantation, FL 33324 weareeverise.com
 individuals on their own behalf should have no relationship to company business
and must comply with local laws and regulations.

Requests for donations may take many forms (e.g. direct requests or indirect
requests such as purchasing a table, a round of golf or otherwise contributing to an
event designated to raise money for a particular charitable cause/organization). All
requests for corporate donations to charities and other not-for-profit organizations
(e.g. schools, hospitals, libraries, etc.) must be approved in advance by the Chief
Financial Officer and the Chief Legal Officer. If you are requested by a public official
to make a donation to a particular charity, please obtain approval before agreeing
to or making the donation. Also consider conducting due diligence when the
proposed charity or not-for-profit organization is not well-known or there may be
question as the legitimacy of the organization as a charity or not-for-profit.

VII. Political Contributions and Lobbying

Do not offer or make contributions to political parties, officials and/or candidates

that might influence, or be perceived as influencing, a business decision.
In the U.S. and other jurisdictions, various federal, state, and municipal laws and
regulations impose specific restrictions and rules with respect to political
contributions, including both those made on behalf of the company or made by
individuals on their own behalf. Violation of these laws and regulations can carry
significant penalties for the company.

If you are in doubt as to whether a proposed political contribution is appropriate,

please consult the company’s Legal Department for assistance.

Do not engage in any lobbying activities on behalf of the company without specific
authorization.
Lobbying activities generally include attempts to influence the passage or defeat
of legislation and may trigger registration and reporting requirements. In many
jurisdictions, the definition of lobbying activity is extended to cover efforts to induce
rule-making by executive branch agencies or other official actions of agencies,
including the decision to enter into a contract or other arrangement.

Everise
600 North Pine Island Road, Suite 320 40
Plantation, FL 33324 weareeverise.com
 You may not engage in lobbying activities on behalf of the company without the
prior written approval of the company’s Legal Department.

VIII. Record-Keeping

Record all our transactions in a complete, accurate and detailed manner so that
the purpose and amount of the transaction is clear.
In addition to prohibiting bribery, anti-bribery legislation and other laws expressly
require accurate and complete recordkeeping and the establishment and
maintenance of an adequate system of internal controls. One purpose of these
provisions is to prevent companies from concealing bribes and to discourage
fraudulent accounting practices.

All transactions should be recorded completely, accurately and with sufficient detail
so that the purpose and amount of any such payment is clear. No undisclosed or
unrecorded funds or assets of the company should be established for any purpose.
False, misleading, or artificial entries should never be made in the books and records
of the company for any reason.

IX. Reports and Complaints

Internal reporting is critical to the company’s success, and it is both expected and
valued. You are required to be proactive and promptly report any suspected
violations of this Policy, or any illegal or unethical behavior of which you become
aware, including, but not limited to, any situations where a public official or other
party requests or appears to request an inappropriate benefit. The confidentiality
of reported violations will be maintained to the fullest extent possible, consistent
with the need to conduct an adequate review and subject to applicable law. No
retribution or retaliation will be taken against any person who has filed a report
based on the reasonable good faith belief that a violation of the Policy has occurred
or may in the future occur.

Employees may report actual or potential misconduct or violations of the Policy to

their supervisor in the first instance, since their supervisor is generally in the best

Everise
600 North Pine Island Road, Suite 320 41
Plantation, FL 33324 weareeverise.com
 position to resolve the issue. Alternatively, you may contact the Human Resources
Department or the Legal Department to report any actual or potential misconduct
or Policy violations, or if you have any specific or general questions. Members of the
subsidiary Boards of Directors should promptly report violations to the Chief Legal
Officer. In the event you do not want to report violations to your supervisor, the
Human Resources Department or the Legal Department, you can always make a
report through the company’s reporting hotline. See the Code for our reporting
hotline information, which is managed by a third-party and allows for anonymous
reporting of suspected violations by phone or email.

Disciplinary Action for Policy Violations

Please note that we reserve the right to take disciplinary action for Policy violations
that fits the nature and particular facts of the violation. This could, in the most
severe circumstances, include immediate termination for cause and, if warranted,
legal proceedings may be brought against you.

X. Key Contacts
If you have any questions on this Policy, please contact:

Dave Palmer, President, [email protected]

Sheena Ponnappan, Chief People Officer, [email protected]

Helen Franco, Chief Legal Officer, [email protected]

August 1, 2022

Everise
600 North Pine Island Road, Suite 320 42
Plantation, FL 33324 weareeverise.com
 Sustainability Policy

Purpose
To ensure the understanding of the fundamental principles for our commitment to the
well-being of employees, communities and the environment, and complying with
applicable laws.

Everise will do this by:

• Adherence to current environmental legislation where applicable

• Streamlining business processes, creating less waste and using less energy in
Everise facilities

• Create a better reputation with environmentally conscious customers

• Supporting and respecting the protection of human rights and ensuring the
Company is not complicit in human rights abuses.

• Work against corruption in all its forms, including extortion and bribery

Corporate Responsibility Statement

Everise activities and services will be legally and ethically conducted by treating
employees, environments, and cultures with respect. We will minimize negative
environmental impacts and ensure social responsibility efforts are done with
transparency and openness.

Transparency Pledge

Everise pledges to conduct its corporate responsibility and sustainability efforts with
transparency and openness. We expect our suppliers to conduct their business in the
same way.

Everise
600 North Pine Island Road, Suite 320 43
Plantation, FL 33324 weareeverise.com
 Roles and Responsibilities

Facilities

• Monitor workplace practices, procedures, and material use, and promote those
providing the greatest reduction of energy, water and materials; and reduce
employee exposure to toxic substances and harm to the environment.

• Lead and facilitate the development of sustainable operations.

• Review building maintenance contracts, remodeling and new building

construction proposals, and internal work plans. Revise as appropriate to ensure
Everise conserves resources and uses non-toxic materials.

• Assist with the development of sustainable operations.

Purchasing

• Write procurement specifications and contract language ensuring contractors,

vendors use resources in the most sustainable manner.

• Research products and practices to be used in the normal and the unique
business of Everise that can be used to further these sustainability goals.

• Monitor the use of sustainable purchasing/procurement procedures.

• Assist with the development of sustainable operations.

Everise Employees

• Reduce or eliminate unnecessary use of supplies and other resources.

• Turn off personal, non-essential computers when leaving work for the day.

• Turn off monitors when leaving work area for an extended period throughout the
workday.

• Comply with the policies outlined in this document.

Everise
600 North Pine Island Road, Suite 320 44
Plantation, FL 33324 weareeverise.com
 Outside Employment Policy

1. Objective

At Everise, we continue to evolve robust protocols for our employees to support our
valued customers, one of which is to prohibit our employees from engaging in outside
employment (moonlighting).

We recognize that for our champions (in the U.S., for non-exempt employees) there are
certain situations where outside employment would be acceptable. This policy
provides guidelines for our champions (in the U.S., non-exempt employees) to engage
in outside employment that does not conflict with the business interests of Everise.

All other employees (in the U.S., all exempt employees) must inform, and obtain the
prior written permission of, the Chief People Officer to engage, or continue to engage,
in outside employment. If permission is granted, the terms and conditions of this policy
shall apply to the outside employment.

For purposes of this policy, self-employment is considered outside employment.

2. Scope

This policy applies to all full-time and part-time employees of Everise who are not
parties to employment contracts that contain restrictions and/or requirements relating
to outside employment.

3. Policy Guidelines

• Permissible if No Conflict of Interest: Outside employment must not adversely affect

an employee’s ability to meet the Company’s work requirements or create a conflict
of interest. Under certain circumstances, if an employee’s outside employment or
personal conduct begins to adversely affect their performance on the job or begins
to make it impossible for them to carry out any or all of their job duties while at work,
appropriate disciplinary action up to and including termination of employment
may be appropriate.

• Clients, Customers and Competitors of the Employer: Employees may not work for
any client or customer of Everise outside of regular work hours as described above

Everise
600 North Pine Island Road, Suite 320 45
Plantation, FL 33324 weareeverise.com
 without the approval of the Chief People Officer or a designated representative.
Employees are prohibited from engaging in outside employment that directly or
indirectly competes with the business of the Company.

• No Liability: Everise will not assume any responsibility for an employee’s outside
employment. Specifically, the Company will not provide workers’ compensation
coverage or any other benefit for injuries occurring from or arising from such
outside employment. The Company will not pay medical benefits for injuries or
sickness to an employee resulting from employment by any employer other than
the Company.

• For U.S. Employees Only – NLRA Activity: Protected concerted activity covered by the
U.S. National Labor Relations Act (NLRA) or the particular collective bargaining
agreement is not prohibited by this policy.

4. Activities Adversely Affecting Employment

Following are examples of outside employment that might adversely affect an

employee’s ability to perform their job duties and are prohibited:

• Employment that directly or indirectly competes with the business of the Company;

• Employment that conflicts with the employee’s work schedule, duties, and
responsibilities or creates an actual conflict of interest (see the conflict of interest
policy in the Everise Code of Business Conduct and Ethics);

• Employment that impairs or has a detrimental effect on the employee’s work

performance with the Company; and

• Employment that requires employees to conduct work or related activities on

Company property, during Company working hours, or using Company facilities
and/or equipment.

5. Guidelines for Outside Employment

The following guidelines apply to all outside employment of Everise employees:

Everise
600 North Pine Island Road, Suite 320 46
Plantation, FL 33324 weareeverise.com
 • The employee cannot use the Company name nor allude to their position in any
way in connection with their outside employment unless specifically approved by
the Chief People Officer in writing.

• The employee shall not use any Company property, services, supplies, stationery,
phone, fax, email, or other Company resources to conduct work-related tasks on
behalf of the Outside employer during Company work time.

• Employees shall not disclose or otherwise use in their outside employment any
confidential business information received as a result of working for Everise unless
such information is generally known to the public or to those in the particular
industry in which the outside employment is undertaken. Such information is
proprietary and confidential to Everise. The employee must comply with the
Company’s Confidentiality Policy, Non-Solicitation, and Non-Disparagement policy
included in the Employee handbook.

Except as stated in paragraph 2 above regarding employment contracts, this policy

supersedes all prior policies, arrangements or understandings regarding its subject
matter, including without limitation any conflicting statements or requirements of
outside business activities set forth in the Code of Conduct.

Everise reserves the right to modify, withdraw, supplement or make exceptions to this
policy in its sole discretion at any time or from time to time.

Everise
600 North Pine Island Road, Suite 320 47
Plantation, FL 33324 weareeverise.com
 Sanctions and Trade Controls Policy

XI. Introduction

Scope
This Sanctions and Trade Controls Policy (the Policy) applies to all Employees
(collectively you) of Everise and its wholly-owned subsidiaries (collectively we, us,
our or the company).

We also expect Associated Persons engaged directly or indirectly by Everise to

comply with this Policy.

Purpose
Everise is committed to complying with all international Sanctions and Trade
Controls that apply to its business. This Policy applies to all Employees and
Associated Persons who must comply with in the conduct of their day-to-day
business.

XII. Definitions

“Associated Persons” means agents, advisers, brokers, consultants, contractors or

other third parties who perform services for or on behalf of Everise.

“Controlled Item” means an Item that is controlled for the purposes of applicable
laws, rules or regulations, (for example, the Item requires a licence or authorisation
from the applicable government(s) prior to export, re-export, transfer, or re-
transfer).

“Dual-Use Items” means any Items which can be used for both civil and military
purposes and including all Items which can be used for both non-explosive uses
and assisting in any way in the manufacture of nuclear weapons or other nuclear
explosive devices.

Everise
600 North Pine Island Road, Suite 320 48
Plantation, FL 33324 weareeverise.com
 “Employees” means Board members (executive and non-executive), all employees
(full time or part time), secondees, agency workers, and temporary workers7 and
any other individual who is engaged by or under the effective control of Everise.

“Item(s)” means any goods, part, product, component, software, technology, or

related technical data.

“Manager” means in relation to (a) Employees, the person to whom they directly
report; and (b) in relation to Associated Persons who are not Employees, the
Employee who manages their services and/or contract with Everise.

“Sanctioned Countries” means countries and/or territories that are subject to

country- and/or territory-wide Sanctions. As at the date of this Policy, this covers
the following countries and territories: Cuba, Crimea, Donetsk, Luhansk, Iran, North
Korea and Syria.

“Sanctioned Persons” means persons, entities or any other parties (a) located,
domiciled, resident, or organised in a Sanctioned Country; (b) targeted by any
Sanctions administrated by the United Nations, the European Union, the US, the UK,
and/or any other applicable country; and/or (c) owned or controlled by or affiliated
with persons, entities, or any other parties as referred to in (a) and (b).

“Sanctions” means any international economic, financial or trade sanctions laws,

regulations, orders or embargoes or measures having similar effect, in each case,
adopted, administered, enacted or enforced from time to time by countries and
countries’ bodies, agencies and institutions.

“Trade Controls” means any prohibitions or restrictions on the trade or movement

of goods, products or services from, to, from or through a particular country,
imposed by the government or relevant authority of a country. Restrictions may be
imposed over direct and indirect imports, exports, re-exports, transfers, and re-

7
For purposes of the Policy, “temporary workers” include non-full-time employees and consultants and contractors etc.
that work on our premises. The business group retaining a temporary worker is responsible for ensuring that the
temporary worker certifies their commitment to comply with the Policy.

Everise
600 North Pine Island Road, Suite 320 49
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 transfers in respect of (a) particular kinds of goods, products or services; (b) the
exporting or destination country or geographic territory; and/or (c) the identity of
the exporter or recipient.

XIII. Policy Statement

Everise is committed to compliance with applicable Sanctions and Trade Controls

and ensuring that our Employees and Associated Persons do likewise when carrying
on business anywhere in the world.

We recognise that a failure to comply with applicable Sanctions and Trade Controls,
or to prevent or manage this risk, would not only constitute a breach of legal and/or
regulatory requirements, but could carry significant reputational damage, legal and
regulatory action and financial loss for Everise.

This Policy sets out the company’s minimum standards and expectations to ensure
compliance with applicable Sanctions and Trade Controls as well as its approach
to identifying, mitigating and managing Sanctions and Trade Controls compliance
risks. Where local laws are more stringent than the standards contained herein,
such local law requirements should be applied in addition to the standards set out
in this Policy.

XIV. Roles and Responsibilities

You must:

• read, understand and comply with this Policy and any other documents aimed
at its implementation;

• demonstrate ethics, integrity and accountability at all times and expect the
same from others;

• ensure that you comply with all applicable Sanctions, including those of the
country or jurisdiction where you may be working, and laws of your country or
countries of citizenship;

• comply with the sanctions screening and due diligence requirements in sections
of this Policy;

Everise
600 North Pine Island Road, Suite 320 50
Plantation, FL 33324 weareeverise.com
 • understand the Trade Controls relevant to any Items that you deal with as part
of your role and comply with them;

• remain vigilant to ensure compliance with this Policy and applicable Sanctions
and report potential breaches;

• not act in a way which is intended to avoid or evade applicable Sanctions

obligations or conceal detection of a transaction which would otherwise breach
this Policy; and

• notify the Chief Legal Officer immediately if you become a target of any
Sanctions.

XV. Sanctions

We must ensure that we are aware if the people, companies, and countries that we
are doing business with are Sanctioned Persons or Sanctioned Countries. This is
because Sanctions can restrict the provision of money, goods, and services to
Sanctioned Persons and Sanctioned Countries.

There are many different types of Sanctions, including:

• targeted financial restrictions on people, companies, governments, and

countries, such as asset freezes or “blocking” sanctions;

• economic sanctions that restrict the financing or provision of financial services

in relation to certain goods, services, or financial products;

• trade-related restrictions that stop or limit the provision of certain goods and
services in relation to targeted people, companies, governments, and countries;

• travel bans on named individuals; and

• anti-boycott regimes.

Sanctions can target either specific individuals or entities, or may target industry
sectors or entire countries/territories. Sanctioned Persons can be anywhere in the
world.

To ensure compliance, Everise should undertake the sanctions screening and due
diligence process described below, in parallel to any additional third-party due
diligence checks (including the procedures outlined in the Third-Party Due Diligence

Everise
600 North Pine Island Road, Suite 320 51
Plantation, FL 33324 weareeverise.com
 Procedures). We also expect our Associated Persons to conduct similar levels of
checks and diligence when conducting business for or on behalf of Everise.

Sanctions Screening

Prior to engaging with any counterparties (e.g. customers, end-users, agents,

suppliers and any other Associated Persons), Employees must conduct Sanctions
screening on those counterparties.

Sanctions screening involves checking whether the potential counterparty has any
links to a Sanctioned Country and/or whether they are listed in any of the following
lists:

• the United Nations Security Council Consolidated List;8

• OFAC’s Specially Designated Nationals and Blocked Persons list and

Consolidated Sanctions List;9

• the EU’s Consolidated List of Persons, Groups and Entities Subject to EU Financial
Sanctions;10

• the UK’s Consolidated List of Financial Sanctions Targets; and 11

• equivalent lists of other relevant countries.

Sanctions screening should also be performed, where possible, on any other

persons who are known to be connected to the proposed transaction. This will need
to be judged on a case-by-case basis.

Sanctions screening should be conducted through a third party screening tool

available to Everise. Basic internet searches may also be carried out.

If any "hits" against any of these sanctions lists are identified, the matter must be
referred to the Chief Legal Officer who will confirm whether the proposed

8
https://www.un.org/securitycouncil/content/un-sc-consolidated-list
9
https://sanctionssearch.ofac.treas.gov/
10
https://ec.europa.eu/info/business-economy-euro/banking-and-finance/international-relations/restrictive-
measures-sanctions_en
11
https://www.gov.uk/government/publications/financial-sanctions-consolidated-list-of-
targets/consolidated-list-of-targets.

Everise
600 North Pine Island Road, Suite 320 52
Plantation, FL 33324 weareeverise.com
 transaction or activity can go ahead or whether further diligence is required (see
below).

Sanctions Due Diligence

Sanctions due diligence must be carried out if (i) the Chief Legal Officer determines
that a proposed transaction with a counterparty carries a Sanctions risk and/or (ii)
if a proposed counterparty is located in, resident in or incorporated under the laws
of, a Sanctioned Country and/or (iii) if there are any other material red flags from
the information available.

The precise scope of the further diligence to be carried out must be agreed with the
Chief Legal Officer on a case-by-case basis and in accordance with Everise
procedures.

If the further due diligence raises any Sanctions-related concerns, the Chief Legal
Officer must provide prior written approval before proceeding with the transaction.

The Chief Legal Officer will also advise on what further steps you should take to
ensure that the relationship does not give rise to any Sanctions risks to the
Company. This may include incorporating specific language in the relevant
contractual documents in order to provide adequate contractual protection
against Sanctions-related risks and on-going monitoring.

XVI. Trade Controls

Many countries impose Trade Controls on the export, import, transfer, re-export, and
re-transfer of military goods and Dual-Use Items. Broadly, Dual-Use Items are items
that are capable of a military or civilian use. The rules are complex and can capture
the transfer of technical data, as well as the movement of physical goods. Often

Everise
600 North Pine Island Road, Suite 320 53
Plantation, FL 33324 weareeverise.com
 the controls are related to the identity of the country of destination, the exporter, or
the recipient of the Items and can extend upon Dual-Use Items.

Each Everise company must ensure that it:

• understands the Trade Controls relevant to and classification of any Items

that it exports, imports, transfers, re-exports, and re-transfers;

• appropriately secures and maintains any Controlled Items in accordance

with applicable laws and regulations;

• implements any necessary travel protocols and data security measures

needed to protect Technical Data relating to Controlled Items;

• secures where required end-user certificates and includes an appropriate

statement on relevant sale, supply, and shipping documents preventing the
diversion of the Items; and

• complies with the terms of any Licenses.

Employees must ensure that they:

• understand the Trade Controls relevant to any Items that they deal with as
part of your role;

• undertake a geographic risk-assessment before the import, export, transfer,

re-export, or re transfer of any Items takes place and ensure that Items are
not delivered to prohibited end-users or for prohibited end-uses;

• obtain prior written approval from the [Legal Department] before they export,
transfer, re-export, or re-transfer of Controlled Items; and

• follow this Policy and any policies imposed by the Everise business they work
for.

XVII. Reporting and Investigating Issues

Reporting actual or suspected issues

Internal reporting is critical to the company’s success, and it is both expected and
valued. You are required to be proactive and promptly report any suspected
violations of this Policy. The confidentiality of reported violations will be maintained
to the fullest extent possible, consistent with the need to conduct an adequate
review and subject to applicable law. No retribution or retaliation will be taken
against any person who has filed a report based on the reasonable good faith belief
that a violation of the Policy has occurred or may in the future occur. This rule is

Everise
600 North Pine Island Road, Suite 320 54
Plantation, FL 33324 weareeverise.com
 applicable even if it is later discovered that they had been mistaken about the
concern raised

Employees may report actual or potential misconduct or violations of the Policy to

their supervisor in the first instance, since their supervisor is generally in the best
position to resolve the issue. The supervisor must judge whether the issue or
allegations are material. If so, they must immediately report the issue to the Chief
Legal Officer.

Alternatively, you may contact the company’s Chief Legal Officer to report any
actual or potential misconduct or Policy violations, or if you have any specific or
general questions. In the event you do not want to report violations to your
supervisor or the Chief Legal Officer, you can always make a report through the
company’s reporting hotline. See the Code of Business Conduct and Ethics for
contact information for our reporting hotline, which is managed by a third-party
and allows for anonymous reporting of suspected violations.

Investigating actual or potential incidents

Any reports of known or suspected violations of this Policy or applicable Sanctions
and Trade Controls must be promptly and appropriately investigated by the Chief
Legal Officer. Precisely how the investigation must proceed should be considered
on a case-by-case basis.

XVIII. Communications with Governments and Regulators

You must obtain approval from the Chief Legal Officer prior to entering into any
communications with a government or regulator regarding Sanctions. Such
communications could involve potential or actual breaches of law, disclosures,
audits, information requests, or the start of an investigation.

XIX. Breaches of this Policy

Everise takes its responsibilities with regard to Sanctions issues very seriously. Proven
violations of this Policy may lead to severe disciplinary action, which could involve:

• a formal reprimand;

• suspension;

Everise
600 North Pine Island Road, Suite 320 55
Plantation, FL 33324 weareeverise.com
 • restitution; and/or

• termination of employment and/or Associated Persons and other contracts.

These penalties may be imposed over and above any separate penalties that may
arise from action taken by regulatory or prosecution authorities. Employees may
also be subject to disciplinary action for failing to assist with the implementation of
this Policy.

XX. Policy Review

The Chief Legal Officer is responsible for the overall implementation, maintenance
and upkeep of this Policy. This Policy will be reviewed regularly to confirm that it
remains fit for its purpose and to ensure that it is being appropriately implemented.

XXI. Key Contacts

If you have any questions on this Policy, please contact:

Helen Franco – Chief Legal Officer, [email protected].

August 1, 2022

Everise
600 North Pine Island Road, Suite 320 56
Plantation, FL 33324 weareeverise.com
 Conflict of Interest Policy
1. Objective
This policy defines the parameters of conflict of interest for all the employees of Everise.
Our employees shall always act in the interest of our Company and ensure that any
business or personal association does not create a conflict of interest with their roles &
duties in our organization and will maintain the highest standard of ethics. This policy
defines and addresses potential, apparent, and actual conflict of interest. It provides
guidance to employees so that conflicts of interest are recognized to enable the
concerned employee to take the necessary action to resolve or avoid the conflict
expeditiously.

We have a zero-tolerance approach to conflict of interest and are committed to acting

professionally, fairly, and with integrity in all our business dealings and relationships. We
uphold all the laws relevant to countering conflict of interest in all the jurisdictions we
operate. While the legislative requirements may be the foundation for our policy, our
policy is far more practical in its application. It takes basic business ethics as its overall
primary standards and objective. Everise views this policy as a statement that binds
the ethics of the Company.

2. Scope
All employees and business associates of Everise, which includes outsourced personnel
working on the Company premises, consultants, suppliers, and vendors associated
either directly or indirectly with the Company.

3. Policy Guidelines
• Conflict of interest may arise where an employee places his or her personal
interests before the interests of the Company and where such personal interests
unduly influence that employee’s business judgments, decisions, or actions. The
employee must not permit ‘relationships with others’ or ‘external business
activities’ to conflict or appear to conflict with the interests of the Company.

• The Company respects the rights of all employees to engage in activities outside
the normal scope of employment, provided such activities do not conflict with or
reflect adversely on Company’s interest or deprive the Company of the
appropriate measure of time and effort.

• The Company requires all employees to avoid situations involving conflicts

including, but not limited to, financial dealings that are contrary to the Company’s
best interests, membership equity or employment relationships that may be in

Everise
600 North Pine Island Road, Suite 320 57
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 conflict, acceptance of favors, money, or other considerations which might
obligate the recipient to take action adverse to Company’s interest.

• The Company will circulate this policy on conflicts periodically and allow
employees to disclose actual or potential conflicts.

• This policy is in addition to and should be read in conjunction with the Company’s
Code of Business Conduct and Ethics and its Anti-Bribery and Corruption Policy.

• The Company will provide suitable mechanisms for resolving conflicts of interest
so that the Company's best interests will be protected while observing its
standards of ethics.
• Employees are required to report any suspected conflicts of interest upon hire, annually,
and upon any new conflict or change in status of a previously reported conflict.

• This policy will be reviewed annually to ensure alignment with relevant legislation.

4. Definitions
Conflict Of Interest: A ‘conflict of Interest’ means a potential, apparent or actual
conflict where an employee’s financial or other personal interest, whether direct or
indirect, conflicts or appears to conflict with the employee’s responsibility to the
Company or with the employee’s participation in any recommendation or decision
with the Company.

External Activity: It means any activity of an employee outside the scope of his/her
employment with the Company undertaken as part of a commercial or volunteer
enterprise.

Relationships: Relationship means any relationship of the employee to a person of

his or her immediate family whether related by blood, adoption, marriage and any
relationship of an intimate and/or financial nature during the preceding one year,
any supervisor-subordinate relationship which is intimate or between any two
members which gives rise to a conflict of interest, or any other past or present
relationship that may give rise to a reasonable apprehension of bias.

Supervisors: Supervisors means the person to whom an employee reports, whether

directly or indirectly or in the case of a committee, the committee chair.

Superior/Subordinate Relationship: Supervisor – subordinate relationship means a

relationship in which one employee reports directly and/ or indirectly to the other
employee.

Specific Conflict: A specific conflict of interest situation occurs when any undue
influence is exercised to alter the materiality of an outcome to the benefit of one or
all the parties involved in the situation.

Everise
600 North Pine Island Road, Suite 320 58
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 Potential Conflict: A potential conflict of interest occurs when there is a divergence
between an individual’s private interests and his or her professional obligation to
the Company such that an independent observer might reasonably question
whether the individual’s professional actions or decisions are determined by
considerations of personal interest, gain, financial or otherwise.

Actual Conflict: An actual conflict of interest depends on the situation and not on
the character or actions of the individual. Further, actual conflict involves a direct
conflict between current duties and responsibilities and existing private interests.

Perceived Conflict: A perceived conflict of interest has the appearance of affecting

an individual’s professional judgment in exercising any Company’s duty or
responsibility.

Third Party: Any product supplier (insurer), any other financial services provider, any
distribution channel (a company that assists with the sale of insurance products to
the greater financial industry), and any other person or Company that has a
relationship with companies within the financial industry (other than suppliers and
service providers defined below).

Supplier: Suppliers of services or goods to the Company outside the insurance

business, e.g., stationery, IT, accounting.

Financial Interest: This means any cash, cash equivalent vouchers, gifts, service,
advantage, benefit, discount, domestic or foreign travel, hospitality,
accommodation, sponsorship, other incentives or valuable consideration, other
than an ownership interest and training that is not exclusively available to a
selected group of providers or representatives on:

• Product and legal matters related to those products

• General financial and industry information

• Specialized technological systems of a third party necessary for the rendering

of a financial service; but excluding travel and accommodation associated with
that training

Immaterial Financial Interest: This means any financial interest with a determinable
monetary value, the aggregate of which does not exceed USD 10,000.00 in any
calendar year from the same third party in that calendar year received by

• A provider who is a sole proprietor; or

• A representative for that representative’s direct benefit

Everise
600 North Pine Island Road, Suite 320 59
Plantation, FL 33324 weareeverise.com
 • A provider, who for its benefit or that of some or all of its representatives,
aggregates the immaterial financial interest paid to its representatives

5. Specific Situations of Conflict of Interest

This section sets out examples of the instances of the situation that shall be
considered to create a conflict of interest, whether specific, actual, potential or
perceived:

• Engages in a business, activity, or relationship with anyone who is a party to

a transaction with the Company

• Is in a position to derive an improper benefit, personally or for any family

members or any person in a close personal relationship by influencing
decisions relating to any transaction

• Utilizing Company time and/ or resources to promote personal interests or

the interest of any person with whom the employee has a relationship

• Serving as an employee or consultant to another similar business

organization without the Company’s consent. The management must grant
permission to provide services to other similar businesses

• “Dating,” attempt to “date” and engaging in close emotional or physical

relationships with a supervisor or other forms of romantic, intimate or
physical or sexual contact with the supervisor

• Participating in or influencing the outcome of the appointment, hiring,

promotion, supervision, or evaluation of a person with whom the employee
has or has had a relationship

• Directing an employee to carry out tasks of personal nature or for a

company or firm in which the employee or a member of his/her immediate
family has a financial interest

• Having a source of income/ borrowing money from a vendor or supplier with

whom the Company conduct business or with one of the Company’s
competitors

• Conducting Company business with someone with whom the employee

has a Relationship (as defined above) or with a business in which the
employee or any person with whom the employee has a Relationship has a
significant interest

• Accepting gifts, other personal obligations, or being entertained are

substantial for him/herself or a family member from a client or suppliers,

Everise
600 North Pine Island Road, Suite 320 60
Plantation, FL 33324 weareeverise.com
 whether local or foreign. Any gift so received, either in cash, bonds, stocks, or
similar item or in kind, should be shared among employees

• Misusing information to which the employee has access due to his or her
position, such as disclosing confidential information to competitors or others
outside the Company or using such information for personal use or gain

• Offering personal/unauthorized facilities/ services to customers rather than

using the facilities/services provided by the Company or its clients

• Speculating or dealing in equipment supplies, properties or materials or

property purchased by the Company or dealing for his/her account in
products sold by the Company

The above guidelines are not intended to be exhaustive; other relationships or

interests that might conflict with the Company's best interests should also be
disclosed. In determining whether a Conflict of Interest, whether specific, actual,
potential, or perceived, exists, the situation could subject the Company to criticism,
embarrassment, or legal action. The employee’s activities that could be seen as
adverse to the Company should be considered.

6. Obligations of the Employees

• Employees of the Company are obligated to avoid situations of conflict of
interest, whether specific, actual, perceived, or potential as defined in the
policy

• Each employee is required to report to Human Resources any suspected

conflicts upon hire, annually, and upon the occurrence a new conflict or a
change in status of a previously reported conflict

• Employees are responsible not to create circumstances that create an

actual weakness or appearance of weakness in the Company’s system of
internal controls

• Any external activities of an employee which has the effect of creating a

Conflict of Interest, whether actual, specific, perceived, or potential, is strictly
prohibited

• The company employee shall not sign any contract or agreement on behalf
of the Company during the period between the commencement of
investigation and completion of investigation proceeding (“Investigation
Period”) by the HR Department under this policy. Any contact and or/
agreement executed by the employee during the Investigation Period shall
not be binding on the Company

Everise
600 North Pine Island Road, Suite 320 61
Plantation, FL 33324 weareeverise.com
 • Employees shall not directly or indirectly, during the term of their employment
with the Company, engage in any business similar or substantially similar to
that of the Company and/or any business which is directly and/or indirectly
competitive with the business of the Company as an owner, partner, agent,
representative or as an employee of any person, firm, corporation or other
entity

7. Company Action
Within fifteen (15) working days after receiving the report regarding the Relationships
that have the effect of creating a Conflict of Interest, whether actual, specific, potential
or perceived, HR shall develop a plan to manage or eliminate Conflict of Interest and
mitigate adverse effects on the involved parties and other third parties. This plan shall
document in writing the actions that shall be taken, including one or more of the
following actions:

• Transferring supervisory, decision – making and /or evaluative

responsibilities

• Providing an additional layer of oversight to the supervisory role

• Transferring one of the individuals to another position, department,

geography, or entity

• Taking any other action reasonably necessary to manage or eliminate the

actual or potential conflict of interest and/or mitigate adverse effects

• If acceptable alternative arrangements are not feasible, the Company will

have a choice to ask the employee to exit the Company without claiming any
compensation/settlement or discontinue the employment with the
Company. For the avoidance of doubt, the termination of employment for
the foregoing reasons shall be in accordance with the Exit Management
policy of the Company and applicable law, including without limitation local
employment law, and shall not be constructed to be unjust and/ or unfair for
any reasons whatsoever. Consequentially, the Company shall not be liable
for payment of any compensation/ settlement, pecuniary or otherwise, other
than the past due salaries which shall be settled in accordance with the
procedure set out in the Exit Management policy of the Company and
applicable law

8. Confidentiality of Disclosure
The Company will seek to ensure that confidential disclosures made by the
employees, whether in the Disclosure Statement (see below) or otherwise, are

Everise
600 North Pine Island Road, Suite 320 62
Plantation, FL 33324 weareeverise.com
 kept strictly confidential and are protected from misuse. To avoid doubt, it is
hereby clarified that Conflict of Interest disclosures will be treated as
confidentially as possible, within the requirements of the law.

9. Policy Violation and Treatment

If an employee’s Relationship:

• Has the effect of creating a Conflict of Interest, whether actual, specific,

potential or perceived

• Interferes with the work of any employee

• Creates a harassing, demeaning, or hostile working environment for any

employee

• Disrupts the smooth and orderly flow of work within the office, or the delivery
of services to the Company’s clients or customers

• Harms the goodwill and reputation of the Company among its customers or
in the community at large

• Tends to place in doubt the reliability, trustworthiness, or sound judgment of

the person involved in the relationship

The employee responsible for such a problem will be subject to disciplinary

action according to the Company’s Corrective Action Plan and Disciplinary
Policy, up to and including termination of employment. In the event of
termination, for the avoidance of doubt, the termination shall be in accordance
with the Exit Management policy of the Company and applicable law. It shall not
be construed to be unjust and/or unfair for any reason whatsoever.
Consequentially, the Company shall not be liable to any
compensation/settlement pecuniary or otherwise other than the past due
salaries or wages, which shall be settled in accordance with the procedure set
out in the Exit Management policy and applicable law.

