Seasonal Employee Handbook - Orion's Mindorionsmind.com/omseasonal20110722.pdf · “To change the...

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1 DRAFT - Last Updated Jan 11, 2010 orionsmind.com Seasonal Employee Handbook

Transcript of Seasonal Employee Handbook - Orion's Mindorionsmind.com/omseasonal20110722.pdf · “To change the...

1

DRAFT - Last Updated Jan 11, 2010

o r i onsm ind . com

Seasonal

Employee Handbook

Orion’s Mind Seasonal Employee Handbook v1 Effective April 1, 2009 Page - 2

Table of Contents

Section 1 - Introduction ............................................................................................................. 8

1.1 - About Our Company .............................................................................................. 8

1.2 – Corporate Office Information ...............................................................................10

1.3 - Corporate Website ...............................................................................................10

1.4 - Smoke-Free Workplace .........................................................................................10

1.5- Keys .......................................................................................................................11

1.6 - Alarm ....................................................................................................................11

1.7 - First Person to Arrive ............................................................................................11

1.8 - Last Person to Leave .............................................................................................11

1.9 - Cleaning Service ...................................................................................................12

1.10 - Garbage ..............................................................................................................12

1.11 - Maintenance .......................................................................................................12

Section 2 - Company Policies....................................................................................................13

2.1 – Orion’s Mind Code of Ethics ................................................................................13

2.2 – Student Confidentiality Policy ..............................................................................16

2.3 - Child Protective Services .......................................................................................17

2.4 – Employee Dating Policy ........................................................................................17

2.5 – Progressive Discipline Policy ................................................................................. 4

2.6 – Involuntary Termination Policy ............................................................................... 4

2.7 – Discrimination and Non-Harassment Policies ........................................................ 7

2.8 – Dress Code Policy.................................................................................................11

2.9 – Expense Policy ......................................................................................................13

2.10 – Drug and Alcohol Abuse Policy ..........................................................................18

2.11 - Background Checks ............................................................................................19

2.12 – Employment References and Verification Policy .................................................20

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Section 3 - Time Away from Work ............................................................................................22

3.1 – Attendance and Time Reporting ..........................................................................22

3.2 - Time Entry Policy ...................................................................................................22

3.3 - Deadlines for Submitting Time Entry Data ............................................................23

3.4 - Your Schedule .......................................................................................................24

3.5 - Overtime ...............................................................................................................24

3.6 - Lunch/Break Periods .............................................................................................24

3.7 – Un-Paid Leave .......................................................................................................25

Section 4 - Company Infastructure............................................................................................27

4.1 – Department Classifications ...................................................................................27

4.2 – Communication ....................................................................................................27

4.3 - Open Door Policy ..................................................................................................28

4.4 - Dispute Resolution ................................................................................................28

4.5 - Phone Calls ...........................................................................................................28

4.6 - Cell Phones ...........................................................................................................29

4.7 – Company E-Mail, Internet, and Computer Use .....................................................29

4.8 - Network Infrastructure ..........................................................................................30

4.9 – Company Car........................................................................................................31

4.10 – Document Library ...............................................................................................31

4.11 - StarMail ...............................................................................................................33

4.12 - HCS Wires ...........................................................................................................33

4.13 - Business Cards ....................................................................................................33

4.14 – Safety and Security .............................................................................................33

4.15 - Protecting Company Assets ................................................................................33

4.16 - Reporting Fire .....................................................................................................34

4.17 - Accidents ............................................................................................................34

Section 5 - Compensation ........................................................................................................35

5.1 – Total Rewards Philosophy .....................................................................................35

5.2 – Work-Life Balance Statement ...............................................................................35

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5.3 - Employment Status ...............................................................................................36

5.4 - Payday ...................................................................................................................37

5.5 - Issues with Paychecks ............................................................................................37

5.6 - Seasonal Benefits ..................................................................................................38

5.7 - Requesting Time Off .............................................................................................38

5.8 - Unpaid Time Off ...................................................................................................39

5.9 – Provisional/Probationary Periods ..........................................................................40

5.10 – Time-Off Related Issues ......................................................................................40

5.11 – Civic Duty ...........................................................................................................41

5.13 — Family and Medical Leave Act ..........................................................................41

5.14 — Military Leave of Absence .................................................................................45

Section 6 – Employee Programs ...............................................................................................45

6.1- Professional Development .....................................................................................45

6.2 - Performance Reviews ............................................................................................45

6.3 - Promotions and Transfers .....................................................................................46

6.4 - Access to Employee Records ................................................................................46

6.5 — Employee Referral Program ................................................................................47

Section 7 — When You Leave OM............................................................................................48

7.1 Exit Interviews .........................................................................................................48

Handbook Acknowledgment - Seasonal ...................................................................................49

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Welcome to Orion’s Mind

Welcome to Orion’s Mind LLC (also referred to as “the Company”), a Chicago-based educational solutions provider. We are excited to welcome you to our team. Our employees are dedicated to delivering creative, high-quality, and effective hands-on educational programs to help students develop both personally and academically. In order to successfully deliver our services to students, we establish and maintain positive relationships with schools, parents, instructors, and students. We also create an effective work environment that includes systems and people who support each program’s operations.

To stay competitive, OM believes in hiring the best people—people like you. We believe that each employee directly contributes to Orion’s Mind’s growth and success, and we hope you will take pride in being a member of our team.

Orion’s Mind Employee Handbook was developed to describe some of the expectations and to outline some of our standard operating procedures. The policies in this handbook and supporting operating procedures that you will be introduced to are intended to make each of us more productive by setting a common standard for how we do business. You should familiarize yourself with the contents of this handbook as soon as possible. It will answer many of the questions you have about employment with Orion’s Mind. We encourage you to check with your supervisor if you have questions about the information contained in this handbook.

We wish you success in your new position and look forward to your suggestions and ideas. Our goal is to make Orion’s Mind a rewarding, stimulating, and enjoyable experience for our employees. We hope that your contributions will be instrumental not only in the continued success of the Company, but also in your personal growth and development.

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Disclaimer – About the Handbook

This employee handbook has been prepared as a general reference guide to help familiarize corporate, seasonal & hourly employees with Orion’s Mind’s policies, procedures, and rules, as well as the many employee benefits that it provides. This handbook applies to all full-time, part-time, and temporary employees. It specifically supersedes and replaces all previous employee handbooks, manuals, and policy statements, whether oral or written, issued by Orion’s Mind.

The employee handbook is NOT intended to be a contract of employment between you and Orion's Mind LLC. The handbook is NOT intended to be an all-inclusive list of policies and procedures of Orion's Mind LLC. (Referred to from this point on as OM). OM reserves the right to change any terms, including, without limitation, the right to unilaterally revise, interpret, or discontinue any of the policies, procedures, rules either orally or in writing at any time. Employment with this firm is "at will". This means that either you (the employee) or the firm may terminate the employment relationship at any time, for any reason. This handbook is meant to comply with all federal, state, and local laws.

Some of the subjects covered in the employee handbook, such as the group insurance plans, are detailed in specific benefit plan documents. It is important to understand that this handbook is only a summary of those benefits and that the written benefit plan document is always the final authority.

To effectively fulfill your responsibilities at OM, you need to have important information available to you. Reading and understanding the employee handbook is a good place to begin. Keep this handbook for future reference. In addition, your supervisor or Human Resources representative is available to answer your specific questions or provide additional information.

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Standard Operating Procedures

A standard operating procedure (SOP) is a set of instructions or steps someone follows to complete a job or task, with no adverse impact on the environment and the company. SOPS are designed to complement our employee handbook and are in place to help you maximize your role in our operational effectiveness.

SOPs are effective catalysts to driving performance improvement and improving organizational results. You will find that there are SOPs for most repeated procedures for the front and back office, plus specific actions by management. It is your responsibility to stay up to date on company SOPs and ask questions when necessary. Throughout your tenure, the company will draft and reserves the right to alter SOPs to meet the needs of its business. This handbook is considered an SOP as it serves a procedural purpose. All SOPs are will be publicly available.

For more information regarding our standard operating procedures, please refer to the company’s Outlook Public Folders under “OM SOPs,” and view the master list of all SOPs or see Human Resources for assistance.

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Section 1 - Introduction

1.1 - About Our Company

At OM, we share our employees’ desire to be successful and productive and to do work that is rewarding and serves the community at large. We believe employees will be successful if we treat them with respect and dignity, and provide them with the information necessary to succeed. Your personal success will not only be driven by the support of the Company but also by your own individual effort, commitment, and creativity.

Our Mission

“To change the world by igniting individuals with a passion for learning”

Our Values

Our values are the reasons we think OM is a wonderful place to work:

• Practice IntegrityPractice IntegrityPractice IntegrityPractice Integrity -- We believe that honesty is the best policy. We are upfront and open with our actions and maintain high ethical and moral standards in our business practices.

• Cultivate LeadershipCultivate LeadershipCultivate LeadershipCultivate Leadership -- We promote the growth of our people. We empower them with knowledge and resources to get results and to grow our business.

• Create TransparencyCreate TransparencyCreate TransparencyCreate Transparency -- We openly share information, knowledge, and the best ideas across the organization. We realize that we are dependent on each other for our company’s success. In smaller companies with aggressive expansion goals, this is invaluable.

• Drive InnovationDrive InnovationDrive InnovationDrive Innovation -- We always evaluate what we are doing to continually challenge our methods and to ask how we can simplify and improve our business. We never rest on our laurels but pause to recognize our achievements and celebrate success.

• Support DiversitySupport DiversitySupport DiversitySupport Diversity -- We promote an environment where people are valued and rewarded on the basis of their efforts and ideas, without regard to their race, gender, or creed.

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• Focus on Focus on Focus on Focus on Customer ServiceCustomer ServiceCustomer ServiceCustomer Service -- Our commitment to providing value-added services to our external clients and employees is the same. We treat others as we would like to be treated ourselves

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Our Culture

At OM, our culture is a state of mind and our way of life. We believe in each other and the service we provide our communities. Our approach is one of integrity, a strong commitment to learning, a continuous passion for what we do, a true team effort, and an environment of openness and acceptance. We believe that these qualities are vital to our continued success and hold them in the highest regard and abide by the Three E’s:

• We are We are We are We are EEEEngagingngagingngagingngaging....

• We are We are We are We are EEEExtraordinaryxtraordinaryxtraordinaryxtraordinary....

• We are We are We are We are EEEExcitingxcitingxcitingxciting....

1.2 – Corporate Office Information

OM’s corporate headquarters is located at 1454 West Willow Ave., Chicago, IL 60642.

The Texas Branch Office is located at 2300 Valley View Lane, Suite 109, Irving, TX 75062.

1.3 - Corporate Website

The corporate website is www.orionsmind.com. This website is used primarily for two functions: a marketing vehicle and a source of information for prospective employees.

1.4 - Smoke-Free Workplace

OM maintains a smoke-free workplace. We actively promote wellness for our employees and ask that employees refrain from smoking on school grounds and in front of students. You may not smoke in the corporate office, garage, or company car at any time. During your break period, you may smoke outside of the office building—15 feet away from any entrance.

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1.5- Keys

Select employees are given keys to the office. Please note that these keys are the property of OM and must be returned should your employment be terminated. You are not permitted to make copies of your office keys; such behavior is grounds for termination. Employees who are given keys will also be assigned a security pass code. Please see the Office Manager if you have any questions or concerns regarding your keys or pass code. If you are not given office keys, you may call a management employee to gain access to the office after hours.

