Overview

VZL Staffing Services, LLC provides equal employment opportunities (EEO) to all employees and applicants for employment without regard to: race, color, religion, creed, gender, sex, pregnancy (including childbirth and related medical conditions), lactation, sexual orientation, gender identity or expression, national origin or ancestry, citizenship or immigration status, age, disability, genetic information or testing, uniformed service member status, status as a covered veteran or any other protected class in accordance with applicable federal, state and local laws. VZL Staffing Services, LLC complies with applicable federal, state, and local laws governing non- discrimination in employment. This policy applies to all terms and conditions of employment, including, but not limited to, recruitment, hiring, placement, benefits, promotion, demotion, termination, layoff, recall, transfer, leaves of absence, compensation, and training.

The Company prohibits unlawful discrimination as well as proscribed conduct that does not rise to the level of being unlawful.

Our commitment to equal opportunity employment applies to all persons involved in our operations and prohibits discrimination by any employee, including supervisors and co-workers, as well as third-parties involved in the Company’s operations. Any individual who believes that they or another individual have been subjected to discrimination in violation of this policy should report it pursuant to the Complaint Procedures in the Sexual and Other Prohibited Harassment policy below. If the Company determines this policy has been violated, appropriate disciplinary action, up to and including termination of employment, will be taken.

Retaliation is prohibited against any person by another employee or by the Company for reporting proscribed discrimination or for filing, testifying, assisting, or participating in any manner in any investigation, proceeding or hearing conducted by a governmental enforcement agency. An individual should report any retaliation prohibited by this policy pursuant to the Complaint Procedures in the Sexual and Other Prohibited Harassment policy below. If a complaint of retaliation is substantiated, appropriate disciplinary action, up to and including termination of employment, will be taken.

Illinois: Equal Employment Opportunity

As set forth in the National Handbook, the Company is committed to equal employment opportunity and to compliance with federal antidiscrimination laws. We also comply with Illinois law, which prohibits discrimination and harassment against any employees or applicants for employment based on their actual or perceived race (including traits associated with race, such as hair texture and protective hairstyles (e.g., braids, locks and twists)), color, sex (including married women and unmarried mothers), religion, age (40 or older), national origin, ancestry, marital status, protective order status, disability, military status, unfavorable discharge from military service, sexual orientation (including actual or perceived orientation and gender identity), citizenship status or work authorization status, genetic information, ancestry, pregnancy (including childbirth or medical or common conditions related to pregnancy or childbirth, past pregnancy condition and the potential or intention to become pregnant), certain arrest or criminal history records, homelessness (i.e., lack of a permanent mailing address or a mailing address that is a shelter or social services provider) and use of lawful products outside of work during nonworking hours. The Company will not tolerate discrimination or harassment based upon these characteristics or any other characteristic protected by applicable federal, state or local law.

The Company also complies with the Illinois law that restricts the circumstances under which employers may base employment-related decisions on an individual’s credit report or credit history and with the Illinois law prohibiting sexual harassment of unpaid interns.

New Jersey: Equal Employment Opportunity

As set forth in the National Handbook, the Company is committed to equal employment opportunity and to compliance with federal antidiscrimination laws. We also comply with New Jersey law, which prohibits discrimination and harassment against any employees or applicants for employment based on race (including traits historically associated with race, such as hair texture, hair type and protective hairstyles), creed, color, national origin, ancestry, age, sex, pregnancy or breastfeeding (including childbirth, breastfeeding or expressing milk for breastfeeding or medical conditions related to pregnancy, childbirth or breastfeeding), marital status, civil union or domestic partnership status, affectional or sexual orientation, gender identity or expression, atypical hereditary cellular or blood trait, genetic information, disability (including AIDS and HIV-related illnesses), liability for service in the U.S. Armed Forces and use or non-use of tobacco products outside the workplace. The Company will not tolerate discrimination or harassment based upon these characteristics or any other characteristic protected by applicable federal, state, or local law.

Additionally, the Company prohibits retaliation against any employee who requests from, discusses with or discloses to a current or former employee, a lawyer from whom the employee seeks legal advice or a government agency information regarding the job title, occupational category, rate of compensation (including benefits), gender, race, ethnicity, military status, or national origin of the employee or any other employee. Employees are not required to disclose their wage information.