Everise
600 North Pine Island Road, Suite 320 63
Plantation, FL 33324 weareeverise.com
 At-Work Policy

1. Dress Code
• Elevate your Style—As a company that celebrates all forms of diversity, we
believe that for you to perform at your best, you need to be yourself. That’s why
we’ve removed traditional dress codes to encourage you to come to work with
a splash of color and reinvent yourself through what you wear.

• When dressing up, always remember to be respectful and humble. For questions
or clarification, please consult the Human Resources Department.

• The Company reserves the right at its sole discretion to address any dress code
violations that may be offensive or distracting to customers, visitors, or other
employees. Employees who do not comply with the dress code may be asked
to return home (without pay) and change into appropriate attire, this includes
any attire that may be considered a safety hazard in an Everise facility. For
example, flip flops can easily cause tripping, especially in an emergency
situation.

• Continued violations may result in disciplinary action up to and including

termination of employment.

2. Allergens in the Workplace

• Recognizing employees and visitors to our offices may have sensitivity or allergic
reactions to various fragrant products, we urge all employees to use such
products sparingly. Examples of fragrant products include, but are not limited
to, fragrances, colognes, lotions, powders, perfumes, hairsprays, body sprays,
cleaning products, and potpourri.

• Any employee with a concern about scents or odors should contact their
supervisor or local the HR Department.

3. Smoking & Tobacco

Everise strives to maintain a healthy workplace environment with high indoor air quality
for all employees. Recognizing that some employees smoke regularly, this policy was
developed to ensure that employees who smoke know when and where they are
permitted to smoke, and to address concerns of non-smoking employees. Employees

Everise
600 North Pine Island Road, Suite 320 64
Plantation, FL 33324 weareeverise.com
 who choose to use tobacco products in compliance with this policy must ensure that
their use of these products does not interfere with their work or professional
appearance.

• Everise maintains a smoke-free and tobacco-free workplace. No smoking or

use of any other tobacco product (including, but not limited to cigarettes,
pipes, vaping, cigars, snuff or chewing tobacco) is permitted in any part of
the building. This includes, but is not limited to, common work areas,
conference and meeting rooms, cafeterias, stairs, restrooms, and private
offices. Smoking or use of other tobacco products is also prohibited directly
in front of the main entrances to the building, or in any vehicles owned,
rented, or leased by the Everise. All buildings are designated tobacco-free.
Any employee wishing to use tobacco must do so in designated smoking
areas. Tobacco products must be extinguished and disposed of in proper
receptacles prior to entering the building. Use of tobacco is not permitted in
or near the front entrance of any Everise facility.

• Everise strives to promote a professional environment in which our

Champions and our customers can interact. In keeping with this effort,
effective immediately, no employees are permitted to smoke, chew tobacco,
or vape while on camera with a customer or another Everise employee.

• Employees may not use tobacco products in car rentals for company
business.

Non-Compliance

Violations of this policy may lead to disciplinary action, up to and including termination.

Please Note: Use of tobacco products is prohibited during any building evacuation
including, but not limited to, fire drills or bomb threats.

4. Use of Company Property and Equipment

4.1 Computer / Email / Internet/ Work At Home Telework/Telephone Use

• All Company computers, email, computer systems, and electronic media

equipment (including computer accounts, laptop computers, cellular phones,
printers, networks, mail servers, fax servers, web servers, workstations, standalone
computers, software, data files, and all internal and external computer and

Everise
600 North Pine Island Road, Suite 320 65
Plantation, FL 33324 weareeverise.com
 communications networks that may be accessed directly or indirectly from our
computer network software, electronic mail, and Internet connections), voice
mail facilities, and Internet access accounts are Company property to be used
solely to facilitate the business of the Company. All information that is
temporarily or permanently stored, transmitted, or received with the aid of
Company computers, email (including personal password-protected web-
based email), and Internet remain the sole and exclusive property of the
Company. As such, employees should have no expectation of privacy in
connection with their access and use of such equipment and systems. The
computer resources are the property of the Company and may be used only for
legitimate Company business purposes. Users are permitted access to the
computer resources to assist them in performance of their jobs.

• Computers are available in designated areas for the personal use of employees
when on break or at lunch.

• Employees should not use or access Company computers, voice mail, email and
Internet systems in any manner that is unlawful, inappropriate, wasteful of the
Company resources, or contrary to the Company’s best interests. These
electronic tools are provided to assist employees to execute their job duties and
should not be abused.

• Employees may be provided with access to the Internet to assist them in

performing their jobs. Use of the Internet must be tempered with common sense
and good judgment. The Company has the right, but not the duty, to monitor
any aspects of its computer system. The Company may use software to identify
and record all Internet activities. Any individual found visiting inappropriate or
sexually explicit Internet sites will be subject to disciplinary action up to and
including termination regardless of their position in the Company. In the event
you encounter inappropriate or sexually explicit material while on the Internet,
immediately disconnect from the site and send an email notification to your
supervisor informing them of the issue. Failure to follow this policy may result in
disciplinary action up to and including termination.

• A teleworker must adequately protect their work site to prevent theft of

equipment or information, the unauthorized disclosure of information or
unauthorized access to Company or client systems.

• The teleworker’s environment must be free from background noise and

distractions, including, but not limited to, music, television, pets, and children.

• A teleworker must have a dedicated work area; no other person is permitted in

their workspace during shift.

Everise
600 North Pine Island Road, Suite 320 66
Plantation, FL 33324 weareeverise.com
 • Upon termination of teleworking activities, an employee is required to return
Company and client equipment within seven (7 days) after their final day of
employment. Failure to return all equipment may result in legal action. Payroll
will refund any applicable deposit to employees who resign or terminate from
Everise upon receipt of equipment, deemed in good working condition. Please
note that the “deposit” you paid is not a purchase of the equipment.

• To ensure the quality of its services, the Company may open and view or listen
to employee telephone calls on the production floor or at the teleworking site as
it sees fit. By continuing to work for the Company, employees consent and agree
to a review of their telephone calls by management. Employees should expect
that these systems are used in an efficient, ethical, and lawful manner.

4.2 Internet

• Internet usage should not interfere with business operations. The downloading
of streaming audio/video clips is strictly prohibited unless directly related to job-
related activities.

• Computer programs that are not business-related should not be downloaded

on a Company computer. Downloading music and trading programs may
violate copyright laws and is against Company policy.

4.3 Access

• the Company management may need to access, review, audit and/or disclose
the contents of business or personal communications at any time with or
without notice or permission of its employees including emails, voicemails, and
other communications. Therefore, employees should not expect that any
message sent or delivered by mean of these resources will be private. The use
of passwords for security does not grant or guarantee confidentiality. Even when
a message is erased, it can be retrieved and read.

• While management reserves the right to access these communications,

employees are expected to respect the privacy of coworker communication.
Employees should only access information and/or communications for which
they have management authorization.

Everise
600 North Pine Island Road, Suite 320 67
Plantation, FL 33324 weareeverise.com
 19.4 Email

• The Company provides email as a resource to facilitate efficient business

communication and support the Company in achieving its mission and goals.
Email is a powerful tool that adds productivity but has the potential for wide,
incorrect, and inappropriate distribution. Emails may be seen by people other
than the intended recipient, published on the Internet or presented in a court of
law.

• Emails sent, received, and retained by employees must be handled in a

responsible manner. The confidentiality and/or privacy of any message sent or
delivered by email must not be assumed.

• Emails are Company property and management has the right to access, review,
audit and/or disclose the contents of business or personal communication at
any time without notice and without an employee's permission.

• Internal email correspondence should not be forwarded outside of the

Company without a valid reason and the consent of the originator. Discretion
should be used when forwarding a string of emails.

• Do not set email to auto-forward out to external domains or personal email

accounts, as well as the email account provided by a client.

• The use of "Reply to All" should only be used when the content is relevant to all
recipients, not just a few select individuals.

• Email inquiries should be responded to within 24 hours on business days. Email

communication should be professional and appropriate at all times.

19.5 Inappropriate Usage

• Electronic resources are not to be used in any manner that is unlawful,

inappropriate, or wasteful of resources or contrary to the Company’s best
interests. In addition, these resources may not be used to create any disruptive
messages, including but not limited to, messages that contain sexual
implications, racial slurs or any other comments that create a hostile
environment. These resources are provided to assist employees with the
execution of their work responsibilities and should not be abused.

• To ensure the quality of services provided by employees, the Company may

open and view, or listen to, employee telephone calls as it sees fit except for
customer relay calls. Employees consent and agree to review of their telephone
calls by management.

Everise
600 North Pine Island Road, Suite 320 68
Plantation, FL 33324 weareeverise.com
 • It is the responsibility of employees to see that systems are used in an efficient,
ethical, and lawful manner. A violation of this policy may result in disciplinary
action, up to and including termination.

5. Use of Cell Phones, Personal Recording Devices, and Other Equipment

• Please be aware that the Company is required by its clients to record employee
telephone calls with Company devices.

• In the event you need to be contacted in an emergency, your family member or

loved one should contact workforce management at the number provided by
your supervisor or the Human Resources Department.

• Please review Everise’s Cell Phone Policy and Electronic Monitoring Policy in this
handbook.

6. Phone Calls and Visitors

• The Company telephones may only be used with the authorization of a

supervisor. Public phones are provided in some facilities for personal calls
during scheduled breaks and lunch. Phone calls should be limited to five (5)
minutes if a co-worker is waiting to use the same phone.

• Unauthorized or excessive use of telephones for personal business is considered

grounds for disciplinary action up to and including termination. The incoming
“800” lines are to be used only for business purposes. Any misuse of these lines
will result in disciplinary action up to and including termination.

• Due to the confidential nature of the Company’s business, visitor access is

controlled and authorized by site management. All visitors to Company facilities
must sign in and sign a confidentiality agreement. Visitor badges are issued
upon sign-in and must be worn at all times. An employee must accompany
visitors to all facilities from the time they enter the building until they leave. Each
employee is responsible for the conduct of their visitor(s) while on the premises.

7. Unscheduled Closings

Employees are expected to report to work for all scheduled times. In the event of an
unscheduled facility closing, non-exempt employees will be paid in the following
manner:

Everise
600 North Pine Island Road, Suite 320 69
Plantation, FL 33324 weareeverise.com
 • Employees who have worked a partial shift and are sent home by site
management will be paid for the hours they have worked. Pay will be for a
minimum of four (4) hours.

• Employees who have worked a partial shift and choose to leave work are paid
solely for hours worked with no minimum.

• Employees who do not report for their shift are not paid (even if they may have
PTO allocation available).

Should there be a need to close any of our facilities, the Company maintains toll-free
information lines for each of our locations that employees may call for an update. The
toll-free phone numbers and messages are also posted in Workday. The messages
are updated frequently during severe conditions due to weather, earthquake, or other
unscheduled events. Employees may log into Workday to access this information.

8. Meal and Rest Breaks

• Office hours may vary from department to department and across locations to
service the continuous needs of our clients. Supervisors have the responsibility
of establishing meal and break schedules that meet the staffing concerns of
their department. Rest breaks are included as paid time and cannot be utilized
to shorten a shift. All breaks should be taken on-site with the exception of meal
breaks.

• Hourly employees are required to log out for meal breaks and log in when
returning from meal breaks. However, the system should not be shut down for
lunch breaks. Employees are required to return from meal breaks and rest
breaks on time. Employees should check with their supervisor about the rules for
meal and rest breaks in their specific department.

• Rest breaks vary from state to state. Contact Human Resources for break
Waivers or additional policy for your state.

9. Break Rooms

Break rooms are located at each center. For the convenience of employees, all break
rooms are typically equipped with a refrigerator, microwave, sink, and vending
machines dispensing snacks and beverages. Employees are required keep these
rooms clean and free of litter.

Everise
600 North Pine Island Road, Suite 320 70
Plantation, FL 33324 weareeverise.com
 10. Food / Drinks on Production Floor

A spill-proof cup is required for any liquid refreshment or water in the training room or
on the production floor. No food is allowed in the training room or on the production
floor at any time and must be removed.

11. Return of Assets and Intellectual Property/the Company Data

• If an employee leaves the Company for any reason, they are required to return
all Company and client assets, which may include: a laptop or desktop
computer, including accessories (such as docking station, monitor, power cord,
connection cables, carry case, external CD drive, etc.), software, hardware,
headsets, y-cords, Company data in the form of files, documents, e-mail, or
"soft copy" data that is linked in any way to any part of the Company, its clients
and partners, books, training materials and manuals. Company-issued cell
phones must also be returned, while personal cell phones used for Company
purposes will be subject to a full "wipe" of all Company information. Employees
who have destroyed or damaged the equipment or property issued to them will
be responsible to reimburse the cost to repair or replace the items.

• Exiting employees should NOT delete or erase any Company data from their
computers, including but not limited to: files, documents, data in shared file
locations, and data on the Company intranet. This information is Company
property and is considered its intellectual property.

12. Prohibited Activities

• Material that is fraudulent, harassing, sexually explicit, profane, obscene,

intimidating, defamatory, or otherwise unlawful or inappropriate may not be
sent by email or other form of electronic media, or displayed on or stored in any
equipment. Users encountering or receiving this kind of material should
immediately report the incident to their Supervisor or their Human Resources
Department.

• Employees may not illegally copy material protected under copyright law or
make that material available to others for copying. Employees may not agree
to a license or download any material without first obtaining the expressed
written permission of their Supervisor and the IT Site Manager.

Everise
600 North Pine Island Road, Suite 320 71
Plantation, FL 33324 weareeverise.com
 • Users may not deliberately perform acts which waste equipment or resources,
or which unfairly monopolize resources to the exclusion of others. These acts
include, but are not limited to, sending mass mailings or chain letters, spending
excessive amounts of time on the Internet, playing games, blogging, engaging
in online chat groups, or otherwise creating unnecessary network traffic.

• Unless expressly authorized, sending, transmitting, or otherwise disseminating

proprietary data, trade secrets, or other confidential information of the
Company is strictly prohibited.

13. Employment of Relatives

The Company considers the application for employment of employees’ relatives the
same way as any other applicant, based on qualifications and valid requirements of
an available position, the only exception being at no time will the relative of an
Employee be placed in a position which may create a conflict of interest, such as a
reporting relationship. Human Resources determines whether a situation constitutes a
conflict of interest.

14. Standards of Conduct

The orderly and efficient operation of the Company and the safety of all employees
require that every employee adheres to strict standards of personal conduct at all
times. Employees who engage in the following conduct may be subject to disciplinary
action, up to and including immediate termination:

• Theft, destruction, or misuse of property or assets.

• Being under the influence of or using intoxicants or narcotics, or the use of illegal
drugs or alcohol during work hours.

• Disorderly conduct of any kind including fighting or any willful act resulting in
injury to others.

• Falsification of any Company record or of any documentation provided by the

employee to the Company.

• Time clock and recordkeeping fraud such as logging in or out for someone else,
having someone else log in or out for you, or unaccounted-for time while still
logged in.

• Posting negative or confidential information about clients to social or other

media.

Everise
600 North Pine Island Road, Suite 320 72
Plantation, FL 33324 weareeverise.com
 • Insubordination, which may include refusal to perform a reasonable request
from Management.

• Failing to call in after two (2) hours from the start of a scheduled shift will be
considered a No call, No show (“NCNS”). Note: Policy in effect for all sites unless
applicable state law applies. The first NCNS will result in a final warning. The
second NCNS will be considered a voluntary resignation from the Company.
NCNS’s are tallied on a rolling six (6) month basis.

• Inappropriate phone handling of customer calls including, but not limited to,
rudeness, tone of voice, not acknowledging calls, deliberately hanging up on a
customer and/or call avoidance.

• Misrepresenting sales or crediting accounts for personal gain.

• Transmitting personal customer information without approval.

• Inability to get along with fellow employees, causing disruption in the

department or other areas within the Company, including use of inappropriate
language.

• Misuse of the Company telephone system, such as misuse of incoming “800”

telephone lines, use of phones for personal business or making outbound
telephone calls without the express permission of a Supervisor.

• Misuse of technology assets and equipment.

• Harassment of any kind, including, but not limited to, on the basis of race, religion,
sex, national origin, age, disability, sexual orientation, marital status, political
beliefs, or gender identification.

• Conflicts of interest, such as working for another company providing customer

contact management or any other business process outsourcing services.

• Any behavior, action or activity that presents itself as a potential safety

emergency or threat issue to another person or Company property.

• Unauthorized use of any electronic devices, pagers, or cell phones during work
hours and while being logged in to Company systems.

• Inappropriate conversations, profanity, or inappropriate language of any kind.

• Sleeping during work hours.

• Violence or threats of violence. The Company maintains a zero-tolerance policy

for all acts of violence including the threat of violence.

Everise
600 North Pine Island Road, Suite 320 73
Plantation, FL 33324 weareeverise.com
 • Possession of a weapon, weapon materials or the use of any object as a weapon
on Company property, except as otherwise provided by law. Please be aware
this policy is unaffected by the possession of a weapons carry permit, either
concealed or unconcealed, unless otherwise mandated or required by
applicable law.

• Theft of any customer data, credit card, making changes on customer’s

property, as well as releasing customer protected information of its customers
is prohibited.

The foregoing list of unacceptable behavior is not exhaustive. Any misconduct must
be reported immediately to the appropriate supervisor or Human Resources
Department for appropriate investigation and follow-up.

Everise
600 North Pine Island Road, Suite 320 74
Plantation, FL 33324 weareeverise.com
 Cell Phone Policy

In an effort to further protect customers’ sensitive information, the use of non-company

issued cell phone equipment or any “personal cell phones and recording devices” (to
include, but not limited to MP3 players, IPODs, cameras, camcorders, personal
computers, PDA’s, tablets, smartphones, smartwatches, or any item that may store
data in video, audio, or text form, hereafter referred to as personal communication
devices) in production areas must be turned off at all times, except for use to login to
systems that require multi-factor authentication (“MFA”).

The device may be turned on during the authentication process, then immediately
turned off and stowed away after the process has ended.

Positions with a legitimate business need to have a cell phone will require prior written
permission of the EVP or CPO and may only be used for business purposes.

All personal communication devices must be stowed away and in the “off” mode (a
status equivalent to the power supply removed from the device) while in any
production area (i.e., QA booths, production floors, training rooms, etc.). The use of
personal communication devices is permitted ONLY in break rooms, outside of the
center and during MFA.

Use of personal communication devices on the production floor is a HIPAA violation.

This policy will be strictly enforced. Violation of this policy will result in immediately being
placed on a final written warning. A second violation of this policy will result in
termination.

Everise
600 North Pine Island Road, Suite 320 75
Plantation, FL 33324 weareeverise.com
 Electronic Monitoring and Recordings Policy

Introduction

Everise is committed to protecting its confidential and proprietary information, as well

as that of its clients. In addition, Everise wants to ensure that its employees can openly
communicate with one another and have the freedom to communicate without the
fear of being secretly recorded without their consent. Many state laws also prohibit the
electronic recording of others without the consent of all participants in the
conversation and many clients require that Everise maintain a cleanroom environment
free of any electronic or recording devices to ensure the security and confidentiality of
its operations.

Many states not only make the undisclosed recording of any call or face-to-face
meeting illegal, but it also makes it a crime to use, or even attempt to use, an illegally
recorded conversation for any purpose. A person who causes another person, by
whatever means, to illegally record a conversation also violates the law.

Electronic Recordings

Everise employees, visitors, clients, vendors, or representatives acting on behalf of the

company may not record conversations of another person without their prior
knowledge and consent. Everise Human Resources reserves the right to refuse such
request. Recordings may include audio, video, webcam by any means, including smart
phones.

Electronic Monitoring

All employees are subject to being recorded by the Company in all Company locations,
including while working at home at their desktops on behalf of Company clients, as a
condition of their employment. This policy shall not limit the right of Everise or its clients’
right to install and use security cameras or webcams for the purpose of monitoring the
employee’s safety and work performance.

Nothing in this policy prevents Everise employees from engaging in any concerted
activity as protected by law, including but not limited to the National Labor Relations
Act.

Everise
600 North Pine Island Road, Suite 320 76
Plantation, FL 33324 weareeverise.com
 A violation of this policy may result in disciplinary action, up to and including
termination of employment.

Everise
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 Chat Room Policy

At Everise, we want our Champions to feel comfortable to do their best work. As

Everise Champions we must all do our part to maintain a respectful work
environment where everyone feels safe and productive.

Our success is dependent on establishing a workplace culture free from

discrimination, harassment, improper tone with co-workers, degrading comments,
ridicule, disparaging remarks, bullying and verbal abuse.

Everise Champions utilize various chat rooms to exchange ideas and assist one
another for training, customer, or work-related purposes.

Whether a chat session is with a customer or an internal employee, group chat or

private chat, all written communication must be free of improper language,
harassment, verbal abuse, accusations and degradation of an employee’s abilities
or performance.

Guidelines

Employees

The following actions are not acceptable in a chat session and are viewed as
disruptive in the workplace setting. These actions may lead to disciplinary actions
including termination from Everise.

• One-on-one agent coaching in front of peers

• Foul or explicit language

• Typing in all Caps to direct, reprimand or get a point across. (Equivalent to

yelling at someone).

• Discussions that are sexual in nature, political, or religious topics

• Derogatory or salacious gossip/discussions about another employee in the

work group.

• Inappropriate JPGs, GIFs or memes that are non-work related, sexual in

nature, derogatory, political, or religious are not allowed.

• Bullying, harassing, or making discriminatory comments.

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 • Displaying weapons or explosive devices of any kind while on video.
Weapons must not be in view of the video camera. This includes: Guns (of
any kind), knives, clubs, swords or any type of explosive device.

Trainers

Everise Trainers are expected to ensure all aspects of the classroom are operating
smoothly and without incident.:

• Set expectations during the first day of class.

• Monitor all chat discussions.

• Frequently, remind class participants, regarding chat protocol and

guidelines.

• Stop inappropriate behavior and address the behavior when reported.

• Counsel employees regarding inappropriate behavior.

• Escalate to your leadership chain of command for violations of this policy

by an employee(s).

Operations Managers

Everise operations managers are critical to ensuring that all aspects of training, and
production are operating smoothly and without incident. Our operations managers
are an escalation point for issues that arise in the workplace, including proper chat
room etiquette.

To ensure proper chat room etiquette, operations managers will:

• Mentor, coach and guide trainers and employees when issues occur.

• Ensure chat room protocol is being followed according to policy.

• Assist in delivery of disciplinary actions for non-compliance of this policy.

Non-Compliance

Non-compliance of this policy will lead to disciplinary actions up to termination from

Everise.

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 Drug-Free Workplace Policy

Purpose

Everise intends to maintain a safe, productive, and comfortable drug-free workplace

for employees, applicants for employment, clients, and customers. With this in
mind, Everise Holdings has established this drug-free workplace policy.

ADA and FMLA

Applicants or employees who currently use illegal drugs or are affected by alcohol on
the job are not protected under the Americans with Disability Act (ADA). The ADA does
protect employees who are seeking treatment or have successfully completed a
supervised rehabilitation program and no longer abuse drugs or alcohol. Employers
may test to determine if an employee or applicant for employment is currently using
illegal drugs or abusing alcohol. The Family and Medical Leave Act (FMLA) considers
recovery from drug addiction a serious health condition.

Definitions

For the purposes of this policy, all abused substances, whether inhaled, injected, or
swallowed, including, but not limited to:

o Alcohol, such as beer, wine and hard liquor;

o Illegal drugs, such as marijuana, hallucinogens, club drugs (also known as rave
or party drugs such as Ketamine, Ecstasy and Rohypnol) and cocaine;

o Non-prescribed prescription medication, such as painkillers and barbiturates;

and

o Inhalants, such as glue, paint thinner, gasoline and hair spray.

Applicant Drug Testing

Applicants will sign a written consent form and submit to a drug testing procedure, free
of charge, as a condition of employment. If an applicant tests positive for cannabis, the
results will be reviewed by the HR Director of Compliance on a case-by-case basis.

Prohibited Behavior

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 Everise Holdings explicitly prohibits the use, possession, solicitation, offer for sale or
being under the influence of restricted substances during work hours, including lunch
and breaks, or on company property at any time. Employees are in violation of
company policy if they:

o Are impaired or under the influence of illegal substances while working for the
company, on or off the premises;

o Report for duty in an altered or impaired condition, as the result of the use of
restricted substances; or

o Are convicted of any federal, state, or municipal criminal drug statute, and fail
to report the conviction to their supervisor within five (5) calendar days of the
occurrence.

Employee Drug Testing

Everise reserves the right to set standards for employment and may require
employees, as a condition of continued employment, to submit to drug testing under
the following circumstances:

• Reasonable Suspicion Testing - Where there is a reasonable suspicion that an

employee is under the influence of a restricted substance, including but not
limited to:

o Direct observation of use of a restricted substance;

o Evidence of drugs or alcohol on or about the employee's person or work

area;

o A significant deterioration in work performance that suggests

impairment;

o Symptoms of being under the influence of a restricted substance, such

as abnormal or erratic behavior or changes in physical appearance.

o A report of use of a restricted substance, provided by a reliable and

credible source; or

o Newly discovered evidence that the employee has tampered with a prior
drug test result;

o Other good cause that suggests the employee may be in violation of the
policy;

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 o Post-Accident Testing - Employees involved in an on-the-job accident,
especially those for which the employee is deemed at fault.

o Reasonable suspicion testing needs prior approval from the HR Director

of Compliance.

Refusal to Test

Any employee who refuses a request to submit to testing under this policy may be
subject to disciplinary action, up to and including termination. Attempts to alter,
substitute or tamper with the collection of the specimen or failure to appear for
testing will be deemed a refusal to take the drug test. A refusal to take a test shall
include the following:

• fails to appear for any test within a reasonable time, as determined by Everise
after being directed to do so;

• fails to remain at the collection site until the testing process is complete;

• fails to provide urine specimen when required for a drug test or a breath
specimen for an alcohol test;

• fails to provide a sufficient amount of urine or breath when directed, and it

has been determined, through a required medical evaluation, that there was
no adequate medical explanation for the failure;

• declines to take a second test as directed;

• fails to undergo an evaluation, as directed by the MRO as part of the

verification process or as directed by Everise as part of the shy bladder
procedures or insufficient breath situation;

• fails to cooperate with any part of the testing process; or

• fails to immediately report a job-related accident for the purpose of avoiding

testing.

Inspections

Please review our Search, Inspection, and Investigation Policy in this handbook.

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 Confidentiality

The results of any drug test will constitute medical information and will remain
confidential. All information, interviews, reports, and statements received by Everise as
part of this policy are confidential communications. Unless authorized by law, Everise
will not release such information without a signed written consent form signed by the
person tested.

Test Results.

Everise will attempt to ensure that all aspects of the testing process are as private
and confidential as reasonably practical. Actual test results will be provided to:

• the Medical Review Officer and their staff;

• supervisors and managers who have a need to know such information;

• the associate tested upon written request;

• any person permitted or required by law or regulation to receive such

information;

• any individual with an associate’s written authorization;

• to law enforcement;

• the decision maker(s) in a legal action initiated by or on behalf of the

employee or placed at issue by the associate in any legal, administrative, or
other proceeding; or

• to any governmental agency or contractor as required by federal or state

law. Non-specified statistical information may be provided upon request to
a corporation, which requires its vendors or subcontractors to maintain drug
and alcohol testing programs in accordance with a contract, or to
governmental agency in accordance with the law.

Disciplinary Action

The severity of the disciplinary action taken against an employee found to violate
this policy will depend on the circumstances of each case. However, any violation of
this policy may be subject to disciplinary action, up to and including termination.

Voluntary Employee Assistance and Rehabilitation

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 Everise supports employees in seeking assistance, including counseling and
rehabilitation services. Everise offers an Employee Assistance Program (EAP) to assist
employees in recovering from or dealing with personal matters, including substance
abuse. Everise encourages the use of Paid Time Off (PTO) or leave without pay, for
purposes of bona fide rehabilitation efforts. Everise will reasonably accommodate
employees who wish to enter an alcohol or drug rehabilitation program. Participation
in employee assistance and rehabilitation programs is confidential. Everise will not use
the employee's voluntary participation in a program as a basis for corrective action,
nor will participation in such a program jeopardize employment or advancement
opportunities. However, participation will not protect employees from disciplinary
action for continued unacceptable job performance or rule violations.

Employee Assistance Program

Everise may suggest an employee to enter an employee assistance or drug

rehabilitation program as a condition of continued employment after a confirmed
positive drug test. However, Everise will not be financially responsible for the cost of the
employee's treatment.

Employees may contact Employee Connect, an Employee Assistance Program, which

provides confidential help 24 hours a day, seven days a week for employees and their
family members. Visit www.guidanceResources.com, (Username: LFGSupport,
Password: LFGSupport1) or call 888-628-4824 for more information.

Time Off

An employee with Everise’s medical certification documentation from a licensed health

provider may request a leave of absence to obtain treatment for substance abuse if
such treatment is required and undertaken. The granting and returning from medical
leave is subject to the company leave of absence policy. To discuss an
accommodation, please contact Human Resources.

Supervisory Responsibility

Supervisors play an important role when it comes to helping employees

with substance abuse problems. They are in direct contact with employees and,
therefore, are more likely to detect issues such as changes in mood or behavior that

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 may indicate substance abuse. Supervisors who suspect that an employee is under
the influence of a restricted substance have the responsibility to:

o Inform employees of the drug-free workplace policy;

o Investigate reports of dangerous practices or suspicious behavior;

o Observe and document changes and/or problems in employee performance

and behavior;

o Counsel employees as to expected performance improvement;

o Clearly state consequences of policy violations; and

o Contact the Human Resources Department for further assistance.

Employee Responsibility

While the use of medically prescribed or over-the-counter medications does not

necessarily violate this policy, employees should not take prescription or over-the-
counter medication that impairs their ability to perform their job or creates a safety
hazard. If they must take medication that adversely affects their job performance, they
should seek advice from the Human Resources Department about possible time off or
accommodation. Additionally, employees aware of substance abuse by another
employee should report this information to their immediate supervisor or the Human
Resources Department.

Prohibited Use

All employees are prohibited from manufacturing, cultivating, distributing, dispensing,

possessing, purchasing or using illegal drugs, including, without limitation, marijuana
(which includes medicinal marijuana regardless of prescription or physician
certification) or other unauthorized or mind-altering or intoxicating substances while
on Company property (including parking areas and grounds), in Company vehicles
(whether owned, leased or rented) or while otherwise performing their work duties
away from the Company’s premises. Included within this prohibition are lawful
controlled substances which have been illegally or improperly obtained.

Employees are also prohibited from having any such illegal or other unauthorized or
mind-altering or intoxicating substances in their system while working (including
marijuana regardless of prescription or physician certification), and from having
excessive amounts of otherwise lawful controlled substances in their systems.

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 Everise employees are also prohibited from possessing, using, selling, or purchasing
any alcoholic beverages on Company property, in Company vehicles (whether owned,
leased, or rented) or having 0.04 presence of alcohol in their systems while at work or
on duty. Furthermore, off-duty alcohol use, while generally not prohibited by this policy,
must not interfere with your ability to perform the essential functions of your job.

Discipline for Policy Violations

Everise Employees who violate this Policy, shall be terminated from employment.
Employees may not avoid imposition of discipline by first requesting such
treatment of a leave of absence after being selected for testing or violating
Everise policies.

• Refusal to Test. Additionally, a candidate or employee who refuses to

submit to alcohol or drug screening will be considered as having tested
positive and may be removed from employment consideration or subject
to discipline, up to and including termination.

• Referral to Law Enforcement. In addition to imposing disciple, Everise may

refer information and any suspected illegal drugs or illegal drug
paraphernalia to law enforcement.

• Automatic Suspension. If an employee is suspected of violating this Policy

or is ordered to submit to a post-accident or reasonable suspicion test, the
employee will be suspended from duty without pay until the test result is
received. If the test result is positive, then the employee is subject to
discipline as described herein.

• Applicants. If a pre-employment test result is positive or if the individual

refuses to submit to a pre-employment test, then Everise shall treat the
individual as having withdrawn the application and it shall withdraw its
conditional offer of employment.

Employer Right to Amend Policy

Everise reserves the right to amend, delete or revise parts of this policy at any time.

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 Equal Employment Opportunity Policy

1. Objective
It is the Company’s policy and practice to provide an environment which provides
equal employment opportunities without any form of discrimination. The Company
provides equal employment opportunity to all qualified individuals regardless of the
individual’s race, color, gender, gender identity, sexual orientation, religion, national
origin, age, disability, or any other protected class status provided by the respective
equal employment opportunity law applicable in the country.

2. Scope
This policy applies to all employees of the Company and temporary or contract
personnel working in the Company premises.

3. Salient Features
Employees and all applicants for employment with the Company will be treated
equally in all respects. This policy applies in all aspects of employment, including, but
not limited to:

• Job advertising, recruiting, and hiring

• Compensation and benefits

• Job assignments, promotions & transfers

• Training activities

• Layoffs, disciplinary procedures, and termination of employment

• Use of all Company facilities

4. Responsibility
• The HR Department is responsible for compliance with this policy as overseen
by the Chief People Officer.

• Any employee who is aware of any act or allegation of discrimination will

report the incident via their supervisor or through the ‘Complaint Reporting
Procedure’ mentioned below.

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 • As an integral part of the supervisor’s responsibility, each supervisor shall
ensure that there is no discriminatory conduct against a fellow
colleague/peer/subordinate/supervisor.

• Any supervisor who is aware of an action or allegation of discriminatory

treatment but fails to report the incident is subject to disciplinary action, up to
and including termination of employment.

5. Complaint Reporting Procedure

• Employees are encouraged to resolve complaints with their immediate
supervisor. However, if the employee prefers, they may file a verbal or written
complaint with the Human Resources Department.

• A description of the offending conduct should be given, including the date of

the incident and the name of the person accused, to the Site HR Manager.

• Every complaint will be investigated, and a decision will be made upon

assessing the best method of handling the issues raised.

• Disciplinary action may be taken to ensure an effective resolution.

• The complainant will be informed about the results of the investigation.

• In cases when the results of the investigation are inconclusive or when a

reasonable doubt remains as to whether the conduct complained of violates
this policy, both employees will receive counselling concerning the
appropriate standard of conduct.

6. Non-Retaliation Policy
Neither the Company nor any employee will retaliate against another employee who
has provided information or cooperated with the investigation of discrimination or
harassment. If instances of retaliation are proven, management will take appropriate
disciplinary action against the offending party.

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 Anti-Harassment, Discrimination, and Retaliation
Prevention

1. The Company is committed to providing all our employees with a work environment
free of discrimination, harassment, and/or retaliation of any kind.

2. No employee will be subjected to any harassment because of age, race, religion,

color, sex, national origin, disability, military or marital status, sexual orientation,
gender identity, genetic information, or any other category protected by federal,
state, or local laws. Any form of discrimination, harassment, and/or retaliation will
not be tolerated.