1.6 - Alarm

OM uses a security system that is set during non-operational hours, and only authorized users with pass codes can enter the office during non-operational hours. Please see the Office Manager to learn how to set and turn off the alarm and to see if you will require a security code.

1.7 - First Person to Arrive

If you are the first person to arrive to the office in the morning, please be sure to unlock all access doors, shut off the alarm, and turn on the lights.

1.8 - Last Person to Leave

Prior to departing, please ensure that there is at least one other authorized key holder available to lock up. If you are the last person to leave the office, take the following steps:

• Walk around the office space, and check that no one else is in the building.

• Turn off the overhead lights.

• Lock all doors behind you once you have set the alarm.

Employee safety and office security is everyone’s responsibility. Please ensure you do your part to protect company assets and each other. For specific procedures with respect to your branch, please see SOPs.

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1.9 - Cleaning Service

Our cleaning service comes to the office twice a week. Please be courteous to your coworkers by cleaning your work area throughout the week. On occasion we have visitors in the office, and all employees are encouraged to keep a neat work station.

1.10 - Garbage

Garbage is taken out daily. Please do your part to take out an overflowing bag and replace it. All garbage can be disposed of in the dumpsters outside the building. For more information, please see the Office Manager.

1.11 - Maintenance

If there are any concerns with the office building, please see the Office Manager for proper procedure.

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Section 2 - Company Policies

2.1 – Orion’s Mind Code of Ethics

OM is an Educational Solutions Provider (ESP), Therefore, we have high expectations for both our Company and our employees when conducting or representing OM in any capacity. All employees are expected to conduct themselves in a professional manner when delivering educational services or presenting at a potential client site or schools. OM believes professional behavior and a cooperative approach with all employees is fundamental to our success. You must be dedicated to serving our students, schools, parents, and instructors in a courteous and professional manner. When an employee is conducting official OM business or is on or near school grounds, the employee not only must act in a professional manner as expected by OM, but also must obey and observe all the school’s conduct policies and its district and governing state guidelines.

This policy is designed to guide our employees with respect to standards of conduct expected in areas where improper activities could damage the Company's reputation and otherwise result in serious adverse consequences to the Company and to employees involved. The purpose of this policy is to affirm, in a comprehensive statement, required standards of conduct and expected ethical practices. Additionally, employees will be asked to sign a Confidentiality and Assignment of Developments Agreement that ensures the preservation and privacy of proprietary OM information

An employee's actions under this policy are significant indications of the individual's judgment and competence. Accordingly, those actions constitute an important element in the evaluation of the employee for position assignments and promotion. Moreover, insensitivity to or disregard of the principles of this policy will be grounds for appropriate management disciplinary action. Standards of conduct follow:

• Employees are responsible for fostering a congenial work environment of respect and professionalism. Therefore, the company prohibits employees from intentionally harming or threatening to harm other employees, clients, students, administrators, parents, instructors, vendors, and visitors or property belonging to any of these parties.

• Employees are responsible for maintaining their work area in a neat and professional manner.

• Employees are responsible for maintaining the confidentiality of all OM-related information that includes, but is not limited to, student identity and school information. .

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• Employees are always encouraged to actively pursue company goals. However, this endeavor should never disrupt the instruction of students in any class.

• Employees are responsible for assuring the security of OM/client schools confidential and proprietary material in their possession and similarly maintaining the security of OM/client-provided equipment. Employees concerned for the security of their work area, students, or equipment must inform their supervisor of such concerns immediately.

Action Violations:

Employees are responsible for maintaining a professional relationship in dealing with other OM employees and clients. Actions that violate this policy include, but are not limited to, the following behaviors:

• Making rude, condescending, insulting, and demeaning statements to others

• Using an angry, hostile tone of voice

• Shouting, throwing things, slamming doors, or other aggressive actions when displeased

• Berating staff and colleagues in front of others

• Showing insensitive, curt, and disrespectful treatment of peers, support staff, and clients

• Being physically or verbally abusive toward those he or she considers less important

• Attacking someone immediately if criticized or crossed

• Threatening litigation when displeased or challenged

• Disdaining authority and believing that rules do not apply to him or her

• Regularly being the source of many issues which, if taken individually, would be of limited relevance, but when taken together become highly significant

Conduct for Code of Ethics

Employees are also responsible for adhering to the following Code of Ethics/Conduct for dealing with anyone on any OM related endeavors:

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• OM employees will treat client information as confidential and will neither take personal advantage of privileged information gathered during an assignment nor enable others to do so.

• OM employees will not encourage unrealistic expectations or promise clients certain benefits from our consulting services unless we can deliver.

• OM employees will not accept commissions, remuneration, or other benefits from a third party in connection with recommendations to a client without the client's knowledge and consent.

• OM employees will disclose any financial interest in goods or services that form part of any recommendations

• OM employees will refrain from inviting an employee of a client to consider employment with our consulting practice without prior discussion with the client.

These standards are meant to ensure that as a member of the OM team, you will perform your responsibilities in the following ways:

• Maintain a high level of ethical conduct in all business dealings. Be fair, honest and aboveboard with clients and potential clients, vendors, and coworkers.

• Display courtesy and professionalism in all interactions.

• Communicate effectively with managers, coworkers, and clients.

• Demonstrate a high level of productivity and efficiency in all work activities.

Disciplinary action will be taken against individuals who authorize or participate directly in a violation of the Code of Ethics policy. Other examples of grounds for disciplinary action follow:

• Any employee who may have deliberately failed to report a violation of the Code of Ethics policy

• Any employee who may have deliberately withheld relevant and material information concerning a violation of this policy

• The violator's managerial superiors, to the extent that the circumstances of the violation reflect inadequate leadership and lack of diligence.

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2.2 – Student Confidentiality Policy

As an OM employee, you deal with a variety of confidential information and you will be working with schools. Students’ confidentiality is protected by law. As an employee of OM, you will be exposed to personal student information, including, but not limited to, contact information, test scores, Individual Education Plans (IEPs), personal health information, and income status. By law and as an OM employee, you are not allowed to share this personal information about a student without written consent from the student’s parent or guardian. You have permission to share this information with the individuals directly providing services to the child. However, you may not disclose a student’s information to anyone who does not need to receive this information in order to do his or her job at OM. Additionally, you may not expose a student’s involvement in the program without written permission from the student’s parent or guardian, since the student’s very participation reveals his or her economic status.

Personal student information may only be used in connection with the delivery of services to students or for contacting parents of current or former students.

Each Program Manager has the following responsibilities for personal information relating to students participating in OM programs at a site:

• The Program Manager must ensure the handling of personal student information is undertaken in accordance with the contract with the school district.

• Personal student information must be maintained in a secure location preventing unauthorized access.

• The Program Manager must maintain a list at the site of names and positions of employees who have access to personal student information.

• The Program Manager may not allow access to personal student information by anyone other than an OM employee, a school district official, or a student's parent or guardian unless such access is approved in advance by the supervisor. The Program Manager must maintain an access log for any person other than an OM employee accessing personal student information that includes the individual's name and affiliation, date, time, and purpose of access.

• All documents containing personal student information received from a school district (such as Individual Education Plans (IEPs), assessment data on state and district assessments, and so on) must be maintained in a manner that will allow the return of the documentation to the school district upon completion of the

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student's program. The Program Manager must return such documentation to the school district upon completion of the student's program.

• The Program Manager must immediately report any infraction of this policy to the Supervisor

In addition, all employees will review this policy during orientation and be asked to sign an acknowledgment agreement that ensures compliance to this policy.

2.3 - Child Protective Services

As an employee of OM, you are required by law to report any suspected child abuse (including neglect or physical, sexual, or emotional abuse) that you observe while working with the students. The nature and the details of the suspected abuse are confidential and should only be shared with the appropriate authorities, which may include Child Protective Services, the school’s principal and/or social worker, parents/guardians, and so on. In addition to reporting to Child Protective Services, you are responsible for providing Human Resources with written documentation of the call.

Should you suspect abuse, you must report it immediately to the Child Abuse National Hotline at 1-800-25-ABUSE (1-800-252-2873).

2.4 – Employee Dating Policy

The company strongly believes that an environment where employees maintain clear boundaries between employees’ personal and business interactions is most effective for conducting business. Although OM’s employee dating policy does not prevent the development of friendships or romantic relationships between coworkers, it does establish very clear boundaries as to how relationships will progress during working hours and within the working environment. Individuals in supervisory relationships or other influential roles are subject to more stringent requirements under this policy due to their status as role models, their access to sensitive information, and their ability to influence others.

ProceduresProceduresProceduresProcedures

1. During working time and in working areas, employees are expected to keep personal exchanges limited so that others are not distracted or offended by such exchanges and so that productivity is maintained.

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2. During nonworking time, such as off-site work sponsored events, lunches, breaks, and before and after work periods, employees are not precluded from having appropriate personal conversations in nonworking areas as long as their conversations and behaviors could in no way be perceived as offensive or uncomfortable to a reasonable person.

3. Employees are strictly prohibited from engaging in physical contact that would in any way be deemed inappropriate by a reasonable person while anywhere on company premises, whether during working or nonworking hours.

4. Employees who allow personal relationships with coworkers to affect the working environment will be subject to the appropriate provisions of the Company disciplinary policy. which may include counseling for minor problem. Failure to change behavior and maintain expected work responsibilities is viewed as a serious disciplinary matter.

5. Employees’ conduct after work is generally regarded as private, as long as such conduct does not create problems within the workplace. An exception to this principle, however, is romantic or sexual relationships between supervisors and subordinates.

6. Supervisors, managers, executives or anyone else in sensitive or influential positions must disclose the existence of any prior relationship with another coworker that has progressed beyond a platonic friendship. Disclosure may be made to the Director of Human Resources or the CEO. This disclosure will enable the organization to determine whether any conflict of interest exists because of the relative positions of the individuals involved.

7. Where problems or potential risks are identified, the Company will work with the parties involved to consider options for resolving the conflict. The initial solution will be to make sure that the parties involved no longer work together on matters in which one employee is able to influence the other or take action for the other. Matters such as hiring, firing, promotions, performance management, compensation decisions, financial transactions, and so on are examples of situations that may require reallocation of duties to avoid any actual or perceived reward or disadvantage.

8. In some cases, more extreme measures may be necessary, such as a transfer to other positions or departments. The individual with the more senior position will

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be considered for transfer first to avoid any perception of retaliation against the less senior person.

9. Refusal of reasonable alternative positions, if available, will be deemed a voluntary resignation.

10. Continued failure to work with the Company to resolve such a situation in a mutually agreeable fashion may ultimately be deemed insubordination and, therefore, serve as cause for immediate termination. The Company’s disciplinary policy will be consulted to ensure consistency, however, before any such extreme measures are undertaken.

11. The provisions of OM’s employee dating policy apply regardless of the sexual orientations of the parties involved.

12. Where doubts exist as to the specific meaning of the terms used above, employees should make judgments on the basis of the overall spirit and intent of this policy.

13. Any employee who feels they have been disadvantaged as a result of this policy, or who believes this policy is not being adhered to, should make their feelings known to the Director of Human Resources.

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2.5 – Progressive Discipline Policy

When OM initiates the termination of an employee, the termination is considered involuntary. Involuntary terminations may occur for a variety of reasons, including with cause (such as employee gross misconduct, performance, economics, and violation of policy), or without cause (such as part of a layoff, downsizing, workforce reduction, and so on).

When practical and applicable, employees will be warned and counseled using a progressive discipline approach to allow the employee to adjust behavior and improve. However, failure to correct behavior or violation of company policies and procedures may result in additional disciplinary action, up to and including termination. Depending on the nature of the offense, OM reserves the right to terminate any employee without warning. Please refer to section of the employee handbook on OM Code of Conduct.