Complaint Procedure

Any individual who believes that they or another individual has been subjected to discrimination, sexual harassment, any other form of prohibited harassment or retaliation should, as soon as possible, report it to their supervisor, People Business Partner, or any member of management with whom the employee feels comfortable; or report the matter through our anonymous third-party vendor, Work Shield, by completing an Incident Report Form online, verano.workshieldportal.com, or they may also call the 24/7 toll-free Call Center at 866.946.5558. If the employee makes a complaint under this policy and has not received a satisfactory response, the employee should contact their local People Business Partner.

Employees are not required to report any prohibited conduct to a supervisor or manager who may be hostile, who has engaged in such conduct, who is a close associate of the person who has engaged in such conduct, or with whom the employee is uncomfortable discussing such matters.

Every supervisor who learns of any employee’s concern about conduct in violation of our Equal Employment Opportunities Policy or our Sexual and Other Prohibited Harassment Policy, whether in a formal complaint or informally, or who otherwise is aware of conduct that may be in violation of those policies must immediately report the issues raised or conduct their local People Business Partner.

Employees are encouraged, but not required, to communicate to the offending person that their conduct is offensive and unwelcome. Individuals who observe any behavior directed at others that may violate this policy are encouraged to take reasonable action to defuse such behavior, if possible, such as intervening directly, alerting a supervisor or The People Team to assist, or making a report under this policy. Physical confrontation, violence, or assault is not an appropriate method of intervention. The intervening person must act in accordance with the Company’s policies.

Investigation

After a report is received, or the Company otherwise has reason to believe discrimination, prohibited harassment or retaliation is occurring, a timely, thorough and objective investigation by the Company will be undertaken. During the investigation, the Company generally will interview the complainant and the accused, conduct further interviews as necessary, and review any relevant documents or other information. The Company will maintain confidentiality surrounding the investigation to the extent possible, consistent with a thorough and objective investigation, and to the extent permitted or required under applicable law.

Once the investigation is completed and a determination is made, the complaining party will be advised that the investigation has been completed and may be informed of the resolution. The Company complies with the law in conducting investigations and employees are expected to provide truthful information when participating in an investigation.

Discipline

If the Company determines that this policy has been violated, including in the event that a supervisor or manager knowingly allows the policy to be violated without reporting it, prompt remedial action will be taken, up to and including termination of employment.

Good Faith Reporting

The initiation of a good faith complaint of discrimination, prohibited harassment, sexual harassment or retaliation will not be grounds for disciplinary or other retaliatory action, even if the allegations cannot be substantiated or the employee was mistaken about aspects of the complaint. Any individual who makes a complaint that is demonstrated to be intentionally false may be subject to discipline, up to and including termination.

Overview

All employees are designated as either non-exempt or exempt by the Company. The following is intended to help employees understand employment classifications and employees’ employment status and benefit eligibility. These classifications do not guarantee employment for any specified period of time, the payment of any particular amount of wages, or the continuation of any benefits. As discussed above, the right to terminate the employment-at-will relationship at any time is retained by both the employee and VZL Staffing Services, LLC.

Non-exempt employees

Employees who are eligible for overtime pay.

Exempt employees

Generally, managers or professional, administrative, or technical staff who are not eligible for overtime pay. With a few exceptions, exempt employees are typically paid a salary. For salaried exempt employees, the salary is intended to compensate them for all hours worked.

Employee Classification Categories

Regular Full-Time Employees

Employees who are not in a temporary status and who are routinely scheduled to work 30 hours or more per week. Regular full-time employees are eligible for the Company’s benefit package, subject to the terms, conditions, and limitations of each benefit program.

Regular Part-Time Employees

Employees who are not in a temporary status and who are routinely scheduled to work less than 30 hours per week. Regular part- time employees are not eligible for certain Company benefits as explained in SECTION 5 BENEFITS, and the applicable summary plan description.