3. Harassment may take several forms, such as degrading comments, intimidation,

offensive material, emails, or language, or other verbal, visual, or physical conduct
of a sexual, racial, ethnic, religious, disability-related, or age-related nature which
could create a hostile, intimidating, or offensive work environment. Such
discrimination, harassment, or retaliation is intolerable, a violation of Company
policy, and will result in appropriate discipline, up to and including termination.

Examples of harassment in violation of Company policy, may include, but are not
limited to:

• Degrading or inappropriate comments of a sexual, ethnic, racial, ageist,

religious, or disability nature.

• Unwelcome sexual flirtations, advances, or propositions.

• Offensive materials, emails, text messages, instant messages, or language of

a sexual, ethnic, racial, age, religious or disability nature.

• Touching, hugging, pinching, patting, or brushing against another person’s

body.

• A display in the workplace of sexually suggestive objects or pictures.

• A threat or action that makes the affected individual’s employment, work-

related opportunities, or benefits subject to submission of sexual demands.

• Retaliation, harassment, discrimination, or intimidation against employees

who make complaints of harassment.

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 4. Any sexual advances or personal relationships between a supervisor and
subordinate are prohibited.

5. If you believe you have been harassed, observe incidents of harassment, or believe
you have been retaliated against, you should immediately report the alleged
incident to the Human Resources Department. Incidents should be reported as
soon as possible so we may begin a prompt investigation.

6. All claims of harassment and retaliation will be thoroughly investigated in an

objective manner and all information obtained will be kept as confidential as
possible.

7. Please do not assume the Company is aware of your problems. Please bring your
complaints and concerns to our attention so we may resolve them.

8. Violations of this policy will not be permitted and will result in discipline up to and
including termination.

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 The Genetic Information Nondiscrimination Act (GINA)

Everise has made every effort possible to comply with the Genetic Information
Nondiscrimination Act (“GINA”). The genetic information protected by GINA, which
Everise will not ask for, or use, includes, but is not limited to:

• carrier screening of employees (for example, if an employee has sickle cell

anemia);

• prenatal genetic testing, susceptibility, and predictive testing (as performed for
certain types of cancer, like breast cancer or Huntington’s disease);

• family medical history of employees;

• analysis of tumors, or genes, mutations, or chromosomal changes.

If any of this information is obtained inadvertently, it will not be shared or disclosed

without the individual employee’s knowledge and consent. Tests not considered to
be genetic tests include but are not limited to, tests on drug and alcohol, HIV, and
cholesterol screenings.

Impermissible Ways to Obtain Genetic Information

In compliance with GINA, Everise will not request, purchase, or require genetic
information from its employees. Everise will not:

• listen to a third-party conversation for the purpose of obtaining genetic

information;

• request an employee’s medical information in a way that elicits genetic

information;

• conduct an internet search to acquire an employee’s genetic information.

Genetic Information Protected

Genetic information will not be used as a factor in any decisions about hiring,
termination or referrals, or other decisions regarding compensation, conditions, or
terms of employment. Everise or any supervisors working for Everise will not subject
an employee to discipline or retaliation for opposing an act/practice made unlawful
by GINA.

Employers will only use genetic information as permitted by GINA which includes:

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 • using that information to satisfy certain Family Medical Leave law
requirements;

• monitoring effects of certain toxic substances or other safety hazards in the

employees’ workplace;

• other specific instances as specified by the statute.

Storage Provisions

In those rare instances in which the employer maintains genetic information, it will
keep that information in separate forms and medical files.

Such genetic information will be treated as confidential medical information and will
not be disclosed except in very limited circumstances as outlined under GINA.

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 Sexual Harassment Policy

Purpose

The purpose of the Everise Sexual Harassment Policy is to ensure all employees
understand that Everise has a zero-tolerance policy for sexual harassment in the
workplace.

Description of Conduct that Constitutes Harassment

• Sexual harassment is unwelcome sexual conduct that is a term or condition of

employment. Unwelcome sexual advances, requests for sexual favors, and
other verbal or physical conduct of a sexual nature constitute sexual
harassment when: (1) submission to such conduct is made either explicitly or
implicitly a term or condition of an individual's employment; (2) submission to or
rejection of such conduct by an individual is used as the basis for employment
decisions affecting such individual; or (3) the conduct has the purpose or effect
of unreasonably interfering with an individual's work performance or creating an
intimidating, hostile, or offensive working environment. Any of the following could,
if part of a pervasive pattern of abuse, constitute sexual harassment:

o Jokes, innuendos or gestures of a sexual nature;

o Sexually-charged computer programs, emails or messages;

o Demeaning language or behavior that is based on sex;

o Compliments about a person's body of a sexual nature;

o Repeated requests for a date despite refusals;

o Unwelcome sexual advances;

o Requests for sexual favors;

o Questions or comments about personal or intimate sexual matters;

o Hugs, kisses, neck rubs, or back rubs;

o Deliberately brushing up against someone else;

o Sexual epithets or name-calling;

o Sexually intimidating behavior or ridicule;

o Objects, pictures, photographs, or cartoons of a sexual nature;

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 o Other verbal or physical harassment of a sexual nature.

o Requesting sex for something such as better job opportunities,

advancement etc.… (Quid Pro Quo)

Zero Tolerance

• Everise is committed to providing a workplace free from sexual harassment. As

such, Everise will not tolerate harassment of any of our employees or
independent contractors by supervisors, co-workers, customers, vendors,
agents and any other third parties.

Complaint Procedure

• If an employee believes that they or any other individual has been subjected
to harassment in violation of this policy, whether by an employee or a third party,
the employee must promptly report the facts and names of the individuals
involved to Everise via Human Resources, or the Everise Whistleblower Hotline.
Any employee who learns of, observes, or has reason to be concerned
about sexually harassing conduct in violation of this policy must immediately
inform their leader and Human Resources. Complaints do not need to be made
in writing.

• Everise takes complaints of sexual harassment very seriously. As a result, all

complaints of sexual harassment made pursuant to this policy will be
thoroughly and promptly investigated.

Confidentiality

• During any such investigation, Everise will take appropriate measures to

maintain the confidentiality of the participants to the extent possible. Although
it may be necessary to divulge some information to ensure that a fair
investigation is conducted, Everise will limit information to only those persons
with a need to know of the complaint or of the investigation.

No-Retaliation

• All parties contacted during a sexual harassment investigation will be expressly

reminded that Everise will not tolerate retaliation in any form against any
employee who believes or is concerned that sexual harassment has occurred

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 and reports such conduct pursuant to this policy. Moreover, Everise will protect
any employee who participates in any sexual harassment investigation from
any resulting retaliatory conduct. If an employee believes that they are
experiencing retaliation because of having made a complaint pursuant to
this policy or having participated in a sexual harassment investigation, the
employee must promptly report the facts and names of the individuals involved
to their leadership or Human Resources.

Discipline for Harassment

• If an investigator concludes that conduct in violation of this policy has occurred,

the offending individual(s) will be subject to corrective action, including formal
discipline, up to and including termination of employment. Please note
that Everise’s Sexual Harassment Policy may be construed to be more protective
of employees than the law requires. Regardless, Everise will discipline any
individual who violates this policy even if such conduct does not rise to the level
of a violation of the law.

Formal Training

• To ensure that Everise's employees remain educated about their obligations

under this policy, Everise will require all employees to periodically receive
training regarding our zero tolerance for sexual harassment at work.

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 Discrimination on the Basis of Gender, Gender Identity or
Transgender Status

Everise prohibits discrimination against and/or harassment of applicants, employees,

and interns based on their actual or perceived gender or actual or perceived status as
an individual who is transgender, gender non-conforming or intersex. For purposes of
this policy, gender includes gender identity, self-image, appearance, behavior, or
expression. Harassment includes, but is not limited to, violence, threats of violence and
similar conduct.

The Company evaluates all requests for reasonable accommodations, including

requests for medical leave or schedule changes, changes to the terms and conditions
of employment, program participation or use of a public accommodation in a non-
discriminatory manner. The evaluation includes, but is not limited to, treating leave
requests for medical or health care needs related to an individual’s gender identity in
the same manner as requests related to other medical conditions.

Employees who engage with the public as part of their job duties are required to
conduct themselves in a respectful, non-discriminatory manner by respecting gender
diversity and ensuring that members of the public are not subject to discrimination
(including discrimination with respect to single-gender programs and facilities).

Preferred Names, Titles and Pronouns

Everise allows employees to self-identify their names and genders and will use an
individual’s preferred name, gendered title (e.g., Mr./Ms.) and pronoun (e.g., he/him/his;
she/her/hers; they/them/theirs; or ze/hir). Requests to be addressed by a certain name
and/or pronoun do not require supporting documentation.

If an employee is unsure what name, title, or pronoun another individual prefers, the
employee should not hesitate to ask the person their preferred method of being
addressed.

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 Facilities Designated as Single-Gender

All employees have the right to use restrooms consistent with their gender identity or
transgender status.

Dress Code

Everise’s dress code and grooming standards are gender neutral, meaning they do not
differentiate or impose restrictions or requirements based on gender or sex. All Everise
employees should dress professionally at Everise facilities and be aware of any safety
concerns regarding their choices; for example, footwear that may cause injury. Please
refer to the Everise dress code policy in this handbook for more information.

Reporting and Anti-Retaliation

Employees with questions or concerns regarding their safety, gender discrimination

and/or a request for a reasonable accommodation, or who feel they have been
subjected to discrimination or improperly denied an accommodation, should contact
their Human Resources representative, or consult the Whistleblower Policy in this
handbook.

Everise prohibits and does not tolerate retaliation against employees who report issues
or concerns of gender discrimination in good faith pursuant to this policy.

Everise
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 Creating a Respectful and Open Workplace Under the
Natural Hair Act of 2020 Policy

(“CROWN Act”)

Everise does not discriminate by refusing to hire or discharge any individual based
solely on natural hair characteristics, texture, form, or manner that is commonly
associated with a particular race, national origin, gender, gender identity or expression,
sexual orientation, religion, or religious practice (including hair that is tightly coiled or
tightly curled or a hairstyle that contains or consists of locks, cornrows, twists, braids,
Bantu knots or Afros).

Everise
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 Diversity, Equity and Inclusion Policy

Everise is committed to fostering, cultivating, and preserving a culture of diversity,

equity, and inclusion.

At Everise, we understand the value diversity has not only in the workplace, but on our
ability to empathize with our customers and deliver world-class customer experiences.
We celebrate all cultures for their uniqueness and strengths. We believe that great
things will happen when we work with people who think differently from us.

We recognize and appreciate the importance of creating an environment in which all

our team members feel valued, included and empowered to do their best work and
bring great ideas to the table in service to our culture and way of life. Through thought
leadership, we create empowering experiences that results in mutual trust and
engagement between our valued employees, our clients, and our customers.

We embrace and encourage our employees’ differences in age, color, disability,

ethnicity, family or marital status, gender identity or expression, language, national
origin, physical and mental ability, political affiliation, race, religion, sexual orientation,
socio-economic status, veteran status, and other characteristics that make our
employees unique.

Everise diversity initiatives are applicable—but not limited—to our practices and policies
on recruitment and selection; compensation and benefits; professional development
and training; promotions; transfers; social and recreational programs; layoffs;
terminations; and the ongoing development of a work environment built on the
premise of gender and diversity equity that encourages and enforces:

• Respectful communication and cooperation between all employees.

• Teamwork and employee participation, permitting the representation of all

groups and employee perspectives.

• Work/life balance through flexible work schedules to accommodate employees’

varying needs.

• Employer and employee contributions to the communities we serve to promote

a greater understanding and respect for the diversity.

All employees of Everise have a responsibility to always treat others with dignity and
respect. All employees are expected to exhibit conduct that reflects inclusion during
work, at work functions on or off the work site, and at all other company-sponsored and

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 participative events. All employees are also required to attend and complete annual
diversity awareness training to enhance their knowledge to fulfill this responsibility.

Any employee found to have exhibited any inappropriate conduct or behavior against
others may be subject to disciplinary action.

Employees who believe they have been subjected to any kind of discrimination that
conflicts with the company’s diversity policy and initiatives should seek assistance from
a supervisor or an HR representative.

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600 North Pine Island Road, Suite 320 100
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 Human Rights Policy

Everise believes in the principles of equality and non-discrimination. Everise is

committed to treating all individuals with respect and dignity, and work to use our
influence and business relationships to promote the opportunity for all people
throughout our value chain to exercise and enjoy fundamental human rights. This
policy outlines the Everise commitment to respect the Principles on Business and
Human Rights.

Everise aims to act as a role model for the business community. One aspect of this is
ethical conduct as expressed through the Business Code of Conduct. The Business
Code of Conduct includes our commitments to:

• Follow high standards of ethical conduct;

• Work with clients, suppliers, and subcontractors that live up to Everise’s

core ethical standards;

• Act lawfully, ethically, and in the public interest;

• Champion an inclusive and collaborative culture that is free from

bullying, discrimination, and harassment, where everyone is treated
with respect and dignity.

Respect for Human Rights

Respect for human rights is a fundamental value of Everise Holdings. We believe in the
principles of equality and non-discrimination, and we are committed to treating all
individuals with respect and dignity, and work to use our influence and business
relationships to promote the opportunity for all people throughout our value chain to
exercise and enjoy their fundamental human rights. We also recognize the
interdependence of human rights and the environment – particularly as it relates to
land and natural resources and the importance of the people whose livelihoods
depend on the ingredients we source.

Fair and Humane Working Environment

Everise provides a workplace free of harassment, discrimination, harsh and inhumane

treatment. Any abusive behavior such as sexual harassment, corporal punishment,
mental or physical coercion, or verbal abuses or threats among employees shall not
be tolerated.

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 Discrimination for reasons of race, age, gender, gender-orientation, ethnicity, disability,
religion, political affiliation, union membership or marital status shall not be condoned.

Safe and Healthy Workplace

The safety and health of our employees is of paramount importance. Our policy is to
provide a safe and healthy workplace and comply with all applicable laws and Local
safety and health laws, as well as internal requirements. We work to provide and
maintain a safe, healthy, and productive workplace, in consultation with our employees,
by addressing and remediating identified risks of accidents, injury and health impacts.

Freely Chosen Employment

We are committed to ensuring all work is voluntary. We take meaningful steps to

prevent the use of forced, bonded, or indentured labor, involuntary prison labor, slavery,
or human trafficking in our workplaces and throughout our supply chain.

Child Labor Inside our organization

Child labor will not be used under any circumstances. All employees must meet the
minimum age requirement set by local laws. We intend to continue improving
identification of and elimination of child labor in our supply chain.

Minimum Wage, Hours and Benefits

We are committed to compensating our employees competitively relative to the

industry and local labor market. We operate in full compliance with applicable wage
laws, including those relating to minimum wages, overtime hours and legally
mandated benefits. Working hours for our employees shall be limited to what is
permitted by local laws.

Privacy and Data Protection

Everise respects individuals in a manner consistent with the rights to privacy and data
protection. Information about people, including its employees, shall be used
appropriately for necessary business purposes, and shall be protected from misuse to
prevent undue harm to individuals such as discrimination, stigmatization or other

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 damage to reputation and personal dignity, impact on physical integrity, fraud,
financial loss or identity theft.

Key Responsibilities

Everise leaders, managers and employees have a personal responsibility for the
application of this Policy on a day-to-day basis. This means they should not undertake
any acts of discriminatory practice in the course of their employment. Furthermore, all
Everise employees should positively promote high equality standards in the course of
their employment wherever possible.

Finally, all staff have a responsibility to bring any potentially discriminatory practice to
the attention of either their Line Manager, the Human Resources Department, or the
Whistle blower Hotline.

Expectations

Everise Team Leaders, Supervisors, Managers, and Executives should be aware that
they will be expected to positively promote high equality standards. Everise leadership
will ensure that all employees of Everise are accountable for the promotion and
implementation of this Policy. We will monitor progress on equality and diversity issues
and initiatives on a regular basis and will ensure the implementation of any relevant
actions points and plans concerning equality and diversity issues.

Everise is committed to fundamental Human Rights in all Everise subsidiaries and

communities where we operate. We want to achieve the right results, the right way by:

• having the courage to lead.

• communicating openly and transparently.

• committing to and support each other.

• promoting and protecting quality outcomes.

• honoring our past while we proudly pursue our future.

The commitment to human rights embodies and reflects these values as they
influence everything we do and serve as the guiding principles that drive our Company
every day. Where appropriate, we engage in dialogue with stakeholders on Human
Rights issues related to our business and the communities where we operate.

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 Process for Implementation

Everise and its subsidiaries are expected to follow the spirit and intent of our guiding
principles to ensure respect for Human Rights. These principles are an integral part of
other related policies, including the Code of Business Conduct and Ethics.

If any employee believes that someone is violating the Human Rights Policy or the law,
they are asked to report it to their Human Resources Department or the Whistleblower
Hotline where a formal review will be conducted regarding the concern.

A copy of this policy will be provided internally and externally. It will be communicated
to our employees, and suppliers.

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 Communication Devices & Workplace Tools Policy

1. Objective
The Communication Devices & Workplace Tools Policy establishes guidelines on the
use of communication devices, systems, and networks in the workplace.

2. Scope
This policy is applicable to Band 3 and above employees, except those sections 3.7 and
3.8 of this policy apply to all employees.

3. Guidelines
3.1 Mobile Phones – Bring Your Own Device (BYOD)

• Employees must use their own handsets and are eligible for a monthly
allowance of $40 towards reimbursement of official calls after seeking prior
approval from their department head and/or the Chief People Officer as
applicable.

• Employees of support functions in Band 4 may be eligible for this benefit, based
on the requirement of the role and after obtaining approval from the
department head, Chief People Officer and Chief Technology Officer.

3.1.1 International Service

• Prior to travelling out of the country, you should contact the telecom department
(if on a Company plan) regarding your service plan and advise which country
you are travelling to and the dates of travel.

• The provision of international roaming and data packages shall be done based
on the approval of the Country HR Head/Chief People Officer. Such requests
should be routed through the respective department head wherever applicable.

• Employees on individual plans should contact their mobile carrier regarding

available international plans and rates. International charges should be
submitted on an expense report, provided you have prior approval from your
manager.

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 • Whether on a Company plan or individual plan, the following guidelines apply
while travelling abroad:

▪ Use local mobile phone connections.

▪ Limit usage of cellular data (i.e.: email, Internet, etc.).

▪ Turn off cellular data in your phone settings when not in use.

▪ Limit usage of voice calling. Calling rates can vary per minute based on
the country you are visiting and/or your wireless carrier.

▪ Use Wi-Fi whenever possible.

▪ Use Skype for Business or Microsoft Teams from your laptop whenever
possible to make calls.

▪ Use your wireless services as if you were paying the bill.

• Employees are required to pay the bills and request reimbursement only for
official calls on a monthly basis.

• If the bill exceeds the eligibility limits, an employee is required to get approval
from their immediate supervisor and department head.

3.2 Laptops

• Windows-based laptops are the standard devices provided to Senior Managers

and above of any department.

• Requests for non-standard devices requests must be approved by the Chief

Technology Officer and Chief People Officer.

• Employees are responsible for maintaining current anti-virus definitions and

security of the device.

• Employees must safeguard Company data by applying strong passwords and

automatic locking after periods of inactivity.

3.3 Privacy/Company Access

• No employee using their personal device should expect any privacy except that
which is governed by law.

• The Company has the right, at any time, to monitor and preserve any
communications that use Company networks in any way, including data, voice

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 mail, telephone logs, and 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.

• Do not store data on personal devices or free cloud (online) storage solutions.
Utilize your One Drive to store personal business files. This is for data protection
and data retention. No personal data of an employee should be stored on
personal devices.

• Management may review the activity and analyze use patterns and may choose
to publicize these data to ensure that Company resources in these areas are
being use according to this policy.

• Furthermore, no employee may knowingly disable any network software or

system identified as a monitoring tool.

• Personal laptops or PC’s require CIO approval.

3.4 Policy Violations

• Employees who have not received authorization from management and who
have not provided written consent will not be permitted to use personal devices
for work purposes.

• Failure to follow Company policies and procedures may result in disciplinary

action, up to and including termination of employment.

3.5 Risks/Liabilities/Disclaimers

• The Company reserves the right to disconnect access to Company systems or

disable services without notification.

• Lost or stolen devices must be reported to the HR Department within 24 hours.

Employees are responsible for notifying their mobile carrier immediately upon
loss of a device.

• The employee is expected to use their devices in an ethical manner at all times
and adhere to the Company’s acceptable use policy as outlined above.

• The employee is personally liable for all costs associated with their device.

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 • The employee assumes full liability for risks including, but not limited to, the
partial or complete loss of Company and personal data due to an operating
system crash, errors, bugs, viruses, malware, and/or other software or hardware
failures, or programming errors that render the device unusable.

• The Company reserves the right to take appropriate disciplinary action up to

and including termination for noncompliance with this policy.

3.6 Security of the Devices

• Employees are responsible for the security of their devices and the information
stored on them. Employees must implement a passcode on any device
containing or accessing Everise data. Always carry the device with you; never
leave them unattended.

• Lost or stolen devices must be reported immediately.

• All Company security policies apply regardless if the device is owned by the
Company or the employee.

3.7 Use of Cell Phones or Similar Devices

3.7.1 General Use at Work

• While at work, employees are expected to exercise the same discretion in using
cell phones. Excessive personal calls during the workday can interfere with
employee productivity and be distracting to other employees. The Company is
not liable for the loss of personal cell phones brought into the workplace.

3.7.2 Unsafe Work Environment

• The Company prohibits employee use of cell phone or similar devices while at
any work site at which the operation of such device would be a distraction to the
work environment and/or create an unsafe work environment. Such work sites
must be secured or the device used only by an employee who is out of harm’s
way.

3.7.3 Use While Driving

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 • An employee who uses a Company-supplied vehicle is prohibited from using a
cell phone, hands on or hands off, or similar device while driving, whether the
business conducted is personal or Company-related. Employees who are
charged with traffic violations resulting from the use of their devices while driving
will be solely responsible for all liabilities that result from such actions. The
employee’s personal vehicle insurance is the primary insurance that will be used
for any accidents.

3.7.4 Confidentiality of Customer Information

• To further protect customers’ sensitive information, the use of non-Company

issued cell phone equipment or any personal cell phones and recording devices
(including, but not limited to, MP3 players, iPod, cameras, camcorders, personal
computers, PDA’s, tablets, smartphones, smartwatches, or any item that may
store data in video, audio or text form, hereafter referred to collectively as
“personal communication devices”) during work hours is prohibited.

• All personal communication devices must be concealed and in the “off” mode
(a status equivalent to the power supply removed from the device) during work
hours and while an employee is logged into Company systems.

• Employees who service accounts of the Company’s healthcare clients may be

violating HIPAA if they use personal communication devices during work hours
or logged into Company systems.

• Employees may not use any cameras, video and audio recording devices, or
video or recording features of cell phones, MP3 players or personal digital
devices with wireless capabilities that can cause violations of privacy and
breaches of confidentiality. Camera phones can present risks to the Company
by potentially compromising customer information.

3.8 Termination

• Upon termination of employment, whether voluntary or involuntary, all access to

Company systems and networks will be disconnected. For Company-owned
devices, services with the mobile carrier will be disconnected and all access will
be disabled. All Company devices must be returned to the HR Department within
seven days after the employee’s termination date.

• Failure to return any Company equipment in a timely manner may result in

penalties and/or legal action. All access will be disabled and the Company

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 stipend will be terminated with respect to any personal communications
devices used for Company business. Payroll will refund any applicable deposit
to employees who resign or terminate from Everise upon receipt of equipment,
deemed in good working condition. Please note that the deposit you paid is not
a purchase of equipment.

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600 North Pine Island Road, Suite 320 110
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 Data Protection and Privacy Policy

Your privacy is important to us, and we're committed to the protection of your privacy
in your employment with us. This Privacy Policy describes what Personal Data (as we
describe further below) our company (as listed above) as well as any of our
subsidiaries, affiliates, and related entities (together, the "Company") collects about you
as a prior, current, or former employee ("Employee").

This Privacy Policy covers what Personal Data we collect about you, how the Personal
Data will be used and shared (if at all), how the Personal Data will be stored, and your
rights in relation to the collection of your Personal Data during, before, or after your
employment with the Company. It also describes how you can access, modify, and if
needed, request deletion of your Personal Data. This Privacy Policy also covers how your
Personal Data is handled by our third-party data processors.

1. Objective
The objective of this policy is to outline various guidelines pertaining to the privacy of
personal date in conjunction with applicable federal and state law.

2. Scope
This policy is applicable to all Company employees and temporary or contract
personnel.

3. Guidelines
3.1 Company Personnel Files

• The Company maintains accurate and complete employee files regarding all
employees. Personnel files are confidential records that contain employment
records and belong to the Company. These files for the most part are
maintained in Workday. Where historical data is not in Workday, there may be
paper files in the Human Resources Department. In accordance with Company
policy, supervisors may retain copies of some employee records, such as
performance evaluations, non-medically related requests for time off, and/or
disciplinary records in departmental files. However, the supervisor is responsible
for maintaining the confidentiality of these records, limiting access to them and

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 ensuring that the department does not keep the originals of any records.
Supervisors may keep only copies of documents that they have sent to the
Human Resources Department. After a supervisor has used a document for its
intended purpose, the supervisor must promptly send the original to the human
resources department. In maintaining its personnel files, the Company will
comply with all applicable state and federal laws.

• The Company also keeps all employees’ health-related information, including

but not limited to pre-employment physicals, drug screen results, FMLA
certifications and/or ADA accommodation requests in a separate set of
confidential files.

• Designated members of the Human Resources Department who access

individuals’ protected health information in performing health plan
administrative functions will adhere to Company policies in maintaining the
separation between the Company’s personnel files and records used in health
plan administration. Only designated classes of employees, Human Resources
Managers, have access to records related to health plan administration. Except
for those records that indicate whether or not an employee is participating in
the health plan, records used for health plan administration purposes will not be
filed in either an employee’s personnel file or their confidential medical file. All
other information related to health plan administration will be kept in files that
are separate and distinct from the Company’s personnel files. No information
used for health plan administration purposes will be used for any other purposes
or considered in any employment-related decisions.

• Only designated individuals and the HR Department have access to employee

personnel files. Supervisors may request access to the personnel files of the
individuals who report to them, but they will not have access to confidential
medical files. Supervisors must request access to their team’s files by
contacting the HR Manager at their site.

• Employees may have access to their files in accordance with Company policy
and applicable law. Unless approved in advance by the Country HR Head, no
employee can remove personnel files from the area designated for file review.
If an individual is granted the authority to view a file in another location, they
must complete the appropriate form to “check out” the file and must promise to
protect its confidentiality and return the file completely intact by the due date
indicated on the “check out” slip.

3.2 Authorization for Release of Medical Information

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 The Company recognizes and respects its employees’ rights to privacy, including the
right to maintain the confidentiality of their personal medical information. However,
under certain circumstances, the Company may require employees either to provide
specified medical information to a Company representative directly or provide the
Company with an executed authorization form that directs a health care provider to
disclose specified information to the Company. The Company will require such
releases when they are necessary to comply with federal or state law or Company
policies. Examples of the types of medical records the Company may require or
situations when the Company may require employee medical information include, but
are not limited to:

• To comply with the requirements of the Family and Medical Leave Act of 1993
(“FMLA”) and/or similar state law, the Company may need a health care
provider to certify the necessity of an employee’s leave.

• When an employee requests an accommodation pursuant to the Americans

with Disabilities Act (“ADA”) and/or a similar state law, the Company may need
information from an employee’s health care provider in order to comply with
the law and consider the employee’s request appropriately.

• Records related to workers’ compensation, occupational injury and/or

workplace medical surveillance.

• Records related to sick leave requests and/or justifications for sick leave.

• Records obtained for the purpose of determining disability and/or life insurance
eligibility.

• Pre-employment physicals.

• The results of drug screens.

• Fitness for duty test results.

• Records related to alcohol and drug-free workplace laws.

When the Company asks an employee to execute an authorization for a health care
provider to release medical information, it will provide the employee with an
authorization form that sets forth the parameters of the requested use and
disclosure of information. The authorization will identify the information to be
disclosed, the party to whom the information should be disclosed and the purpose
of the requested disclosure. The Company will keep all employees’ health-related
information in set of confidential files that are maintained separately from

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 employee personnel files. Employees may have access to their files in accordance
with Company policy and applicable law.

3.3 HIPAA

• It is the Company’s intent to safeguard and protect the privacy and security of
its applicants’ and employees’ “protected health information” as defined by the
Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the
protected health information of its healthcare clients’ members.

• Employees and managers cannot at any time access, use or disclose to any
person or entity any such protected health information, except as legally
necessary and authorized in the course of their duties and responsibilities.

3.4 No Waiver or Interference with HIPAA Rights

• The Company will not intimidate, threaten, coerce, discriminate against, or take
other retaliatory action against individuals who exercise their rights, file a
complaint, participate in an investigation or oppose any improper practice
under HIPAA. Furthermore, no individual will be required to waive their privacy
rights as a condition of treatment, payment, enrollment, or health plan eligibility.

3.5 Marketing of Data

• The Company does not market confidential data without express written
consent of those whose information may be marketed.

3.6 Duty to Report Violations

• Each employee has a duty to report suspected violations of this policy either
through a phone call or a letter. There will be no retribution against any
employee reporting violations in good faith. Violations can be reported to an
employee’s supervisor, the Human Resources Department or Country HR Head.

3.7 Client Notifications

Should a request for information or a violation of this privacy policy be submitted, the
below steps must be followed:

• Immediate escalation to Leadership by the appropriate Client Services Director;

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 • The Client Services Department will communicate directly with the client within a
reasonable time frame;

• All client policies and procedures will be strictly adhered to with the Company’s full
cooperation; and

• The Company will partner with a client to track and monitor a potential privacy
breach until closure of the issue is mutually reached with the client.

Violations of this policy may result in suspension of work duties, removal of

responsibilities, demotion, termination and/or criminal and financial penalties. Self‐
reporting a violation will not excuse the violation itself. However, the extent and
quickness of reporting will be considered in determining appropriate actions.

Contacts

Contact details are as follows:

All Everise Employees – [email protected]

You may contact us for any questions you have about the handling and processing of
your Personal Data. You may also contact us to have access to your Personal Data or
any other request. If you are unsatisfied with the handling of your Personal Data, you
may make a complaint with the relevant data protection authority.

Collection of Personal Data

We collect different types of Personal Data in different ways. Some of the Personal Data
gathered is automatic (through technologies which give us information about you),
and some of the information is given by you directly to us.

To ensure that we are meeting our responsibilities and duties as your employer, we
collect, process, and maintain different types of Personal Data in regard to those
individuals who seek to be, are, or were employed by us, including, but not limited to:

- Gender

- Marital status, for the purpose of ascertaining and distributing benefits such
as health insurance

- Date of birth

- General contact information, such as address, telephone number, and

email

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 - Resumes that you provide and/or application(s) that you fill out and
provide to us

- Your start date

- Your job title

- The location where you are working

- Any training or education programs you undertake through us

- Professional or personal references

- Company policies and employment forms signed by you

- Payroll Information: This includes, but is not limited to, tax forms such as a
W9, state tax forms, 1099’s, your social security number, bank account
information, additional direct deposit Information, and your photo ID. If, at
any point, your payroll information changes, you will be required to fill out
updated payroll forms. These forms will be kept in your file along with any
previous payroll forms that you have given the Company.

- Forms that contain any information relating to your personal employee

benefits, health care plans, insurance policies and the like.

- Beneficiary information

- The contact information of the individual that you list to be first notified in
the event of an emergency. This includes phone numbers, addresses, and
any other personally identifying information for that individual.

- Assessments, evaluations, performance reviews, training completion rates,

and training scores.

- Any monetary raises, bonuses, stock information, 401k information,

commissions, overtime rate, salaried rate and/or regular hourly rate.

- Any requested time off, accrued paid time off, tardiness, or requests to
leave before the scheduled end of your workday.

- Grievances, including complaints made by fellow employees or clients or

customers, corrective action plans for inappropriate behavior and write-
ups.

- Accolades, including recommendations, awards, or other instances of

recognition for quality work.

- Letter of resignation, if received by the Company

- Letter of termination, if given

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 - Other personal details you voluntarily provide to us

Use of Personal Data

We use the information that we collect about you to effectively run our business and to
help us provide a pleasant, safe, and productive work environment for you.

We also use Personal Data to:

- Accurately process payroll

- Enroll insurance policies

- Manage and plan our business

- Send out business mailings

- Conduct employee reviews

- Handle internal disputes or grievances

- Analyze your qualifications

- Process any claims you bring

- For internal accounting

- Oversee your work

- Put you through education or training

- Generally, comply with applicable law

We only process your Personal Data where we are permitted by law or required to do
so, including where we must process Personal Data for your employment with us, where
we have a legal obligation to do so as your employer, for legitimate business purposes,
to protect your vital interests, or if we have your consent to do so. We may, though, have
to process your Personal Data without your consent or knowledge, but only when
required to do so by law. We won’t make any decisions on the automated processing
of Personal Data without your consent.

We also process your Personal Data to prevent fraud and ensure the security of all
aspects of our business.

Special Categories of Personal Data

Although we do not collect any sensitive data, please be advised that certain types of
data may be considered sensitive under relevant applicable law and if you are asked

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 for any of these categories of data, you may request the purpose for which the data is
required and refuse to provide it, if desired. Sensitive data includes, but is not limited to,
racial and ethnic origin, religious beliefs, political opinions, sexual orientation, criminal
background, health, genetic or biometric data, and trade union membership.

Data Sharing

We only share your Personal Data when to those individuals and entities who assist in
fulfilling our responsibilities within the employment relationship with you or when
required to do so by applicable law (collectively, “Third-Party Service Providers”). These
Third-Party Service Providers include, but are not limited to, the website in which you
submitted your employment application (if applicable) security personnel companies,
payroll information and pay stub viewing applications and companies, scheduling
programs, I9 processing systems, company insurance providers and others similarly
situated to assist in the employment relationship.

We use these Third-Party Service Providers to help us operate the Company, but we’ll
never share your Personal Data other than as described here without your explicit
consent. Personal Data will only be disclosed if such Third-Party Service Providers agree
to ensure an adequate level of protection of your Personal Data that is consistent with
this Privacy Policy. Please note that the Third-Party Service Providers that we utilize will
access your Personal Data only on an “if needed” basis as a part of their partnerships
with us. If you have any questions as to how these Third-Party Service Providers handle
your Personal Data, you may contact them or us.