Progressive Discipline Steps*

• Step 1 - Verbal Counseling

• Step 2 - Written Notice

• Step 3 – 2nd Written Notice

* Documentation will happen at every stage and a Performance Improvement Plan (PIP) can be

executed at any point in time. Any corrective action can lead to and include termination.

In the event that an employee is involuntarily terminated, OM will inform the employee of the reason for termination, and the date of separation will be the employee’s last day worked. All employees will go through an exit process. If you have any questions with respect to this policy or process, please see Human Resources or refer to SOP #3.

2.6 – Involuntary Termination Policy

In order to ensure uniform and consistent procedures for employee terminations, Orion’s Mind (The Company) has established rules applicable to all such terminations.

All involuntary terminations must be approved by the employee’s manager, coordinated with Human Resources and processed in accordance with the provisions outlined in this policy. Notwithstanding the foregoing, should a manager be present when serious misconduct occurs, he/she may immediately suspend the employee, pending an

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investigation and notification to Human Resources. This policy applies to all full-time and part-time employees of the Company.

Procedural Notes

1. When the Company initiates a termination (i.e., the employee is terminated), the termination is considered involuntary.

2. Involuntary terminations may occur for a variety of reasons, including with cause (i.e., employee misfeasance or malfeasance) or without cause (i.e., as a part of a layoff).

3. When practical, employees will be warned and counseled. However, failure to correct behavior or further violation of company policy may result in additional disciplinary action, up to and including termination. Depending on the nature of the offense, the Company reserves the right to terminate any employee without warning.

4. Warnings and counseling are to be documented on the Disciplinary/Counseling/Termination documents. The Company will generally terminate an employee after or on the third offense but reserves the right to terminate at will depending on the nature of the offense.

5. With respect to all involuntary terminations:

a. The company will inform the employee of the reason for termination.

b. The date of separation will be the employee’s last day worked.

6. With respect to all involuntary terminations without cause:

a. The employee’s record will indicate an involuntary termination without cause (i.e., from layoff).

b. Severance pay is:

i. Discretionary, based upon a number of factors (i.e., length of service to the Company, level of responsibility, reason for separation, etc.). No employee is entitled to severance pay upon termination.

ii. Given only with the approval of the Chief Executive Officer.

7. The employee’s manager must complete a Payroll Transaction Form provided by Human Resources. This form must be completed to ensure that the employee is

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terminated in a uniform and consistent manner from all appropriate systems, that Company property is reclaimed and that the employee’s final paycheck is paid in accordance with state and federal laws or regulations, etc.

8. All terminated employees will be paid in accordance with state and federal laws.

The company will inform the employee of the reason for termination on the day of separation and that will be the employee’s last day worked.

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2.7 – Discrimination and Non-Harassment Policies

Purpose

The purpose of these policies is to make clear that harassment will not be tolerated at OM, to identify what constitutes harassment, and to communicate the procedure for filing harassment complaints. OM is committed to maintaining a productive work environment that is free from all forms of discriminatory, harassing, or disruptive activity. In keeping with this commitment, we maintain the right to observe a zero tolerance standard for violation of these policies. This applies to all OM employees, either male or female, and any employee or non-employee, including visitors, vendors, clients, and other third parties with whom our employees interact while performing their job duties.

Non-Discrimination Policy

In order to provide equal employment opportunities to all individuals, employment decisions at OM are based on an assessment of the individual's merits, qualifications, and abilities. The Company embodies an equal employment opportunity (EEO) approach to all of our practices and embodies the equal opportunity employer distinction. There will be no discrimination against any employee, employee of a client, and/or applicant for employment on any basis prohibited by law, including race, color, national origin, religion, sex, age, veteran status (disabled or Vietnam era), sexual orientation, disability, or any other characteristic protected by law. The Company will provide reasonable accommodations, as required by law, for qualified individuals with disabilities unless doing so would result in an undue hardship for the company.

Non-Harassment Policy

OM is committed to the premise that all individuals have a right to work in an environment that is safe, productive, respectful, and free from discrimination. In keeping with this commitment, harassment, based on legally protected characteristics, will not be tolerated. Any words, or actions, that create an intimidating, hostile, or offensive working environment are disrespectful and contrary to OM’s business objectives. We are all responsible for ensuring that harassment does not occur.

OM prohibits harassment between team members and between a team member and a contractor, client, customer or other non-employees who conduct business with us. Retaliation against an individual who, in good faith, files a harassment complaint or participates as a witness in the investigation of such a complaint, is prohibited. OM also

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prohibits frivolous and malicious harassment complaints. The policy applies in our offices and other work-related settings.

These policies against discrimination and harassment, govern all aspects of employment including: job selection, job assignment, compensation, discipline, discharge, and training.

Definitions

Harassment:

The term harassment based on legally protected characteristics, is a form of illegal discrimination as defined by The Society of Human Resource Management. Harassment generally occurs when words or actions create an intimidating, hostile, or offensive working environment. OM prohibits harassment on the basis of the race, color, religion, gender, sexual orientation, national origin, age, disability, veteran status, or any other legally protected characteristic of an individual. Furthermore, OM prohibits harassment against team members and clients on the basis of any legally protected characteristic of a team member’s relatives, friends, or associates.

Sexual Harassment:

The Equal Employment Opportunity Commission (EEOC) guidelines define sexual harassment as “unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when such conduct is made either explicitly or implicitly a term or condition of an individual’s employment; or (when) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual; or (when) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.”

There are three types of sexual harassment: “quid pro quo”, “hostile work environment,” and “indirect victim.”

Quid Pro Quo Harassment:

Quid pro quo literally means “this for that” and occurs when someone with authority to tries to influence a person’s jobs or threatens to use that authority to extort sexual favors. Some examples of quid pro quo sexual harassment include offering employment benefits or giving preferential treatment in exchange for sexual favors, and retaliating against or getting back at a team member who rejects sexual advances.

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Hostile Environment Harassment:

This type of harassment occurs when a coworker, contractor, client, customer, or other non- employee who conducts business with OM engages in behavior that alters the conditions of an OM team member’s job and creates a hostile or abusive working environment. Some examples of conduct that may constitute hostile work environment sexual harassment follow:

• sexual gestures

• display of sexually suggestive objects or pictures

• whistling and catcalls

• derogatory or sexual comments

• epithets or jokes

• unwelcome physical contact

• threatening conduct, including assault or blocking someone’s movement

• repeated and unwelcome comments about someone’s physical appearance.

Indirect Victim Harassment:

This type of harassment occurs when victim of the harassment is not necessarily the target of the harasser, but who nonetheless suffers. This is the most uncommon form of harassment but can and should still be considered.

Sexual harassment includes words or actions between people of different genders or of the same gender.

Sexual harassment involves “unwelcome conduct,” meaning conduct that was not solicited.

Responsibilities

An individual who believes that he or she has been harassed or has witnessed harassment occurring should bring this incident to the attention of his or her supervisor and/or Human Resources before the harassment becomes severe or pervasive. Reporting harassment as soon as possible can prevent escalation of the behavior and

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help OM respond effectively. When evaluating a claim, OM realizes the importance of using the reasonable person standard, which states that each person owes a duty to behave as a

reasonable person would under the same or similar circumstances. While the specific circumstances of

each case will require varying kinds of conduct and degrees of care, the reasonable person standard

undergoes no variation itself. Supervisors and Human Resources have the special responsibility, as agents of the employer, to address and eliminate any discrimination or harassment that exists in their areas of responsibility.

Complaint Procedure

An individual, who brings a harassment complaint to the attention of the supervisor and/or Human Resources, in good faith, will have the complaint investigated in an impartial manner. Complaints will be handled in a confidential manner consistent with the need to investigate and take corrective action. If a harassment complaint is substantiated, immediate and appropriate remedial action will be taken against the harassing party, up to and including job termination. If the complaint is not substantiated, the matter will be closed. In either case, however, the employee who filled the harassment complaint will be advised of the results of the investigation. In an effort to maintain full understanding of these policies, OM is committed to providing all employees with harassment training when they join the Company. All employees will be asked to sign a waiver saying that they understand the scope of this training, and it will be kept in the employees’ permanent records. If you have any questions about the preceding guidelines, please contact the Human Resources Department or refer to SOP #24.

Policy Against Retaliation

The Company’s policy prohibits retaliation against any employee who lodges a good faith complaint of unlawful discrimination or harassment in the workplace, who files a charge regarding the same, or who participates in any related investigation or proceeding. Employees should use the above-referenced complaint procedure to report incidents of alleged retaliation. The same procedures will be followed in investigating and responding to such reports. The Company wants to encourage the reporting of unlawful discrimination, harassment, and retaliation and, at the same time, to protect the reputation of any employee wrongfully charged with such conduct.

Please Note: This policy is applicable at all company events or at any time another OM employee is involved.

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2.8 – Dress Code Policy

This policy sets forth the expectations of OM’s corporate dress code. The purpose of the Dress Code Policy is to establish guidelines for work attire that conveys a professional image of OM.

This policy is not comprehensive in defining acceptable and unacceptable standards of dress and appearance. The OM staff should use good judgment in adhering to principles of the policy set forth. Employees should consider how this policy relates to their work environment, particular role and duties, and contact with others during the course of their employment.

Supervisors are responsible for ensuring the employees they manage adhere to the Dress Code Policy at all times. All employees are required to comply with the principles of the Dress Code Policy. Failure to adhere to OM’s standards of dress and appearance may constitute misconduct and result in disciplinary action, up to and including termination.

OM recognizes the diversity of cultures, religions, and abilities of its employees and will take a sensitive approach when these individual differences affect dress requirements. OM reserves the right to offer a reasonable accommodation in such circumstances.

Management reserves the right to alter the Dress Code Policy at any time, with or without written notice, based on the role and responsibility of each employee. Note that our business at times accommodates visits from clients and parents. On such days, we ask that employees observe either formal or business casual attire.

Corporate Events and Meetings – Formal Business Attire

When you are asked to wear business formal attire you should wear a suit or work attire equivalent to a suit.

The Office – Business Casual Attire

Slacks, Pants, and Suit PantsSlacks, Pants, and Suit PantsSlacks, Pants, and Suit PantsSlacks, Pants, and Suit Pants

Slacks that are similar to Dockers and other makers of cotton or synthetic fabric pants, wool pants, flannel pants, pants that match a suit jacket, and nice-looking, dressy synthetic fabric pants are acceptable.

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Skirts, Dresses, and Skirted SuitsSkirts, Dresses, and Skirted SuitsSkirts, Dresses, and Skirted SuitsSkirts, Dresses, and Skirted Suits

Dresses, skirts, skirts with jackets, dressy two-piece knit suits or sets, and skirts that are split at or below the knee are acceptable. Dresses and skirts should be at long enough for you to sit comfortably in public. Short or tight skirts that ride halfway up the thigh are inappropriate for work.

Shirts, Tops, Blouses, and JacketsShirts, Tops, Blouses, and JacketsShirts, Tops, Blouses, and JacketsShirts, Tops, Blouses, and Jackets

Shirts, dress shirts, sweaters, tops, and turtlenecks are acceptable attire for work if they contribute to the appearance of formal, professional dress. Most suit jackets or sport coats are also desirable attire for the office.

Shoes and FootwearShoes and FootwearShoes and FootwearShoes and Footwear

Conservative walking shoes, dress shoes, oxfords, loafers, boots, flats, dress heels, and backless shoes are acceptable for work.