Seasonal/Temporary Employees

Employees who have been engaged to work in a position for a specified number of hours a week, with the understanding that the position will be eliminated at a specified date or upon completion of a specific project or assignment. Employment beyond any initially stated period does not in any way imply a change in employment status or the provision or continuation of any benefit. Seasonal/temporary employees are not eligible for Company benefits, except where required by law.

Overview

Work schedules for cultivation centers and retail facilities are based on business needs. Each employee’s manager advises the employee regarding their specific working hours. Where possible, employees will be provided with a 72-hour advance notice for schedule changes, except where greater notice is required by law. Requirements regarding advance notice of your work schedule may vary by your work location. Please contact your manager for more specific details.

Punctual and consistent attendance is a condition of employment and an essential function of all positions at the Company. Various factors, such as workloads, operational efficiency, and staffing needs, may require variations in an employee’s starting and ending schedule times and total hours worked each day or each week. Employees are required to take meal and rest periods where required by law. The Company may, at its sole discretion, adjust the work week to fit the needs of the business including shift hours, rotation of shifts and/or weekend schedules, in accordance with applicable laws.

The Company reserves the right to assign duties to employees other than their usual assignments. In addition, employees may be required to work overtime or hours other than those normally scheduled whenever necessary. Changes in an employee’s schedule, hours, duties, or assignments does not alter an employee’s at-will employment status or guarantee any fixed terms and conditions of employment, continued employment of any kind or the provision of any employment-related benefit.

Illinois [Evanston]: Schedules and Hours Under the Fair Workweek Ordinance

The Company complies with Evanston’s Fair Workweek Ordinance (FWO). In accordance with that law, the Company adopts the policies and practices described below.

These policies and practices apply to all nonexempt employees who, in a calendar week, perform at least two hours of work for the Company within the geographic boundaries of the City of Evanston. Employees must also work in a covered industry, including hospitality, food service and restaurants, retail, warehouse services, manufacturing, or building services.

Good Faith Initial Estimate of Work Schedule

Prior to or upon the commencement of employment, the Company will provide covered employees, in writing, with a good faith estimate of the employee’s projected days and hours of work for the first 90 days of employment, including:

• The average number of weekly work hours the employee can expect to work each week;

• Whether the employee can expect to work any on-call shifts; and

• A subset of days and times or shifts that the employee can expect to work, or days of the week and times or shifts on which the employee will not be scheduled to work.

This good faith estimate does not constitute a contractual offer, and the Company is not bound by the estimate.

Prior to or upon the commencement of employment, employees may request that the Company modify the initial estimate of work schedule. The Company will consider any such request, and in its sole discretion may accept or reject the request. The Company will notify the employee of its determination in writing (including in physical or electronic format, e.g., email or text) within three days of the employee’s request.

Advance Notice of Work Schedule

The Company will provide covered employees with written notice of their work hours by posting their work schedules no later than 14 days before the first day of any new schedule (“the deadline”). The written work schedule will span at least a calendar week and will generally include the shifts and on-call status of all current covered employees at that worksite. The Company will transmit work schedules electronically upon an employee’s written request.

Upon request, the Company will refrain from posting or transmitting to other employees the work schedule of an employee who is a victim of domestic violence or sexual violence or who has a family or household member who is a victim of domestic or sexual violence. Under the circumstances, the Company may request a written statement from an employee that states the employee is, or has a family or household member who is, a victim of domestic violence or sexual violence. The written statement will suffice as the documentation needed for the Company to implement the request. The Company will not require such a written statement more than once in a calendar year from any employee for this purpose.

The Company reserves the right to change a covered employee's work schedule after it is posted and/or transmitted, but such changes are subject to notice and compensation requirements if made less than 14 days before the first day on the work schedule. The Company may also add an employee to a posted work schedule after the deadline when that employee is returning to work from a leave of absence.

Declining Schedule Changes

Employees can decline any previously unscheduled hours that the Company adds to the employee's schedule if the employee has been provided less than 14 days’ advance notice before the first day of any new schedule.