In certain cases, we may have to disclose your Personal Data to third parties without
your consent or prior knowledge. We limit that disclosure to the following
circumstances:

- To protect our legal rights

- To satisfy any local, state, or Federal laws or regulations

- To respond to requests, such as discovery, criminal, civil, or administrative

process, subpoenas, court orders, or writs from law enforcement or other
governmental or legal bodies

- To bring legal action against an Employee who has violated the law

- In the case of any business transfer, sale, or transfer of assets of the Company

- To generally cooperate with any lawful investigation about our past, present, or
potential employees

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 - If we suspect any fraudulent activity within or in relation to the Company, or if we
have noticed any activity which may violate our ethics, guidelines, or other
applicable rules

Data Transfer

We are based in the United States, specifically in the following city and state: Plantation,
FL. In other words, your Personal Data may be transferred from the location in which
you reside to our physical location in the United States. It may also be transferred to
third parties, as described above, located in the United States. The risks of transferring
data outside of your jurisdiction to the United States include the possibility of data
breaches and loss. Before beginning employment, we ask you to specifically consent
to the transference of your Personal Data to the United States. We will continue to
process your Personal Data in the manner described herein, and if we change anything
about how we handle your Personal Data, including the international transfer of your
Personal Data, we will seek your explicit consent again.

Data Storage and Security

We only store your Personal Data if it is necessary for providing you with the benefits
and protections that employment with us entails or until you cease your employment
with us and request deletion of your data. We may also store your Personal Data for
any applicable legal record-keeping, including after the termination of your
employment or for additional business purposes (e.g., maintaining our accountancy
records or otherwise maintaining the safety and security of our Company, for a time
period permitted by applicable law).

We employ organizational and technical security measures to protect your Personal

Data, such as limiting access to your Personal Data, secured networks, and encryption.
We ensure that your Personal Data is protected against unauthorized access,
disclosure, or destruction by utilizing practices that are consistent with standards in the
industry to protect your privacy.

Please note, however, that no system involving the transmission of information via the
Internet or the electronic storage of data is completely secure, no matter what
reasonable security measures are taken. Although we take the protection and storage
of your Personal Data very seriously, and we take all reasonable steps to protect your
Personal Data, we cannot be responsible for data breaches that occur outside of our
reasonable control. We will, however, follow all applicable laws in the event a data

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 breach occurs, including taking reasonable measures to mitigate any harm as well as
notifying you of such breaches as soon as possible.

Your Rights

You have the right to access your Personal Data and to correct, amend, or delete it if it
is inaccurate or has been processed in violation of this Privacy Policy, except when the
burden or expense of providing access, correction, amendment, or deletion would be
disproportionate to the risks to your privacy, or where the rights of other people would
be violated. To exercise any of these rights, you can contact us.

You may also contact us to restrict the sharing of your personal with third-parties, in
compliance with the California Consumer Protection Act.

If the Personal Data we collect, covered by this Privacy Policy, is to be used for any
purpose materially different from the purpose described here or disclosed to a third
party not acting as our agent, in a manner other than as disclosed here, we’ll always
give you an opportunity to opt-out of this materially different use or disclosure.

Modifications and Revisions

We reserve the right to modify, revise, or otherwise amend this Privacy Policy at any
time and in any manner. If we do so, however, we will notify you and obtain your consent
to the change in processing. Unless we specifically obtain your consent, any changes
to the Privacy Policy will only impact the information collected on or after the date of
the change.

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 Health Insurance Portability and Accountability Act -
HIPAA

• It is the Company’s intent to safeguard and protect the privacy and security of
its applicants’ and employees’ “protected health information” as defined by the
Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the
protected health information of its healthcare clients’ members.

• Employees may not access, use or disclose to any person or entity any such
protected health information, except as legally necessary and duly authorized
in the course of their duties and responsibilities.

• Healthcare organizations, including those that are clients of Everise, Inc, are
required to comply with HIPAA, the federal privacy law that was created to
improve access to health insurance, protect the privacy of healthcare
information, and promote standardization of electronic healthcare related
records. Anyone who may be exposed to HIPAA protected data is required to
safeguard privacy of the protected health information if they encounter such
information.

• Everise, during its partnership with our healthcare clients, will work to ensure we
comply with all federal HIPAA privacy provisions and rules as well as with all
state laws and regulations.

• Everise requires completion of HIPAA training

• within the first 60 days of starting on the program (or sooner if directed
by client)

• when there are updates to the policies or laws

• annually or as necessary to comply with client’s requirements

Protected Health Information

Protected health information (“PHI”) means information that is created or received by

the Company and relates to the past, present, or future physical or mental health
condition of a Patient/Client; the provision of health care to a participant; or the past,
present, or future payment for the provision of health care to a participant; and that
identifies the participant or for which there is a reasonable basis to believe the
information can be used to identify the participant. PHI includes information of persons

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 living or deceased.
For example, the following items are PHI:

• Name
• Social Security Number
• Any geographic location smaller than a state (street address, city, county,
etc.) Dates (date of birth, date of death, date of prescription fill)
• telephone numbers Email, URL, IP Address
• Prescription number, account number, Medicare ID number Any other
identifying unique number, characteristic, or code

• Treatment, payment, hearth care options

• Medical records
• Images of the individual including diagnostic studies (e.g., X-rays, MRIs)
• Any health information that can lead to the identity of an individual or the
contents of the information can be used to make a reasonable assumption
as to the identity of the individual

PHI may be used and disclosed only if necessary and as legally authorized, as part of
an individual’s professional responsibilities. Everyone must help safeguard PHI.

Employees must comply with all applicable HIPAA privacy and information security
policies. If after an investigation you are found to have violated the Company’s HIPAA
privacy and information security policies, you will be subject to disciplinary action up
to termination or legal ramifications if the infraction merits it.

Everise
600 North Pine Island Road, Suite 320 122
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 Health, Safety & Environment Policy

1. Objective
To provide quality workplace conditions that foster a safe and secure environment for
the Company’s employees, customers, and visitors, and safeguard its facility from
intruders, theft, violence, or any other danger.

2. Scope
All Company employees and temporary or contract personnel working on Company
premises.

3. General Guidelines

3.1 Employee Identification Badge

• For security purposes, employees are issued an ID/security badge on their first
day of employment if an employee is at an Everise facility.

• All employees, regardless of their position, must present their ID/security badge
upon entering any Company facility. ID/security badges must be worn and
clearly visible at all times while on Company premises. ID/security badges
should be worn above the waist.

• The ID/security badge allows employees to enter secured areas required by their
job. All employees should carry authorized ID and access badge to enter the
facility and their work areas. Tailgating or piggybacking through a secure
entrance behind another employee and not swiping their access badge each
time they enter their authorized area is strictly prohibited.

• Employees are responsible for their ID/security badges. There is a replacement

cost for lost ID/security badges. Under no circumstances is an employee to use
another employee’s ID/security badge. If an employee forgets their ID/security
badge, a temporary one for use that day may be issued by Security upon receipt
of approval from their supervisor or HR. Temporary ID/security badges must be
returned by the end of the day. There is a replacement cost for unreturned
temporary ID/security badges. The maximum use of a temporary ID/security

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 badge by any employee is three (3) consecutive days, after which the employee
will be required to pay the cost for a replacement badge.

• Failure to adhere to the ID/security badge control procedures may be cause for
disciplinary action, up to and including termination.

3.2 Security Inspections

• The Company maintains a work environment free of illegal drugs, alcohol,

firearms, explosives, weapons, and other improper materials. The Company
prohibits the possession, transfer, sale, or use of such materials on its premises.
The Company requires the cooperation of all employees in administering this
policy.

• Desks and other storage devices are provided for the convenience of employees
but remain the sole property of the Company. A manager with a member of the
Human Resources Department present may inspect a storage device, as well as
any articles found within, at any time, either with or without notice.

• Theft or unauthorized possession of the property of other employees, visitors, or

customers is strictly prohibited. The Company will pursue violators to the fullest
extent of the law. To enforce this policy, the Company or its representative may
inspect desks and storage cabinets, persons entering and/or leaving the
premises, and any packages or other belongings.

3.3 Clean Workstation and Operations Policy

• In general, paper of any kind is not permitted on the production floor including,
but not limited to, newspapers, notebooks, loose leaf paper, paperback books,
and crossword puzzles on a facility floor or for work from home employees with
access to customer data.

• Client-specific paper such as logs, downtime forms, flash training notices, etc.,
or Company-specific paper such as timesheets, login/out reports, QA scan
forms, etc., may be permitted according to client requirements or at the
discretion of management.

• No handwritten notes may be made at the workstation.

• Limited personal belongings are allowed on the workstation desktop.

Everise
600 North Pine Island Road, Suite 320 124
Plantation, FL 33324 weareeverise.com
 3.4 Work Related Injuries

• All employees are protected by the Company’s worker’s compensation

insurance policy while employed by the Company. Coverage is available at no
cost to the employee and covers injury or illness resulting from legitimate work
activities while the employee is working on Company premises, working from
home, traveling on official Company business, or attending a Company activity.

• It is the responsibility of the employee to notify their manager and the HR

Department each time they are involved in or witnesses an accident or safety
incident.

• An employee injured on the job, even if medical assistance is not sought, must
immediately notify a supervisor, regardless of the severity of the injury. A report
of the injury will be completed promptly by the employee and supervisor and
submitted within twenty-four (24) hours to the Human Resources Department.

• The following triage toll-free number is available to provide immediate

assistance to an injured employee: 800-775-5866. Employees are encouraged
to use this service to get prompt medical assistance.

• Failure to report an accident or safety incident is a serious matter and may

preclude coverage under worker’s compensation insurance. When there is a
workplace accident/injury, the employee(s) involved are required to have a
post-accident/incident drug test. Such test shall be coordinated by the Human
Resources Department and/or Operations.

• Employees are to receive authorization from the Human Resources Department

prior to seeking medical attention for any work-related injury or illness. In
emergency situations requiring immediate medical attention, the employee
should seek treatment and submit any associated documentation to their
Human Resources Department upon their return to work.

• Everise does not require managers or employees to be first aid responders, but
care and concern for an injured employee is very important. When in doubt,
please use 911 for emergencies.

3.5 Violence in the Workplace

• The safety and security of the Company’s employees, customers, vendors,

contractors, and visitors are of vital importance. Therefore, acts of violence
made by an employee against another person’s well-being will not be tolerated.

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 Employees found guilty of acts or threats of violence will be subject to discipline,
up to and including termination of employment.

• In accordance with this policy, employees are required to report to

management personnel any behavior that compromises the Company’s ability
to maintain a safe work environment.

• It is everyone’s responsibility to prevent violence in the workplace. Employees

can help by reporting what they see in the workplace that could indicate that a
coworker is in trouble. No one is expected to endanger their own life or health to
help others.

3.6 Weapons

• To the extent allowed by law, the possession or use of any firearm, ammunition,
fireworks, explosives, knives, or other dangerous weapons of any kind on
Company premises is prohibited.

• Employees found with such items will be subject to disciplinary action, up to and
including immediate termination of employment.

3.7 Workplace Monitoring

• The Company reserves the right to install surveillance cameras for legitimate
business purposes, such as ensuring security or preventing theft, except in areas
where privacy is necessary, such as restrooms or changing areas. However,
employees should not have an expectation of privacy on Company premises,
especially in common or public areas.

• The unauthorized recording of conversations, meetings, or other interactions

without the knowledge of those recorded may be illegal, and anyone who does
so may be subject to disciplinary action.

3.8 Inspections and Privacy Expectations

• The Company maintains a work environment which is free of illegal drugs,

alcohol, firearms, explosives, weapons, and other improper materials. The
Company prohibits the possession, transfer, sale, or use of such materials on its
premises.

• In addition, theft, or the unauthorized possession of the property of other

employees, visitors, or customers is strictly prohibited.

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 • To ensure the safety and confidentiality of the employees, clients, and visitors,
the Company reserves the right to inspect Company-supplied property,
including, but not limited to, Company-issued cellular phones, offices, desks, file
cabinets, computers and software, Company vehicles, lockers, and other
storage facilities, are subject to inspection by managers at any time, with or
without notice. Employees should have no reasonable expectation of privacy in
property owned and/or supplied by the Company.

• Employees may be permitted to store personal items in Company facilities.

However, the Company is not responsible for loss, damage, or theft of
employees’ personal belongings; employees should exercise discretion in
storing any personal items on Company premises.

• The Company reserves the right to search all packages, containers, purses,
briefcases, backpacks, lockers, desks, or persons entering or located on
Company premises. Any violation of this policy, including refusal to promptly
permit a search, will result in disciplinary action, up to and including termination.

3.9 Employee Responsibilities

• Employees are responsible for the security of their workstation. Any information
that needs to be left at the workstation, such as useful telephone numbers,
helpful instructions, or tips, will be laminated by operations management.

• Personal belongings may not be accessed from the production floor. Personal
items such as backpacks, lunches, purses, etc., must never be placed on the
workstation desktop. These items must be stored in a locker or placed
underneath the desk. Please be aware some lines of business require all
personal possessions be stored in lockers.

• Any client-specific paper must be turned over to the manager at the end of a
shift.

• The Company may provide lockers for storage of employee personal items but
assumes no responsibility for any loss associated with their use. Employees are
responsible for securing lockers with their own lock. The Company reserves the
right to inspect any locker contents at any time, with or without notice to the
employee. Employees should have no expectation of privacy with regards to the
contents of their lockers.

• Storage lockers may only be used while an employee is logged in and working
at the location. Lockers must be cleared out and the personal lock removed
after the employee’s shift ends. The Company reserves the right to remove locks

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 remaining on lockers after shifts have ended.

• Employees are responsible for parking their vehicle only in designated parking
spots. Employees are not allowed to park in any unauthorized spots. Failing to
adhere to this rule could result in the employee’s vehicle being towed at the
employee’s cost. With respect to sites that share the building with other tenants,
employees should refrain from using their neighbor’s property for congregation,
smoking, playing or any other activity that could result in disrupting their
business.

3.10 Building and Fire Safety

• To ensure the safety and security of our workforce, the Company expects all
employees to become familiar with general fire and evacuation procedures.

• Emergency procedures are reviewed as part of an employee’s initial training.

Such procedures are also available on the Company’s intranet. During an
emergency that requires an evacuation, all employees should remember the
following:

▪ Do not panic.

▪ Do not use elevators.

▪ Always use the nearest exit.

▪ Once you have evacuated the center, move as far away from the
building as possible following evacuation routes to designated areas.
This allows emergency crews better access and ensures a safe
distance from breaking glass.

▪ Do not smoke.

▪ Do not leave the Company premises.

• The Company may have unannounced fire drills to validate the efficiency and
effectiveness of its evacuation procedures.

• Employees are encouraged to contact their supervisor or the HR department

for additional information.

Everise
600 North Pine Island Road, Suite 320 128
Plantation, FL 33324 weareeverise.com
 Search, Inspection & Investigation Policy

1. Objective
It is Company policy, when deemed necessary by management, for authorized
persons to search and inspect both company property and personal items,
including vehicles, brought onto company property. An employee’s refusal to
cooperate in a search, inspection or investigation will result in disciplinary action up
to and including termination.

2. Scope
This policy applies to all employees of the Company. Consultants and temporary
employees are exempt from this policy.

3. Procedures for Conducting Searches

3.1 Decision to search.

The Chief People Officer and Chief Legal Officer are required to approve all
searches prior to their occurrence.

3.2 Conducting searches

3.2.1 A minimum of three management representatives are required to conduct an

unannounced search. Two of these representatives should conduct the search,
and the third representative should record the inventory. Items found and
identifying locations should be noted.

3.2.2 One of the Company representatives conducting the search must be of the
same gender as the person whose belongings are being searched.

3.2.3 The search should be conducted in the following manner:

3.2.3.1 The employee involved will be taken to a private location and informed
that the Company would like to conduct a search and inspection of their
personal possessions (including a vehicle), in accordance with company policy.
The company representative conducting this meeting should ask the employee
if they will cooperate with the search.

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 3.2.3.2 The search should not begin until the employee gives written consent to
the search. An employee who refuses to cooperate with a search request from
an authorized management representative should:

• Not be detained in any way or for any reason but should be informed that a
refusal to cooperate will be grounds for disciplinary action up to and
including termination.

• Be immediately relieved of duty and placed on unpaid suspension pending

investigation.

3.2.3.3 In the presence of the employee, the designated Company

representatives will search as necessary through the employee's locker, work
area, personal items, or vehicle. The designated Company representatives
should record an inventory of all items found during the search and secure
relevant items. The following may be searched:

• Any Company property, including lockers, desks and other individually

assigned spaces.

• Any employee personal property on Company premises, including:

▪ Pockets

▪ Purses/wallets

▪ Briefcases

▪ Cars/trucks

▪ Shopping bags/boxes

▪ Removable clothing

• The employee may be asked to remove a coat, sweater, or similar type of

outer clothing so that it can be inspected. The employee may be asked to
turn their pockets inside out. The search should not include any form of body
searching.

3.2.3.4 After the search is completed, the designated Company representatives

should:

• Conclude the search by either thanking the employee for their cooperation
or by placing the employee on unpaid suspension pending the outcome of

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 the investigation.

• Set up a specific time for the employee to meet with their supervisor, or other
designated Company representative.

• Immediately write a report of the incident, signed by all involved in the search,
including the employee(s). The report(s) should be delivered to the Chief
People Officer or their designee. The following information must be included
in the report:

▪ Reason for the search.

▪ Who was involved in the search.

▪ Where the search was conducted.

▪ Date and time of the search.

▪ What, if anything, was found during the search.

▪ What actions were taken with the employee involved.

▪ What items were seized and what action was taken with the
item(s).

▪ What instructions were given to the employee.

• The Chief People Officer or their designee should immediately report to the
appropriate authorities any illegal items that are found and should
document such notification. These items will be placed in a secure location
until the authorities arrive.

Everise
600 North Pine Island Road, Suite 320 131
Plantation, FL 33324 weareeverise.com
 Rewards And Recognition Policy

1. Objective

Implement a Rewards & Recognition Program that recognizes the employees by

exemplifying the core values of Everise through their interactions with customers,
client, and co-workers.

2. Scope

The guidelines identified in this process is applicable to all employees of the

United States based on the terms, conditions, and eligibility of the respective
program.

3. Responsibility

This program is managed by the Human Resources Department in collaboration

with each function.

Team Responsibilities

To track the overall program mechanics and implementation.

HRBP The HRBP will manage all relevant documentation and
communication of all rewards and recognition programs

To ensure that all forms of rewards are reflected in the Workday

profiles of employees when applicable. The HRMS team is
HRMS
responsible for including any monetary rewards in the payroll
instruction reports

To ensure all rewards reported for payroll processing to be

Payroll
included in the payroll schedules for crediting

4. Various Reward Programs:

4.1 Rockstar Awards

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 4.1.1 Overview

Positive feedback and a job well done are positive ways to recognize
employees for accomplishing their tasks, going the extra mile, and
helping their co-workers. The Rockstar Awards are a global R&R
program aimed at recognizing Everisers exhibiting the company’s
core values.

4.1.2 Eligibility

4.1.2.1.1 You Rock Award is a general kudos that an employee can

give to a co-worker or anyone the employee interacts with
for a positive experience or effort worth commending. This is
given to any organization that has exhibited a positive deed
or behaviour related to the 3 Everise core values.

4.1.2.1.2 Rock Rookie is an award given to a new hire on training or

any employee attending a class or learning session for
outstanding participation or shared impact during activity.

4.1.2.1.3 Rockstar of the Week is an award given to those who have

accomplished an outstanding/significant task, goal, project,
or action item. A Superior, Customer, Client can give this, or
anyone Everise conducts business with.

4.1.2.1.4 Game Changer is an award given to an employee with

outstanding work performance in a month or a quarter
based on the set overall performance target by the
program or department.

4.1.2.1.5 Standing Ovation is an award given to the most outstanding

employee of the site. This is awarded and commended by
the Site Head, CEO, or President.

4.1.3 Guidelines

4.1.3.1.1 All commendations must be submitted to the Human

Resources team.

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 4.1.3.1.2 Commendations should include details such as the name
of the employee, the commendation or testimonial, and
their photograph.

4.1.3.1.3 The supervisor shall create and provide the awardee's

certificate, which will be handed over during their team
meetings or team events.

4.1.3.1.4 HR shall include the awardee in the weekly announcements

and post certificates in closed Facebook groups,
engagement channels in Teams, and LinkedIn.

4.1.3.1.5 Leaders are encouraged to post their Rockstars on LinkedIn.

4.2 Anniversary Recognition

4.2.1 Overview

Each month, Everisers celebrate their tenure milestone in the

organization. The Anniversary Recognition is done through an email
certificate received by the awardee on their Anniversary.

4.2.2 Eligibility

All Everisers celebrating their work anniversaries based on their hire

date are eligible.

4.2.3 Guidelines

4.2.3.1.1 HR maintains a database of all employees’ hire dates.

4.2.3.1.2 On the day of an employee’s work anniversary, HR sends an

email certificate to the awardee and their respective
Supervisor.

4.2.3.1.3 HR shall include work anniversary recognition in closed

Facebook groups, engagement channels in Teams, and
LinkedIn.

4.2.3.1.4 Leaders are encouraged to post their awardees on LinkedIn.

Everise
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 4.3 Tenure Awards

Everise recognizes each of our Champions who have stayed with Everise to
support our business. Your dedication and longevity will be recognized
through the Everise Tenure Awards.

4.3.1 Eligibility

The Everise award program is available to all Everise Champions who

are regular full-time employees in good standing. All employees
whose anniversaries fall within the fiscal year will be honored.

An employee is eligible to receive their first award once they hit their
10-year anniversary date with Everise.

4.3.2 Tenure Schedule

The following tenure schedule will be awarded:

Years of Service Amount of Award

Champion X - 10 Years $1,000 per person

Champion XV - 15 Years $1,500 per person

Champion XX - 20 Years $2,000 per person

Champion XXV - 25 Years $2,500 per person

4.3.3 Termination of Employment

Employees who terminate employment prior to the service award

anniversary date are not eligible for the award.

4.3.4 Inactive Status

Employees eligible for a service award while on vacation or other

inactive status (e.g., leave of absence, military duty, disability) will
receive the award upon returning to work and resuming active status.

Any deviation to this process will need the approval of the Chief People Officer and
Global CEO.

Everise
600 North Pine Island Road, Suite 320 135
Plantation, FL 33324 weareeverise.com
 Taxable Income – Gifts and Cash/Gift Card Policy

The IRS requires that any cash benefit or incentive be taxable, including gift cards. The
IRS requires that gift cards be taxed as ordinary income and reported at the time they
are made available to the employee.

However, “de minimis” fringe benefits can be excluded from taxable income. De minimis
benefits are those that are so small as to make accounting for them unreasonable or
impractical.” For example, occasional tickets for entertainment events; holiday gifts;
holiday turkey; coffee mug; water bottle; flowers, fruit, books, provided under special
circumstances, etc., with a value of less than or equal to $100 are not taxable.

The IRS has ruled that items with a value exceeding $100 cannot be considered de
minimis. Additionally, cash and cash equivalent gifts or prizes (such as gift certificates)
cannot be considered de minimis or excluded from income because there is no
difficulty in accounting for such prizes. As a result, all gifts cards that serve as a cash
equivalent – for example, a $25 Amazon.com gift card or a Visa cash card –will be
taxable regardless of the amount.

Everise
600 North Pine Island Road, Suite 320 136
Plantation, FL 33324 weareeverise.com
 Work-at-Home Policy

The following work-at-home requirements for remote employees are meant to ensure
that an employee’s remote workspace is properly protected against:

• theft of equipment or information

• the unauthorized use or disclosure of information

• unauthorized access to the company or client systems

1. Employee is required to take and pass computer-based training on security

awareness and privacy responsibilities prior to their being authorized to participate
in the Work-at-Home program.

2. Employee is required to comply with all the company’s security policies and
procedures, including any non-disclosure policy or agreement signed by the
employee upon hire, regardless of work location.

3. Employee must have a dedicated workspace.

4. Employee must submit two photos of their workspace to their immediate supervisor
within 15 days after setup. The photos must show the full workspace from two
different angles and all equipment that was provided by the company or the client,
as applicable. The photos should not include any personally identifiable information
(PII), protected health information (PHI) or payment card information (PCI).
Workspace audits may occur at any time at the company’s discretion.

5. Employee must maintain an encrypted broadband Internet connection at their own

expense. The speed must comply with company specified requirements.

6. The use of equipment, software, data, supplies and furniture when provided by the
company for use at the remote work location is limited to use by employees
performing their assigned job duties.

7. No one other than the employee should be allowed in the workspace during a shift.
Care-giving (dependent, pet, etc.) is not permitted while performing Work-at-Home
duties for clients. If care is needed for a dependent or disruptive pet, the employee
is responsible for arranging for alternate care. Emergency or temporary situations
may relax these requirements, but any exceptions must be clearly documented.

8. Email and chat applications on the desktop should be used exclusively for company
business to communicate with supervisors and receive updates.

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 9. No personally identifiable information (PII), protected health information (PHI) or
payment card information (PCI) should be included in an email or sent via chat.

10. Employee will not be paid for any reason involving equipment failure/internet
outages except where otherwise specified in the company’s handbook and
timekeeping policies.

11. When Work-at-Home activities are terminated, the employee is responsible for
returning all company and client equipment to the company in good repair. If the
employee fails to return the equipment in good repair or at all within seven days
after termination, lack of return in good repair may result in penalties and/or legal
action.

12. Your work at home office location has been approved based on several factors
including:

a. the state you reside in, which Everise is currently authorized to conduct
business in.

b. the speed test that you provided.

c. the site setup and pictures that you provided.
d. the internet site address of your home.
e. client requirements.

Changing your location, whether temporarily or permanently, could negatively

impact client and legal requirements. Therefore, you must notify Everise at least
two weeks in advance if you plan to change the location of your work at home
office to a different country or state home location. You may risk your employment
status if you fail to do so.

The email for providing your notification should be addressed to your

supervisor/manager, HR manager and a copy should be sent to Human Resources.
You may contact Human Resources through Workday which can be accessed on
Workday through the Workday portal from your desktop, Workday mobile app, and
Workday Bot (on Workday portal).

The HR and Operations team will review and decide as to whether the location
change will be approved.

Everise
600 North Pine Island Road, Suite 320 138
Plantation, FL 33324 weareeverise.com
 For technical assistance, the Global Service Desk may be contacted at:

Phone: 877-493-4357 24 x 7

Application: http://c3servicedesk.c3connect.lan

Chat: https://tinyurl.com/ev-gsd-chat.

Everise
600 North Pine Island Road, Suite 320 139
Plantation, FL 33324 weareeverise.com
 Equipment Guidelines

These guidelines for equipment deposits, equipment failures, internet outages and
electrical outages are below. Any item not clearly specified is required to be
reviewed and approved by the Global COO.

All equipment provided is the property of Everise. Per the terms each employee
agreed to in their offer letter, Everise will deduct a total of $90 in three instalments
of $30 each from the first three pay checks as a non-interest-bearing property
return security deposit; however, no deduction will reduce pay below minimum
wage for the pay period in question. Note: If an employee is assigned to a Group 2
program (see the Program Information Sheet for the Group assignment), the
property return security deposit does not apply as long as the employee remains
on that program.

Additionally, if all company-owned property is returned on time in good repair,

normal wear and tear excepted, the full amount of the property return security
deposit will be refunded within 21 days after the date that the last of such items has
been returned to the Company.

If any equipment is not returned within 21 days, or if a returned item must be

repaired to be usable by another employee, the Company may deduct the
reasonable cost of replacing or repairing the item from the amount of the property
return security deposit.

Employees will be paid for equipment failures with an accompanying IT Ticket for
the following reasons:

• Client system outage confirmed by the Team Leader/Supervisor or

Operations Manager.
• Everise hardware failure (except if the result of damage by user) maximum
of 2 shifts or 16 paid hours to send replacement equipment.
• Everise major incident impacting application access if incident is handled
within 8 hours, no more than one shift or 8 paid hours.
• Issue with Everise password if password portal is down (to get paid user must
share details of errors/issue with Global Service Desk promptly) up to 8 paid
hours per month.

Everise
600 North Pine Island Road, Suite 320 140
Plantation, FL 33324 weareeverise.com
 Employees may be paid for the following on a case-by-case basis after review of
tracking information and validation with carrier and employee Supervisor

• Shipment delay by Everise authorized vendor (for example Amazon Business

Services).

Employees will not be paid for equipment failures for the following reasons:
• User ISP or electrical issues
• Asset damaged by user
• Hardware issue with user-owned equipment
• Evidence of behavioral issues (Ex: VPB lost show successful login against user
claim of inability to login)
• User is unavailable to troubleshoot following repeated follow up by Global
Service Desk.
• Delay in equipment delivery due to user being unavailable to receive it.
• User providing incorrect information regarding error that delays resolution of
the issue.
• Password reset issue as a result of user not registered on password portal.

What Constitutes Company Equipment, Intellectual Property and Data?

• Company equipment includes Client assets, laptops or desktop computers,

including accessories (such as docking station, monitor, power cord,
connection cables, carry case, external CD drive, etc.), software, hardware,
headsets, y-cords, Company data in the form of files, documents, e-mail, or
"soft copy" data that is linked in any way to any part of the Company, its
clients and partners, books, training materials and manuals.
• Company-issued cell phones must also be returned, while personal cell
phones used for Company purposes will be subject to a full "wipe" of all
Company information.

Employees may be placed on final written warning for damaging any company
equipment in their possession. Employees may also be held legally liable for
reimbursing the cost of damaged equipment in accordance with applicable laws.

Eff: 03/25/2022

Everise
600 North Pine Island Road, Suite 320 141
Plantation, FL 33324 weareeverise.com
 Headset Policy

Objective

The objective of this policy to define the guidelines for headsets.

Scope

All employees whose jobs involve usage of headsets across various sites of the U.S.

Guidelines

Headsets are to be provided by each employee and remain in good working

condition throughout employment with Everise.

This policy applies to both work-at-home and onsite employees.

Use of one of the following headsets is required:

• Plantronics 3320 Blackwire – Approx. $55.00 on Amazon

o No other cords required

• Plantronics 5220 Blackwire – Approx. $81.00 on Amazon

o No other cords required

• Plantronics EncorePro 520 – Approx. $75.00 on Amazon

o Requires the purchase a DA80 USB Plug Adapter. Approx. $20.00on

Amazon

• Note: Amazon is only noted as an example of cost estimation

Damage or Headset replacement for Existing Employees

Employees are responsible for replacing the headset if it lost or damaged and
cannot be repaired or repairing it if it is damaged.

Everise is not responsible for payment of wages for any employee downtime orloss
of productivity due to a lack of a headset.

Employee Resignation/Termination

Everise
600 North Pine Island Road, Suite 320 142
Plantation, FL 33324 weareeverise.com
 Headsets need not be returned to the company, including supplied by Everise priorto the
effective date of this policy.

Employees Moved to Work from Home in 2020

For employees moved to Work at Home in 2020 from an Everise facility, the equipment
deposit already withheld for a headset while on site reverted to a full equipment
deposit. To avoid confusion, while this is a headset policy, as of Dec. 1, 2021, those who
fall under this category should understand that their deposit is considered a full
equipment deposit and all policies related to returning equipment apply to receive the
return of any deposits made while an employee at an Everise Facility. Please note that
the ”deposit” you paid is not a purchase of the equipment. You are required to return
all company and client equipment back to Everise if you leave the company, and in
some instances, change positions.

Policy Deviation

Any deviation from this policy must be preapproved by the Chief People Officer. This
policy is effective as of December 1, 2021. Management reserves the right to modifythis
policy or rescind it entirely at any time.

Effective: January 1, 2021

Everise
600 North Pine Island Road, Suite 320 143
Plantation, FL 33324 weareeverise.com
 Monitor Policy
1. Objective

The objective of this policy to define the guidelines for computer monitors.

2. Scope

This policy applies to all employees whose jobs involve usage of Everise computer
monitors while working from home across the U.S.

3. Guidelines

• One monitor will be provided to each employee upon employment with Everise.
The monitor should remain in good working condition throughout the
employee’s employment.

• The monitor provided by Everise could be contained in an All-in-One unit, in this

case the monitor is provided in that device.

• All Everise client programs require production staff to use a 2nd monitor. The
employee must provide a 2nd monitor at their own expense.

4. Damaged Monitors for Existing Employees

• Employees who have monitors provided by Everise are responsible for shipping
back any monitor that is broken or cannot be repaired. The Company will not
replace a second monitor, as it will be the employee’s responsibility to provide
their own 2nd monitor going forward.

• Everise is not responsible for payment of wages for any employee downtime or
loss of productivity due to a lack of a second monitor

5. Employee Resignation/Termination

• Monitors must be returned to the company (along with all company and client
equipment provided), including monitors supplied by Everise prior to the
effective date of this policy.

• Payroll will refund any applicable deposit to employees who resign or

terminated from Everise upon receipt of equipment, deemed in good working
condition.

• Any deviation from this policy must be preapproved by the Chief People Officer.

Management reserves the right to modify this policy or rescind it entirely at any time.

Everise
600 North Pine Island Road, Suite 320 144
Plantation, FL 33324 weareeverise.com
 Effective: July 27, 2021

Web Clock Acknowledgement

Everise, Inc (“Everise” or the “company”) has provided me with a web clock provided by
Workday, the Everise HR/payroll system, as a method for entering my time for each shift.
In connection with this new system for logging in my time, I acknowledge as follows:

• The company will add 5 minutes to my payroll for each shift I work to allow me
adequate time to access the web clock at the start of my shift.

• The 5 minutes of additional wages per shift accurately reflects the time it takes
for me to access the web clock.

• By adding 5 minutes of wages to each of my shifts, the company is making

reasonable efforts to ensure that my wages fully compensate me for the
number of hours I’ve worked.

• If I experience issues with accessing the web clock at the start of a shift, I will
immediately report the issue to my supervisor, who will determine whether
additional time should be added to the 5 minutes allotted for that shift.

• I understand that I have access to Workday and that it is recommended that I

access Workday on a regular basis to check the number of hours I’ve worked
during each two-week pay period.

• If I have any questions regarding Workday, how to access Workday or my payroll

information, I am aware that my supervisor or the HR Department at my work
site is happy to answer any questions or assist me with access to Workday.

• My supervisor will determine and communicate if I should utilize the web clock
or another company-approved means of tracking time. I will use the method
assigned by my supervisor.

Everise
600 North Pine Island Road, Suite 320 145
Plantation, FL 33324 weareeverise.com
 Compensation & Benefits Policy

1. Objective
To help employees understand the different components of their compensation
structure.

2. Scope
This policy applies to all regular full-time employees of the Company.

3. Compensation Components

3.1 Mandatory Deductions

• Mandatory payroll deductions, as required, are withheld for Federal and State (if
applicable) Withholding Tax (FIT/SIT), Social Security Taxes (FICA), Medicare and
Court-ordered wage garnishments.