Accessories and JewelryAccessories and JewelryAccessories and JewelryAccessories and Jewelry

Tasteful professional ties, scarves, belts, and jewelry are encouraged. Jewelry should be worn in good taste; body-piercing jewely should be kept to a minimum.

Makeup, Perfume, and CologneMakeup, Perfume, and CologneMakeup, Perfume, and CologneMakeup, Perfume, and Cologne

A professional appearance is encouraged, and excessive makeup is unprofessional. Remember that some employees are allergic to the chemicals in perfumes and makeup. Employees are advised to wear these substances with restraint.

Hair, Hats and Head CoveringHair, Hats and Head CoveringHair, Hats and Head CoveringHair, Hats and Head Covering

Hair and facial hair should be professionally groomed and kept neat at all times. Hats are not appropriate in the office. Head coverings that are required for religious purposes or to honor cultural tradition are allowed.

Casual Fridays and Holiday Attire

Certain days—Fridays, the workday before a holiday, and the last workday of each month—can be declared “dress-down” days. On these days, business casual attire, although never clothing potentially offensive to others, is allowed. Clothing that has the company logo is encouraged. Sports team, university, and fashion brand names on clothing are generally acceptable. You might want to keep a jacket in your office for the

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days when a client unexpectedly appears on a dress down day, especially if the client is wearing a suit.

Guidelines for Casual Attire

1. On Fridays, the workday before a holiday, and the last workday of each month, jeans, tee shirts, sweatshirts, and athletic shoes are allowed to be worn. All clothing should be neat in appearance and without tears or holes.

2. Keep in mind that tee shirts and sweatshirts should not contain offensive slogans or pictures.

3. Business reasons might require employees to wear business attire on casual day.

Unacceptable Clothing

The following items of clothing are examples of unacceptable clothing at all times. We ask that you NOT WEAR ripped or revealing clothing, shorts; bib overalls; halter tops; spaghetti-strap tops; midriff tops; tube tops; tops with bare shoulders or plunging necklines; beachwear workout attire; tank tops; spandex or other form-fitting pants,; distracting, offensive, or revealing clothes; extremely short skirts or dresses; and tee shirts with any offensive language or images. Tattoos should be appropriately covered.. Flip-flops and slippers are not acceptable. For more information on the OM Dress Code Policy, please see OM SOP #13

2.9 – Expense Policy

PurposePurposePurposePurpose

During your tenure with Orion’s Mind, you may be required to make travel and general business purchases as part of your job responsibilities. All expenses should be properly authorized, reported, reimbursed and governed through OM’s policy. Under no circumstances should personal expenses be charged to, or be temporarily funded by, OM. It is OM’s policy to reimburse employees for reasonable expenses and costs. In today’s competitive environment, all employees should keep expenses to a minimum. Employees who are traveling for business purposes will be reimbursed according to OM’s Expense Policy. OM reserves the right to update this policy as it sees fit. Please ask your supervisor for the most updated copy of the Expense Policy and an Expense Reimbursement Form, or see SOP #8 in the company Outlook Public Folders.

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Reporting ExpReporting ExpReporting ExpReporting Expensesensesensesenses

It is the employee’s responsibility to report his or her actual travel, lodging, and meal expenses in a responsible, ethical, and timely manner. All employees/contractors should act in accordance with the regulations set forth in the OM’s Code of Ethics, state regulations, district policies, and customer contracts or as outlined in the Employee Handbook. Any exceptions to OM’s Expense Policy must be submitted to your manager for approval. It is duly noted that travel time in and of itself is not considered an expense and therefore shall not be paid for as such.

NOTE: ANY PURCHASES THAT ARE INCONSISTENT WITH THIS POLICY OR EXCEED THE LIMITS ESTABLISHED WITHIN THIS POLICY WILL BE THE RESPONSIBILITY OF THE EMPLOYEE.

Gifts, Incentives, and RewardsGifts, Incentives, and RewardsGifts, Incentives, and RewardsGifts, Incentives, and Rewards

Because of the regulatory environment of our industry, OM’s Code of Ethics, and the nature of our clients, no gifts should ever be purchased for or given to any parent, student, school, district, or individual affiliated with a school or district. Any purchases that falls into this category must be approved by an Orion’s Mind attorney or C-level employee. Please note that any such unauthorized activities can and may result in a major violation that could lead to employee termination.

Approval of TravelApproval of TravelApproval of TravelApproval of Travel

All travel must be approved by the employee’s manager prior to booking any travel expenses. Employees may not approve the reimbursement of their own travel expenses. All expenses must be approved by the employee’s manager. In addition, an employee should not approve the travel expenses of an individual to whom he or she either directly or indirectly reports. Travel expenses follow the standard OM Expense Policy and should be submitted as outlined in SOP #8.

Transportation ExpensesTransportation ExpensesTransportation ExpensesTransportation Expenses

Transportation expenses shall be approved in advanced by the employee’s manager and will be reimbursed based on the most economical mode of transportation and the most commonly traveled route consistent with the authorized purpose of the trip. If in doubt, always ask a manager. Transportation tickets should be procured in advance in order to obtain any discounts offered by the carrier or negotiated by OM. When securing travel tickets, employees should purchase from discount travel sites such as Orbitz,

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Travelocity, and Expedia to name a few. Any flights over $350.00 or hotels higher than $150.00 per night will require the approval from OM’s Vice President of Finance. Employees are always able to use their own private transportation for OM business. In the event that this occurs, OM requires that an employee drives an insured vehicle and has a valid driver’s license.

MealsMealsMealsMeals

When employees travel on OM business that requires an overnight stay, the Company is responsible for the cost of meals and snacks up to the following limits:

• Breakfast - $10.00

• Lunch - $15.00

• Dinner - $20.00

Original itemized receipts are required for all expenses. Meal allowances are reimbursed after the trip is completed.

Hotel and LodgingHotel and LodgingHotel and LodgingHotel and Lodging

Rooms should be procured in advance in order to obtain economical rates or any conference discounts. Employees are expected to stay in the most economical three-star hotel in reasonable proximity to their travel objective. When securing hotel, employees should purchase from discount travel sites such as Hotels.com, Orbitz, Travelocity, and Expedia to name a few. Please check with Human Resources (HR) on any special corporate rate programs before booking hotel and lodging.

Air TravelAir TravelAir TravelAir Travel

Coach class or any discounted class airfare shall be used in the interest of economy. The use of business or first-class or other higher cost services is not authorized under any circumstances.

Air travel shall be approved in advanced by the employee’s manager and will be reimbursed based on the most economical flight consistent with the authorized purpose of the trip without deference for a preferred carrier or personal mileage accounts. If in doubt, always ask a manager.

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Tickets should be procured in advance in order to obtain economical rates. When securing travel tickets, employees should purchase from discount travel sites such as Kayak, Orbitz, Travelocity, and Expedia to name a few. Any flights over $350.00 will require the approval from your manager.

Use of an EmployeeUse of an EmployeeUse of an EmployeeUse of an Employee----owned Automobile owned Automobile owned Automobile owned Automobile

Travelers may use their private vehicle for business purposes if it is less expensive than renting a car, taking a taxi, or using alternative transportation.

All employees are expected to follow all traffic and parking laws and to keep current on their personal auto insurance and state and city registrations. Any penalties as a result of not following such laws are the sole responsibility of the employee.

Mileage ExpensesMileage ExpensesMileage ExpensesMileage Expenses

OM does not reimburse for standard commuting expenses (otherwise referred to as the employee’s normal commuting area) that consist of travel to or from the employee’s residence and his or her first or last place of work of that day. Mileage is only paid when traveling from a place of business (such as corporate headquarters, district building, or school) to another place of business. Home offices are not considered a place of business in terms of mileage reimbursement. Business travel outside the employee’s normal commuting area (typically, out-of-state and/or overnight) is reimbursable. Any additional district travel outside of the primary assigned district will be reimbursed at a flat rate. Please see your Manager/Area Director (AD) for details.

Note: Orion’s Mind is not responsible for and will not reimburse employees for fees attributed to violations (traffic, parking, damage, theft, etc.) while using personal vehicle for business purposes.

The sole source of reimbursement in relation to the use of any employee-owned vehicle is mileage reimbursement. The standard OM mileage reimbursement rate is paid at $0.41 per mile. Documentation of miles traveled is required and must be attached to the signed and approved travel expense report when submitting it for reimbursement.

Rental CarsRental CarsRental CarsRental Cars

• A vehicle may be rented when renting would be more advantageous to OM than other means of commercial transportation, such as using a taxi.

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• Advance reservations should be made whenever possible.

• A compact or economy model should be requested.

• The traveler is responsible for obtaining the best available rate commensurate with the requirements of the trip without deference to a particular brand or personal rewards program.

• The discount negotiated with car rental agencies by the Company should be requested when available.

• Employees must have personal car insurance that covers them while renting a car

• Rental cars should always be purchased with a corporate card as the AMEX provides additional blanket coverage for collision, theft, or loss (secondary to personal insurance; will also cover deductibles). Thus the Company will not be responsible if the employee elects to purchase additional insurance coverage through the car rental company.

The following items that may be associated with overnight business travel will be reimbursed by OM:

• Office Expenses – Faxes, photocopies, Internet charges, data ports, and business telephone calls incurred while on travel status can be reimbursed. Original itemized receipts are required.

• Parking – Original receipts are required for parking fees (including airport parking) totaling $3.00 or more. The lodging bill can be used as a receipt when charges are included as part of the overnight stay.

• Telephone Calls – The use of company cell phones for business and personal calls while traveling is approved.

• Tolls – Original receipts are required for tolls totaling $3.00 or more.

• Miscellaneous Transportation – Original receipts are required for taxi, bus, subway, metro, ferry, and other modes of transportation if costs are $3.00 or more for each occurrence.

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The following items that may be associated with overnight business travel will The following items that may be associated with overnight business travel will The following items that may be associated with overnight business travel will The following items that may be associated with overnight business travel will notnotnotnot be be be be reimbursed breimbursed breimbursed breimbursed by OM:y OM:y OM:y OM:

• Airline club memberships

• Business class or first class for all flights

• Child care, babysitting, house sitting, pet sitting, kennel charges

• Commuting between home and place of business

• Costs incurred by traveler’s failure to cancel travel or hotel reservations in a timely fashion

• Evening or formal wear expenses

• Haircuts and personal grooming

• Passports, vaccinations, and visas when not required as a specific and necessary condition of the travel assignment

• Personal entertainment expenses including in-flight movies, headsets, health club facilities, hotel pay-per-view movies, in-theatre movies, social activities, and related incidental costs

• Travel accident insurance premiums and/or purchase of additional travel insurance

• Upgrades for airfare, hotels, or rental cars

• Other expenses not directly related to the expense policy

For a detailed procedure of how to submit expenses please see SOP #8 on how to submit expenses in the Outlook Public folders.

2.10 – Drug and Alcohol Abuse Policy

In compliance with the Drug-Free Workplace Act of 1988, OM has a long-standing commitment to providing a safe, quality-oriented and productive work environment consistent with the standards of the community in which we operate. Alcohol and drug abuse pose a threat to the health and safety of OM employees and to the security of the

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families and clients that we serve. For these reasons, OM is committed to the elimination of drug and/or alcohol use and abuse in the workplace.

OM from time to time provides opportunities for social events where employees will be able to drink. Under no circumstances should anyone under the age of 21 be permitted to drink. Additionally, please be advised that no supervisor or member of management is permitted to buy employees alcoholic beverages. Rather OM observes and asks that employees use appropriate discretion when individually consuming alcohol at company-sponsored events. Accordingly, such conduct as an employee losing control and becoming impaired at a company sponsored event will subject employees to disciplinary action, up to and including termination.