Alterations to Work Schedules

If the Company alters a covered employee's work schedule after the deadline, in addition to the regular rate of pay, the employee will receive:

• With less than 14 days’ notice, but 24 hours or more notice to the employee, one hour of predictability pay for each shift in which the Company:

o Adds or subtracts hours of work;
o Moves to another date or time;
o Cancels; or
o Adds to an employee’s schedule a previously unscheduled shift.

• With less than 24 hours of notice to the employee, in addition to the employee’s regular pay for working the shift:

o Four hours or the number of hours in the employee’s scheduled shift, whichever is less, when hours are canceled or reduced; or

o One hour of predictability pay for all other changes.

Predictability pay means wages paid to an employee, calculated on an hourly basis at the employee’s regular rate as compensation for schedule changes made by the Company to a schedule under the ordinance, in addition to any wages earned for work performed by that employee.

The Company will amend the posted work schedule and transmit it to the employee in writing within 24 hours of a schedule change.

Exceptions to Predictability Pay

The predictability pay requirements outlined above do not apply in the following situations:

• The work schedule changes because of events outside the Company’s control, such as: threats to the Company, Company property or employees; a recommendation by civil authorities that work not begin or continue; public utilities fail to supply electricity, water, or gas, or the sewer system fails to serve the location of work; war; civil unrest; strikes; threats to public safety; pandemics; or acts of nature (e.g., floods, earthquakes, tornadoes or blizzards) or weather that would prohibit business operations;

• If there is a work schedule change requiring an employee to work additional hours due to one of the foregoing events that are outside the Company’s control, the Company will:

o Within 72 hours of the schedule change, provide notice in writing to the employee of the schedule change and the reason for the schedule change as well as why the employee is deemed essential to the continued operations of the employer, and
o Pay the employee whose schedule has been changed, $2.00 per hour as hazard pay in addition to the wages that the employee would normally earn for the shift that the employee works. The hazard pay will continue for the entire duration that the employee is required to work in any of the events described above.

• The work schedule change is a mutually agreed upon shift trade or coverage arrangement between employees, subject to any existing Company policy regarding required conditions for employees to exchange shifts;

• An employee requests a shift change that is confirmed in writing, including but not limited to use of sick leave, PTO, or other policies offered by the Company;

• The Company subtracts hours from a work schedule for disciplinary reasons for just cause; or

• When employees self-schedule.

Additional Work Hours to Existing Employees

When the Company needs to fill additional shifts of work, it will first offer such shifts to existing employees who are covered by this policy, if the employees are qualified to do the additional work, as determined by the Company. Whenever practicable, the Company will first offer the hours to part-time employees, but the Company may choose to offer only the number of hours required to give the part-time employee 35 hours of work in the calendar week.

In distributing hours, the Company will not discriminate or tolerate discrimination on the basis of race, color, creed, religion, ancestry, national origin, sex, sexual orientation, gender identity, disability, age, marital or familial status, family caregiving responsibilities or status as a student. The Company will not distribute hours in a manner intended to avoid application of the Patient Protection and Affordable Care Act.

Employees may, but are not required to, accept the offer of additional work hours. For additional work for an expected duration of more than two weeks, the part-time employee has 72 hours to accept the additional hours, after which time the Company may hire new employees to work the additional hours. When the offer of additional work hours is for an expected duration of two weeks or less, the part-time employee has 24 hours to accept the additional work hours, after which time the Company may hire new employees to work the additional hours. The 24- or 72-hour periods begin either when the employee receives the written offer of additional hours, or when the Company posts the offer of additional hours, whichever is sooner. A part-time employee who wishes to accept the additional hours must do so in writing.

Whenever the Company offers additional hours to existing employees, the Company will make the offer either in writing or by posting the offer in a conspicuous location in the workplace where notices are customarily posted. The notice will include the total hours of work being offered, the schedule of available shifts, whether those shifts occur at the same time each week, the length of time the Company anticipates requiring coverage of the additional hours, and the process by which employees may notify the Company of their desire to work the additional hours.

Right to Rest and Additional Pay

Employees have the right to decline work schedule hours that occur within 11 hours after the end of the employee’s last shift. An employee who agrees in writing to work such hours will be compensated at one-and-a-half (1.5) times the employee’s regular rate of pay for any hours worked less than 11 hours following the end of a previous shift.