3.2 Base Pay

Base pay is an independent component of the salary structure. It determines the

employee’s gross salary & differentiates the compensation of the employees within
a band/level. It is fully taxable as per current tax legislation.

3.3 Bonus/Incentive

• A bonus or incentive refers to any compensation above the base hourly wage
or salary. This includes, but is not limited to, performance bonuses, referral
bonuses, sales incentives or any other compensatory cash or prizes.

• A bonus or incentive may vary depending on the employee’s specific position

and on specified requirements having been satisfied.

• Bonuses or incentives are payable at the sole discretion of the Company

depending on the employee’s and Company’s performance during the year.
Bonuses or incentives are subject to deduction of applicable income and payroll
taxes.

Everise
600 North Pine Island Road, Suite 320 146
Plantation, FL 33324 weareeverise.com
 • Bonuses or incentives are payable only to employees who are on the payroll of
the Company on the date of the cash payout.

3.4 Overtime

• Although working overtime is normally not mandatory, employees are required

to share in their department’s overtime needs when circumstances arise. When
the Company does require overtime work, refusal of overtime may be cause for
disciplinary action up to and including termination.

• Overtime is paid at a rate of time and one-half to non-exempt employees. In all

cases, overtime must be pre-approved by the employee’s immediate
Supervisor.

• Overtime hours are calculated based on the actual number of hours worked in
excess of 40 hours per week (unless state law dictates otherwise), excluding all
paid, but unworked hours, such as Holiday, Vacation, Personal leaves or any
other leave of absence.

• Each employee approved for overtime will be required to work their scheduled
hours. Changes should be coordinated in advance through their Supervisor.

3.5 Administrative Pay Corrections

• Everise takes all reasonable steps to ensure that employees receive the correct
amount of pay in each paycheck and that employees are paid promptly on the
scheduled payday. In the unlikely event that there is an error in the amount of
pay, the employee should promptly bring the discrepancy to the attention of
their direct manager so that corrections can be made as quickly as possible.

3.6 Salary Advances

• In general, the Company does not provide salary advances. In emergency
situations, an advance may be granted by the Company under certain
conditions.

• The employee will be required to demonstrate the urgent need for the advance
and provide appropriate documentation when requested prior to the advance
being issued.

• In no case will the amount of the advance exceed 65% of the amount already
earned in the pay period. Advances are repaid the following payday.

Everise
600 North Pine Island Road, Suite 320 147
Plantation, FL 33324 weareeverise.com
 • An employee may not receive more than two advances each rolling twelve-
month period.

• All Advances are approved by the Chief People Officer. The company does not
provide loans to employees.

4 Pay Period and Direct Deposit

• The two-week pay period begins on Sunday morning at 12:00 a.m. and ends on
Saturday at 11:59 p.m. for all employees.

• Pay day is every other Friday. Employees are paid for the two-week period ending
at 11:59 p.m. the previous Saturday.

• The Company pays all active employees via direct deposit or stored value cards.
Direct deposit information may be updated online via Workday at any time.

5 Payroll Deductions

The Company withholds legally required deductions from the total amount an
employee earns each pay period. The Company will, with the employee’s prior written
authorization, withhold additional deductions.

6 Salary Confidentiality

The Company maintains salary records for each employee on a confidential basis.
Some employees, while performing their regular job duties, may come in contact with
salary records. Failure by those employees to adhere to the Company’s policy on
maintaining the confidentiality of the Company’s records of the salaries of other
employees may subject them to disciplinary action up to and including termination.

7 Benefits

7.6 Health Insurance

• Employees who have met the eligibility requirements in their respective position,
and who are scheduled to work an average of 30 or more hours per week, are
eligible for group health insurance.

• A change of name, address, telephone number, number of dependents or

Everise
600 North Pine Island Road, Suite 320 148
Plantation, FL 33324 weareeverise.com
 marital status must be reported to the HR Department immediately. These
changes may affect eligibility for benefits.

• Health insurance laws require employees to inform the Company within 30

calendar days after an event such as divorce, death, or loss of legal custody
that results in a spouse’s or dependent’s loss of eligibility for insurance benefits.

• Legal dependents may be covered by an employee’s medical insurance until

age 26 unless the dependent has coverage available through their own
employer or state law dictates otherwise.

• Benefits plans may be amended at any time at the Company’s sole discretion.
Please review the benefits summary provided to each employee for additional
information regarding these policies.

7.7 Everise Insurance Benefits

The Company offers the following benefits package designed to meet employee needs
employees. For more detailed information, please refer to the specific policy or the
Summary Plan Description (SPD) of the specific benefit plan or contact the Human
Resource Department for more information.

Benefits for full-time employees are as follows:

• Basic Life Insurance

• Flexible Spending Accounts

• Medical, Dental, Vision

• Short-Term Disability

• Long-Term Disability (exempt employees only)

• Prescription Coverage

• Everise Retirement Savings (401(k)) Plan (also available for part-time

employees)

• Prepaid Legal Insurance

• Supplemental Life Insurance

• Supplemental Accidental Death & Dismemberment Insurance

• Tuition Reimbursement

• Critical Illness Insurance

Everise
600 North Pine Island Road, Suite 320 149
Plantation, FL 33324 weareeverise.com
 • Accident Insurance

• Employee Assistance Program

7.8 Tuition Assistance Program

• Everise encourages the professional and personal growth of all its employees
by offering tuition assistance to support the academic pursuits of eligible
employees.

• All courses must be approved by respective supervisor, the site director, and
Human Resources Department prior to the start of the course to be eligible for
reimbursement.

• Courses should be related to the business of Everise. An employee may not

receive tuition assistance if they are under warnings of any kind.

• Full-time employees with a minimum of 180 days of continuous service are

eligible for tuition assistance.

• Employees must be employed at the time of reimbursement with the likelihood

of continued employment.

• Final grades must be submitted within 30 days of course completion to be

considered for reimbursement.

• Each year a maximum amount toward tuition assistance is determined for the
entire Company. Once this has been reached, no new tuition assistance
requests will be approved for the calendar year.

7.8.1 Reimbursement of Tuition Cost

• Reimbursement of tuition costs is based on the following rates:

▪ 100% for a grade of “A”

▪ 75% for a grade of “B”

▪ 50% for a grade of “C”

▪ No reimbursement for grades of “D” or “F”

• Reimbursement of tuition expenses is limited to a maximum of two (2)

courses per semester and $1,000 per rolling 12-month period for approved
courses.

• Employees leaving the Company within one year of reimbursement shall be

Everise
600 North Pine Island Road, Suite 320 150
Plantation, FL 33324 weareeverise.com
 required to repay tuition assistance benefits on a prorated basis of 1/12 th per
month.

7.9 Domestic Partners

Employees who are not married but who meet the requirements are eligible to register
their domestic partners for purposes of benefits. Domestic partners are eligible for
health, dental, vision, the Employee Assistance Program, life insurance, accidental
death and dismemberment insurance, wellness programs, and other benefits and
services provided by the Company.

7.10 Flexible Spending Plan

• Regular employees working an average of 30 or more hours per week are

currently eligible to participate in the company’s Flexible Spending Plan.

• This plan provides participating employees the choice of receiving certain

benefits on a pre-tax basis.

• Employees may enroll in the flexible benefits plan during open enrollment at
year end for the next coming year (April 1 through March 31). The election is
irrevocable after January 1 of each year unless the employee experiences a
family status change.

• Elections will not continue from one year to the next; a new election must be
made each year.

7.11 Types of Plan

• Flexible Spending Account (FSA): Employees may elect to have a specified

amount of their salary redirected, before it is taxed, to a fund from which they
can cover any qualified out-of-pocket expenses.

• Medical and dental reimbursement for medical, dental, prescriptions, vision,

etc.

• Dependent-care reimbursement to cover qualified dependent-care

expenses.

• Medical and dependent-care expenses that are reimbursed must have been
incurred during the period of coverage under the plan even though the
expense may not be billed or paid until a later time. Qualified expenses

Everise
600 North Pine Island Road, Suite 320 151
Plantation, FL 33324 weareeverise.com
 incurred during the plan year may be submitted for reimbursement up to 60
days after the end of the plan year.

8 COBRA – Continuation of Benefits

• The right to continuation coverage for group health plan benefits was
created by federal law, the Consolidated Omnibus Budget Reconciliation Act
of 1985 (“COBRA”).

• COBRA continuation coverage can become available to you when you would
otherwise lose your group health coverage.

• It can also become available to other members of your family who are
covered under the group health plan when they would otherwise lose their
group health coverage.

• Continuation of coverage under the COBRA program requires monthly

payments of 102 percent of the Everise full premium cost and is valid for a
limited time.

• For additional information about your rights and obligations under the group
plan and under federal law, review the plan's Summary Plan Description
(SPD) or contact the HR Department.

9 Retirement Savings Plan

• The Company has established a 401(k) tax-deferred savings plan, known as

the Everise Retirement Plan and a ROTH 401(k) post-tax-deferred savings
plan, for our employees (both for full-time and part-time).

• These plans are intended to provide a means for employees to voluntarily

join a savings investment plan to supplement retirement income.

• Employees are automatically opted into the plan. If an employee does not
want to participate, they may opt out by calling OneAmerica or creating an
account and changing their deferral to 0. This does take 1-2 pay periods to
complete.
• The maximum amount allowed by law may be invested in the plan.
Deductions in the amount requested by the employee are automatically
deducted from gross pay.

Everise
600 North Pine Island Road, Suite 320 152
Plantation, FL 33324 weareeverise.com
 • After the employee meets all eligibility requirements, Everise may elect to
match contributions to this fund based upon the current plan document and
business performance.

10 Company Contributions/Profit Sharing

• As per current Company policy, the employee pays a portion of the health
care premium. While on paid leave, the Company will continue to make
payroll deductions to collect the employee’s share of the premium.

• While on unpaid leave, the employee must continue to make this payment,
either in person or by the mail.

• The payment must be received by the FMLA administrator by the first day of
each month. If the payment is more than thirty (30) days late, the employee's
health care coverage may be dropped for the duration of the leave.

• If the employee contributes to a life insurance or disability plan, the Company

will continue making payroll deductions while the employee is on paid leave.

• While the employee is on unpaid leave, the employee may request

continuation of such benefits, and pay their portion of the health care
premium. If the employee does not continue these payments, the employer
may discontinue coverage during the leave.

Everise
600 North Pine Island Road, Suite 320 153
Plantation, FL 33324 weareeverise.com
 Internal Job Posting (“IJP”) Policy

1. Objective

This policy is intended to provide an opportunity to apply for open positions within the
organization, for promoting career growth and effective utilization of the skills aligned
with the Company objectives.

2. Scope

This policy applies to all regular full-time employees of the Company who meet the
policy’s requirements.

3. Eligibility Requirements

For any open position received by the talent acquisition team, internal employees shall
be assessed through IJP prior to assessing external candidates.

The following will be the eligibility guidelines for the IJP movements:

3.1 Lateral IJPs – Minimum 6 months in production in the current role, which
does not include nesting time, with a performance rating of “Meets
Expectations” and above.

In addition, all required training and development programs must be

completed.

The employee must apply to the position to be considered.

3.2 Vertical IJPs – Minimum 6 months after production in the current role, with a
performance rating of “Meets Expectations” and above.

• An employee with a written warning for behavior or performance issues

will not be eligible. Employees with one verbal warning are eligible.
(Pertains to U.S.)

• An employee with one NCNS within a 6-month period is eligible.

Everise
600 North Pine Island Road, Suite 320 154
Plantation, FL 33324 weareeverise.com
 • The employee must apply for the position to be considered.

• All required training and development programs must be

completed.

• In case an employee applies for simultaneous multiple IJPs, and if

they get selected in any of these, the employee will automatically
not be eligible for the other lateral IJPs that the employee has
applied for.

• Additional qualifiers can be added over and above the defined IJP
policy depending on the skill requirements for any position by talent
acquisition in consultation with the department head.

4. Guidelines

Application of IJP is fully automated through Workday, and the step-by-step

process is as below:

• Talent acquisition will obtain approvals and release the IJP through internal
communication emails and other appropriate channels which may include
posters, intranet, etc.

• The communication should specify the skillset required, the job description,
eligibility criteria in terms of performance scores, tenure, etc. with an end date
of submission of applications.

• Upon the release of the IJP, eligible employees shall submit their applications
through Workday, wherein the application will be auto-routed to their
supervisors and department heads for approval.

• On receipt of recommendations from the respective managers, talent

acquisition, in consultation with the Department Head, shall discuss the IJP
evaluation process (i.e., written tests, group discussion, personal interview,
etc.) along with the supervisor’s ratings.

• The final results of the IJP will be based on the evaluation.

• Feedback will be arranged along with talent acquisition and specific lines of
business for those employees who do not qualify the evaluation.

Everise
600 North Pine Island Road, Suite 320 155
Plantation, FL 33324 weareeverise.com
 5. Selection and Deployment

• On completion of the IJP selection process, the talent acquisition team will
announce the results of the evaluation to the employee.

• Selected employees shall be released from their current role on or before a

30-day period from the time an employee is selected.

6. Compensation

• For all lateral movements, there will not be any immediate increase in
compensation. However, if an employee is moved to a new department or
line of business and the base pay is less than the minimum salary grade of
the new department/line of business, the existing base pay shall be brought
at par with the minimum grade of the new position.

• For all vertical movements, if the base pay of the selected employee is higher
than the minimum salary grade of the promoted level, the existing base pay
shall be increased based upon the new role.

• If the base pay of the selected employee is lower than the minimum base
pay of the promoted level, the existing base pay shall be brought at par with
the minimum grade of the new position.

• IJP movement letters will be issued to the selected employee by a Human

Resources Representative with the changes in title or compensation along
with the corresponding effective date.

7. Transfer process

7.1 The internal transfer process is as follows for all promotions outside of the
employee’s current function.

• An employee who would like to be considered for internal openings must qualify
and apply through Workday. Refer to section 4

• Talent Acquisition team will advise if the employee is eligible to apply once the
application is approved by their supervisor.

Everise
600 North Pine Island Road, Suite 320 156
Plantation, FL 33324 weareeverise.com
 • Once the employee is selected, the Talent Acquisition team will forward the
information to Human Resources to discuss with the hiring manager and seek
appropriate approvals.

* Verification of compensation and recommendations of compensation is

managed by the Human Resource function*

• Human Resources will notify the Talent Acquisition team whether the transfer
has been approved.

• When approved, the Talent Acquisition team will coordinate with the current
supervisor on the effective date of transfer and document in writing to Human
Resources.

• Once the promotion process and approval requirements are completed,

Human Resources will prepare a promotion letter and provide it to the
employee for signature.

• Upon receipt of the signed promotion letter from the employee, Human
Resources will complete the final process requirements in Workday.

7.2 Transfer process for agent bulk moves

Please contact Human Resources for information on the internal transfer process for
agent bulk moves.

Exceptions to this policy may be made, based on business necessity, with the written
approval of the Chief People Officer.

Everise
600 North Pine Island Road, Suite 320 157
Plantation, FL 33324 weareeverise.com
 Promotion Policy

1. Policy Purpose

1.1.1 The purpose of this policy is to outline the principles, requirements, and process for
promotions within the company. It also sets out the minimum standards that should
be adhered to.

The Company is an equal opportunity employer. Promotion decisions are based on

merit, experience, and potential, without regard to race, color, national origin,
gender/sex, marital status, age, religion, disability, sexual orientation, ethnicity, veteran
status or any other characteristic protected from discrimination by applicable federal,
state, or local laws.

2. Policy Statement

2.1.1 The Company’s promotion philosophy is fundamentally based on the concept of

“promotability of the candidate.” It requires employees to have demonstrated
behaviors and capabilities needed to be elevated to the next level of responsibility, over
and above being an exceptional contributor.

Recommendations for promotion should be based on the following factors:

• Sustained performance of the candidate

• Potential displayed by the individual for taking on higher responsibilities

• Availability of vacancies

Recommendations may not be based on:

• A managers’ subjective opinions unsupported by performance or metrics

• Discrimination

• Fraternization

• Favoritism

• Nepotism

Everise
600 North Pine Island Road, Suite 320 158
Plantation, FL 33324 weareeverise.com
 Promotions shall be role-based except in case of the following:

• SVP to EVP (Band 1)

• Director to Senior Director (Band 2)

• Manager to Sr. Manager (Band 3)

• Lead to Assistant Manager (Band 3)

• Assistant to Specialist (Band 4)

This policy shall not apply to the Sales function, as the roles are completely market-
facing.

3. Procedures

3.1 Eligibility Requirements

3.1.1 The following requirements must be met for an employee to be considered for
promotion:

• Job – The employee must meet the minimum requirements contained in the
role’s job description. The employee must also be able to perform the
essential functions of the position, with or without reasonable
accommodation.

• Good Standing – The employee must be in good standing (be clear of a

Performance Improvement Plan or any disciplinary action for a minimum of
one year).

• Minimum Tenure – The employee must meet the minimum tenure

requirements specified in paragraph 3.2 below.

• Performance – A business case will need to be submitted that demonstrates

the following during the required tenure period:

o KPI/Scorecard performance requirements that were met

o Measurable performance impact in 2 or more of the following areas:

• Reduced expenditures

• Increased revenue

• Improved process efficiencies

Everise
600 North Pine Island Road, Suite 320 159
Plantation, FL 33324 weareeverise.com
 • Enhanced client experience

• Enhanced employee experience

• Innovation

o Company values that were demonstrated

o How the company’s diversity initiatives are supported

• Employee Potential – The employee must have demonstrated the potential

to take on higher roles and responsibilities.

The mere eligibility of these requirements shall not guarantee an automatic

promotion. The employee’s promotion must also be approved per the requirements
specified in section 3.2 below.

Exceptions to these requirements may only be made upon the unanimous approval
of the Global CEO and CPO.

3.2 Process Requirements

3.2.1 As a rule, all inter-band promotions shall be strictly role-based. It will be

mandatory to complete a tenure period of:

• Band 1 - 2

2 years with exceptional performance or 3 years if meets minimum

performance requirements.

• Bands 2 & 3

1 year with exceptional performance or 2 years if meets minimum

performance requirements.

• Band 4

o Lateral IJPs – Minimum 6 months in the current role, which

does not include training time, with a performance rating of
good & above.

o Vertical IJPs – Minimum 12 months in the current role, with a

performance rating of good & above.

Everise
600 North Pine Island Road, Suite 320 160
Plantation, FL 33324 weareeverise.com
 3.2.2 Promotions must not merely be recommended based on tenure or other
factors which are not directly connected with performance or the elevated
role of the employee.

3.2.3 In the case of Band changes for the employee and the promotion, there
also needs to be a job enlargement for the same employee and the
promotion. Job enlargement would mean increasing the scope of a job
currently handled by the employee by extending the range of his job duties
and responsibilities.

3.2.4 Double promotions (skipping a sub-band level) are not permitted.

3.2.5 A promotion recommendation is required to be initiated in Workday. The

promotion recommendation, facilitation, and approval matrix are as
follows:

Recommended
Band Titles Facilitated By Approved By
By

Promotion
Committee
Band 1 SVP, EVP, CXO CEO/CXO Corporate HR consisting of - CEO,
President, CPO and
CFO

Promotion
Committee
Function Head &
VP Corporate HR consisting of - CEO,
Country Head
President, CPO and
Band 2 CFO

Promotion
Director,
Function Head & Committee
Senior Corporate HR
Country Head consisting of two
Director
CXOs and CPO

Everise
600 North Pine Island Road, Suite 320 161
Plantation, FL 33324 weareeverise.com
 Recommended
Band Titles Facilitated By Approved By
By

Team Leader,
Assistant
Country HR
Manager, Country HR Head,
Band 3 Function Head Head/Location
Manager, Country Head
HR Leads
Senior
Manager

Country HR
Country HR Head,
Band 4 CSR, Function Head Head/Location
Country Head
Specialist/SME HR Leads

3.2.6 Salary Approvals

3.2.6.1 Salary adjustments are required to be approved in Workday in

accordance with the matrix below.

Compensation Changes – Propose and Request Comp

Band HR Site Site Functional Executive Vice President Chief
Manager Director Head of Head President/CEO People
HR Officer

Band 4 Approval Approval Approval Approval Workday Not Workday

(Job Notification Applicable Notification
Amount Amount
Family is
change change Amount Amount
CSR)
Less than greater increase increase
<10% than >20%? greater than greater
10% than 10%
Job Level Job Level
– Band is Band is 4 Job Level Band Job Level
4 is 4 Band is 4

Band 4 Not Approval Approval Approval Workday Not Workday

(Job Applicable Notification Applicable Notification
Amount
Family is
change Amount Amount
NOT CSR
greater increase increase
than 20%? greater than greater
10% than 10%
Job Level -
Band is 4 Job Level - Job Level –
Band is 4 Band is 4

Everise
600 North Pine Island Road, Suite 320 162
Plantation, FL 33324 weareeverise.com
 Band 3 Not Approval Approval Approval Workday Not Approval
(3A, 3B, Applicable Notification Applicable (All Comp
3C, 3D) Changes)
& Band
2C

Band 2 Not Not Not Not Approval (2B & Approval Approval
(2C, 2B, Applicable Applicable Applicable Applicable 2A) (2B & 2A) (All Comp
2A) Changes)

Band 1 Not Not Not Not Approval Approval Approval

(1A, 1B, Applicable Applicable Applicable Applicable (All Comp
1C, 1D) Changes)

3.2.6.2 Adjustments may not be communicated to employees until the

promotion letter has been issued by HR.

3.2.7 Once the promotion process and approval requirements are completed,
Human Resources will prepare a promotion letter and provide it to the
employee for signature.

3.2.8 Upon receipt of the signed promotion letter from the employee, Human
Resources will complete the final process requirements in Workday.

4. Enforcement

An employee found to have violated this policy may be subject to disciplinary

action, up to and including termination of employment. No exceptions to this policy
may be made without the prior written approval of the CPO.

Everise
600 North Pine Island Road, Suite 320 163
Plantation, FL 33324 weareeverise.com
 Time Off Policy

1. Objective

The objective of this time off policy is to provide guidance on the application and
management of time off and to enable employees to maintain a healthy work-life
balance.

2. Scope

This policy covers all full-time employees of the company in the U.S. Employees working
fewer than 30 hours per week are not eligible for paid time off (unless applicable state
law mandates otherwise).

3. Paid Time Off Guidelines

• Paid time off (“PTO”) is available for use by a non-exempt employee after
completing 180 days of employment unless mandated by state law or mandate.

• PTO is available for use by an exempt employee immediately upon Supervisor

approval.

• Employees will only be allowed to use actual accrued hours as paid time off.
Negative balances are not recognized for purposes of PTO accrual.

• PTO use must be approved in advance by the employee’s supervisor by

submitting the request in Workday. When requesting PTO, employees are
expected to exercise good judgment based on their knowledge of their job
responsibilities. Generally, PTO requests should be made as far in advance as
possible. As a rule of thumb, employees must make a written request to their
supervisor at least (5) days prior to the use of PTO. In all cases, employees must
provide the Company with reasonable notice of the need to take PTO. Whether
notice is “reasonable” is considered in context and will consider the reason for
the leave, circumstances affecting the Company, and the foreseeability of the
leave. The Company recognizes that there may be certain situations in which
advance notice may not be practicable, such as accidents, emergencies, or
other illnesses. In such extreme circumstances, an employee must provide
notice of their request for PTO at the earliest possible time that the employee is
able to give notice.

Everise
600 North Pine Island Road, Suite 320 164
Plantation, FL 33324 weareeverise.com
 • Employees should request planned PTO absences through their supervisor. If an
employee requests PTO during a particularly busy time or at a time when many
others have also requested time off, the supervisor may deny the request and
the employee may be required to postpone the time off. PTO which is requested
for vacation or similar purposes may be denied or postponed in order to
accommodate business needs and the PTO requests of other employees. Any
PTO requests for an excessively long period of time may be denied due to
business needs.

• Once an employee has given notice of resignation, accrued PTO may not be
used during the notice period.

• PTO may not be used in advance of having been accrued.

• For all employees who are scheduled by Workforce Management, requests for
use of accrued PTO must be submitted and approved through Workforce
Management before being added to Workday.

• Unless otherwise required by law, an employee forfeits any accrued, unused PTO
at the time of separation of employment. Any such unused PTO will not be paid
out upon separation unless otherwise required by law.

4. Use of PTO

PTO may be used for any purpose permitted by applicable law, including:

• The diagnosis, care, or treatment of an injury, illness or health condition of, or

preventative care for, the employee or the employee’s family member;

• The closure of the employee’s place of business,

• The closure of a school or place of care for a child of the employee or a child of
the employee’s spouse or domestic partner,

• Any other public health emergency; or

• To address domestic or sexual violence, abuse, or stalking.

5. Certification of PTO Use

• The Company may require an employee who uses PTO on three or more
consecutive workdays to provide reasonable documentation that the PTO was
used for purposes permitted by this policy. Reasonable documentation
includes documentation signed by a healthcare professional indicating that

Everise
600 North Pine Island Road, Suite 320 165
Plantation, FL 33324 weareeverise.com
 the use of PTO was necessary. In the case of domestic violence, sexual violence,
abuse or stalking, the following documents are considered reasonable:

▪ A police report;

▪ A protective order, injunction against harassment, general court order, or

other evidence from a court or prosecuting attorney;

▪ A signed statement from a domestic violence or sexual violence

program, or victim services organization affirming that the employee or
employee’s family member is receiving services related to domestic
violence, sexual abuse, or stalking;

▪ A signed statement from a witness advocate concerning services from

a victim services organization affirming that the employee or employee’s
family member is receiving services related to domestic violence, sexual
abuse, or stalking;

▪ A signed statement from an attorney, member of the clergy, or a medical

or other professional affirming that the employee or employee’s family
member is receiving services related to domestic violence, sexual abuse,
or stalking; or

▪ An employee’s legible, written statement concerning status of the

employee or the employee’s family member as a victim of domestic
violence, sexual violence, abuse, or stalking that signals the employee’s
identity and (if applicable) relationship to the family member.

6. Exempt Employee Paid Time Off (PTO)

• As used in this policy, the term “exempt employee” refers to exempt employees
up to and including the Senior Manager level.

• An exempt employee is entitled to 17 days (136 hours, based on an eight-

hour workday) of PTO per accrual period (September 1st through August 31st)
for the first five continuous years of employment and up to 20 days (160 hours,
based on an eight-hour workday) of PTO beginning on the sixth anniversary of
the employee’s hire date.

• The first year of PTO and the sixth year of PTO for a newly hired exempt
employee will be prorated based on their hire date. Exempt employees are
eligible to begin using PTO immediately with Supervisor approval.

Everise
600 North Pine Island Road, Suite 320 166
Plantation, FL 33324 weareeverise.com
 • Non-exempt employees promoted to exempt level positions will have
their allocation set as if they had been exempted from their original hire date,
less any time already taken. However, under no circumstances shall the
maximum allocation be exceeded.

• Non-exempt employees promoted to Compensation Grade 4 or above;

however, remaining on Non-exempt compensation plan, are eligible for Exempt
level PTO. Upon promotion, Non-exempt level PTO will be removed, and Exempt
PTO will be entered at a prorated amount for the remainder of the year.

• Exempt employees who are currently entitled to an allocation of more than 17

days per year will be grandfathered and continue to receive their PTO
entitlement per year in accordance with the company’s previous PTO policy.

• PTO not used during the PTO accrual period (September 1st through August 31st)
may not be carried forward to the following PTO accrual period unless
mandated by state law.

7. Non-Exempt PTO Breakdown

Paid Holidays

Everise has removed US Holidays for its Operational non-exempt employees

(Champions, Quality Assurance, Operations Team Leaders and Trainers). Employees
may use those days as floating holidays in their PTO balance. This change allows for
Everise Champions to celebrate and recognize their differences in accordance with the
Company’s people-first values.

PTO Accruals

All full-time operational non-exempt employees who have worked for Everise for 6
months or more will accrue PTO Hours (unless otherwise mandated by state law); per
paid hour worked, (paid holidays + PTO = new PTO accrual per paid hour worked) as
follows:

• Champions, QA, Operations Specialists: These roles will receive 0.053846 PTO
hours per paid hour.

• Operations Team Leads and Trainers: These roles will receive 0.080769 PTO hours
per paid hour.

Everise
600 North Pine Island Road, Suite 320 167
Plantation, FL 33324 weareeverise.com
 How to Calculate PTO Accrual

PTO accrual will now be calculated by paid hour worked.

Example: 72 hours worked at a Champion, QA, or Operations Specialist level:

72 (hours worked) X 0.053846 (accrual rate per hour) = 3.877 hours accrued

*PTO accrual will not exceed 40 Worked Hours in a week. PTO is not accrued while on
paid time off.

PTO Accrual Schedule

The accrual period is from September 1st through August 31st.

PTO will restart each September 1st. This accrual period will allow employees to use
accrued PTO time during our off-season/non-peak period.

Example: On July 1st, 2023, an employee has 16 hours of accrued PTO. The
employee would need to use the PTO plus any time accrued during July and
August 2023, prior to September 1st, 2023.

Transfers

As an employee transitions from one LOB to another, their approved PTO time-off
request may need to be re-evaluated by their supervisor. Please check with your new
leader.

Blackout Days

Each LOB will create its own blackout periods. Please check with your supervisor
regarding specific blackout dates.

Non-Exempt Re-employment

Any unused time off under this policy will be reinstated for non-exempt employees who
are re-employed with the Company within nine (9) months after their immediately
preceding separation date.

8. Director-Level and Above Paid Time Off

• Director-level and above full-time employees will have unlimited PTO from the

Everise
600 North Pine Island Road, Suite 320 168
Plantation, FL 33324 weareeverise.com
 first date of hire and may use it from their hire date; no waiting period is required.

• PTO use must be approved in advance by the employee’s supervisor by

submitting the request in Workday.

• When requesting PTO, employees are expected to exercise good judgment

based on their knowledge of their job responsibilities. PTO which is requested for
vacation or similar purposes may be denied or postponed in order to
accommodate business needs and the PTO requests of other employees.

• Generally, PTO requests should be made at least thirty (30) days in advance or
as far in advance as possible.

• Once an employee has resigned, PTO may not be used during the notice period.

• There will be no cashing out of PTO hours at the end of a year.

• Unused PTO shall not be paid upon separation from employment, unless
otherwise required by applicable law.

• In the event that any provision of this section conflicts with any provision of PTO
for exempt employees, the provision specific to Director-Level and Above
employees will control.

9. Jury Duty

• Leave is available for jury duty in response to a court order and not for civil, traffic
or criminal court appearances on the employee’s own behalf. The Company
does not provide payment for jury duty unless required by applicable law;
however, the Company grants employees approved time away from work when
summoned for jury duty. Employees may use allocated PTO when on jury duty, if
available. Since part-time employees are not eligible for PTO, all jury duty served
by part-time employees will be without pay unless otherwise required by
applicable law.

• Upon receipt of notification from the state or federal courts of an obligation to

serve on a jury, the employee should notify their supervisor. The supervisor will
verify the notification and make scheduling adjustments in order to
accommodate the employee’s obligation.

• The employee must provide documentation of the obligation to the supervisor,

such as a copy of the jury duty notice or summons.

Everise
600 North Pine Island Road, Suite 320 169
Plantation, FL 33324 weareeverise.com
 • Employees who are released from jury service before the end of their regularly
scheduled shift or who are not asked to serve on a jury are expected to advise
their supervisor to coordinate returning to work.

10. Bereavement Leave

The Company does not provide paid bereavement leave unless required by applicable
law. In the unfortunate situation of an immediate family member passing, employees
may be granted up to three days of leave without pay or use their PTO allocation (if
available).

For the purposes of this bereavement leave policy, immediate family is defined as:

• Spouse

• Child

• Parent

• Sibling

• Domestic partner

• Stepchild*

• Stepparent*

• Stepbrother/stepsister

• Grandparent/Step grandparent

• Person who is acting legally in one of the above capacities or another

relative living in the employee’s residence

Upon hire, all employees may receive unpaid bereavement leave of one (1) day for
extended family members defined as:

• Son-in-law or daughter-in-law*

• Mother-in-law or father-in-law*

• Sister-in-law or brother-in-law*

*This includes applicable relatives of a domestic partner (affidavit required).

• Bereavement leave must be approved by your supervisor.

• Documentation, such as an obituary or death certificate, may be requested

by your supervisor and/or the HR Department. Bereavement leave must be

Everise
600 North Pine Island Road, Suite 320 170
Plantation, FL 33324 weareeverise.com
 taken within two weeks after the death of the loved one. Depending upon
the circumstances, exceptions to this stipulation may be made with
approval from the HR Department.

11. First Year Medical Leave

• The company provides leave for medical conditions for full-time employees
who have been employed at least 90 days but who have not yet reached
eligibility under the Family and Medical Leave Act (“FMLA” or the “Act”). Non-
FMLA leave is not a job-protected leave.

• The maximum amount of non-FMLA leave is six weeks. Medical

documentation must be submitted by the employee to the Human
Resources Department in advance or as soon as possible for the leave to be
approved.

• For leaves due to the serious medical condition of the employee, prior to
returning to work, the employee must submit to the Human Resources
Department a return to work Certification from their Healthcare Provider. The
Human Resources Department will work with Talent Acquisition and
Operations to return the employee to work in a suitable position, if available.

12. Family and Medical Leave Act

The Family and Medical Leave Act (“FMLA”) provides eligible employees the
opportunity to take unpaid, job-protected leave for certain specified reasons.
The maximum amount of leave you may use is either twelve (12) or twenty-six
(26) weeks within a twelve (12) month period depending on the reasons for the
leave.

Employee Eligibility

To be eligible for FMLA leave, you must:

• Have worked at least twelve (12) months for the Company in the preceding
seven (7) years (limited exceptions apply to the seven-year requirement);

• Have worked at least 1,250 hours for the Company over the twelve (12)
months preceding the date your leave would commence; and

All periods of absence from work due to or necessitated by service in the

uniformed services are counted in determining FMLA eligibility.

Everise
600 North Pine Island Road, Suite 320 171
Plantation, FL 33324 weareeverise.com
 Conditions Triggering Leave

FMLA leave may be taken for the following reasons:

• Birth of a child, or to care or bond with a newly-born child (up to 12 weeks);

• Placement of a child with the employee for adoption or foster care (up to 12
weeks);

• To care for an immediate family member (employee’s spouse, child, or

parent) with a serious health condition (up to 12 weeks);

• Because of the employee’s serious health condition that makes the

employee unable to perform the employee’s job (up to 12 weeks);

• To care for a Covered Servicemember with a serious injury or illness related

to certain types of military service (up to 26 weeks) (see Military-Related
FMLA Leave for more details); or,

• To handle certain qualifying exigencies arising out of the fact that the
employee’s spouse, son, daughter, or parent is on duty under a call or order
to active duty in the Uniformed Services (up to 12 weeks) (see Military-
Related FMLA Leave for more details).