This policy will be handed out during the OM hiring process and reviewed during new hire orientation. The policy will outline the practice and procedures designed to correct instances of identified alcohol and/or drug use in the workplace. This policy continues to apply to all employees and all applicants for employment of OM. The Human Resources Department is responsible for policy administration. Employees will be asked to submit to a drug test.

If an employee receives a positive result on the confirmatory drug test, employees will be notified of the results and given an opportunity to explain or challenge the test result. They also may request a confirmatory re-test of the original blood and/or urine sample at their own expense. The Company will review any information provided by the employee in connection with any adverse employment action that it is considering or has taken. However, OM reserves the right to take whatever action it, in its sole discretion, deems appropriate under the circumstances.

For more information about this please see SOP#17 - Drug and Alcohol Abuse Policy.

2.11 - Background Checks

Because many of our clients are schools and we work with children, we are required to comply with their policies regarding background checks. OM is committed to providing a high-quality work environment and to ensuring our clients that we meet our clients’ standards. All employees will be extended a conditional offer of employment and then asked to submit and successfully pass some or all of the following as part of our background checks:

• felony/misdemeanor

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• education verification

• employment references

• FBI level finger printing

• tuberculosis testing

• credit check

These checks or tests will be conducted at various levels based on the position that you are applying for and/or at a client’s request. If a client requires additional background information, an employee will be requested to comply by authorizing a release of information to the client. All information received under this policy will be treated as confidential and will be recorded in a separate file in the human resources department. According to Fair Credit Reporting Act (FCRA) federal guidelines, employees must read and understand the Notice and Authorization form and sign a release as part of the on-boarding paperwork.

In the specific event in which an employee’s criminal background is negatively impacted while in the employment of OM, the matter should be addressed immediately with Human Resources. If the information is revealed in a background check performed by OM or an OM client subsequent to the employee’s initial “new employee” background check, the employee is subject to suspension without pay and/or termination.

If an unsatisfactory result is received, OM will, at its discretion, decide the appropriate course of action which may include but is not limited to termination.

For detailed information regarding backgrounds and this policy, and all associated forms and notices are available in OM SOP #18 - Background Investigations available in the Outlook public folders.

2.12 – Employment References and Verification Policy

To ensure that individuals who join the OM Team are well-qualified and have a strong potential to be productive and successful, the recruiter follows the policy of checking the employment references of the selected applicant prior to extending a job offer.

The Human Resource Department is designated to respond to reference check and employment verification inquiries. All calls, contacts, and written inquires concerning current or former employees should be referred to the Human Resources. It is the policy

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of OM to provide neutral references concerning former employees. On an occasion when we receive a request for a reference of a current employee, we will ask for written consent from the employee authorizing OM to release information. In all cases, OM will only confirm dates of employment, wage rates, and the title of position held, for former employees OM will state whether or not they are eligible for re-hire.

Solicitation and Distribution

In order to protect employees from annoyance, harassment, and interference, and to maintain a workplace free of undue litter, the Company has adopted the following rules concerning solicitation and distribution of literature:

1. There will be no solicitation of any kind or in any manner by employees during working time or in work areas. (“Solicitation” includes, among other things, sales of products or raffle tickets, requests for donations or contributions, solicitations for lotteries or sports pools, and solicitations for membership in or support of any organization or cause.)

2. Employees will not distribute literature in working areas at any time.

3. Employees will not distribute literature in non-working areas during working time.

4. Anyone not employed by the Company will not be permitted to distribute literature or solicit our employees for any reason at any time on Company property.

5. As used in these rules, the term “working time” means the period of time that an employee is supposed to be performing his or her job duties. It includes the time when either the employee soliciting or distributing literature or the employee being solicited or receiving literature is supposed to be working. “Working time” does not include free time such as time allotted for break or lunch periods or periods before or after work.

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Section 3 - Time Away from Work

3.1 – Attendance and Time Reporting

The success and smooth operation of our Company depends to a great extent on everyone being at work on time each day. If you are absent or late in reporting for work, you place an extra burden on other members of the team. Whenever possible, all OM employees are personally responsible for reporting absences to their supervisor before employees are scheduled to begin the workday.

Occasionally, all of us have situations come up that cause us to be late or absent to work. Unless you are on an extended leave of absence or are an on-call seasonal worker, it is critical that you contact your supervisor as soon as you know that you will not be able to work your scheduled hours on each day you are absent. Absences must be reported no later than 9:30 a.m. If your supervisor is not available, you should leave a message for your supervisor and contact Human Resources. Any important business that may need to be completed during your absence should be conveyed during your phone call. It is your responsibility to make sure that your contact information is up to date in the company directory at all times so that your supervisor can contact you, should the need arise. Regular attendance is a condition of employment. Failure to call in or report to work for three consecutive days constitutes a voluntarily resignation or job abandonment. Employees are expected to adhere to the attendance policy. Violation of this policy, as well as excessive tardiness, poor attendance and unexcused absences, may be viewed as a performance problem and will be subject to disciplinary action—

suspension without pay and/or termination.

Good attendance is a condition of employment at OM. In addition to working your scheduled days and hours, we also expect that you start and return from lunches and breaks as scheduled. We cannot emphasize strongly enough the valuable role that you play in serving our clients and in some cases your peers. When you are not available, service suffers as your coworkers attempt to pick up your responsibilities in addition to their own. Excessive absenteeism and tardiness will not be tolerated.

3.2 - Time Entry Policy

All non-exempt, seasonal, and hourly employees are required to use Quickbase (QB) to record their hours worked. Non-exempt employees are required to clock in/out for payroll and attendance purposes. The time entry records will be used to track class attendance for Field Operations and are closely tied to variable compensation. In some

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cases, exempt employees will have the responsibility of collecting time entry data from their respective teams and e-mail that information to the appropriate department for processing.

If there is a problem with Quickbase, the employee should notify the supervisor who will direct the employee to fill out manual time sheets that will be faxed to the company’s data team for reporting.

3.3 - Deadlines for Submitting Time Entry Data

Managers are required to approve and submit data with the exception of Field Operations personnel in which case Area Directors are responsible for approving and submitting data. In either case all data must be submitted by 12 noon every Monday.

Hourly exempt employees (seasonal staff) are required to submit time and attendance data to their respective PMs on a daily basis before 9:00 am CST. PMs are then responsible for collecting all data and e-mailing their assigned data team member for appropriate processing.

If the employee misses an entry into the timekeeping system or violates process, the employee will notify the supervisor as soon as possible. The supervisor will manually enter the employee’s work hours. All late time sheets should be submitted with proper approval within a two-week period from the time worked. Employees who consistently miss time clock entries will be subject to disciplinary action.

Non-exempt corporate employees are permitted to work overtime with prior authorization from the assigned supervisor/manager. Overtime includes clocking in early or late or working through the scheduled lunch period. Nonexempt employees who work overtime without prior authorization will be subject to disciplinary procedures. Employees may not use another employee’s information to clock in or clock in for another employee.

Supervisors are free to implement disciplinary actions proceedings when employees have various, albeit repeated offenses to the time keeping policy and/or procedures. This could include situations where employees may have clocked in, but are repeatedly absent from their work site during work hours or have missed time clock entries in addition to working unscheduled overtime. Additionally, this is considered part of the administrative follow through for each employee and is considered part of the job responsibilities. Excessive violation and lack of compliance to this policy will be dealt with as a performance problem.

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Please refer to the Disciplinary Policy SOP #3 for direction on the appropriate disciplinary actions.

3.4 - Your Schedule

OM has set forth corporate operational hours of 9:00 9:00 9:00 9:00 aaaa....mmmm. to 6:00 . to 6:00 . to 6:00 . to 6:00 pppp....mmmm.... The normal (or regular) full-time work schedule for OM employees consists of five eight-hour days totaling 40 hours each workweek, and an hour each day for lunch. These hours of operation should be used as a guideline that employees may be required to work on any given day. Work performed in addition to regular work hours is customary with professional responsibilities and is often required in order to maintain the highest level of customer service and program quality.

Employees may also be required to be available at specific times and to change their schedules to accommodate fluctuations in work demands. If your particular job requires you to be somewhere at a particular time and you are not able to meet this requirement, you must find a suitable replacement in advance.

3.5 - Overtime

Salaried and exempt employees are not eligible for overtime pay. Only non-exempt and hourly employees are eligible for overtime pay for all hours worked in excess of 40 in a week. Non-exempt employees will be paid at the rate of one and one-half times their regular hourly rate of pay for each hour of overtime work. Vacation days, holidays, or any other leaves of absence are not considered hours worked when calculating overtime pay. All overtime hours must have the prior approval of your supervisor. Non-exempt and hourly employees who work overtime without prior approval are subject to disciplinary action, up to and including termination.

3.6 - Lunch/Break Periods

Employees generally work eight hours per day with a one hour unpaid lunch period. All employees working more than 7.5 hours in a day must take a 30-minute lunch break by the fifth hour worked. Excessive tardiness of lunch/break periods is not acceptable and will be treated as a performance problem. OM feels it is important that you periodically get up to stretch, get a cup of coffee or water, and generally refresh yourself. Your lunch break is a time for you to take care of personal calls or errands, socialize with your coworkers, or get a change of scenery. Taking these breaks allows us to be dedicated to our work during office hours and contributes to our work-life balance philosophy.

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3.7 – Un-Paid Leave

Sometimes we may need time off from our jobs to deal with unusual personal situations not covered under other leave of absence or time off policies. If you experience a situation that temporarily prevents you from working, you may apply for a personal leave of absence without pay. You must complete your introductory period of employment to be eligible to apply for an unpaid personal leave.

In an effort to recognize the need of employees who require time off in addition to bonus days or vacation, the Company may consider a personal leave of absence without pay for up to a maximum of 90 days.

Eligibility

All regular employees employed by OM for a minimum of 1 year may be eligible to apply for an unpaid personal leave of absence. Job performance, absenteeism and departmental requirements will all be taken into consideration before a request is approved. Requests for unpaid personal leave may be denied or granted by the Company for any reason or no reason and are within the sole discretion of the Company. Approvals of the immediate supervisor, department director and Human Resources are required.

Requesting unpaid personal leave:

Employee--An eligible employee should submit a request in writing to his/her immediate supervisor.

The employee should be reasonable and understand that all requests for personal leaves are not granted.

Supervisor--The immediate supervisor will review the request, taking workload scheduling and departmental requirements into consideration and will return a decision to the employee as soon as feasible after receipt of the written request.

The supervisor will review the request with his/her department manager and obtain the approval of the department director/manager and Human Resources.

If the request is approved, the supervisor will submit a Leave Request Form to Human Resources as soon as practically possible.

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Once the employee returns, the supervisor should complete a Change of Status form returning the employee to active status and submit to Human Resources.

Payroll--Payroll is responsible for ensuring that any employee on an approved personal leave of absence is not paid.

Returning to work/requesting extension to unpaid personal leave—In either event the employee is required to return from the unpaid personal leave with a letter establishing accomplishment of goal or releasing the employee to return to work. If the employee is unable to return, he/she must request an extension of the leave in writing.

If the company does not extend the leave, the employee must then return to work on the originally scheduled return date or be considered to have voluntarily resigned from his or her employment. Extensions of leave will only be considered on a case-by-case basis.

NOTE: This policy does not constitute a guarantee of continued employment. Rather, employment with the company is on an "at will" basis.