Right to Request a Flexible Working Arrangement

Employees also have the right to request a modified work schedule, including, but not limited to: additional shifts or hours; changes in days of work; changes in shift start and end times; permission to exchange shifts with other employees; limitations on availability; part-time employment; job sharing arrangements; reduction or change in work duties; or part-year employment.

Retaliation Prohibited

The Company will not discriminate in any manner or take adverse action against any employee in retaliation for exercising rights protected under Evanston’s Fair Workweek Ordinance, including but not limited to disclosing, reporting or testifying about any violation.

Illinois [Chicago]: Schedules and Hours Under the Fair Workweek Ordinance

The Company complies with Chicago’s Fair Workweek Ordinance. In accordance with that law, the Company adopts the policies and practices described below.

These policies and practices apply to employees who (a) spend the majority of their time at work while physically present within the City of Chicago; (b) earn less than or equal to certain minimum wage or salary thresholds; and (c) perform the majority of their work in building services, healthcare, hotels, manufacturing, restaurants, retail, or warehouse services.

Good Faith Initial Estimate of Work Schedule

Prior to or upon the commencement of employment, the Company will provide covered employees, in writing, with a good faith estimate of the employee’s projected days and hours of work for the first 90 days of employment, including:

• The location(s) at which the employee will work;
• The average number of weekly work hours the employee can expect to work each week;
• Whether the employee can expect to work any on-call shifts; and
• A subset of days and times or shifts that the employee can expect to work, or days of the week and times or shifts on which the employee will not be scheduled to work.

This good faith estimate does not constitute a contractual offer, and the Company is not bound by the estimate.

Prior to or upon the commencement of employment, employees may request that the Company modify the initial estimate of work schedule. The Company will consider any such request, and in its sole discretion may accept or reject the request. The Company will notify the employee of its determination, in writing, within three days of the employee’s request.

Advance Notice of Work Schedule

The Company will provide covered employees with written notice of their work hours by posting their work schedules no later than 14 days before the first day of any new schedule (“the deadline”). The written work schedule will span at least a calendar week and will generally include the shifts and on-call status of all current covered employees at that worksite. Upon request, the Company will refrain from posting or transmitting to other employees the work schedule of an employee who is a victim of domestic violence or sexual violence or the family member of a victim of domestic or sexual violence. The Company will transmit work schedules electronically upon an employee’s request.

The Company reserves the right to change a covered employee’s work schedule after it is posted and/or transmitted. The Company may also add an employee to a posted work schedule after the deadline when that employee is returning to work from a leave of absence.

Declining Schedule Changes

Employees can decline any previously unscheduled hours that the Company adds to the employee’s schedule if the employee has been provided less than 14 days advance notice before the first day of any new schedule.

Alterations to Work Schedules

If the Company alters a covered employee’s work schedule by more than 15 minutes after the deadline, in addition to the regular rate of pay, the employee will receive:

• One hour of predictability pay for each shift in which the Company:

o adds hours of work;
o changes the date or time of a work shift with no loss of hours; or
o with more than 24 hours‘ notice, cancels or subtracts hours from a regular or on-call shift.

• No less than 50% of the employee’s regular rate of pay for any scheduled hours the employee does not work because the Company, with less than 24 hours’ notice, subtracts hours from a regular or on-call shift, or cancels a regular or on- call shift, including while the employee is working on a shift.

The Company will amend the posted work schedule and transmit it to the employee in writing within 24 hours of a schedule change.

Exceptions to Predictability Pay

The predictability pay requirements outlined above do not apply in the following situations:

• The work schedule changes because of events outside the Company’s control, such as: threats to the Company, Company property or employees; a recommendation by civil authorities that work not begin or continue; war; civil unrest; strikes; threats to public safety; pandemics; or acts of nature (e.g., floods, earthquakes, tornadoes or blizzards);

• The work schedule change is a mutually agreed upon shift trade or coverage arrangement between employees, subject to any existing Company policy regarding required conditions for employees to exchange shifts;

• A work schedule change that is mutually agreed to by the employee and the Company and is confirmed in writing;

• The posted work schedule is changed by 15 minutes or less;

• The employee requests a shift change, that is confirmed in writing, including but not limited to use of sick leave, PTO, or other policies offered by the Company;

• The Company subtracts hours from a work schedule for disciplinary reasons for just cause; or

• When employees self-schedule.