The maximum amount of leave that may be taken in a twelve (12) month period for all
reasons combined is twelve (12) weeks, with one exception. For leave to care for a
Covered Servicemember, the maximum combined leave entitlement is twenty-six (26)
weeks, with leaves for all other reasons constituting no more than twelve (12) of those
twenty-six (26) weeks.

Definitions

A “Serious Health Condition” is an illness, injury, impairment, or physical or mental

condition that involves either an overnight stay in a medical care facility, or continuing
treatment by a health care provider for a condition that either prevents the employee
from performing the functions of the employee’s job, or prevents the qualified family
member from participating in school or other daily activities for more than three full
calendar days. The continuing treatment requirement includes two visits to a health
care provider or one visit to a health care provider and a continuing regimen of care.
An incapacity caused by pregnancy or prenatal visits, a chronic condition (such as
asthma, diabetes or migraines) that continues over an extended period of time and
requires periodic visits (at least two per year) to a health care provider, permanent or

Everise
600 North Pine Island Road, Suite 320 172
Plantation, FL 33324 weareeverise.com
 long-term conditions requiring supervision but not active treatment by a health care
provider, or absences due to multiple treatments ordered by a health care provider
may also meet the definition of a Serious Health Condition.

Identifying the 12-Month Period

The Company measures the twelve (12) month period in which leave is taken by the
“rolling” twelve (12) month method, measured backward from the date of any FMLA
leave with one exception. For leave to care for a Covered Servicemember, the
Company calculates the twelve (12) month period beginning on the first day the eligible
employee takes FMLA leave to care for a Covered Servicemember and ends twelve (12)
months after that date. FMLA leave for the birth or placement of a child for adoption or
foster care must be concluded within twelve (12) months of the birth or placement.

Using Leave

Eligible employees may take FMLA leave in a single block of time, intermittently (in
separate blocks of time), or by reducing the normal work schedule (including the
elimination of required overtime) when medically necessary for the serious health
condition of the employee or immediate family member, or in the case of a Covered
Servicemember, their injury or illness. Eligible employees may also take intermittent or
reduced-scheduled leave for military qualifying exigencies. Intermittent leave is
generally not permitted for birth of a child, to care for a newly-born child, or for
placement of a child for adoption or foster care; such leave must be taken in at least
two-week increments. Employees who require intermittent or reduced-schedule leave
for planned medical treatment must try to schedule their leave so that it will not unduly
disrupt the Company’s operations. Intermittent leave is permitted in increments of at
least one hour.

Use of Paid Leave

Depending on the purpose of your leave request, you may choose (or the Company
may require you) to use accrued paid leave (such as sick leave, vacation, or PTO),
concurrently with some or all your FMLA leave. In order to substitute paid leave for FMLA
leave, an eligible employee must comply with the Company’s normal procedures for
the applicable paid-leave policy (e.g., call-in procedures, advance notice, etc.).

Everise
600 North Pine Island Road, Suite 320 173
Plantation, FL 33324 weareeverise.com
 Maintenance of Health Benefits

If you and/or your family participate in our group health plan, the Company will
maintain coverage during your FMLA leave on the same terms as if you had continued
to work. If applicable, you must make arrangements to pay your share of health plan
premiums while on leave. In some instances, the Company may recover premiums it
paid to maintain health coverage or other benefits for you and your family. Use of FMLA
leave will not result in the loss of any employment benefit that accrued prior to the start
of your leave. Consult the applicable plan document for all information regarding
eligibility, coverage, and benefits.

Notice and Medical Certification

When seeking FMLA leave, you must provide:

• Sufficient information for us to determine if the requested leave may qualify for
FMLA protection and the anticipated timing and duration of the leave. Sufficient
information may include that you are unable to perform job functions, a family
member is unable to perform daily activities, the need for hospitalization or
continuing treatment by a health care provider, or circumstances supporting
the need for military family leave. You must also inform the Company if the
requested leave is for a reason for which FMLA leave was previously taken or
certified.

• Thirty (30) days advance notice of the need to take FMLA leave, if the need for
leave is foreseeable, or notice as soon as practicable in the case of
unforeseeable leave and in compliance with the Company’s normal call-in
procedures, absent unusual circumstances.

• Medical certification supporting the need for leave due to a serious health
condition affecting you or an immediate family member within fifteen (15)
calendar days of the Company’s request to provide the certification (additional
time may be permitted in some circumstances). If you fail to do so, we may
delay the commencement of your leave, withdraw any designation of FMLA
leave or deny the leave, in which case your leave of absence would be treated
in accordance with our standard leave of absence and attendance policies,
subjecting you to disciplinary action, up to and including termination. Second
or third medical opinions and periodic re-certifications may also be required;

• Periodic reports as deemed appropriate during the leave regarding your status
and intent to return to work; and

Everise
600 North Pine Island Road, Suite 320 174
Plantation, FL 33324 weareeverise.com
 • Medical certification of fitness for duty before returning to work, if the leave was
due to your serious health condition, unless your absence was taken on an
intermittent or reduced leave schedule. The Company will require this
certification to address whether you can perform the essential functions of your
position.

Failure to comply with the foregoing requirements may result in delay or denial of leave,
or disciplinary action, up to and including termination.

Employer Responsibilities

To the extent required by law, the Company will inform you whether you are eligible for
leave under the FMLA. Should you be eligible for FMLA leave, the Company will provide
you with a notice that specifies any additional information required as well as your
rights and responsibilities. The Company will also inform you if leave will be designated
as FMLA -protected and, to the extent possible, note the amount of leave counted
against your leave entitlement. If you are not eligible for FMLA leave, the Company will
provide a reason for the ineligibility.

Job Restoration

Upon returning from FMLA leave, you will be restored to your original job or to an
equivalent job with equivalent pay, benefits, and other employment terms and
conditions.

Failure to Return after FMLA Leave

If you fail to return to work as scheduled after FMLA leave or exceed the twelve (12) week
FMLA entitlement (or in the case of military caregiver leave, the twenty-six (26) week
FMLA entitlement), you will be subject to the Company’s standard leave of absence
and attendance policies. This may result in termination if you have no other Company-
provided leave available to you that applies to your continued absence. Likewise,
following the conclusion of your FMLA leave, the Company’s obligation to maintain your
group health plan benefits may end (subject to any applicable COBRA rights). If you
are unable to return to work after FMLA/CFRA leave, you must notify the Human
Resources Department. Once the Company is aware of the need for additional leave,
the Company will engage in an interactive process to determine whether additional
leave may be provided as a reasonable accommodation.

Everise
600 North Pine Island Road, Suite 320 175
Plantation, FL 33324 weareeverise.com
 Other Employment

The Company prohibits employees from holding other employment, including self-
employment, while on leave of absence. This policy remains in force during all leaves
of absence including FMLA leave and violation may result in disciplinary action, up to
and including immediate termination of employment.

Fraud

Providing false or misleading information or omitting material information in

connection with an FMLA leave will result in disciplinary action, up to and including
immediate termination.

13. Military-Related FMLA Leave

FMLA leave may also be available to eligible employees in connection with certain
service-related medical and non-medical needs of family members. There are two
forms of such leave. The first is Military Caregiver Leave, and the second is Qualifying
Exigency Leave. Each of these leaves is detailed below.

Definitions

A “Covered Servicemember” is either: (1) a current servicemember of the Armed Forces,

including a member of the National Guard or Reserves, with a serious injury or illness
incurred in the line of duty for which the servicemember is undergoing medical
treatment, recuperation, or therapy, is otherwise in outpatient status, or is otherwise on
the temporary disability retired list; or (2) a “covered veteran” who is undergoing
medical treatment, recuperation, or therapy for a serious injury or illness.

A “covered veteran” is an individual who was discharged under conditions other than
dishonorable during the five (5) year period prior to the first date the eligible employee
takes FMLA leave to care for the covered veteran.

The FMLA definitions of “serious injury or illness” for current Servicemembers and
veterans are distinct from the FMLA definition of “serious health condition.” For purposes
of Military-Related FMLA Leave, the term “serious injury or illness” means an injury or
illness incurred by the Servicemember in the line of duty while on active duty in the
Armed Forces that may render the Servicemember medically unfit to perform the
duties of the Servicemember’s office, grade, rank, or rating, or one that existed before

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 the beginning of active duty and was aggravated by service in the line of duty while on
active duty.

With regard to covered veterans, the serious injury or illness may manifest itself before
or after the individual assumed veteran status, and is: (1) a continuation of a serious
injury or illness that was incurred or aggravated when the covered veteran was a
member of the Armed Forces and rendered the Servicemember unable to perform the
duties of the Servicemember’s office, grade, rank or rating; (2) a physical or mental
condition for which the covered veteran has received a VA Service Related Disability
Rating (VASRD) of 50 percent or greater and such VASRD rating is based, in whole or in
part, on the condition precipitating the need for caregiver leave; (3) a physical or
mental condition that substantially impairs the veteran’s ability to secure or follow a
substantially gainful occupation by reason of a disability or disabilities related to
military service or would be so absent treatment; or (4) an injury, including a
psychological injury, on the basis of which the covered veteran has been enrolled in
the Department of Veterans Affairs Program of Comprehensive Assistance for Family
Caregivers.

“Qualifying exigencies” include activities such as short-notice deployment, military

events, arranging alternative childcare, making financial and legal arrangements
related to the deployment, rest and recuperation, counseling, parental care, and post-
deployment debriefings.

Military Caregiver Leave

Unpaid Military Caregiver Leave is designed to allow eligible employees to care for
certain family members who have sustained serious injuries or illnesses in the line of
duty. The family member must be a “Covered Servicemember,” as defined above.
Military Caregiver Leave is not available to care for servicemembers on the permanent
disability retired list.

To be eligible for Military Caregiver Leave, you must be a spouse, son, daughter, parent,
or next of kin of the Covered Servicemember. “Next of kin” means the nearest blood
relative of the Servicemember, other than the Servicemember’s spouse, parent, son, or
daughter, in the following order of priority: blood relatives who have been granted legal
custody of the Servicemember by court decree or statutory provisions; brothers and
sisters; grandparents; aunts and uncles; and first cousins; unless the Servicemember
has specifically designated in writing another blood relative as their nearest blood

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 relative for purposes of Military Caregiver Leave. You must also meet all other eligibility
standards as set forth within the FMLA Leave policy.

An eligible employee may take up to twenty-six (26) workweeks of Military Caregiver

Leave to care for a Covered Servicemember in a “single twelve (12) month period.” The
“single twelve (12) month period” begins on the first day leave is taken to care for a
Covered Servicemember and ends twelve (12) months thereafter, regardless of the
method used to determine leave availability for other FMLA-qualifying reasons. If you
do not exhaust your twenty-six (26) workweeks of Military Caregiver Leave during this
“single twelve (12) month period,” the remainder is forfeited.

Military Caregiver Leave applies on a per-injury basis for each Covered

Servicemember. Consequently, an eligible employee may take separate periods of
caregiver leave for every Covered Servicemember, and/or for every serious injury or
illness of the same Covered Servicemember. A total of no more than twenty-six (26)
workweeks of Military Caregiver Leave, however, may be taken within any “single twelve
(12) month period.”

Within the “single twelve (12) month period” described above, an eligible employee may
take a combined total of twenty-six (26) weeks of FMLA leave including up to twelve (12)
weeks of leave for any other FMLA-qualifying reason (i.e., birth or adoption of a child,
serious health condition of the employee or close family member, or a qualifying
exigency). For example, during the “single twelve (12) month period,” an eligible
employee may take up to sixteen (16) weeks of FMLA leave to care for a Covered
Servicemember when combined with up to ten (10) weeks of FMLA leave to care for a
newborn child.

An employee seeking Military Caregiver Leave may be required to provide appropriate

certification from the employee and/or Covered Servicemember and completed by an
authorized health care provider within fifteen (15) days. Military Caregiver Leave is
subject to the other provisions in our FMLA Leave Policy (requirements regarding
employee eligibility, appropriate notice of the need for leave, use of accrued paid leave,
etc.). Military Caregiver Leave will be governed by, and handled in accordance with,
the FMLA and applicable regulations, and nothing within this policy should be construed
to be inconsistent with those regulations.

Everise
600 North Pine Island Road, Suite 320 178
Plantation, FL 33324 weareeverise.com
 Qualifying Exigency Leave

Eligible employees may take unpaid “Qualifying Exigency Leave” to tend to certain
“exigencies” arising out of the duty under a call or order to active duty of a “covered
military member” (i.e. the employee’s spouse, son, daughter, or parent). Up to twelve
(12) weeks of Qualifying Exigency Leave is available in any twelve (12) month period, as
measured by the same method that governs measurement of other forms of FMLA
leave within the FMLA policy (with the exception of Military Caregiver Leave, which is
subject to a maximum of twenty-six (26) weeks of leave in a “single twelve (12) month
period”). The maximum amount of “Qualifying Exigency Leave” an employee may utilize
to bond with a military member on short-term, temporary rest and recuperation during
deployment is fifteen (15) days.

Although Qualifying Exigency Leave may be combined with leave for other FMLA-
qualifying reasons, under no circumstances may the combined total exceed twelve
(12) weeks in any twelve (12) month period (with the exception of Military Caregiver
Leave as set forth above). The employee must meet all other eligibility standards as
set forth within the FMLA policy.

Persons who can be ordered to active duty include active and retired members of the
Regular Armed Forces, certain members of the retired Reserve, and various other
Reserve members including the Ready Reserve, the Selected Reserve, the Individual
Ready Reserve, the National Guard, state military, Army Reserve, Navy Reserve, Marine
Corps Reserve, Air National Guard, Air Force Reserve, and Coast Guard Reserve.

A call to active duty refers to a federal call to active duty, and state calls to active duty
are not covered unless under order of the President of the United States pursuant to
certain laws.

Qualifying Exigency Leave is available under the following circumstances:

• Short-notice deployment. To address any issue that arises out of short notice
(within seven days or less) of an impending call or order to active duty.

• Military events and related activities. To attend any official military ceremony,
program, or event related to active duty or a call to active-duty status or to
attend certain family support or assistance programs and informational
briefings.

Everise
600 North Pine Island Road, Suite 320 179
Plantation, FL 33324 weareeverise.com
 • Childcare and school activities. To arrange for alternative childcare; to
provide childcare on an urgent, immediate need basis; to enroll in or transfer
to a new school or daycare facility; or to attend meetings with staff at a
school or daycare facility.

• Financial and legal arrangements. To make or update various financial or

legal arrangements; or to act as the covered military member’s
representative before a federal, state, or local agency in connection with
service benefits.

• Counseling. To attend counseling (by someone other than a health care

provider) for the employee, the covered military member, or for a child or
dependent when necessary as a result of duty under a call or order to active
duty.

• Temporary rest and recuperation. To spend time with a covered military

member who is on short-term, temporary rest and recuperation leave during
the period of deployment. Eligible employees may take up to fifteen (15) of
days of leave for each instance of rest and recuperation.

• Post-deployment activities. To attend arrival ceremonies, reintegration

briefings and events, and any other official ceremony or program sponsored
by the military for a period of up to ninety (90) days following termination of
the covered military member’s active duty status. This also encompasses
leave to address issues that arise from the death of a covered military
member while on active duty status.

• Mutually agreed leave. Other events that arise from the close family
member’s call or order to active duty, provided that the Company and the
employee agree that such leave shall qualify as an exigency and agree to
both the timing and duration of such leave.

An employee seeking Qualifying Exigency Leave may be required to submit appropriate

supporting documentation in the form of a copy of the covered military member’s
active duty orders or other military documentation indicating the appropriate military
status and the dates of active duty status, along with a statement setting forth the
nature and details of the specific exigency, the amount of leave needed and the
employee’s relationship to the military member, within fifteen (15) days. Qualifying
Exigency Leave will be governed by, and handled in accordance with, the FMLA and
applicable regulations, and nothing within this policy should be construed to be
inconsistent with those regulations.

Everise
600 North Pine Island Road, Suite 320 180
Plantation, FL 33324 weareeverise.com
 14. USERRA Military Leave

• A military leave of absence will be granted to employees who are absent

from work because of service in the U.S. uniformed military services in
accordance with the Uniformed Services Employment and Reemployment
Rights Act (“USERRA”).

• Advance notice of military service is required, unless military necessity

prevents such notice, or it is otherwise impossible or unreasonable.

• Employees returning from military leave will be returned to their position in

accordance with then-current law. They will be treated as though they
were continuously employed for purposes of determining benefits based
on length of service.

Eligibility: To qualify for reemployment rights following military service, an employee

must meet the following five eligibility criteria:

• Must have left a civilian job;

• Must have given notice that they were leaving to perform military service;

• Must have been released from service under honorable or general

conditions;

• Must have reported back to work or re-applied for a position with the
Company.

15. Maintenance of Health Benefits

• Under the USERRA Military Leave Policy, the employee pays a portion of the
health care premium. While on paid leave, the Company will continue to
make payroll deductions to collect the employee's share of the premium.

• While on unpaid leave, the employee must continue to make this payment,
either in person or by mail. The payment must be received by the HR
Department by the first day of each month. If the payment is more than thirty
(30) days late, the employee's health care coverage may be dropped for the
duration of the leave. If the employee contributes to a life insurance or
disability plan, the Company will continue making payroll deductions while
the employee is on paid leave. While the employee is on unpaid leave, the
employee may request continuation of such benefits, and pay their portion

Everise
600 North Pine Island Road, Suite 320 181
Plantation, FL 33324 weareeverise.com
 of the health care premium. If the employee does not continue these
payments, the employer may discontinue coverage during the leave.

16. Reinstatement to Position

• An employee who takes leave under the USERRA Military Leave Policy will
generally be able to return to the same position or a position with equivalent
status, pay, benefits and other employment terms.

• An employee is entitled to reinstatement only if the employee would

have continued to be employed had leave not been taken. Thus, an
employee is not entitled to reinstatement if, because of a layoff, reduction in
force or other business reason, the employee would not be employed at the
time job restoration is sought.

• An employee will be considered to have voluntarily resigned their position if

the employee:

▪ Fails to return to work on the first day after the leave of absence
expires;

▪ Applies for or engages in any other employment during the leave

of absence, unless the employee received prior written permission
from the Company; or

▪ Provides false reason or certification for any requested leave of

absence.

17. Victims of Domestic Violence Time Off Policy

• Employees may take up to three days of unpaid and job-protected leave in

any 12-month period for specific domestic violence situations.

• Any available vacation or other time off must be exhausted before domestic
violence leave can be utilized or approved.

• Appropriate documentation must be submitted by the employee to the

Human Resources Department in advance or as soon as possible for the
leave to be approved.

• Massachusetts residents – Employees may take up to 15 days per 12-month

period.

Everise
600 North Pine Island Road, Suite 320 182
Plantation, FL 33324 weareeverise.com
 18. Personal Time Off

• Employees who have completed at least one (1) year of service and who
have exhausted all their available vacation may be granted personal leave
of up to 30 days when pressing personal reasons, not connected with
business ventures or permissible employment outside the Company,
necessitate a period of absence.

• No compensation is paid to an employee on personal leave.

• There is no guarantee of re-employment.

19. State Mandated Time Off

• If local or state legal requirements for time off (whether paid or unpaid) or
absences from work in the state in which the employee is employed are more
generous than federal requirements, employees will be granted the time off
or absence in accordance with the state or local government.

This policy shall be effective as of March 1, 2020, and, except as otherwise stated herein,
shall replace any previous policy relating to the subject matter covered by this policy.

Everise
600 North Pine Island Road, Suite 320 183
Plantation, FL 33324 weareeverise.com
 Company Paid Holidays

Everise has removed US Holidays for our Operational Non-Exempt employees

(Champions, Quality Assurance, Operations Team Leaders and Trainers) Those
employee groups now have those days to use as floating holidays as a part of your
PTO Balance. This change allows for Everise Champions to celebrate and recognize our
differences while staying a people-first company.

Everise observes the following paid holidays for Employees:

• New Years’ Day (Jan 1)

• Memorial Day

• Independence Day (July 4)

• Labor Day (1st Monday in September)

• Thanksgiving Day

• Christmas Day (Dec 25)

Eligibility and Scheduling

• Full-time exempt employees are eligible for paid holidays upon hire.

• Eligible employees who take the holiday off receive holiday pay for the day.

Observance of Holidays

Sunday occurrence: Scheduled holidays falling on Sunday will typically be observed

the following Monday. Saturday occurrence: Scheduled holidays falling on Saturday
will typically be observed the preceding Friday.

Everise
600 North Pine Island Road, Suite 320 184
Plantation, FL 33324 weareeverise.com
 Attendance and Absence Management
Policy

Everise depends on the regular and punctual attendance of all employees to meet
scheduled production and business obligations.

Absence and/or tardiness from work results in the loss of efficiency and productivity
and all employees are expected to consistently report to work on the days and at the
times they are scheduled to work.

Unauthorized or excessive absenteeism or tardiness may result in disciplinary action

and may negatively impact future transfer requests, pay increases, promotions,
continued employment etc.

Gateway to Bonus/Incentives

• Your role at Everise is critical to our clients and their customers. Because our
clients rely on us to staff their programs to match call volumes with trained team
members, we need your cooperation to ensure your and the Company’s success.
However, we cannot ensure this success unless you work the full schedule that is
assigned to you.

• To encourage you to meet this goal, beginning April 1, 2020, the Everise incentive
plans will be tied to meeting attendance standards to include a reduced pay-
out below 95% attendance.

• Specifically, the gateways to Incentives will require every team member to have
worked at least 90% of their scheduled monthly hours to qualify for any portion
of the incentives calculated for that month or the bonus time frame. Eligibility for
performance incentive pay-outs is based on the following attendance
standards:

95% or higher: 100% pay-out

90% - 94.99%: 80% pay-out

89.99% or below: No pay-out

• 4x10 Staff (must have been on this schedule for the entire month to qualify for
the following adjustment):

94.2% or higher: 100% pay-out

90% - 94.19%: 80% pay-out

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 9.99% or below: No pay-out

• If you are scheduled to work 40 hours a week (a total of [160] hours a month),
you will need to work a minimum of [151] hours in that month to be eligible for
100% of the performance incentive pay-outs.

• To help you succeed under the Gateway to Incentives policy, approved PTO time,
FMLA hours, make up time in approved areas where needed or any other
authorized leave will not count against your incentive calculations. Adhering to
the Gateway to Incentives policy means you may enjoy the full benefit of our
incentive programs.

1. Attendance Measurement

Attendance is tracked daily. Hourly employees have occurrences they can use to
effectively manage their unexpected time off. An occurrence will remain active for a
rolling 180 days. Employees have the opportunity to remove (1) occurrence every time
they have perfect attendance for thirty (30) consecutive calendar days.

2. Employee Responsibilities

• Employees unable to be at work as scheduled, must call into the designated

contact number at least one hour before the start of the scheduled shift each
day that they are absent or tardy. Family members or friends may not call on
an employee’s behalf.

• Employees are required to report to their supervisor in writing, if they feel that
their attendance has been recorded inaccurately, within two weeks of the issue.

• Employees should be ready to begin working at their scheduled starting time.

• Employees should notify their supervisor as far in advance as possible whenever

they are unable to report for work, know they will be late or must leave early.
Such notification should include a reason for the absence and an indication of
when the employee can be expected to report for work. If the supervisor is
unavailable, notification should be made to someone else in management, or
as a last resort, on the supervisor’s voicemail.

• Employees who report for work without proper equipment (such as ID badges or
headsets) or in improper attire may not be permitted to work. Employees who
report for work in a condition considered not fit for work, whether for illness or
any other reason, will not be allowed to work. Applicable attendance policies will
apply.

Everise
600 North Pine Island Road, Suite 320 186
Plantation, FL 33324 weareeverise.com
 • Employees generally are expected to report for work during inclement weather
conditions if the Company does not declare an emergency closing. If you select
to not come to work due to weather conditions; but the Company is open for
business; you shall not be paid any PTO pay.

• Employees must obtain permission in advance from their supervisor in order to

deviate from their work schedule.

• Employees who are absent without notifying their lead, supervisor or manager
may be subject to discipline, up to and including immediate termination.

3. Attendance Guidelines

3.1 Planned Absences with Notice

For an absence to be considered a “Planned Absence” the employee must give a

minimum of (10) working days’ notice in advance and receive approval from Everise
management. All absence requests are made via Workday and supervisors
approve/reject such requests via Workday.

• Requests will be processed in order in which they are received; priority will be
given to employees with accrued time available.

• Approval from Everise must be received prior to the requested date of the
planned absence.

• Approved planned absences will not result in an occurrence.

• Absences are also excused for down staffing, all approved LOA’s, when allowed
as a reasonable accommodation for a disability, and when protected by any
sick leave statute.

3.2 Unplanned Absences, Tardy or Leave Early (Without Notice)

An unplanned absence is any absence, tardy/late or leave early that does not fall into
the “Planned Absence section above”. Note: An unplanned absence when the
employee has sick time in their bank will still result in an occurrence although the
absence may be paid.

• An unplanned absence will result in one (1) occurrence. An unplanned absence

occurs when an employee misses more than 50% of their scheduled shift.

• A tardy/late will result in a ½ occurrence. A tardy/late occurs when an employee

is late to work or is late from their meal break by more than five (5) minutes.

• A leave early will result in a ½ occurrence. A leave early occurs when an

employee leaves work before the end of their scheduled shift but has already
worked at least 50% of their schedule. Leaving early without notifying the

Everise
600 North Pine Island Road, Suite 320 187
Plantation, FL 33324 weareeverise.com
 appropriate supervisor or calling the designated number will subject the
employee to disciplinary action.

• Absences of consecutive days will count as multiple occurrences unless proper

medical documentation is provided, within 24 hours of your return to work. If
documentation is provided, only one occurrence will be given.

• Critical Days: The Company may identify and designate certain days as
“Critical Days”. These are days that, because of the business need, are critical
to the operation. These days are typically days before and after holidays, or
high call volume days. Everise will provide as much notice as possible of
upcoming critical days. In the event of an absence or late/tardy on a “critical
day” the occurrence points are doubled.

4. No Call No Show

Employees failing to call in after two (2) hours from the start of their scheduled shift will
be considered a No Call, No Show (NCNS). (Note: Policy in effect for all sites unless
applicable state law applies).

• The first NCNS will result in a final warning

• The 2nd NCNS will be considered a voluntary resignation from the Company

• NCNS are on a rolling six (6) month basis

5. Disciplinary Action Process

All Full time and/or part-time Non-Exempt (hourly) employees whose number of
occurrences reach the levels listed below will be subject to disciplinary action. See
attendance policy FAQ’s below for what constitutes an occurrence.

Please use the disciplinary steps below:

Occurrences Disciplinary Action

0-4 None
5 Verbal Coaching
6 1st Written Warning
7 2nd Written Warning
8 Final Warning
9 Termination

6. New Hire Training Attendance

Everise
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Plantation, FL 33324 weareeverise.com
 Attendance requirements during training are client-specific and may vary by client.
Training attendance expectations will be shared at that time.

Our clients demand exemplary attendance from our employees during training,
including the time in nesting. Based on the client’s requirements and Everise’s
attendance policy, any absence while in a training or nesting may result in disciplinary
action up to and including termination. Everise will make every effort to work with an
employee to make up training time missed for documented illnesses or emergencies.
If circumstances, at the sole discretion of management, do not permit make-up time,
failure to meet the client attendance requirement may result in removal from that
program or termination.

7. Unscheduled Closings

Employees are expected to report to work for all scheduled times. In the event of an
unscheduled facility closing, non-exempt employees will be paid in the following
manner:

• Employees who have worked a partial shift and are sent home by site
management will be paid for the hours they have worked. Pay will be for a
minimum of four (4) hours.
• Employees who have worked a partial shift and choose to leave work are paid
solely for hours worked with no minimum.
• Employees who do not report for their shift are not paid (even if they may have
PTO allocation available).
• Should there be a need to close any of our facilities, the Company maintains toll
free information lines for each of our locations that employees may call for an
update. The toll-free phone numbers and messages are also posted in
Workday. The messages are updated frequently during severe conditions due
to weather, earthquake, or other unscheduled events. Employees may log into
Workday to access this information.

Everise
600 North Pine Island Road, Suite 320 189
Plantation, FL 33324 weareeverise.com
 Accommodation Policy

Americans with Disabilities Act (ADA)

Summary

Everise and its subsidiaries will make reasonable accommodation for known physical
and mental limitations of qualified applicants, employees, and contractors, consistent
with the Federal and State laws, such as the Americans with Disabilities Act (ADA), as
amended to date.

Definitions

Disability under ADA: Under ADA, a disability is defined as a physical or mental

impairment that limits one or more major life activities. An employee may be
considered disabled if the employee exhibits a disability, has a record of such
impairment, or would be perceived as having such impairment. However, in all
circumstances, Everise can accommodate only when such a disability is made known
in sufficient detail to the company by the employee not by a third party.

Reasonable Accommodation: An adjustment to the job or work environment that

enables a qualified employee with a known disability to perform the essential job
functions and may include any of the following:

• Restructuring the non-essential functions of the job;

• Implementing part-time or modified work schedules;

• Re-designing work areas or equipment;

• Making facilities accessible;

• Providing reasonable periods of time off.

Policy

1. Requesting an Accommodation

Everise
600 North Pine Island Road, Suite 320 190
Plantation, FL 33324 weareeverise.com
 Through an Interactive Process, Everise will work with the employee, management,
and their health care provider(s) to identify a reasonable and effective
accommodation for a disability.

An employee has the following key responsibilities to enable Everise to conduct this
process:

• Demonstrate their qualifications to perform the job;

• Be capable of performing the essential functions of the job;

• Notify Human Resources that an accommodation is needed;

• Provide all applicable supporting documentation needed by Human

Resources according to the timelines established by Human Resources to
determine whether an accommodation is needed, and if so, the nature and
scope of the accommodation.

2. Reasonable and Effective Accommodation

• A disabled employee is entitled to a reasonable and effective

accommodation provided they meet the threshold requirements under the
ADA, which may not be the accommodation that the employee requested or
prefers.

• Through an interactive process, Everise will work with the employee,

management, and the employee’s medical provider(s) to identify a
reasonable and effective accommodation.

• Everise may periodically review accommodations granted to the employee

under this policy to ensure consistency with business necessity and absence
of change in the underlying circumstances.

• Everise may require the employee to submit updated documentation from

their medical provider(s).

3. Health and Safety Considerations

• An accommodation is not reasonable or effective if it puts the employee, co-

workers, or others at risk.

• Similarly, Everise may ask any employee to demonstrate fitness for duty at
any time if it appears that the employee cannot safely perform their job.

Everise
600 North Pine Island Road, Suite 320 191
Plantation, FL 33324 weareeverise.com
 • The above applies to all employees, regardless of whether they have a
demonstrated disability.

For more questions on ADA Accommodations and the ADA process, please contact
Human Resources.

Pregnancy Accommodations
Everise provides female employees with job-protected unpaid leave, for up to 6 weeks
of continuous leave if they have not been with the company for one-year (Exempt
employees) or 1250 (non-exempt employees) hours of work. This includes disabilities
relating to pregnancy, childbirth, or related medical conditions (meaning a physical or
mental condition intrinsic to pregnancy or childbirth).

• Pregnancy employees that qualify for FMLA, after one year of employment
(Exempt) or 1250 hours worked (non-exempt), will be allowed up to 3 months of
leave.

• Please contact Human Resources for more information on Pregnancy

Accommodations and the use of PTO and/or Short-Term Disability benefits.

Mother’s Room Accommodations

Everise will comply with all federal and state laws regarding breastfeeding in the
workplace. Everise will provide access to a private room at its sites and reasonable
unpaid breaks to an employee who needs to express breast milk for her infant, up to
one year from the child’s birth. The break time should, if possible, run concurrently with
any break times already provided to the employee.

Service Animal Accommodations

Animals are generally prohibited from all Everise facilities and premises with the
exception of approved service animals. Everise recognizes that in some
circumstances, a service animal may be a reasonable accommodation to an
individual with a disability under the ADA.

If you have a need for a service animal under ADA, please contact Human Resources
for the company guidelines for this accommodation.

Everise
600 North Pine Island Road, Suite 320 192
Plantation, FL 33324 weareeverise.com
 Religious Accommodations

Everise respects the religious beliefs and practices of all employees and on request will
make an accommodation for such observances when a reasonable accommodation
is available that does not create undue hardship on the company’s business.

An employee whose religious beliefs or practices conflict with their job, work schedule,
vaccination status or with Everise policy or practice on dress and appearance, or with
other aspects of employment, must submit a written request for the accommodation
to Human Resources. The written request should include the type of religious conflict
that exists and the employee’s suggested accommodation.

Rehire & Reinstatement Policy

Eligibility is determined based on how the Employee left Everise, skills, performance, and
attendance.

1. Layoffs / Closure / Program Ended – Employees who have demonstrated good

performance are eligible for rehire. There is no waiting period to apply for available
openings based upon qualifications, attendance, and performance.

2. Voluntary Termination with Two Weeks’ Notice – Employees who work through their
full two (2) week notice and meet overall good performance and behavioral
standards are eligible for rehire. There is no waiting period to apply for available
openings based upon qualifications, attendance, and performance.

3. Involuntary Terminations – Employees who were terminated for misconduct,

violation of Company policy, unsatisfactory performance, excessive absenteeism
or lateness, or any other for-cause terminations are generally not eligible for rehire.

4. Service Dates - Employees rehired within 90 days will be reinstated with an adjusted
service date (“ASD”). Employees rehired after 90 days will be treated as a new hire.
If the employee had benefits such as health, dental, or vision, the reinstated
employee will be able to enroll in the health insurance programs the first of the
month following 30 days after rehire for hourly employees, and the first of the month
following rehire for salaried employees.

Everise
600 North Pine Island Road, Suite 320 193
Plantation, FL 33324 weareeverise.com
 5. Background Checks More than 30 Days - Employees rehired more than 30 days
after the completion of their most recent background check and drug screen will
be required to complete a new background check and drug screen.

6. Background Checks Less than 30 Days - If the date of a background check is within
30 days of the rehire date, a new background check is not required unless the
Statement of Work (SOW) or Master Service Agreement (MSA) requires otherwise. If
the date on the background check is greater than 30 days old, a new background
check is required.

7. Paid Time Off (“PTO”) - Employees who leave the Company and are rehired within
one (1) month of their termination date will receive credit for previous years of
service in determining their PTO grant rates.

Everise
600 North Pine Island Road, Suite 320 194
Plantation, FL 33324 weareeverise.com
 Global Travel Policy

1. Policy

• To provide guidelines through which Domestic & International business travel

should be arranged and the parameters that must be adhered to for
accommodation and other incidental expenses.