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Section 4 - Company Infastructure

4.1 – Department Classifications

OM has the following departments:

• Administration

• Human Resources

• Field Operations

• Curriculum

• Business Intelligence

• Supply Chain Management

• Marketing and Communications

For descriptions of each department’s function and associated jobs underneath the specific classifications, please see the individual job descriptions given to you on your first day of employment or in your on-line Human Resource Information System employee file also known as the employee self service portal.

For more information regarding the OM organizational structure, please refer to SOP #9 and view OM internal structure.

4.2 – Communication

Good communication is important in every organization. We want to make sure that employees have the information they need in order to effectively do their job and to provide the excellent service our customers have come to expect. Good communication is a shared responsibility; we expect you to seek out the information you need. Equally, if you have a problem or a concern, we expect you to discuss the situation with your supervisor or manager.

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4.3 - Open Door Policy

OM believes that all of our employees are vital to our continued success. You are encouraged to discuss any suggestions or concerns with your supervisor. If you believe that your immediate supervisor cannot adequately address the situation, please speak with your manager or the Human Resources Manager. Every effort will be made to resolve problems at this level.

4.4 - Dispute Resolution

To further OM’s commitment to maintaining a workplace in which all employees contribute to both their personal success and the Company’s success, we must work together as a team to communicate effectively. We encourage all employees to share their ideas and concerns in a constructive way. Every employee, regardless of position, will be treated with respect and in a fair and just manner at all times. All employees’ suggestions, concerns, complaints, and compliments will be given full consideration.

If you have a problem, we ask that you first talk with the individuals involved. If you are unsuccessful in resolving the issue or for some reason do not wish to talk to the relevant individual(s), please bring your concerns to your supervisor. If you are not comfortable discussing the issue with your supervisor, please speak with the Human Resources department.

4.5 - Phone Calls

The majority of OM’s business is conducted over the telephone. It is important that calls be answered promptly and that we do not leave callers on hold for extended periods of time.

It is everyone’s responsibility to answer the office phone. All Company employees need to know how to answer the phone, put a caller on hold, retrieve callers from being on hold, and check the office voicemail. Office phone calls should never go to voicemail as long as there is at least one person in the office.

While we understand that occasionally you may need to place or receive a personal call during business hours, these calls should be kept short. We want to ensure that employees are available to our clients and to other members of our staff who may be trying to relay business information.

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4.6 - Cell Phones

It is OM’s policy that representatives of our organization who are issued a company cellular phone understand that the phones are for business use only. Employees are expected to make every effort to adhere to the business-only requirement and not exceed the current contracted allowed minutes when possible.

Cell phones should be turned off or set to silent or vibrate mode during meetings and conferences and in other locations where incoming calls may disrupt normal workflow. For more information on company cell phone usage, please see SOP #7.

Please Note: Since our office space is open, we must be aware of our noise level. Please do not speak loudly, slam doors, play loud music, or cause noisy disruptions during business hours when your coworkers may be on the phone.

4.7 – Company E-Mail, Internet, and Computer Use

This policy sets forth OM’s rules regarding the use of its electronic communications systems, which include, but are not limited to e-mail, voice mail, telephones, facsimiles, copiers, computers and related equipment, and the World Wide Web. We encourage creativity and recognize that the Internet and its use may involve some personal use for conducting research, social networking, and so on. However, the employee is reminded that the use of any and all OM property is primarily for the purpose of OM business. Any personal use of the Internet is expected to be on the user's own time and is not to interfere with the person's job responsibilities. All systems are for work use only. Monitoring can be on option and management reserves the right to access all electronic communications.

This policy should be read and interpreted in conjunction with all other OM policies including, but not limited to, policies prohibiting harassment, discrimination, and offensive or inappropriate conduct, as well as to adhering to OM’s code of ethics and professional standards. Employees are prohibited from accessing the Internet for any unethical purposes, including but not limited to pornography, violence, gambling, racism, harassment, or any illegal activity.

The employee must abide by all federal and state laws with regard to information sent through OM’s electronic communications system. Employees are also prohibited from using OM systems for any other business or profit-making activities.

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In general, employees should exercise the same restraint and caution in drafting and transmitting messages over the Internet as they would when writing memos. Employees should assume that their message will be saved and reviewed by someone other than the intended recipients.

Employees are expected to adhere to the Internet use policy and the Internet usage policy of each client. Violation of this policy will be subject to suspension without pay and/or termination.

When using the Company’s property, all employees are expected to exercise care, perform required maintenance, and follow all operating instructions, safety standards, and guidelines. Employees must immediately complete an incident report and notify their supervisor if any equipment, machines, or tools are damaged or defective or need repair. These requests need to be submitted to the Supply Chain Management. Prompt reporting of damages, defects, and the need for repairs could prevent deterioration of equipment and possible injury to employees or others. The improper, careless, negligent, destructive, or unsafe use or operation of equipment, machines, or tools can result in disciplinary action, up to and including termination.

4.8 - Network Infrastructure

The K drive is the Company’s public network drive. All work-related documents should be stored on the K drive where they may be accessed by other OM employees. Only one version of a document may be live at any one time. Please use caution when multiple people are sharing a document. Please be aware that any document deleted from the K drive is permanently deleted. The document cannot be recovered by going to the recycle bin; all deletions from the K drive are final.

Private documents may be stored on the U drive. Limited use of the U drive is acceptable. Understand that information on the U drive is not private and may be reviewed by others.

No documents are to be saved on the desktop or C drive. Please note the C Drive is not a recoverable drive, and you stand to loose any information that is stored on there.

Please be cautious of downloading information from the Internet that may put our network at risk of receiving a virus. Since all Company employees share a network, it is of the utmost importance that you exercise extreme care and caution when downloading information from the Internet so as not to contaminate our network with unwanted

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viruses. Do not overburden our office network with personal activity, such as downloading music libraries.

Because of the open nature of our offices, we insist that all employees lock their computers before leaving their workstations so as to control access to department specific sensitive information. At the end of the workday, please shut down your computer and turn off your monitor. For more information on Internet usage and technology, please see SOP #16.

4.9 – Company Car

OM has a company car that it makes available to employees who did not drive to work and may need to drive on-the-job. Employees must verify that they have a valid driver’s license before checking out the company car. The below guidelines, regarding the company car, must be followed:

• First log onto the OM’s Microsoft Office Outlook, create a calendar event, and reserve the company car by following the directions in OM SOP #6.

• If the car is available, the Office Manager will contact you via e-mail to confirm your reservation and provide you with further instructions. Please make sure to be clear as to when the car must be returned.

• You must present a valid driver’s license to the Office Manager in order to check out the company car. There will be no exceptions to this rule.

• Return the car key to the Office Manager, who will maintain a log of whom has checked out the company car and when it has been returned.

For additional information on the company car and other company resources, see OM SOP #6 in the Outlook Public Folders.

4.10 – Document Library

The document library is a place where you can find historical documents, presentations and training information. The document library is a place where employees can capitalize on an opportunity to bring themselves up to speed on previous corporate-training initiatives. We have web conference meetings that will allow remote and seasonal employees to dial in bi-weekly and participate in professional development sessions. Trainers discuss various topics pertinent to the Company’s practices. The

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knowledge session schedule can each be found in Quickbase. Each knowledge session will be led by a member of the corporate training team.

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4.11 - StarMail

Company announcements, updates, and pertinent information are relayed periodically through StarMail and HCS Wires. StarMail is a weekly e-mail that is meant to communicate company- wide updates and upcoming events.

4.12 - HCS Wires

HCS Wires are different in that they specifically highlight Human Resources - employment policies, employment news, and information that impacts our employee population. These e-wires are meant to provide Human Resources (HR) to you, our employees, on current HR matters. HCS wires will typically contain information about HR services and provide refreshers on employment policies relevant to specific times of the year.

Employees are encouraged to review all archived communications and to understand both past and current events. For more information regarding Star Mail and HCS Wires, please refer to OM SOP #15.

4.13 - Business Cards

Upon employment, the employee will receive company business cards. The OM Office manager will review the options for business cards and make sure that the employee’s information appears as requested. It is mandatory that each employee carry his or her business cards at all times while at a client site. Business cards are given to employees as an effort to build the OM brand. Please use them.

4.14 – Safety and Security

OM is committed to providing and maintaining a safe and secure work environment. We must all be alert to possible safety hazards and security issues and work to eliminate them through either our own actions or by working with our supervisor. If you have any concerns, please be sure to let your supervisor know immediately. Your safety and security are important.

4.15 - Protecting Company Assets

OM has a variety of assets, including physical property and proprietary information. To safeguard the property of our employees and our customers, OM maintains its right to question employees and all other persons entering and leaving our premises and to

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inspect any packages and personal belongings. OM encourages employees to make every effort to store, lock, and secure personal items. OM is not responsible for loss or stolen personal property. You should be aware that all offices, desks, computers, phones, files, and so forth are the property of OM and may be inspected at any time at the Company's discretion. This property is given to you for your use as an employee of OM. Refusal to cooperate in an inspection may result in disciplinary action, up to and including termination.

4.16 - Reporting Fire

If you smell smoke or see fire, alert your coworkers and immediately vacate the work area using the nearest available exit. Use any phone outside of the work area to call 911. Be prepared to give the address and the approximate location of the fire.

Pay attention to alarms at all times. You never know whether the alarms are for drill purposes or a genuine emergency. You will be given specific information related to your location, such as scheduled tests of the emergency systems, assembly points, and so on, during your orientation by the Office Manager. For more information, please see the Public Folders and view OM SOP #16 on Emergency Plans.

4.17 - Accidents

If you are injured while at work, you must let your supervisor and Human Resources know immediately. We want to be sure you get proper medical treatment and accurately record the accident. All injuries and illnesses that require a doctor’s treatment should also be reported to your supervisor immediately. If you are unable to complete your workday because of a work-related injury, you will be paid for the remainder of your workday. For more information on reporting incidents, please see OM SOP #23.

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Section 5 - Compensation

5.1 – Total Rewards Philosophy

At OM our compensation philosophy is simple; we take a total rewards approach to compensation and present our employees with competitive base salaries, reward performance, and add value to our employees’ lives by providing competitive benefits. Our total rewards approach means fair pay based on your role in the organization, the market value of your job, and your performance compiled with the value of company-provided benefits.

To attract and keep the best people, we offer meaningful rewards when you, your department, and the organization achieve specific business goals or when you demonstrate outstanding individual performance at the company discretion. We provide all employees with the opportunity to earn additional compensation beyond their base rate by using a creative approach to rewarding our employees.

5.2 – Work-Life Balance Statement

OM recognizes that there are tangible benefits from supporting flexible working practices, implementing family friendly initiatives, and assisting employees to achieve a balance in their work commitments and their life outside of work. The Company is committed to policies and working practices that enable its employees to strike a mutually beneficial balance between the needs of the Company, its employees and other stakeholders, and the commitments of home and family life. There needs to be a commitment from all parties concerned to strike this balance. Guidelines for achieving OM’s work-life policies follow:

• Employees must recognize their roles in providing services through the Company to the community at large and to the schools and families we service.

• Work-life balance policies and practices developed around time reporting and un-paid time off will help employees successfully combine work with non-work responsibilities.

• Managers, supervisors, and employees will be encouraged to work together to ensure the successful implementation of new ways of working.

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• OM’s commitment to work-life balance policies and practices will be publicized and communicated to employees.

• OM will be promoted externally as an organization, which is committed to establishing work-life balance through its compensation programs, policies, and practices.