Additional Work Hours to Existing Employees

When the Company needs to fill additional shifts of work, it will first offer such shifts to existing employees who are covered by this policy, if the employees are qualified to do the additional work, as determined by the Company.

When distributing additional work hours among qualified and interested existing employees, the Company will first distribute work hours to employees whose regular workplace is the location where the work will be performed. If no such employee accepts the available shifts, the Company will distribute them to employees covered by this policy who work at other locations before hiring outside the Company. Whenever practicable, the Company will first offer the hours to part-time employees.

The Company may choose to not schedule employees to work hours required to be paid at a premium rate.

In distributing hours, the Company will not discriminate or tolerate discrimination on the basis of race, color, creed, religion, ancestry, national origin, sex, sexual orientation, gender identity or expression, disability, age or marital or familial status.

Right to Rest and Additional Pay

Employees have the right to decline work schedule hours that are less than 10 hours after the end of the previous day’s shift. Employees may voluntarily consent in writing to work a shift that begins sooner than 10 hours after the end of the previous day’s shift. When an employee works a shift that begins less than 10 hours after the end of the previous day’s shift, the Company will pay the employee at a rate of 1.25 times the employee’s regular rate of pay for that shift, except that hours in such a shift that exceed a workweek of 40 hours will be paid at the usual overtime rate of 1.5 the employee’s regular rate of pay.

Right to Request a Flexible Working Arrangement

Employees also have the right to request a modified work schedule, including, but not limited to: additional shifts or hours; changes in days of work; changes in shift start and end times; permission to exchange shifts with other employees; limitations on availability; part-time employment; job sharing arrangements; reduction or change in work duties; or part-year employment. The Company will respond to such requests in writing.

Retaliation Prohibited

The Company will not retaliate against an employee for exercising rights protected under Chicago’s Fair Workweek Ordinance, including reporting or testifying about any violation, or requesting changes to their working arrangement.

Illinois: Mandatory Time Off/Day of Rest

The Company will provide nonexempt, nonsupervisory employees working more than 20 hours per week with at least one day (24 consecutive hours) of rest during every consecutive seven-day period when required by law.

Pennsylvania [Philadelphia]: Schedules and Hours Under the Fair Workweek Ordinance

Employees who (a) work within the geographic boundaries of the City of Philadelphia; (b) are nonexempt under federal or state law; and (c) have job duties that involve the provision of retail trade services, food services or hospitality services (not including administrative and professional hourly employees such as those in human resources, payroll or receptionist positions) are covered by the Philadelphia Fair Work Week Ordinance. Employees with questions should contact their People Business Partner.

Overview

It is the Company’s policy to comply with all laws regarding meal and rest breaks. Should this policy conflict with any applicable state or local law regarding meal and rest breaks, the Company will comply with the applicable law.

If an employee works in a state where there are no applicable meal or rest break requirements, the Company generally provides break time as appropriate, subject to operational needs and supervisor discretion. The Company does not contract to provide such break time in these states. Generally, in states where there are no applicable laws, non-exempt employees are given a paid 10-minute rest period for each four hours worked or major fraction thereof. Employees are required to remain on site and clocked in during this 10-minute rest period. Employees who leave the work premises or clock out during a rest period may be disciplined up to and including termination. In states where there are no applicable laws, non-exempt employees who work five hours or more in a day are generally provided an unpaid lunch break of at least 30 minutes. Meal and rest breaks will be scheduled by the department manager. Rest periods cannot be combined with the lunch break. Meal periods or rest breaks may not be skipped to shorten the workday. Non-exempt employees must clock out for meal periods, clock in at the end of the meal period and must not perform any work during the meal period. If for any reason an employee does not take the applicable rest and meal periods, the employee must notify their manager immediately.

Employees should contact People Business Partner with questions regarding meal and rest breaks.