• It is Everise policy to reimburse employees for necessary and authorized travel

expenses when directly connected with or pertaining to the transaction of Everise
business.

• All travel must be done in accordance with this policy. Those traveling on Everise
business are asked to exercise prudent business judgment regarding expenses
covered by this policy.

2. Purpose

• This policy shall provide guidelines on the accurate documentation of all travel
business transactions.

3. Scope

• All employees across all locations of the Company, who need to travel both
internationally and domestically for business purposes.

4. Guidelines

• For domestic travel, the President’s approval is required. For international travel,
the department head’s approval and global CEO’s approval is also required.

• Employees must only undertake international business travel if the nature of the
work cannot be completed through telecom/video-conference alternatives.

• All travel must be booked only through our travel partner, Vikas Chopra at Fly
Premier Class & using our automated Travel Requests process in NetSuite for:

o Air travel

o Hotel

o Car Rentals

Everise
600 North Pine Island Road, Suite 320 195
Plantation, FL 33324 weareeverise.com
 • All travel must be planned as far in advance as possible and scheduled to
minimize impact on the workday.

5 Procedure

5.1 Mode of Travel

The mode of travel as applicable to different categories of employees is as below:

International Travel

Band Class of Travel

Economy Class
Band 1 – SVP/EVP/CXO
Business class if one-way travel time exceeds 5 hours

Economy Class
Band 2 – VP/Senior
Director/Director Premium economy if one-way travel time exceeds 7
hours

Band 3, 4 – Senior Manager &

Economy Class
below

Domestic Travel

Band Class of Travel

Band 1 – SVP/EVP/CXO Economy Class

Band 2 – VP/Senior
Economy Class
Director/Director

Band 3, 4– Senior Manager &

Economy Class
below

5.2 Expenditure Entitlements

Everise
600 North Pine Island Road, Suite 320 196
Plantation, FL 33324 weareeverise.com
 International travel entitlements (in USD) as applicable to different categories of
employees are listed below:

Daily Lodging Daily Allowance

Band
Entitlement Entitlement

Band 1 – SVP/EVP/CXO $250 $75

Band 2 – VP/Senior
$175 $60
Director/Director

Band 3, 4 – Senior Manager and

$150 $50
below

5.3 Travel Accommodations

5.3.1 Travel Requisition Approvals and Procedures

• Employees who need to travel for business purposes must E-mail the travel
request to our travel partner, Vikas Chopra at Fly Premier Class

• Vikas Chopra provides various options including rates to employees via E-

mail. Employee to confirm the travel options by sending an E-mail to Vikas

• Employee to initiate travel form on NetSuite with complete details including

costs and submit for approval

• Upon approval from Department Head/CPO/President/CEO, Vikas sends an

E-mail with an itinerary for travel

• Should a new hire not yet be set up in NetSuite, they will need to contact the
Global Service Desk. The GSD will provide the necessary form to be
completed and they will submit the request for approval and completion.

5.4 General Travel Policy

• Cash advances will not be provided except in special circumstances and will
require the prior approval of the Country HR Head, CPO, and Chief Financial
Officer (“CFO”).

• Expenditures incurred on commuting from residence to airport and airport to

hotel and back locally and at an international location shall be reimbursed

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 additionally only on submission of bills.

• The daily allowance will cover all boarding expenses including basic laundry,
meals, etc.

• The Company will not reimburse tips greater than 20%.

• Other reasonable travel expenses may be considered such as emergency

business calls received while overseas. This would, however, need to be
justified in an itemized bill during the reimbursement process and need to be
approved by the head of department.

• Luggage, briefcases, magazines, newspapers, books, airline club dues and/or

initiation fees, traffic fines, toiletries, hair-cuts, shoe shines, in-flight
movies/headsets, excessive personal phone calls, parties, personal recreation
and alcoholic beverages are all considered personal in nature and will not be
reimbursed.

• Personal vehicle mileage will be paid at the IRS recommended rate for U.S.
Employees. Personal vehicles that are used, must use personal insurance as
the primary insurance. The company auto policy is secondary insurance.

• While on international trips, employees shall use the local sim card of the
country being visited, which shall be facilitated by the IT and Administration
leads of that country. As an alternative, the employee will be allowed the use
of a data roaming package from the local telco Company (in lieu of obtaining
local sim card) and the amount is capped at USD $50.00 per two-week trip.
Any excess claimed requires additional approval from Head of Department.

• Expenses incurred on local transport should be supported by receipts. In case

of non-availability of receipts, exception approval of the Head of Department
should be taken.

• Any payment greater than what is allotted shall require approval from the
head of department and the CFO.

5.5 Lodging Policy

It is the Company’s policy for all employees to stay with our preferred and negotiated rate
properties. When requesting lodging arrangements, employees should observe the
following:

• All reservations must be made through NetSuite Travel Requisition Form. Please
note that hotel rooms are NOT automatically paid for by Everise. All hotel rooms

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 must be pre-approved prior to trip, otherwise they will not be reimbursable.
This does not include incidentals.

• Employees must utilize Airbnb services whenever the length of stay is more
than 5 days.

• Hotel reservations that are not going to be used, must be cancelled 24 hours
prior so that guarantee charges are not incurred. Employees who do not
cancel reservations may not have such expenses reimbursed. Mini-bar and
room service charges will be included as part of daily allowance calculation.
Other charges (e.g., in-room movie or spa or other luxury services) will be
considered personal in nature.

• Each employee must include the itemized hotel receipt with the expense report
to be reimbursed. Cancellations should be handled by the employee
contacting our Travel Coordinator.

5.6 Car Rental Policy

When renting automobiles, employees should observe the following:

• All reservations must be made through NetSuite travel requisition form. Please
note that the car rentals are not automatically paid for by Everise. All car rentals
must be pre-approved prior to trip, otherwise they will not be reimbursable.

• All cars rented should be of compact or intermediate size (based upon the
number of employees traveling together). The Company will not reimburse
luxury automobiles. It is encouraged to use UBER.

• Employees are not to purchase additional insurance when picking up a rental

vehicle.

• In case of accident, processing of insurance varies from country to country.

The employee should coordinate with someone in the recipient country for the
processing of required documents.

▪ No extras will be reimbursed by Everise (GPS, etc.).

▪ Employees should return the rental vehicle with a full gas tank (or if the
trip will exhaust a tank of gas, the employee may pre-purchase the gas
from the auto rental Company as often this is less expensive than
buying the gas yourself).

▪ The Everise auto policy covers rental cars for business-related travel
only.

Everise
600 North Pine Island Road, Suite 320 199
Plantation, FL 33324 weareeverise.com
 ▪ Report the accident to:

Liberty Mutual – 800-362-0000

Everise CustomerContactChannels

Everise Policy # AS6-Z91-468870-018

Please put your supervisor on notice of the incident to report to:

Helen Franco

[email protected]

Jordan Parnell

[email protected]

225-218-2492

5.7 Travel Time Policy for Non-Exempt/Hourly Employees

• Business trips involving non-exempt champions must be pre-approved by the

Country HR Head, the department head, and the President.

• In general, time spent traveling during a non-exempt employee’s regularly

scheduled hours is considered compensable. Time spent traveling outside of
the non-exempt employee’s regularly scheduled hours is not considered
compensable.

• Working time spent on an out-of-town business trip should be recorded and is

considered time worked except for normal time spent in transit from home and
the regular mealtime of 30 to 60 minutes.

• Business-related travel time of non-exempt employees is also credited as time

worked when calculating eligibility for overtime, as defined in the local area
(daily/weekly). The Champion’s manager should review non-exempt
employees daily logged hours to ensure accuracy and compliance with
applicable State and Federal laws.

5.8 Expense Reimbursement Process

It is Everise Policy that all employees shall record in a timely fashion all expenses
incurred in the conduct of authorized Company business on the electronic employee
expense report.

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 • Expense reports must be submitted during the same month in which you
traveled. Any expenses submitted later than 30 days post travel completion
will run the risk of not being reimbursed. Itemized and fully legible receipts
(business name, amount, date, etc.) must be presented.

• Signed credit card slips should be included but are not considered sufficient
support without an itemized receipt. All T & E’s are paid out bi-weekly on non-
payroll Fridays.

• To be reimbursed timely, all T & E’s must be completed in NetSuite by EOD

Monday following that Friday so that supervisors and accounting have
enough time to view and approve. All expense reports should have itemized
receipts included for each expense line item and mileage should have the
number of miles included. Bank statements without support are not sufficient
documentation of expenses and do not qualify for reimbursement.

• The only exceptions to this are bank fees incurred as a result of currency
exchange which may appear on a bank statement and cash tips as reflected
in the statement with date, vendor, and amount. Any expense reimbursement
that does not adhere to this travel policy will be rejected by Finance.

5.9 Authorized Travel Agent – Travel Partner at Fly Premier Class

• Travel Partner at Fly Premier Class is the only authorized travel agency
authorized for all Everise employees.

• Travel Partner at Fly Premier Class will follow and enforce the Everise travel
policy.

• All travel arrangements for Everise employees will be processed through the
SSC travel services support team.

Travel Partner at Fly Premier Class is not authorized to book or issue travel tickets when
directly contacted by a Everise employee.

Everise
600 North Pine Island Road, Suite 320 201
Plantation, FL 33324 weareeverise.com
 5.10 Travel Services Support Contact Information

Contact Name Contact number Contact Email

Authorized Travel Agent:
Toll Free 877.477.3326
Vikas Chopra, Travel
Cell 240.472.4502 Vikas@
Partner at Fly Premier
WhatsApp# 240.472.4502 flypremierclass.com
Class
Kopal Rana, Travel Partner US-703.740.0216 Kopal@
at Fly Premier Class India # +91 95992 32500 flypremierclass.com

Any deviation from this policy will need approval of the Chief People Officer and Global
CEO.

Everise
600 North Pine Island Road, Suite 320 202
Plantation, FL 33324 weareeverise.com
 Progressive Coaching Process

To ensure compliance with Company policies and sustained performance

expectations, Everise has in place a coaching and counseling process that is intended
to improve performance when, in the opinion of management, improvement is
warranted. Employees at all levels should be open to feedback and respond
accordingly.

The disciplinary action process is subject to the severity of the offense but could
commence at any of the following steps.

1. First Warning / Coaching Statement: If undesirable action or performance occurs,

this warning is issued to make the employee aware of any gap in behavior or
performance and create awareness for immediate corrective action.

2. Second Warning: If an undesirable action or performance is repeated, the

employee is given a written warning and a documented coaching session with up
to a 30-day corrective action plan by their Supervisor. The purpose of this meeting
is to discuss the behavior or performance gap in more detail and collaborate on a
solution with the employee.

3. Final Warning – The employee is given a final written warning and documented
counseling session with up to a 30-day corrective action plan by their supervisor.
Termination of employment may occur if immediate corrective action is not taken.

4. If similar action continues, pending the circumstances, termination of employment

may occur. Termination as a result of disciplinary action must be approved by the
Chief People Officer or their designee.

5. An employee may also be placed on a Performance Improvement Plan (PIP). The

PIP process may run concurrently with the coaching and counseling process or in
place of it. During the PIP period, regular meetings and feedback between the
employee and their supervisor are required.

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 6. Suspension – Suspension is not used as a form of disciplinary action. An employee
is suspended when, to thoroughly investigate an issue, management determines
it is best that the employee is not at the workplace. The employee should contact
an HR manager to find out the status of their employment at the designated time.
If the employee is reinstated, the time away is paid based upon the employee’s
normal work schedule. If the employee is not reinstated, the employee is paid
through their last hour of work. Employees who do not call as requested are
considered to have voluntarily resigned.

Everise
600 North Pine Island Road, Suite 320 204
Plantation, FL 33324 weareeverise.com
 Employee Resources

1. Communications
o We believe all employees should be kept fully informed about Everise and any
current events. Your supervisor is always your best source of information.
Workday, the Company website, and the bulletin boards are also excellent
sources to access information of general interest.

o Company information may also be dispersed by Company email and phone. If

you have any questions or suggestions, please feel free to discuss them with your
supervisor, any member of the management team, or a representative from the
Human Resources Department.

2. Employee Assistance Program

o The Company presently provides an Employee Assistance Program (EAP) for all
employees and members of their households. The EAP offers help dealing with
such issues as mental health, family counseling, depression, anxiety, drug
addiction, legal and financial counseling.

o All services provided by the EAP are free to the employee and their household. If
an individual accepts a referral to an outside resource, they are responsible for
the costs incurred. Contact the HR Department for more details on the
Company's EAP.

o Contact EAP at 888-628-4824 or go to www.guidanceResources.com, Username:

LFGSupport, Password: LFGSupport1.

Everise
600 North Pine Island Road, Suite 320 205
Plantation, FL 33324 weareeverise.com
 Dispute Resolution Process

The dispute resolution process (DRP) is used to resolve internal disputes or issues that
may occur in the workplace. Everise Champions should follow the following process
for internal disputes or other HR related issues that may develop.

Bringing Employees and Management Together

The DRP brings both management and employees together in an environment to

discuss and resolve concerns from minor everyday misunderstandings to potential
violations of legally protected rights.

Everise believes that open communication within an atmosphere of mutual trust is of

prime importance to its employees. Realizing that effective communication is always
a two-way street, the company values employee feedback, input, and suggestions on
any matter.

Everise Process to Resolve Issues in the Workplace

1. The open-door option is frequently the best choice because it is easy to use,
informal, and can resolve problems with your supervisor or manager quickly
and efficiently.

2. The Human Resources Department is another option that you can choose to
discuss an issue with an HR representative by opening a ticket in Workday or
contacting your HR representative directly.

3. The Dispute Resolution Review Committee can be requested through Human

Resources, which will review your concern by 2-3 senior leaders.

Everise
600 North Pine Island Road, Suite 320 206
Plantation, FL 33324 weareeverise.com
 1. Open Door – Speaking with Your Supervisor or a Manager

• Supervisors perform a key role at Everise in helping employees understand their

specific role within our organization while excelling in their job requirements.
Supervisors are responsible for working with employees to plan future career
goals, discuss pertinent activities and projects and participate in evaluations of
job performance.

• We realize that in the normal course of business questions, issues, or concerns

will sometimes arise. It is important we resolve any of these issues and
concerns in a timely manner to avoid escalation and loss of focus on our goals.
For this reason, we strongly encourage any employee to meet with their
immediate supervisor regarding any concern or issue which may arise.

• We encourage you to bring any questions, issues, or concerns to our attention,

so we can make every effort to resolve them. If you feel it would be
inappropriate to discuss an issue with your direct supervisor, you should bring
it to your Line of Business leader and/or the Human Resources Department.

• In most cases, talking with a supervisor is the most effective way to share your
feedback or suggestion. However, an employee may discuss problems or
suggestions with a higher-level manager, executive or the HR Department
instead of, or in addition to, their supervisor.

• The company will attempt to keep the investigation, and the terms of any
resolution confidential. However, while investigating and resolving concerns,
some disclosure of information to others may be necessary.

2. Human Resources Department

• The HR Department may provide information regarding policies, procedures,
accommodations, pay and benefits, as well as support employees in other
areas.

• HR representatives are also available to discuss and assist with matters that
are personal or private in nature in confidence, provide resources and answer
questions.

• Employees may log a ticket in Workday to resolve disputes or request a

conversation with an HR representative regarding any workplace issues.

3. Dispute Resolution Review Committee

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 • The Dispute Resolution committee consists of 2 to 3 senior leaders who assist in
resolving disputes within the company after a Human Resource review and/or
investigation has been completed.

• The committee will review any escalated issues that may not have been
resolved satisfactorily after employees have utilized the Open Door policy and
reviewed the issue with Human Resources.

• A review by the committee may be requested by opening a ticket for HR in

Workday.

• An employee must first have taken advantage of the Open Door policy and if
the issue remains unresolved, discuss it with Human Resources before
requesting a review by the committee.

Dispute Resolution Channels

Step 1 Step 2 Step 3

Human DRP Review
Open Door
Resources Committee
Direct discussions • Payroll Issues Serious issues that
with your supervisor • Benefits Issues were not resolved
or manager for • FMLA requests through the Open-
issues such as: • ADA requests Door process or
• Scheduling • Medical Leave Human Resources.
Conflicts • Escalation of
• Performance performance Employees must
clarification management request this option
• Metrics and questions by opening a ticket
Objectives • Resolution of in Workday.
• PTO requests conflicts with
• Work related fellow employees,
questions supervisors, or
managers

4. Whistleblower Hotline (External)

The Whistleblower Hotline is available for issues affecting the company such as anti-
bribery, corruption, fraud, or a violation of international or federal law that would result

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 in significant monetary or reputational loss to the company. Some examples of
reporting that is appropriate for reporting on the hotline are:

• Receiving bribes including facilitation of payments to city, state or federal

officials;

• Giving or receiving expensive gifts and entertainment for new business (Quid
Pro Quo);

• Making political donations and lobbying to influence business decisions; or

• Disclosing any accounting or financial discrepancies.

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 Whistleblower Policy and Procedure

Rationale

Everise Holdings, its affiliates, and subsidiaries (“Everise” or the “company”) is

committed to ensuring the highest possible standards of ethical, moral and legal
business conduct and practices including openness and accountability in all aspects
of its business. With the establishment of this Whistleblower Policy and Procedure (this
“policy”), employees, advisors, contractors, and vendors are encouraged to raise
genuine concerns regarding Detrimental Actions and Improper Conduct occurring
within Everise globally. Capitalized terms are defined under “Procedural Guidelines”
below.

The purpose of this policy is to:

• Provide a consistent, systematic, corporate-wide process for managing any

suspected Detrimental Action and Improper Conduct;
• Provide a mechanism for employees and others to report their concerns freely and
without fear of reprisal or intimidation if they act in good faith;
• Protect individuals who in good faith report Detrimental Actions or Improper
Conduct on a confidential basis; and
• Assist in ensuring that Detrimental Actions and Improper Conduct are identified
and dealt with appropriately.

This policy supplements (but does not replace) any and all existing company policies
and procedures relating to the treatment of wrongful or improper conduct.

Coverage
This policy applies to all whistleblowers as defined below.

Policy

A Whistleblower as defined by this policy may be an employee, advisor, contractor, or

vendor of Everise who reports an activity that he/she/it considers to be illegal or
dishonest to one or more of the parties specified in this policy. The Whistleblower is not
responsible for investigating the activity or for determining fault or corrective
measures; appropriate management officials are charged with these responsibilities.

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 Examples of illegal or dishonest activities include violations of federal, state, or local
laws; billing for services not performed or for goods not delivered; and fraudulent
financial reporting.

If an individual has knowledge of or a concern that illegal or dishonest fraudulent

activity has occurred, the mediums for reporting are:
• Face-to-face meetings (Open Door Policy)
• Email
• Mail
• Phone
• Toll-free Hotline
• Corporate Website (if applicable)

Employees are expected to immediately report any wrongdoing by reaching out to

his/her immediate supervisor, others in management, Human Resources, or the
Country Human Resources Head. The employee must exercise sound judgment to
avoid baseless allegations. An employee who intentionally files a false report of
wrongdoing will be subject to discipline up to and including termination.

Whistleblower protections include maintaining confidentiality of the Whistleblower and

against Retaliation. Insofar as possible, the confidentiality of the Whistleblower’ identity
will be maintained. However, identity may have to be disclosed to conduct a thorough
investigation, to comply with the law and to provide accused individuals with their legal
rights of defense. Everise will not retaliate against a Whistleblower in any manner,
including retaliation in the form of an adverse employment action such as termination,
compensation decreases, poor work assignments and threats of physical harm. Any
Whistleblower who believes he/she is being retaliated against must contact the Human
Resources Country Head immediately. The right of a Whistleblower for protection
against retaliation does not include immunity for any personal wrongdoing that is
alleged and investigated.

All reports of illegal and dishonest activities will be promptly submitted to the Country
Human Resources Head who is responsible for investigating and coordinating
corrective action for each country. Employees with any questions regarding this policy
should contact Human Resources or Helen Franco, the head of the company’s Legal &
Compliance Department.

Local references for your geography are available in the Annex attached to this
policy.

Everise
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Plantation, FL 33324 weareeverise.com
 Procedural Guidelines

I. Definitions
Complaint A disclosure of Improper Conduct made by a
Whistleblower
Confidential Includes, without limitation:
Information • Information about the identity, occupation,
residential address, work address or
whereabouts of (i) the Whistleblower; and (ii)
the person against whom the Whistleblower
has made a Complaint;
• Information disclosed by the Whistleblower;
and
• Information that, if disclosed, may cause
detriment to any person.
Retaliation / Any reprisal action against a Whistleblower
Detrimental Action including, but not limited to:
• Action causing injury, loss or damage;
• Intimidation or harassment;
• Interference with the lawful employment or
livelihood of the Whistleblower, including
discrimination, discharge, demotion,
suspension, disadvantage, termination,
adverse treatment in relation to the
Whistleblower’s employment or the taking of
disciplinary action; and
• A threat to take any of the above actions.
Improper Conduct Any unethical behaviour, malpractice, illegal act or
any other wrongful or improper conduct within
Everise that if proved, constitutes a disciplinary
offense or a criminal offense.
Whistleblower Any Everise employee, advisor, contractor, or
vendor making a Complaint and / or providing a
report using a method described in this policy or
to any Compliance Officer.
CMS Case Management System

Everise
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 II. The Whistleblower Hotline
A Toll-free Whistleblower Hotline has been created to encourage company
employees, advisors, contractors, or vendors to speak up when they have
legitimate concerns about misconduct. Confidentiality and anonymity are
critical factors in a properly managed ethics hotline. As such, all hotline
information, including CMS passwords and copies of reports, are managed by
the Primary Contact in a secure environment and that access to this
information is limited only to those individuals who have a “need to know.”

III. Roles
Below are the various functions performed by individuals involved with our
hotline program. One person may perform multiple roles at any given time.
Provided below are the descriptions and persons assigned to each role:

Whistleblower A committee formed for the purpose of receiving,

Committee processing, investigating, and determining the
(“WBC”) genuineness of any Complaint or Report received
from a Whistleblower or a Recommendation
received from the Compliance Officer in order that
appropriate action can be taken to address the
Complaint, Report or Recommendation. The WBC
shall also be responsible for dealing / liaising with
the Compliance Officer in respect of any matters
pursuant to the Recommendation.
Compliance Officer Responsible for ensuring that all complaints about
unethical or illegal conduct are investigated and
resolved. The Compliance Officer will advise the
Board of Directors on all complaints and their
resolution and will report at least annually on any
compliance activity relating to accounting or
alleged financial improprieties. The Compliance
Officer is empowered to conduct their
investigations in isolation of the Board in order to
maintain independence, but are free to involve
members of the Board as necessary. It is solely the
Compliance Officer’s charge to determine

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 whether a complaint can be considered valid for
investigation though any individual may submit a
complaint as noted above.
The company Compliance Officer is Helen Franco.
Investigation Team A team made up of members nominated by the
WBC on an ad-hoc basis for the purpose of
investigating any Complaint, Report or
Recommendation as directed by the WBC.
The Investigation Team consists of the following
members:
• Investigation Team Lead
• Representative from Management (preferably
Sr. Manager or up) who may or may not be
from the same Department
• Representative from HR who will also be
responsible for taking the minutes of meetings.
Investigation Team Usually, the Country Human Resources Head or
Lead other company employee designated by the WBC
to lead the Investigation Team
Primary Contact By emailing [email protected], the
primary contact will manage the list of designated
recipients for reports and inform the vendor of any
changes to the companies in the Everise group.
The primary contact will also receive email
notification of any upgrades to the company’s
services, administrative matters and program
correspondence.
The Primary Contact will be the Everise legal team.
Designated All reports are sent via email to our designated
Recipient recipients. The hotline agreement provides Everise
with the opportunity to specify who will receive
Fraud, Ethics, Compliance and Human Resource
cases.
To ensure appropriate immediate action is taken,
the mailboxes are segregated below:
• Fraud, Compliance & Ethics: Helen Franco &
Sheena Ponnappan, Chief People Officer
• Human Resource Concerns (including, but not
limited to, harassment): Helen Franco, Sheena

Everise
600 North Pine Island Road, Suite 320 214
Plantation, FL 33324 weareeverise.com
 Ponnappan, and Country Human Resource
Heads
CMS Administrator Helen Franco & Sheena Ponnappan

The CMS Administrator has unrestricted access to

our entire online database and is responsible for
updating information related to the database. In
addition, CMS Administrators also assign reports
to CMS Investigators and add new users. The
company may designate an unlimited number of
CMS Administrators.
CMS Investigator Legal Team and Country Human Resource Heads
Investigators have limited access to the CMS and
can investigate, track progress, dialog, and upload
files to reports they have been assigned by the
Administrator.
The company may designate an unlimited
number of CMS Investigators.

IV. Hotline Details

Below are the international calling instructions for employees (Worldwide Toll-
Free Number) for countries that do not use a direct dial toll-free number.

a. For Employees:
i. Make sure you have an outside line.
ii. Enter the Access Code for the country and/or the telephone
system you are calling from.
iii. An English-language voice prompt will ask for the number you are
calling.
iv. Enter our toll-free number: 800-603-2869. There is no need to dial
'1' before the toll-free number. You are now connected to the
hotline.
v. A Lighthouse greeting will be played in multiple languages. Make
a choice from the prompts or press 0 and tell the English operator
the language you speak (preferably in English). An interpreter will
then join the call in 2 – 3 minutes. The Lighthouse operator will
interview you aided by the interpreter.

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 vi. A report in English is then sent to the designated recipient(s) of
your company.
vii. Access codes are subject to change.

b. Calling Instructions

1. Make sure you have an outside line.

2. Enter the Access Code for the country and/or telephone
system you are calling from. You will then hear a “bong”.
3. An English-language voice prompt will ask for the number
you are calling.
4. Enter the toll-free number: 800-603-2869. There is no need
to dial “1” before the toll-free number.
5. You are now connected to the hotline.
6. A Lighthouse greeting will be played in multiple languages.
Make a choice from the pre-recorded language prompts or
press 000 and tell the English operator the language that
you speak (preferably in English). An interpreter will then join
the call in 2 to 3 minutes. The Lighthouse operator will
interview you, aided by an interpreter.
7. A report in English is then sent to the designated recipient(s)
of your company.
8. Access codes are subject to change.

c. Access Codes for calls made outside North America:

i. Guatemala:
• English - 999-9190
• Spanish - 999-9190
ii. Malaysia: - 1-800-80-0011
iii. Singapore:
• SingTel - 800-011-1111
• StarHub - 800-001-0001
iv. Philippines:
• PLDT English - 1010-5511-00
• PLDT Tagalog - 1010-5511-10, 2nd Option 105-11
• Globe English - 105-11
• Globe Tagalog - 105-12

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 • Philcom English - 105-11
• Philcom Tagalog - 105-12 Digitel 105-11
• Digitel Tagalog - 105-12
• Smart English - 105-11
• Smart Tagalog - 105-12
• Bayan 105-11
v. Colombia - 01-800-911-0010
vi. Japan
• Japan (KDDI) - 00-539-111
• Japan (NTT) - 0034-811-001
• Japan (Softbank Telecom) - 00-663-5111
vii. Ireland
• Ireland - 1-800-550-000
• Ireland (UIFN) - 00-800-222-55288
viii. India - 000-117

Website
Employees also have the option to file a complaint online by going to: Whistleblower
Submission .

V. Case Management Guidelines

a. Reports received via the Hotline are sorted by the Designated
Recipient/s and, where appropriate, provided to the Chief People Officer
or her designate, for appropriate action.
b. Once a case is turned over to the Country Human Resource Head,
discipline management procedures must be followed.
c. Where necessary, such as for serious ethics infractions (for example,
harassment), an Investigation Team is created and usually led by an
Investigation Team Lead.
d. The Investigation Team shall provide the necessary Investigation inputs
upon which the Disciplinary Action or Non-Action, where applicable, shall
be based.
e. All cases must be recorded in the CMS.
f. The following access is provided to the roles below:

CMS Administrator ‒ View reports online at your convenience

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 ‒ Assign incidents to the appropriate party for
investigation
‒ Set the risk level, priority and status of reports
‒ Record follow-up and outcome notes
‒ Anonymously dialog with reporter if enabled
‒ Create reports and charts to help track
activity and analyze trends
‒ Review an audit trail for added internal control
‒ Upload digital files and documents to a
record
‒ Search the database using keywords and
date filters
‒ Create multiple user levels
‒ Add customized fields
‒ Send messages to system users
‒ Integrate system data using API
CMS Investigator ‒ Assign incidents to the appropriate party for
investigation
‒ Set the risk level, priority and status of reports
‒ Record follow-up and outcome notes
‒ Anonymously dialog with reporter if enabled
‒ Create reports and charts to help track
activity and analyze trends
‒ Upload digital files and documents to a
record
‒ Search the database using keywords and
date filters.

g. The Compliance Officer is responsible for providing progress updates

and reports of closure, aside from the regularly released compliance
reports, to shareholders and executive leadership as necessary.

VI. Protection for Whistleblowers

a. NON-DISCLOSURE OF CONFIDENTIAL INFORMATION
i. Confidential information is defined as:
• Information about the identity, occupation, residential address,
work address or whereabouts of (i) the Whistleblower; and (ii)

Everise
600 North Pine Island Road, Suite 320 218
Plantation, FL 33324 weareeverise.com
 the person against whom the Whistleblower has made a
Complaint;
• Information disclosed by the Whistleblower; and
• Information that, if disclosed, may cause detriment to any
person.
ii. Should the person against whom a Complaint is made request
access to Confidential Information, the Investigation Team must
seek approval from the person who made the Complaint before
such information is disclosed. Without such consent, the
Whistleblower shall maintain his/her anonymity.

b. Non-Retaliation
Whether or not the Complaint is substantiated, the company shall take
appropriate disciplinary action for any Retaliation or Detrimental Action
against a Whistleblower.

This policy is effective as of January 7, 2019.

Everise
600 North Pine Island Road, Suite 320 219
Plantation, FL 33324 weareeverise.com
 ANNEX

Local Reference per Geographic Location

United States 1. False Claims Act:

www.law.cornell.edu/uscode/text/31/3729
2. Sarbanes-Oxley Act:
www.law.cornell.edu/uscode/text/18/1514A
3. Dodd-Frank Act:
www.law.cornell.edu/uscode/text/12/chapter-53
4. Defend Trade Secrets Act of 2016, Public Law 114–
153:
https://www.congress.gov/114/plaws/publ153/PLAW-
114publ153.pdf
Philippines The Philippines has whistleblower protection laws in
place to encourage disclosure of
wrongdoing in both the public and private sectors.
While there is no whistleblower protection
code, the following are some of the laws that provide
for whistleblower protections:
1. Presidential Decree No. 442 or the Labour Code
of the Philippines;
2. Republic Act No. 6981 or the Witness Protection,
Security and Benefit Act;
3. Presidential Decree No. 749 grants immunity
from prosecution to givers of bribes and other
gifts in bribery and other graft cases against
public officers;
4. Republic Act No. 6770 or the Ombudsman Act
of 1989;
5. Commonwealth Act No. 108 or the Anti-Dummy
Law; and
6. Republic Act No. 10667 or the Philippine
Competition Act
Malaysia Malaysia’s Whistleblower protection laws are
pursuant to the Whistleblower Protection Act 2010.
An English translation of this is available at:
www.bheuu.gov.my/portal/pdf/Akta/Act%20711.pdf

Everise
600 North Pine Island Road, Suite 320 220
Plantation, FL 33324 weareeverise.com
 International Singapore and Guatemala have no specific
Guidelines whistleblower protection laws in place. However,
whistleblower protection is now recognized as part
of international law. In 2003, the United Nations
adopted the United Nations Convention against
Corruption (UNCAC) which is a legally binding
multilateral treaty which was signed by 140 nations
and formally ratified, accepted, approved, or
acceded by 137 nations, including the United
States. Article 32 and Article 33 of the UN
Convention endorse protections for whistleblowers.

Everise
600 North Pine Island Road, Suite 320 221
Plantation, FL 33324 weareeverise.com
 Enterprise Information Security Policy
Objective

The main objective of the security program is to ensure the availability, confidentiality,
and integrity of information/data and systems across the entire organization. Security
is an enterprise-wide risk management issue.

• Senior executives at each operating business have full accountability on

securing information and systems across their business and operation.

• All employees and authorized users, including 3rd party vendors and
contractors, are responsible for protection information and systems against
threats and risks.

Access

All requests for logical access must be defined within a Service Request in the ticketing
system. Access to information and application systems and functions are restricted to
the minimum necessary to perform your job function. Privileges are formally authorized
and controlled, allocated to users on a need to use and event by event basis for the
functional role.

Each user of the system is granted a unique User ID. There is no shared access or
accounts. No guest or anonymous accounts are created.

Upon termination, either voluntary or involuntary, logical, and physical access is

removed.

Password policy

Rules govern the creation and maintenance of passwords for the User IDs. Passwords
are never set to not expire. The expiration duration is forty – two (42) days. After this,
the password must be changed by the user.

Passwords should be changed whenever there is any indication of possible system or

password compromise. Default passwords are never permitted.

General Standards

• You may not use the previous 24 passwords

• Passwords expire in 42 days

• Password must be in affect a minimum of 1 day

Everise
600 North Pine Island Road, Suite 320 222
Plantation, FL 33324 weareeverise.com
 • Minimum password length 8 characters

• Passwords may not contain the user’s entire account name or full name.

• Passwords must contain characters from three of the following five categories:

• Uppercase characters of European languages (A through Z, with diacritic marks,

Greek and Cyrillic characters)

• Lowercase characters of European languages (a through z, sharp s, with diacritic

marks, Greek and Cyrillic characters)

• Base 10 digits (0 through 9)

• Non-alphanumeric characters: ~!@#$%^&*_-+=`|\(){}[]:;"'<>,.?/

• Passwords should not contain the company name in any form

A passphrase is suggested to provide for a higher level of security. A passphrase is a

sequence of words or text used instead of a password. It may be easier for you to
remember but harder for hackers to crack.

A password dictionary is utilized to enforce strong passwords and block any change
requests that matches a password on the banned password list.

Everise utilizes the application, Jarvis, to assist with changing your password.
https://jarvis.weareeverise.com/. Users will need to pre-register in Jarvis prior to utilizing
the services. You will need to provide your User ID, Employee ID and set up 3 security
questions. After registration is complete, you may use the Forgot Password and Unlock
Account features. Failure to register could impact your ability to be productive in your
role as you may not have the ability to log in for an extended period.

In addition to your username and password, multi-factor authentication may be

required for certain applications. Multi-factor authentication (MFA) is an additional
layer of security where an additional factor is introduced to authenticate access. A
token, which is a series of numbers, is systematically generated from an application or
received via email.