5.3 - Employment Status

Your position is classified as either exempt or non-exempt, based on your job responsibilities as compared to state and federal guidelines. In addition to being classified as exempt or non-exempt, you may be full-time, part-time, temporary, or seasonal. An employee’s classification may change based on the nature of his or her job assignment, responsibilities, and/or compensation. Non-exempt employees are subject to the minimum wage, overtime, and time record provisions of the Fair Labor Standards Act (FLSA), as well as state wage and hour regulations. All non-exempt employees are required to report their time in accordance with these regulations.

Definitions

ExemptExemptExemptExempt An individual is exempt from the overtime provisions of the Fair Labor Standards Act because they are classified as an executive, professional, administrative, or outside sales employee and meet the specific criteria for exemption.

NonNonNonNon----exemptexemptexemptexempt An individual who is not exempt from the overtime provisions is therefore covered by the provisions of the FLSA. Such an individual is therefore entitled to receive overtime for all hours worked beyond 40 in a workweek (as well as any state overtime provisions).

HourlyHourlyHourlyHourly An individual who receives an hourly wage for work performed is considered an hourly worker. Such individuals, because of the method of payment, are classified as non-exempt and are subject to the overtime provisions of the FLSA.

Temporary and or seasonal employees and may work full or part-time hours for a defined or limited period. For more information, please refer to the seasonal employee handbook located in OM SOP #1 in the Outlook Public Folders or see Human Resources for assistance.

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5.4 - Payday

Compensation is paid on a bi-weekly basis (26 pay periods per year). The paycheck will reflect time worked for the two weeks preceding the week you receive the paycheck otherwise referred to as two weeks in arrears. OM’s pay period begins on Saturday and runs through the following Friday. Employees are paid every other Friday. If the payday falls on a holiday, you will be paid on the next banking day. OM offers employees different options of payment: either a direct deposit or a check mailed by the US Postal Service. In some cases, employees may have the desire to have an alternative method of payment and choose to have their checks held at the office. These arrangements need to be discussed during your first week of employment during your orientation or communicated in writing to OM’s Payroll Department two weeks in advanced of the next pay cycle. There are absolutely no exceptions to these rules.

Your check will show your gross and net pay as well as all deductions, including taxes. No other deductions are made unless required or allowed by law or contract. You may authorize voluntary deductions, such as group insurance premiums, in writing.

If you have any questions about your pay, please discuss them with your manager.

5.5 - Issues with Paychecks

Improper deductions from the salary of employees are a serious violation of Company policy. OM encourages any employee who believes his or her salary has been improperly reduced to report the problem immediately to his or her immediate supervisor. The Company will review the deduction to determine if it was proper. The review process may require the employee to provide information or present documents to the Company. The employee will be notified of the results of OM’s review. Should the Company determine that the deduction was improper, the employee will be reimbursed for the improper deduction on the next pay cycle. Employees are assured that OM is committed to comply, and expects all supervisors and managers to comply, with this policy and to carefully avoid making improper deductions from the salaried employees. Employees also are assured that no retaliatory action will be taken for reporting improper deductions. Employees who suspect retaliation should report their concerns immediately to their immediate supervisor and bring it to the attention of HR.

In the event that an employee requests to have a paycheck mailed to his or her home, OM is not responsible for delays with the US postal service. The employee will be

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required to notify the Payroll Department after 8-10 business days have passed. The employee will have the option of having a new check issued to him or her on the next pay cycle after OM has voided the missing check and deducted a $15 dollar service charge for reissuing the new check. Because of the large volume of our payroll, OM cannot cut single checks and therefore makes no exceptions to issue new checks for pick up at our offices on the very next pay cycle. There are no exceptions to this rule.

Note: In order to ensure that you are paid correctly, you are responsible for notifying OM immediately in writing of any changes in your personal information, such as name, address, telephone number, withholding allowances, emergency contact, and so on.

5.6 - Seasonal Benefits

At OM, you have the opportunity to enjoy a comprehensive seasonal benefit package that provides a variety of protections for you. You are eligible to participate in the seasonal benefit programs on the first day of full-time employment. With the ever-increasing cost of health care, these benefits have become a valuable part of your total income and a major component to our Total Rewards Compensation Philosophy. The seasonal benefits program is fully funded by the employee and OM does not share the cost of the premiums for these benefits.

In the event of loss of employment, the employee must elect to either continue or discontinue his/her benefits coverage by completing a COBRA enrollment/waiver form, which can be obtained by contacting Human Resources, provided an employee’s seasonal benefits have begun.

If the employee chooses to continue benefits coverage through COBRA, benefits will continue to be administered through OM, but it will be completely at the employee’s expense. COBRA coverage shall remain in effect for a period of up to 18 months from the date of enrollment.

For more information regarding our benefits service offerings, please refer to OM SOP #19 in the company outlook public folders.

5.7 - Requesting Time Off

Time-off hours should be requested and approved using the time-off request form. Seasonal employees requesting time off will do so with the notice that this is un-paid time off The employee’s manager maintains the discretion to approve time-off hours that have been requested. Once approved, time-off hours must be reported on the

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employee’s time sheet(s) and documented in the “HR Time-Off Calendar” located in Outlook Public Folders. For more information on how to post approved time off to the “Time-Off Calendar,” refer to SOP #4. Please note that hours may only be taken in either four- or eight- hour blocks with no exceptions.

All time-off hours taken totaling more than four hours must be requested and approved at least three business days in advance by the employee’s manager. In cases in which advanced notice was not given for time-off hours taken, the employee is still responsible for notifying his or her manager of an absence as soon as possible. The employee must adhere to all protocols for documenting and obtaining approval of time-off.

5.8 - Unpaid Time Off

Sometimes employees may need time off from their jobs to deal with unusual personal situations not covered under other leave of absence or time-off policies. If you experience a situation that temporarily prevents you from working, you may apply for a personal leave of absence without pay. You must complete your introductory period of employment to be eligible to apply for an unpaid personal leave.

In an effort to recognize the need of employees who require time off, the Company may consider a personal leave of absence without pay for up to a maximum of 90 days.

Eligibility

All seasonal employees who have worked at OM for a minimum of 90 days may be eligible to apply for an unpaid personal leave of absence. Job performance, absenteeism, and departmental requirements will all be taken into consideration before a request is approved. Requests for unpaid personal leave may be denied or granted by the Company for any reason or no reason and are within the sole discretion of the Company. Approvals of the immediate supervisor, department director and Human Resources are required.

Guidelines for unpaid personal leave follow:

EmployeeEmployeeEmployeeEmployee’s ’s ’s ’s requesrequesrequesrequestttt An eligible employee should submit a request in writing to his or her immediate supervisor. The employee should be reasonable and understand that all requests for personal leaves are not granted.

SupervisorSupervisorSupervisorSupervisor’s process’s process’s process’s process The immediate supervisor will review the request, taking workload scheduling and departmental requirements into consideration. He or

Orion’s Mind Seasonal Employee Handbook Effective April 1, 2009. 40

she will return a decision to the employee as soon as feasible after receipt of the written request.

• The supervisor will review the request with his or her department director/manager and obtain the approval of the department director/manager and Human Resources.

• If the request is approved, the supervisor will submit a Leave Request Form to Human Resources as soon as practically possible.

• Once the employee returns, the supervisor should complete a Change of Status Form returning the employee to active status and submit to Human Resources.

PayrollPayrollPayrollPayroll Department’s Department’s Department’s Department’s responsibilityresponsibilityresponsibilityresponsibility Payroll is responsible for ensuring that any employee on an approved personal leave of absence is not paid.

Employee’s return to workEmployee’s return to workEmployee’s return to workEmployee’s return to work An employee is required to return from the unpaid personal leave on the originally scheduled return date. If the employee is unable to return, he or she must request an extension of the leave in writing.

• If the Company does not extend the leave, the employee must then return to work on the originally scheduled return date or be considered to have voluntarily resigned from his or her employment.

• Extensions of leave will only be considered on a case-by-case basis.

NOTE:NOTE:NOTE:NOTE: This leave is not intended to be an extension of short-term disability (STD), long-term disability (LTD), and/or any other current benefit provided by the company. This policy does not constitute a guarantee of continued employment. Rather, employment with the company is on an "at will" basis.

5.9 – Provisional/Probationary Periods

An employee required entering a 90-Day provisional period, or an extension thereof, will not be approved to take time off hours during his or her provisional period. However, upon successful completion of the provisional period, time off hours may be considered.

5.10 – Time-Off Related Issues

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Seasonal employees are here for a set amount of time and therefore required t o be at work for the length of the season. Consistent tardiness to meetings and/or absences could constitute or result in disruptive attendance patterns; this will be considered as excessive and may be treated as a performance issue subject to counseling and/or disciplinary action leading up and to termination.

5.11 – Civic Duty

If you are called to serve as a juror during your scheduled work hours, you will need to submit a copy of your summons to your supervisor prior to the jury date. OM will compensate you at your regular pay for a maximum of two weeks. If you are non-exempt, you will earn your regular, hourly pay based on the number of hours you are regularly scheduled to work.

Employees appearing as a plaintiff, defendant, or for non-subpoenaed court appearance will not receive paid time off. PTO or unpaid time should be used for these instances. In addition to this, there will be no interruption in the length of the employee’s service with OM.

5.13 — Family and Medical Leave Act

The following provisions briefly describe the Family and Medical Leave Act (FMLA) and are intended to comply with the FMLA. The Company will be guided by the specific provisions of the FMLA and its implementing regulations issued by the U.S. Department of Labor when interpreting and applying this policy in individual cases.

EligibilitEligibilitEligibilitEligibility:y:y:y: Upon the approval of the Director of Human Resources, all employees—full-time, part-time, or temporary—who have been employed by OM for at least 12 months and have worked at least 1,250 hours during the 12 months preceding the date leave is needed, are eligible for up to 12 workweeks of unpaid leave per rolling 12-month period. This 12-month period is measured backward from the date on which the employee uses any FMLA leave. An employee is entitled to FMLA leave for the following reasons:

• for incapacity due to pregnancy, prenatal medical care, or child birth

• to care for the employee's child after birth or placement for adoption or foster care

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• to care for an immediate family member (spouse, child, or parent) with a serious health condition

• to take a medical leave when the employee is unable to perform the functions of his or her job because of a serious health condition

If leave is taken for the birth or placement of a child or to care for a parent who has a serious health condition, and both spouses are employed by the Company, the spouses are jointly entitled to a combined total of 12 workweeks of leave.

Military Family Leave:Military Family Leave:Military Family Leave:Military Family Leave: Eligible employees with a spouse, son, daughter, or parent on active duty or call to active duty status in the National Guard or Reserves in support of a contingency operation may use their 12-week FMLA leave entitlement to address certain qualifying exigencies. Qualifying exigency leave is not available to family members of the regular Armed Forces on active duty or with respect to calls to active duty by state governments. Qualifying exigencies may include attending certain military events, arranging for alternative childcare, addressing certain financial and legal arrangements, attending certain counseling sessions, and attending post-deployment reintegration briefings.

FMLA also includes a special leave entitlement that permits eligible employees to take up to 26 weeks of leave to care for a spouse, son, daughter, parent, or next of kin who is a covered service member during a single 12-month period. Although an employee may use up to 26 weeks of leave to care for a covered service member, an employee that takes leave to care for a covered service member is nonetheless limited to an aggregate total of 26 weeks of leave in a 12-month period for all types of FMLA leave.