Connecticut: Meal and Rest Breaks

Employees who work seven and one-half or more consecutive hours will be provided one 30-minute meal break. The meal break generally should be taken after the first two hours of work and before the last two hours of work.

An uninterrupted 30-minute meal break will be unpaid for nonexempt employees. All nonexempt employees must record their meal breaks.
Employees who are unable to take all of the meal breaks to which they are entitled in accordance with this policy, or who have been prevented or discouraged from taking a break to which he or she is entitled under this policy, should immediately notify their People Business Partner.

Illinois: Meal Breaks

Employees who work a shift of between seven and one-half consecutive hours and twelve consecutive hours will be provided one 20-minute meal break, to begin no later than five hours after the start of work. Employees who work a shift of between twelve and sixteen and one-half consecutive hours will be provided two 20-minute meal breaks, with the first to begin no later than five hours after the start of work. The second break will generally be taken after the beginning of the twelfth hour of work. Employees who work more than sixteen and one-half consecutive hours of work will be provided a third 20-minute meal period, and employees who work a shift in excess of twenty-one consecutive hours of work will be provided a fourth 20-minute meal period. During the break, employees will be relieved of all duties. Reasonable time using restroom facilities will not be considered a meal period.

The above provision does not apply to employees for whom meal periods are established through the collective bargaining process.

An uninterrupted meal break lasting 30 or more minutes will be unpaid. All nonexempt employees must record their meal breaks.

Employees who are unable to take all of the meal breaks to which they are entitled in accordance with this policy, or who have been prevented or discouraged from taking a break to which they are entitled under this policy, should notify their People Business Partner immediately and, if possible, prior to the beginning of the fifth hour of work or other applicable time frames.

Maryland (Retail Only): Meal and Rest Periods

Eligible retail employees who work four to six consecutive hours will be provided with a 15-minute nonworking shift break. However, if the employee is entitled to a 30-minute shift break, as detailed below, they will not also be provided with a 15-minute break.

Employees who work more than six consecutive hours will be provided with a 30-minute nonworking shift break. Employees who work more than eight consecutive hours in a single shift will be provided with an additional 15-minute nonworking shift break. For each additional four-hour consecutive shift worked, employees will be provided with an additional 15-minute nonworking shift break.

If an employee’s hours do not exceed six consecutive hours, the employee may waive his or her 15-minute shift break by mutual written agreement between the employee and the Company.

The shift break may be considered a working shift break if:

• The type of work prevents an employee from being relieved of work during the nonworking shift; or

• The employee is allowed to consume a meal while working and the working shift break is counted toward the employee’s work hours; and the employee and the Company mutually agree in writing to the working shift break.

Massachusetts: Meal Breaks

Employees who work six or more continuous hours will be provided at least a 30-minute meal break. Employees must not perform any work during the meal break and are free to leave the workplace premises. Employees are expected to return to work promptly at the end of every meal break.

An uninterrupted 30-minute meal break will be unpaid for nonexempt employees. All nonexempt employees must record their meal breaks.

Employees who are unable to take all of the meal breaks to which they are entitled in accordance with this policy, or who have been prevented or discouraged from taking a break to which they are entitled under this policy, should immediately notify their People Business Partner.

Nevada: Meal and Rest Breaks

Employees who work eight continuous hours are permitted at least one 30-minute uninterrupted meal break. During the break, employees will be relieved of all duties. An uninterrupted meal break lasting at least 30 minutes will be unpaid for nonexempt employees.
Employees are also allowed one 10-minute paid rest break for each four hours (or major fraction of four hours) worked. When determining how many hours an employee has worked for purposes of providing rest breaks, unpaid meal breaks will not be counted. Rest breaks will be provided in accordance with the following schedule:

Rest breaks will be provided as close as practical to the middle of each four-hour work period.

Employees who are unable to take all of the breaks to which they are entitled in accordance with this policy, or who have been prevented or discouraged from taking a break to which they are entitled under this policy, should immediately notify their People Business Partner.
All nonexempt employees must record their meal breaks.

West Virginia: Meal Breaks

Employees will be provided at least a 20-minute meal break when they work six or more hours. An exception may arise when an employee is afforded necessary breaks and/or has an opportunity and is permitted to eat lunch while working. Meal breaks will occur at times reasonably designated by the Company. Employees may not take a shorter meal period or skip a meal period to leave early.

An uninterrupted meal break lasting 30 minutes or more will be unpaid for nonexempt employees. All nonexempt employees must record their meal breaks.

Employees who are unable to take all of the meal breaks to which they are entitled in accordance with this policy, or who have been prevented or discouraged from taking a break to which they entitled under this policy, should immediately notify a supervisor and/or their People Business Partner.

Employee files are maintained by the People Team and are considered confidential. Managers and other leaders may only have access to personnel file information on a need-to-know basis.

Employees who wish to review their personnel file may do so by appointment. Personnel files are to be reviewed in the People Team office. Personnel files may not be taken outside the People Team office. Upon written request, employees may obtain a copy of the information or part of the information contained in their personnel file in accordance with state law.

Employee’s personnel data should be accurate and current at all times. It is the responsibility of each employee to promptly notify the People Team of any changes in personnel data such as: mailing address, telephone numbers, name and number of dependents, marital status, and individuals to be contacted in the event of an emergency.

The Company is concerned about the accuracy of any information provided to individuals outside our organization regarding current or former employees. Consequently, in the event someone inquires about an employee’s employment with us, employee information may only be released by the People Team. To be consistent, the People Team will only verify an employee or former employee’s your position(s) and dates of employment and the request must come to the People Team in writing. Requests for further information require written authorization from the employee indicating specific information to be released. The only exception is information requested for legal or regulatory review of Company records requiring this data.

The People Team does not provide employment references for current or former employees that include information other than dates of employment and last position held.

Termination of employment is an inevitable part of personnel activity within any organization. Below are a few examples of some of the most common circumstances under which employment is terminated:

a. Layoff: an involuntary employment termination initiated by the Company for non-disciplinary and/or non-behavioral reasons. If a layoff occurs, employees will have their job eliminated based on defined factors, which may include, but are not limited to, business needs, qualifications, past performance, and demonstrated ability.

b. Termination: an involuntary employment termination initiated by the
Company for reasons other than layoff.

c. Resignation: a voluntary employment termination initiated by an employee. As a courtesy, employees are requested to give their manager written notice of their resignation as far in advance as possible, generally not less than two weeks before their intended resignation date. The announced resignation date will be considered the effective date of an employee’s resignation unless the employee is otherwise informed by the People Team. The People Business Partner may schedule an exit interview or survey when an employee resigns. Exit interviews are confidential.

d. Job Abandonment: Employees who fail to report to work or contact their manager for two consecutive workdays shall be considered to have abandoned their job without notice, effective at the end of their normal shift on the second day. The manager shall notify the People Team at the expiration of the second workday.

e. Shift Abandonment: Absent extraordinary circumstances, employees who leave and fail to communicate with their manager and/or the highest level of authority on-site prior to their scheduled shift end time will be subject to discipline, up to or including termination.

Any employee who terminates employment with VZL Staffing Services, LLC shall, when employment with the Company ends, or at any earlier request of the Company, return all files, records, laptops/computers, keys, Company Confidential Information and any other materials that are the property of the Company. Employees shall not retain any copies that the employee is not expressly authorized by the Company in writing to retain. All records related to the Company’s business received or created by an employee in the course of employment is the property of the Company.

Employees may retain records concerning pay, payroll, benefits, and other employment terms that were furnished to them or obtained by lawful means.

Upon request, an employee must provide the Company reasonable means to access and verify that no Confidential Information or other Company property has been retained by the employee on personal computers, cell phones, email, or cloud storage accounts, or in any other place that is subject to the employee’s ownership or control. We may also take all action deemed appropriate to recover or protect Company property.

Employee’s benefits will be affected by employment termination in the following manner: All accrued vested benefits that are due and payable at termination per state law, will be paid according to that state law. Some benefits may be continued at the employee’s expense (See Section 5, Benefits) if the employee elects to do so. The employee will be notified of the benefits that may be continued and of the terms, conditions, and limitations.