Everise
600 North Pine Island Road, Suite 320 223
Plantation, FL 33324 weareeverise.com
 After 6 repeated unsuccessful password attempts, your User ID will be locked. The
lockout duration is 30 minutes or until an administrator enables your User ID. Idle
sessions of more than 15 minutes require you to re-enter your password.

Your workstation may be protected with several security protocols. Anti-virus software,
intrusion detection, firewall, operating system updates, restricted ability to save, copy,
print, download or install software. Full and quick anti-virus scans will run at scheduled
intervals as well as update virus definitions. Security patches are delivered on a pre-
determined schedule. Security protocols are centrally managed and should not be
tampered with, disabled, or bypassed.

Only approved software may be installed. All software must be purchased via the
Everise procurement process. The use of removable media devices is not permitted.

Security Awareness Training

The Security Awareness program provides a general overview of the common-sense

techniques to keep data safe. Training may cover topics such as privacy and key
security policies and procedures, legal and regulatory considerations, and fraud
related issues staff should know to prevent, detect, and respond to information security
incidents. Security Awareness Training is required of all staff members upon hire.
Training is repeated at least annually. The frequency and content of training may
change based on emerging threats and technology.

Incident Response

The Company seeks to ensure that all personnel react appropriately to any actual or
suspected security incident relating to Information Systems and Data. Incidents should
be reported to the Global Service Desk (through any channel). A ticket will be created
and routed to the appropriate group for handling. Reports should include, where
possible, a description of the event, the date of the occurrence or discovery, a
description of the types of information involved. Reporting should be done without
reasonable delay.

Any security incident should be reported to the Global Service Desk and CISO as soon
as you are aware of an incident.

Everise
600 North Pine Island Road, Suite 320 224
Plantation, FL 33324 weareeverise.com
 •[email protected]

•[email protected]

Any concerns regarding security policies, procedures, or compliance with them, may
be reported to the Information Security Officer at [email protected].

Everise
600 North Pine Island Road, Suite 320 225
Plantation, FL 33324 weareeverise.com
 Employee Acceptable Use Policy
DATA PROTECTION POLICY

The Company possesses information that is sensitive and valuable. Some information
is protected by federal, state, and local laws or contractual obligations that prohibit its
unauthorized use or disclosure. The exposure of sensitive information to unauthorized
individuals could cause irreparable harm to the Company or our clients and could also
subject the Company to fines or other government sanctions. Additionally, if the
Company information were tampered with or made unavailable, it could impair the
Company’s ability to do business. The Company therefore requires all employees to
diligently protect information as appropriate for its sensitivity level.

Failure to comply with this policy may subject personnel to disciplinary measures.
Failure to comply could result in termination.

Explicit management approval is required to use the Company technology and

resources.

All Employees and Contractors

1. You may only access information needed to perform your legitimate duties as an
employee and only when authorized by the appropriate management.
• You may only access acceptable network locations for the technologies on the
network for which you have been approved access.
• You may only store Company data in Company approved systems and/or
locations such as OneDrive, SharePoint, Teams. Client data should only reside
within client systems. Company data must not be stored in company issued
devices, personal devices, or cloud (online) storage solutions.
• You may only work from approved locations.
• The use of a personal VPN is not permitted while using Company systems or
logging into Company applications.
2. You are expected to ascertain and understand the sensitivity level of information to
which you have access through training, other resources or by consultation with
your manager.
3. You may not in any way divulge, copy, release, sell, loan, alter or destroy any
information except as authorized by management within the scope of your
professional activities.

Everise
600 North Pine Island Road, Suite 320 226
Plantation, FL 33324 weareeverise.com
 4. You must understand and comply with the Company’s requirements related to
Personally Identifiable Information (PII), Patient Health Information (PHI) and
Payment Card Information (PCI).
(collectively referred to as “covered data”.)
• You may not engage in inappropriate access to covered data of neighbors,
colleagues, and relatives.
• Covered data are prohibited from being stored onto local hard drives, floppy
disks, and other external media.
• Covered data are prohibited from being placed in any system within the
Company network or cloud based systems. This includes email, O365, the
Service Desk portal, Workday, etc. Covered data should only be used within the
client system where it originated or is intended for.
• Workstations must be locked when away.
5. You must adhere to the Company’s requirements in protecting any computer used
to conduct and transact Company business regardless of the sensitivity level of the
information held on that system.
6. You must protect the confidentiality, integrity, and availability of the Company’s
information as appropriate for the information's sensitivity level wherever the
information is located, e.g., held on physical documents, stored on computer media,
communicated over voice or data networks, exchanged in conversation, etc.
7. You must safeguard any physical key, ID card or computer/network account that
allows you to access Company information. This includes creating difficult-to-
guess computer passwords. You should not share your login and password for any
system with anyone else, regardless of the circumstances.
8. You must destroy or render unusable any confidential or highly confidential
information contained in any physical document (e.g., memos, reports, microfilm,
microfiche) or any electronic, magnetic, or optical storage medium (e.g., USB key,
CD, hard disk, magnetic tape, diskette) before it is discarded.
9. You must report activities that you suspect may compromise sensitive information
to your supervisor or to the Company Information Security Officer.

[email protected]

10. Your obligation to protect sensitive information continues even after you leave the
Company.
11. While many federal, state and local laws create exceptions allowing for the
disclosure of confidential information in order to comply with investigative
subpoenas, court orders and other compulsory requests from law enforcement
agencies, anyone who receives such compulsory requests should contact the Legal
Department of the Company before taking any action through:

Everise
600 North Pine Island Road, Suite 320 227
Plantation, FL 33324 weareeverise.com
 Legal Department
[email protected]
600 North Pine Island Road, Suite 320
Plantation, FL 33324

12. If you are performing work for the Company that handles information subject to
specific security regulations (Laws pertaining to the policies, methods, means and
standards required to protect data from unauthorized access, use, disclosure,
modification or destruction, and to ensure the confidentiality, availability and
integrity of such data and IT Assets.), you will be required to acknowledge that you
have read, understand and agree to comply with the terms of this policy annually.

Managers and supervisors

In addition to complying with the requirements listed above for all employees and
contractors, managers and supervisors must:

1. Ensure that departmental procedures support the objectives of confidentiality,

integrity and availability defined by the Security Manager and designees, and that
those procedures are followed.
2. Ensure that restrictions are effectively communicated to those who use, administer,
capture, store, process or transfer the information in any form, physical or
electronic.
3. Ensure that each staff member understands his or her information security-related
responsibilities.

Technology Staff
In addition to complying with the policy requirements defined for all employees and
contractors, and managers and supervisors, those who manage computing and
network environments that capture, store, process and/or transmit Company
information, are responsible for ensuring that the requirements on confidentiality,
integrity, and availability, as defined by the appropriate management, are being
satisfied within their environments. This includes:

1. Understanding the sensitivity level of the information that will be captured by,
stored within, processed by, and/or transmitted through their technologies.
2. Developing, implementing, operating and maintaining a secure technology
environment that includes:

◦A cohesive architectural policy;

Everise
600 North Pine Island Road, Suite 320 228
Plantation, FL 33324 weareeverise.com
 ◦Product implementation and configuration standards;
◦Procedures and guidelines for administering network and system accounts
and access privileges in a manner that satisfies applicable security
requirements; and
◦ An effective strategy for protecting information against generic threats posed
by computer hackers that adheres to industry-accepted "best practices" for the
technology.

3. Ensuring that staff members understand the sensitivity levels of the data being
handled and the measures used to secure it.

Information Definitions
The confidentiality requirement for an information collection will be expressed in the
following terms:

• “Public” information can be freely shared with individuals on or off campus

without any further authorization by the appropriate Company Management.
• “Private” information can only be shared on a “need to know” basis with
individuals who have been authorized by the appropriate Company
Management, either by job function or by name. This information could result in
moderate risk to the Company. Anything that is not explicitly classified as
Restricted or Public should be treated as Private.
• “Restricted/Confidential” information can only be shared on a “need to know”
basis with a limited number of individuals who have been identified by the
appropriate Company Management. Unauthorized disclosure, alteration or
destruction of this information could cause significant harm to Company.
Examples include information protected by state and federal privacy
regulations or confidentiality agreements.

The integrity/availability requirement for an information collection will be expressed as

follows:

• Information is “Non-critical” if its unauthorized modification, loss or destruction

would cause little more than temporary inconvenience to the user community
and support staff, and incur limited recovery costs. Reasonable measures to
protect information deemed non-critical include storing physical information in
locked cabinets and/or office space, using standard access control
mechanisms that prevent unauthorized individuals from updating computer-
based information, and making regular backup copies.

Everise
600 North Pine Island Road, Suite 320 229
Plantation, FL 33324 weareeverise.com
 • Information is “Critical” if its unauthorized modification, loss, or destruction
through malicious activity, accident or irresponsible management could
potentially cause the Company to:
▪ Suffer significant financial loss or damage to its reputation,
▪ Be out of compliance with legal/regulatory or contractual requirements,
▪ Adversely impact its clients.
• Additional safeguards for "Critical" information:
▪ “Critical” information must be verified either visually or against other
sources on a regular basis; and
▪ A business continuity plan to recover “critical” information that has been
lost or damaged must be developed, documented, deployed, and tested
annually.

Non-compliance with any or all the requirements will constitute a security violation and
will be reported to the management of the Company and Company CIO and will result
in short-term or permanent loss of access to the Company computing systems and
such other systems. Serious violations may result in civil or criminal prosecution.

Everise
600 North Pine Island Road, Suite 320 230
Plantation, FL 33324 weareeverise.com
 Social Media Policy

This policy governs employee use of social media, including any tools used to share
content and profiles, including but not limited to social networking websites, apps, and
blogs. The lack of explicit reference to a specific site or type of social media does not
limit the application of this policy.

Social media can be an interesting and rewarding way to share your life and opinions
with family, friends, colleagues, and people all over the world, even with strangers. The
Company respects the rights of all employees to use social media. However, because
communications by Company employees on social media could, in certain situations,
negatively impact business operations or create legal liability, it is necessary for the
Company to provide these guidelines. These guidelines are intended to ensure
employees understand the types of conduct that are prohibited and to assist you in
making responsible decisions about your use of social media. This policy will not be
interpreted or applied to interfere with the rights of employees to discuss or share
information related to their wages, hours, or other terms and conditions of employment.
Employees have the right to engage in or refrain from such activities.

Employees engaging in use of social media are subject to all the Company’s policies
and procedures, including, but not limited to, the Company’s policies: (1) protecting
trade secrets and confidential information related to the Company’s operation; (2)
safeguarding Company property; (3) prohibiting unlawful discrimination, harassment
and retaliation; and (4) governing the use of Company IT.

1. Scope & Coverage

• This social media policy applies to all employees of the Company and its
affiliates and subsidiaries globally, regardless of rank, position, or nature of
employment.

• As the world of electronic communication and technology is rapidly evolving,

social media can mean many things. For purpose of this policy, “social media”
includes all means of communicating and posting information or content of any
sort on the Internet or on any web or mobile based applications (including your
own or someone else’s sites), whether or not these sites are associated or
affiliated with Everise. The lack of an explicit reference to a specific site or type of

Everise
600 North Pine Island Road, Suite 320 231
Plantation, FL 33324 weareeverise.com
 social media does not limit the application of this policy. Social media shall
include, but is not limited to, the following:

▪ Web, mobile, multi-media and social networking websites such as

Facebook, Yahoo! Groups, Twitter, Instagram, Google+, LinkedIn or any
other similar sites.

▪ Content communities like YouTube, Teams, or similar platforms.

▪ Blogs (both Everise blogs and personal blogs), online journal or diary,
personal website, web bulletin boards or chat rooms.

▪ Advertising content applications like Google.

▪ Collaborative content sites such as Wikipedia and any other site where
text can be posted.

• To be clear, social media also includes new and emerging applications; thus,
you should be aware that this policy is intended to apply to sites or services that
exist now or come into existence while this policy is in effect.

2. Principle of Accountability

• As a global organization that believes in being ahead of the technology curve,

we have come to embrace the opportunities for connection in its many forms.
Social media has exploded in the last decade and will continue to grow in the
years ahead. As an employee of Everise, you are our ambassadors out in the
world. We celebrate your successes and your feedback on our own social media
platforms. It's important to remember, however, that in a digital world, how we
behave in a private setting is more public than ever.

• You are ultimately responsible for what you post online in any social media
application. Before creating and posting content, consider the reward and, even
more carefully, the risks in your statements or postings. We recommend being
respectful and avoiding inappropriate subject matters while communicating in
your personal blogs or commenting and posting on social media, and we
encourage you to exercise your best judgment when expressing your views.

• You must make sure that you are always honest and accurate when posting
information and news, and if you make a mistake in your posting, you should
take steps to correct it immediately. You must be open about any previous posts
you have changed or corrected. It is good to remember that the Internet and
Social Media applications record everything; so, even when you delete posts or
comments, those can still be searched and appear in searches.

Everise
600 North Pine Island Road, Suite 320 232
Plantation, FL 33324 weareeverise.com
 Should you have any questions regarding this reminder, please contact:

• Helen Franco, Chief Legal Officer at [email protected]

• Sheena Ponnappan, Chief People Officer at

[email protected]

3. Guidelines

• You must observe these basic principles in your use of social media.

3.1 Know and Follow the Standards and Employee Handbook

• You are expected to carefully read this policy, the Company standards and
this handbook, which includes policies on harassment. You must ensure that
your statements, declarations, and postings in social media are consistent
with all of these policies. Inappropriate postings that include discriminatory
remarks, harassment, intimidation, threats of violence, or any inappropriate or
unlawful conduct are prohibited.

3.2 Be Respectful

• You are expected to respect your audience and avoid inappropriate subject
matters while communicating in your personal blogs or commenting and
posting in social media. Ethnic, religious, gender, sexual orientation, and racial
slurs, personal insults, obscenity, and similar postings are disrespectful and
should be absolutely avoided.

• You should exercise your best judgment when expressing your views and
opinions in social media. Although you represent your own self in public and
do not always represent Everise ’s official views, your acts, communications
and behavior may be considered reflective of the Everise culture and values.
In this regard, you are considered an ambassador of Everise in any public
setting.

• It is understood that there may be times when you disagree with co-workers
about work or management issues. Everise employees are encouraged to
address such issues and concerns using the internal channels.

Everise
600 North Pine Island Road, Suite 320 233
Plantation, FL 33324 weareeverise.com
 • You should always be respectful and courteous to fellow employees and
other people in your writings and communications. Also, bear in mind that you
are more likely to resolve work-related complaints by speaking directly with
your co-workers, managers, or Human Resources, or by emailing
[email protected] than by posting complaints to a social
media outlet.

3.3 Be Honest and Accurate

• You must make sure that you are always honest and accurate when posting
information and news, and if you make a mistake in your posting, you should
take steps to correct it immediately. You must be open about any previous
posts you have changed or corrected. It is good to remember that the Internet
and social media applications record everything; so, even when you delete
posts or comments, those can still be searched and appear in searches. You
should never post any information that you know to be false or spread rumors
about Everise, fellow employees, customers, vendors, and people working on
behalf of Everise or its competitors.

3.4 Post Only Appropriate Content

You should always be mindful of the laws, regulations and Company policies that may
apply to your postings in social media. Thus, you are advised:

• Not to create a link from your blog, website, page or posting to any Everise
websites without specific prior permission from Everise Brand Marketing and
Communications Department.

• Not to represent yourself as a spokesperson for Everise. When you express

opinions, they should be your personal opinions, and identified as your
personal opinions.

• Not to use social media to post or to display comments about co-workers,

supervisors, customers, vendors, suppliers, or members of management that
are obscene, physically threatening or intimidating, or otherwise constitute a
violation of the Company’s workplace policies against discrimination,
retaliation, or harassment. If you have been harassed, intimidated, or abused
by a co-worker via social media, you should report the conduct to your
immediate supervisor or contact Human Resources.

Everise
600 North Pine Island Road, Suite 320 234
Plantation, FL 33324 weareeverise.com
 • Not to use social media to post or display content that is an intentional public attack
on the Company’s products and/or services in a manner that a reasonable person
would perceive as calculated to harm the Company’s business and is unrelated to
any employee concern involving the terms and conditions of employment.

• Not to post a photograph or video of a vendor, supplier, or customer on social media

without that individual’s express permission.

• Not to misrepresent on social media an employee’s title or position with the

Company.

• You should use your personal email address when using Social Media. You are not
allowed to use your Everise email address to register on Social Media sites or for
social networks, blogs or other online tools utilized for personal use. You should
respect the intellectual property rights of others. You should not post or share
material that is protected by copyright or trademark.

• You should refrain from discussing non-public as well as sensitive topics related to
Everise even if a disclaimer is being used. For example, comments and speculations
on the organization’s business performance (including both past performance and
anticipated performance for upcoming quarters or future periods), business plans,
unannounced strategies, or prospects (including information about partnerships or
joint ventures), potential acquisitions or divestitures, similar matters involving the
Company’s competitors, legal or regulatory matters, and other similar subjects
could negatively affect the company.

3.5 Do Not Disclose Confidential and Proprietary Information

• You are required to strictly maintain the confidentiality of Everise business

information (including Trade Secrets and other Confidential Information, as
previously defined) and other confidential information. Trade secrets include, but
are not limited to, information regarding the development of systems, processes,
products, service offerings, call flows, scripts, customer lists, software, pricing
information, work flows, financial metrics, financial forecasts and other financial
information, technology, and other matters relating to Everise business operations.
Beware of congratulating co-workers online and referencing significant Everise
achievements that have not been publicly disclosed (i.e. successful development
of a new product or launch of a new partnership, acquisition of a significant new
customer, and achievement of a key financial metric.)

Everise
600 North Pine Island Road, Suite 320 235
Plantation, FL 33324 weareeverise.com
 • The Company has well established means of communicating publicly to the
marketplace or to the general public; hence only officially designated employees
have the authorization to speak on behalf of the Company.

• You are also not allowed to post internal reports, policies, procedures, or other
internal business-related confidential communications in any social media
platform.

3.6 Do Not Let Social Media Interfere with Your Work

• You should not allow social media activity to interfere with your job responsibilities.
You are expected to devote your full time and attention to your work during your
work hours.

3.7 Social Media Monitoring

• You should be aware that the Company may observe and monitor the content and
information posted by employees on social media when, to the extent allowed by
applicable privacy regulations, there is a legitimate business interest in doing so,
such as an investigation into whether there has been a violation of this policy and
other Company policies.

You may also be subject to disciplinary actions where you have:

• violated local laws by making threats of physical harm, libeling, slandering or

defaming customers, clients, co-workers, officers or directors, or other persons;

• violated copyright laws, such as illegal downloading of music videos or movies

where the downloads are loaded to or accessible from Company systems;

• disclosed Company confidential information or the confidential information of our

clients, customers, partners or vendors;

• disclosed personal information of customers, clients, co-workers, officers or

directors, or other persons such as social security numbers or government ID
numbers, credit card or banking information, address, or other personal
information;

• used social media in violation of Company policies, including anti-harassment and

anti-discrimination policies, such as inappropriate or sexually suggestive
comments and graphics, or any demeaning or disparaging jokes and comments;

Everise
600 North Pine Island Road, Suite 320 236
Plantation, FL 33324 weareeverise.com
 Where your postings violate this policy, the Company may also require you or the
relevant social media application to remove the applicable posting or thread.

3.8 Reservation of Rights

• The Company reserves its right to institute civil and criminal proceedings against
you for violation of this policy, and to recover payment for fines, penalties or
damages to its business and reputation, and to claim and file for other legal relief
and remedies to protect its interests.

3.9 Retaliation is Absolutely Prohibited

Taking negative action against any employee for reporting a possible violation of this
policy or for cooperating with an investigation is prohibited.

3.10 Dealing with Media

You should not speak to the media on behalf of Everise.

All media inquiries should be directed via email to the Corporate Communications
Department: [email protected]

If you have questions about this policy or need additional information or guidance,
please contact your local Human Resources representative.

Everise
600 North Pine Island Road, Suite 320 237
Plantation, FL 33324 weareeverise.com
 Confidentiality, Non-Solicitation and Non-
Disparagement Policy

CONFIDENTIALITY:

Information about Everise, Inc. (the “Company”), its employees, clients, suppliers, and
vendors is to be kept confidential and disclosed only to individuals with the Company
with both a need to receive and authorization to receive the information. If in doubt as
to whether information should be divulged, err in favor of not divulging information and
discuss the situation with the Company president.

All records and files maintained by the Company are confidential and remain the
property of the Company. Records and files are not to be disclosed to any outside
party without the express written permission of the Company president. Confidential
information includes but is in no way limited to: financial records; business, marketing,
and strategic plans; personnel and payroll records regarding current and former
employees; the identity of, contact information for, and any other account information
on clients, vendors, and suppliers; programs, trade secrets, formulas, techniques and
processes; and any other documents or information regarding the Company’s
operations, procedures or practices. Confidential information may not be removed
from the Company premises without express authorization.

Confidential information obtained during or through employment with the Company

may not be used by any employee for the purpose of furthering current or future
outside employment or activities for obtaining personal gain or profit. The Company
reserves the right to avail itself of all legal or equitable remedies to prevent
impermissible use of confidential information or to recover damages incurred as a
result of the impermissible use of confidential information.

NON-SOLICITATION:

Prior to Employees termination date with the company and for the 12 month period
following termination, the employee agrees not to, directly or indirectly, whether for the

Everise
600 North Pine Island Road, Suite 320 238
Plantation, FL 33324 weareeverise.com
 employee’s own account or for the account of any other individual or entity, (a) solicit,
induce, enter into any agreement with, or attempt to influence any individual who was
an employee, consultant or contractor of the Company at any time during the
preceding twelve (12) month period to terminate their employment relationship with
the Company, or interfere in any other way with the employment or other relationship
of any employee, consultant or contractor of the Company, or (b) solicit any customer
(including any prospective customer with respect to which the Company had taken
any material steps toward establishing a business relationship at any time on, or within
the nine (9) months prior to, the Termination Date (a “Prospective Customer”)) or
vendor of the Company, induce any of the Company’s customers or vendors to
terminate its existing business relationship with the Company, diminish the amount of
business a customer or vendor is doing with the Company or interfere in any other
manner with any existing business relationship between the Company and any
customer, vendor or third party or any potential business relationship between the
Company and any Prospective Customer.

NON-DISPARAGEMENT:

During and after their employment with the Company, the Employee agrees not to
make any disparaging statements about the Company or to engage in disparaging
conduct directed at the Company. The Employee agrees to refrain from engaging in
any type of communication, electronic, written or verbal, with third parties in an effort
to directly or indirectly disparage or injure the Company, or from assisting others in
doing so, or from otherwise engaging in or assisting others in negative activities with
respect to the Company, including in the commercial marketplace, financial
marketplace and broadcast media, including print, television, radio and Internet. This
non-disparagement provision does not prohibit or restrict the Employee from
disclosing information about unlawful acts in the workplace or communicating with
any government agencies or otherwise participating in any investigation or
proceeding that may be conducted by any government agency, including by
providing documents or other information, without notice to the Company, and without
waiving any right to receive an award for providing any such documents or
information.

Everise
600 North Pine Island Road, Suite 320 239
Plantation, FL 33324 weareeverise.com
 ENFORCEABILITY:

The Employee hereby acknowledges and agrees that the restrictions contained in in
this policy are necessary for the reasonable protection of the Company. The Employee
agrees that, in the event of any breach or threatened breach of any provision
contained in this policy, the Company shall have the right, in addition to any other rights
or remedies it may have, (a) to a temporary, preliminary or permanent injunction or
injunctions and temporary restraining order or orders to prevent breaches of such
provisions and to specifically enforce the terms and provisions thereof without having
to post bond or other security and without having to prove special damages or the
inadequacy of the available remedies at law, and (b) to require the Employee to
account for and pay over to the Company all compensation, profits, monies, accruals,
increments or other benefits derived or received by them as a result of any transaction
constituting a breach of any of the provisions of this policy.

Receipt of Confidentiality, Non-Solicitation & Non-Disparagement Policy

I have received and signed a copy of the Company’s Confidentiality, Non-Solicitation

& Non-Disparagement Policy, and I agree to abide by all terms of this Policy.

Everise
600 North Pine Island Road, Suite 320 240
Plantation, FL 33324 weareeverise.com
 Separation and Termination Process

1. Separation from the Company is classified as voluntary (employee initiated) or

involuntary (Company initiated).

2. Employees voluntarily leaving the Company are expected to give a minimum notice
of 14 calendar days. Failure to give proper notice may result in ineligibility for re-hire.

3. Unused PTO time is forfeited at termination and not paid out (unless mandated by
applicable law).

4. Employees may not utilize PTO once their notice has been given. Employees are
expected to work through their notice period.

5. Employees who fail to work all their scheduled shifts during the notice period will be
subjected to a reduction in hours.

6. Layoffs / Closure / Program Ended: Employees who have demonstrated good

performance are eligible for rehire. There is no waiting period to apply for available
openings based upon qualifications, attendance, and performance.

7. Voluntary Termination with Two Weeks’ Notice: Employees who work through their
full two (2) week notice and meet overall good performance and behavioral
standards are eligible for rehire. There is no waiting period to apply for available
openings based upon qualifications, attendance, and performance.

8. Involuntary Terminations – Employees who were terminated for misconduct,

violation of Company policy, unsatisfactory performance, excessive absenteeism
or lateness, or any other for-cause terminations are generally not eligible for rehire.

9. Rehire Eligibility: Eligibility is determined based on how the employee left Everise,
skills, performance, and attendance.

Everise
600 North Pine Island Road, Suite 320 241
Plantation, FL 33324 weareeverise.com
 9.1 Rehire/Reinstatement:

• Employees rehired within 90 days will be reinstated with an adjusted service

date (ASD). Employees rehired after 90 days will be treated as a new hire.

• If the employee had benefits such as health, dental, or vision, the reinstated
employee will be able to enroll in the health insurance programs the first of the
month following 30 days after rehiring for hourly employees and first of the
month following rehire for salaried employees.

• Employees rehired more than 30 days after the completion of their most recent
background check and drug screen will be required to complete a new
background check and drug screen.

• All employees rehired after 30 or more days of separation will be treated as a

new hire for the purposes of allocated PTO (unless otherwise mandated by
applicable law).

Everise
600 North Pine Island Road, Suite 320 242
Plantation, FL 33324 weareeverise.com
 Arbitration Statement & Agreement

• This Arbitration Statement & Agreement between the Company and its employees
is intended to provide the exclusive means of resolving all employment-related
disputes between them that may otherwise be brought in a court or before a
governmental agency, except as otherwise set forth in this agreement. In
consideration of the decision to accept or to continue employment and the mutual
promises herein, both the Company and employees agree that any claim, dispute,
and/or controversy that an employee may have against the Company (or its
owners, directors, officers, managers, employees, agents, and parties affiliated with
its employee benefit and health plans) or that the Company may have against an
employee, arising from, related to, or having any relationship or connection
whatsoever with an employee seeking employment with, employment by,
termination of employment from, or other association with the Company, shall be
submitted to and determined exclusively by binding arbitration under the Federal
Arbitration Act.

• Included within the scope of this agreement are all past, current and future claims,
disputes, and controversies, whether based on tort, contract, statute, regulation, or
equitable law (including, but not limited to, claims of discrimination, harassment,
retaliation, unpaid wages, wrongful termination and retaliation, under Title VII of the
Civil Rights Act, the Civil Rights Acts of 1866 and 1991, the Americans with Disabilities
Act, the Age Discrimination in Employment Act, the Fair Credit Reporting Act, the
Family and Medical Leave Act, the Fair Labor Standards Act, the Equal Pay Act, the
Employee Retirement Income Security Act, the Worker Adjustment and Retraining
Notification Act, the Consolidated Omnibus Budget Reconciliation Act, or any other
federal, state, or local law), with the exception of claims arising under the National
Labor Relations Act that are brought before the National Labor Relations Board,
claims for medical and disability benefits under state workers' compensation laws,
administrative claims for unemployment benefits, or as otherwise required by law.
Further, nothing herein shall prevent an employee from filing and pursuing
administrative proceedings before the United States Equal Employment
Opportunity Commission or an equivalent state, county or municipal agency
(although if the employee chooses to pursue a claim following the exhaustion of
such administrative remedies, that claim would be subject to the provisions of this
agreement). Actions by either the Company or an employee for a temporary

Everise
600 North Pine Island Road, Suite 320 243
Plantation, FL 33324 weareeverise.com
 restraining order or other preliminary injunctive relief may be pursued in a court of
competent jurisdiction pending resolution of the underlying dispute in arbitration.

• Further, in compliance with the Ending Forced Arbitration of Sexual Assault and
Sexual Harassment Act, an employee has the option of asserting any claims that
fall within that Act’s definition of sexual harassment and/or sexual assault either in
court or in arbitration under this agreement. If the employee elects to pursue their
sexual harassment and/or sexual assault claims in court, however, the employee
agrees that such claims will be tried only to a judge and not a jury.

• All claims brought under this agreement shall be brought in the individual capacity
of the employee or the Company. This agreement shall not be construed to allow
or permit the consolidation or joinder of other claims or controversies involving any
other employees or to permit such claims to proceed as a class action, collective
action, private attorney general action or any similar representative action. No
arbitrator shall have the authority under this agreement to order any such class or
representative action.

• In addition to requirements imposed by law, the arbitrator selected by the parties

shall be a retired state court trial judge or U.S. District Court Judge (or other similarly
qualified individual with arbitration experience as mutually agreed to by the parties)
and shall be subject to disqualification on the same grounds as would apply to a
judge of such court.

• To the extent applicable, the federal rules shall apply and be observed: pleading,
rules of evidence, rights to discovery and rights to resolution of the dispute by
means of motions for summary judgment and judgment on the pleadings.
Resolution of the dispute shall be based solely upon the law governing the claims
and defenses set forth in the pleadings, and the arbitrator may not invoke any basis
(including, but not limited to, notions of "just cause") other than such controlling law.
The arbitrator shall have the immunity of a judicial officer from civil liability when
acting in the capacity of an arbitrator, which immunity supplements any other
existing immunity.

Everise
600 North Pine Island Road, Suite 320 244
Plantation, FL 33324 weareeverise.com
 • The arbitrator, and not any federal, state, or local court or agency, shall have
exclusive authority to resolve any dispute relating to the scope, arbitrability,
interpretation, applicability, enforceability or formation of this agreement including,
but not limited to, any claim that all or any part of this agreement is void or voidable.

• To the extent permitted by law, if an employee initiates any action in court over a
claim covered by this agreement, the employee shall be liable to the Company for
any costs (including, but not limited, to attorney’s fees) incurred in compelling the
dispute to arbitration.

• All communications during or in connection with the arbitration proceedings are

privileged. As reasonably required to allow full use and benefit of this agreement,
the arbitrator shall extend the times set for the giving of notices and setting of
hearings. Awards shall include the arbitrator's written reasoned opinion.

• Should any term or provision or portion of this agreement be declared void or

unenforceable, it shall be severed, and the remainder of this agreement shall be
enforceable.

• This is the entire agreement between the Company and the employee regarding
dispute resolution and supersedes any and all prior agreements regarding that
issue. It is further agreed and understood that any agreement contrary to the terms
of this agreement must be in writing signed by the Company and the employee.
Oral representations made before or after the employee is hired do not alter this
agreement.

EMPLOYEE UNDERSTANDS AND AGREES TO THIS BINDING ARBITRATION PROVISION, AND BOTH
EMPLOYEE AND EVERISE GIVE UP THEIR RIGHT TO TRIAL BY JURY OF ANY CLAIM EMPLOYEE OR
EVERISE MAY HAVE AGAINST EACH OTHER.

EMPLOYEE’S SIGNATURE ON THE ACKNOWLEDGEMENT FORM ON THE LAST PAGE OF THIS

HANDBOOK ATTESTS TO THE FACT THAT EMPLOYEE HAS READ, UNDERSTANDS AND AGREES
TO BE LEGALLY BOUND TO ALL OF THE ABOVE TERMS OF THIS ARBITRATION STATEMENT AND
AGREEMENT.

Everise
600 North Pine Island Road, Suite 320 245
Plantation, FL 33324 weareeverise.com
 Acknowledgement of Employee Handbook

I understand it is my responsibility to read and abide by the Employee Handbook. The

handbook may be revised periodically. It is my responsibility to check the online
Employee Handbook which is found on the Intranet. I acknowledge my obligation to
read and understand its contents, and further acknowledge and agree that:

• The Employee Handbook is only intended to provide a general overview of the

Company’s personnel policies and does not necessarily represent all such policies
or practices in force at any particular time.

• The current version of the Employee Handbook supersedes any previous version of
the Employee Handbook that may have been issued by the Company.

• Neither this Employee Handbook, nor any other written or unwritten policy or
practice of the Company is intended to create an express or implied contract,
covenant, promise or representation of continued employment for an employee.
Employment is at-will, for no fixed term and may be terminated by the Company at
any time with or without cause or notice. However, employees should note that the
Arbitration Statement & Agreement included herein is intended to, and indeed does,
create a contractual obligation between the Company and the employee. No other
policy or practice should be construed as creating any contractual obligation.

• Other than the Arbitration Statement & Agreement and the Web Clock
Acknowledgement, the Company reserves the sole right to add, change, or rescind
any policy or practice at any time except that any such modification shall not alter
any employee right, or the right of the Company, to terminate employment at any
time without cause or notice.

• My electronic signature in Workday indicates that I take responsibility for

participating in or waiving 401(k) benefits with the Company. I also understand that
3% of my salary will automatically go to the Everise Retirement Savings Plan after 90
days of employment unless I decline to participate in the plan on-line.

Everise
600 North Pine Island Road, Suite 320 246
Plantation, FL 33324 weareeverise.com
 • My electronic signature in Workday indicates that I take responsibility for enrolling in
or waiving all benefits for which I may be eligible with the Company at least a week
prior to my eligibility.

▪ Benefit eligibility, unless otherwise specified, is on the first of the month

following:

o 60 days for hourly or non-exempt employees

o 30 days for salaried or exempt employees

• My electronic signature in Workday attests to the fact that I have read, understand,
and agree to be legally bound by the Arbitration Statement & Agreement and the
Web Clock Acknowledgement.

• My electronic signature in Workday attests to the fact that, in addition to

acknowledging and accepting the Employee Handbook, I have read, understand,
and agree to be legally bound by the Code of Ethics and Business Conduct, and will
abide by any other policy duly adopted by the Board of Directors of Everise Holdings
Pte. Ltd. or the Board of Directors of any of its direct or indirect subsidiaries.

Everise
600 North Pine Island Road, Suite 320 247
Plantation, FL 33324 weareeverise.com