FMLA Leave Notification and CertificationFMLA Leave Notification and CertificationFMLA Leave Notification and CertificationFMLA Leave Notification and Certification:::: Requests for FMLA leave should be submitted in writing to Human Resources. All employees are required to give 30 days notice prior to the taking of FMLA leave when the need is foreseeable. If 30 days is impossible, then the employee must give notice as soon as practical and generally must comply with the Company’s normal call-in procedures for reporting absences. Leave to accommodate planned medical treatment should, when possible, be scheduled to avoid disruption of OM’s operations. Employees must provide sufficient information for the Company to determine if the leave may qualify for FMLA protection and the anticipated timing and duration of the leave. If an employee seeks leave for a reason for which he or she has previously been granted FMLA leave within the past 12 months, the employee must specify the reason for which FMLA leave was previously taken.

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After receiving a request for FMLA leave, the Company will inform the employee whether he or she is eligible under the FMLA. If the employee is eligible, OM will inform the employee about any additional information the employee must provide to qualify for FMLA leave as well as the employee’s rights and responsibilities concerning FMLA leave. If the employee is not eligible for FMLA leave, OM will inform the employee why he or she is not eligible.

The Company may require that when leave is requested due to illness or serious condition of the employee or a relative, a certification from a health care provider establishing the existence of a serious health condition, the need for the leave, and its probable duration be submitted. A certification form will be provided to the employee by OM. When required, such certification must be submitted as soon as practicable, but in no event, later than 15 calendar days after the request. If the Company concludes that an employee’s medical certification is insufficient, it will notify the employee in writing of the additional information that is necessary to complete the certification. The employee then has 7 calendar days to provide the requested information. If OM questions the validity of the certification, it can require the employee to submit to an examination for a second opinion at the Company's expense. If there is a conflict between the original certification and the second opinion, a third health care provider can be requested to provide a certification at the Company’s expense to break the tie. The third opinion will be final and binding.

The Company will then inform the employee whether leave will be designated as FMLA-protected and, if known, the amount of leave that will be granted. OM will also notify the employee if it determines that the leave is not FMLA-protected.

Employees on FMLA leave must periodically notify Human Resources of their status and intention to return to work, and may be required to submit periodic medical recertification’s. In addition, in order to return to work after an FMLA leave due to the employee’s own serious health condition, the employee must submit a certification from his or her health care provider that the employee is able to resume work and perform the essential functions of the employee's job, or “fit for duty.” An employee will not be returned to work until he or she has submitted this documentation.

Failure to meet the notice and certification requirements may result in denying a request for leave; counting the employee’s days off against his or her attendance record; taking disciplinary action, up to and including termination; or denying reinstatement following the leave.

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1. FMLA Leave Impacts on Healthcare and Other Benefits:FMLA Leave Impacts on Healthcare and Other Benefits:FMLA Leave Impacts on Healthcare and Other Benefits:FMLA Leave Impacts on Healthcare and Other Benefits: All employees who receive FMLA leave are entitled to the same health care coverage that the employee received prior to the commencement of the leave and on the same terms as if the employee had continued to work (including the employee's share of any premium increases). If applicable, arrangements will need to be made for employees to pay their share of health insurance premiums while on leave. If an employee is more than 30 days late with the premium co-payment, OM may elect to discontinue its portion of the health insurance coverage premium. If the employee does not return to work after the leave expires, the employee must reimburse the Company for all premiums the Company paid during the leave, unless the employee does not return because of the continuation, recurrence or onset of a serious health condition, or other circumstances beyond the employee’s control.

Employees will not lose any employment benefits earned and accumulated before their FMLA leave begins. The employee should note that FMLA runs concurrently with his/her PTO, BPTO, Holiday’s or leave without pay. Also note that PTO days are not accrued during FMLA leave.

2. RRRReturning from FMLA Leave: eturning from FMLA Leave: eturning from FMLA Leave: eturning from FMLA Leave: Employees who return to work from an FMLA leave within their maximum 12 weeks per rolling 12-month period will be restored to their original job, or to an equivalent job with equivalent pay, benefits, and other employment terms and conditions. However, under specified and limited circumstances when restoration to employment will cause substantial and grievous economic injury to the operations of the Company, OM may refuse to reinstate certain highly paid "key" employees after their return. A key employee is defined as any salaried employee who is among the highest paid 10 percent of all the employees of the Company. Also, an employee has no greater right to reinstatement or to other benefits and conditions of employment than if the employee had been continuously employed by the Company during the FMLA leave period. Therefore, if changes in OM’s business occur during an employee’s FMLA leave and the employee would have been terminated, laid off or reassigned had he or she been on active status, the employee is not guaranteed reinstatement.

3. EEEEnforcement:nforcement:nforcement:nforcement: An employee may file a complaint with the U.S. Department of Labor or may bring a private lawsuit against an employer.

FMLA does not affect any Federal or State law prohibiting discrimination, or supersede any State or local law or collective bargaining agreement which provides greater family

Orion’s Mind Seasonal Employee Handbook Effective April 1, 2009. 45

or medical leave rights. OM recognizes that there may be time when FMLA leave will need to be taken interminably and will evaluate each claim on a case by case basis.

5.14 — Military Leave of Absence

OM recognizes and applauds its employees who elect to serve our country and serve in the United States Armed Forces. An approved military leave, whether voluntary or involuntary, will not be charged against the employee’s accrued PTO or sick time. OM will grant up to two weeks per calendar year of pay differential (the difference between the employees base salary and military base salary, inclusive of a housing allowance) for military training, reserve, active duty, or a pre-induction medical examination. The employee will be required to provide OM with a letter from his/her commanding officer outlining the anticipated time and duration of the leave. The employee will also be responsible for providing OM with a pay voucher verifying military pay to be received during the time of leave.

OM will comply with all state and federal laws regarding the employment and re-employment rights of members of the uniformed services. Any questions regarding these guidelines should be directed towards Human Resources.

Section 6 – Employee Programs

6.1- Professional Development

At OM, we believe that honest 360-degree feedback is important to encourage successful professional growth. Feedback is a shared responsibility, however. Your supervisor has the responsibility for providing you with information about your job performance and opportunities for development. You have the responsibility of managing your own work activities, as well as your relationships with others on the OM team.

6.2 - Performance Reviews

Every employee of the company will be given a performance review at least once a year, typically to coincide with the company fiscal year end so as to initiate any changes prior to the beginning of the following year. Reviews are conducted by the employee’s direct manager and will incorporate 360-degree feedback from peers, clients, and the

Orion’s Mind Seasonal Employee Handbook Effective April 1, 2009. 46

employee under review. Reviews are the basis for salary adjustments, promotions, and yearly bonuses.

Because of the nature of our business, we have two very different review cycles. Our Academic Programs seasonal staff reviews will be conducted at the end of the program season and must be completed and submitted by March 15th of the year. It is the Company’s intent to have all reviews and change requests completed prior to the fiscal year-end. Increases are neither automatic nor guaranteed at review time. Factors that will be considered relating to the employee’s accomplishments include, but are not limited to, performance, ability, reliability, initiative, judgment, and other factors relevant to the job role and overall company performance. OM takes a proactive approach to match market rates, and salaries are typically reviewed once per year to ensure our employees are being compensated accordingly.

6.3 - Promotions and Transfers

OM encourages internal promotions. As job openings become available, OM has a job-bidding process in place that will give first consideration to current qualified staff members for any open position. Current employee-candidates must meet the same requirements and qualifications for an open position as would an outside candidate. OM will look at the employee’s performance in addition to skills and abilities when considering him or her for promotion or transfer.

Recruitment for a position occurs internally and externally simultaneously. When a vacancy occurs within a department and an employee of that department meets the minimum qualifications, then the employee may be promoted and the job-bidding process may be waived. It is intended that the job-bidding process will be used as often as practicable as a means of filling vacant positions. For more information on the job-bidding process, please see SOP #13.

6.4 - Access to Employee Records

OM maintains files on each employee. These files contain information relating to the employee’s hiring, training, performance appraisals, and so on. OM considers these files to be personal and confidential. Generally, without written consent from the employee, only direct supervisors who have a legitimate business reason to review information in the files are allowed to do so. OM’s Human Resources Department strives to maintain confidentiality and audits files regularly to meet the standards of federal, state, and local regulatory agencies.

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All company regional branches will have access to duplicate copies of very basic employee data up and to including performance-related files. However, all permanent originals will reside at the corporate office. You may review your personnel file up to one time per calendar year. To request your file, OM asks that you submit a written request to the Human Resources Department.

To ensure that your file is up to date at all times, notify the Human Resources Department of any changes in your personal information, such as your name, telephone number, home address, marital status, number of dependents, beneficiary designations, scholastic achievements, emergency contacts, and so forth.

6.5 — Employee Referral Program

OM is always looking for good people, and you can help. Research has shown, and our own experience supports this, that new hires that come into a company through employee referrals are excellent contributors, stay with the company longer, and are a more cost-effective recruits.

That's where you come in! If you know people who would be a good addition to OM, it may be worth a prize if you refer them for employment and they are hired!

Refer candidates who meet the qualifications by having them log on to www.orionsmind.com and choosing the position that best fits their professional profile. Once candidates select a position, they will need to fill out the on-line application, select “employee referral” from the pull down menu, and state your name in the notes/comments section.

At the end-of-year company party, we will hold a drawing for a nice prize. For every referral you make, your name will be entered in the drawing. For each hired candidate you refer, you will have 5 entries for your name! The drawing box will be cleared at the end of the year.

Orion’s Mind Seasonal Employee Handbook Effective April 1, 2009. 48

Section 7 — When You Leave OM

For a variety of reasons, your employment relationship with OM may terminate. While OM is an at-will employer, as a professional courtesy, we would ask that you provide the customary two weeks’ notice to allow us to transfer your job responsibilities and projects in a way that allows us to continue to provide a high level of client service. Additionally, we ask that you put your resignation in writing to your supervisor and Human Resources for storage in your permanent record.

7.1 Exit Interviews

OM conducts exit interviews for all employees. Exit interviews allow the company an opportunity to gain valuable insight into the following:

• employees’ perception of OM’s work environment and culture

• current policies and procedures

• the need for better benefits programs and higher compensation

• potential problems with supervision, job assignments, and workloads

Also, the exit interview will be used to provide exiting employees with information regarding the status of company benefits, eligibility for rehire, as well as to arrange the return of OM/client property, such as computers, ID badges, swipe cards, and so on. Exit interviews are conducted by Human Resources.

Every employee regardless of his or her participation in the exit interview will be required to complete various separation paperwork, including, but not limited to a “COBRA Enrollment/Waiver” form and “Employee Exit” form prior to his or her last day of employment.

We want to remind you that when you leave the Company for any reason, you may not disclose or use OM confidential information for any purpose. Additionally, programs or content that you created or information that you developed while at OM remains the property of OM after you leave.

All Company property must be left with the Office Manager on your last day. This includes, but is not limited to, your keys, computer, phone, credit cards, files, printers, marketing or program materials, and other OM property and materials.

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Handbook Acknowledgment - Seasonal

I have received a copy of the OM Seasonal Employee Handbook and have read and understand its contents, specifically including the statements in the About This Handbook section describing the purpose and effect of the handbook. I understand that OM is an at-will employer and as such, employment with OM is not for a fixed term or definite period and may be terminated at the will of either party with or without warning, notice, or cause. I understand that nothing contained in OM’s Employee Handbook may be construed as creating a promise of future benefits or a binding contract with OM for benefits or for any other purpose.

In addition, I understand that this Employee Handbook states OM’s policies and practices in effect on the date of publication, and supersedes and replaces any prior policy of the same subject matter. I also understand that these policies and procedures are regularly evaluated and may be amended, modified, or terminated at any time, with or without notice.

Please sign and date this acknowledgment, and return it to your supervisor immediately. Your signed acknowledgment will be kept in your personnel file at all times.

Employee Name:

(Please Print)

Employee Signature: Date: