Handbook

This text is copied from \\wxystudio\data02\0_office\Employee Handbook\230920_Employee Handbook Folder\240520_Employee Handbook.pdf

Welcome

Welcome to WXY! We are glad to have you on board. As a team member at WXY, you are an essential part of a collaborative studio’s effort to develop and design spaces that work for all people. We hope that you will find your position and time at WXY rewarding, challenging, and productive. Every team member plays a vital role in our operations, and we value the abilities, perspectives, and life experiences you bring with you to the studio.

This handbook has been prepared to acquaint you with the culture, employment policies, and practices at WXY. While every attempt has been made to create these policies consistent with federal and state law, if any inconsistency arises, the policy(s) will be enforced consistent with the applicable law.

We may, at our discretion, change, modify, remove, and add a practice or policy at any time, except for policies that are mandated by federal, state, and city law or discriminatory.

Please read this manual carefully and keep it for future reference. If you have any questions, please contact the HR representative or your Advisor Mentor.

This Employee Handbook contains the employment policies and practices of the organization in effect at the time of publication. All previously issued handbooks and any inconsistent policy statements, or memoranda are superseded.

Purpose of the Handbook

The beginning of this handbook will introduce you to the organization’s values, culture, and goals. WXY expects all staff to incorporate this information into dayto- day job performance, striving to meet WXY’s values in everything we do.

The remainder of this handbook will familiarize you with policies, privileges, benefits, and employee responsibilities at WXY. Please understand that this handbook can only highlight and summarize our organization’s policies and procedures. If you have specific questions about policies, please talk to the HR Representative.

Please read the policies and sign the acknowledgment at the end of the document.

What WXY Strives to Achieve

WXY is dedicated to making cities more livable, dynamic and equitable. We are dedicated to innovating the public realm. We do this by working across scales and disciplines - through designing public space and civic architecture, planning with communities and analyzing data. Our clients, among many, are city agencies, community-based organizations, institutions, landowners and developers. We pride ourselves on a work approach that emphasizes clear communication; design and analysis that is curious, innovative and effective; and project management that is aware of the contexts we work within, including physical, social and financial parameters.

What You Can Expect from WXY

WXY believes in a work environment that fosters innovation and collaboration to meet the challenges of our business. WXY believes in providing a quality workspace for our employees and in providing quality design and planning work for our clients. Through this commitment, WXY will continue to ensure our success and growth.

What WXY Expects from You

Providing enduring, people-centered design and urban planning at every development stage is crucial to our mission and our success as a studio. This would not be possible without the unique skill sets, creative collaboration, and dedication of our talented staff. At WXY, we expect and depend upon you to perform to the best of your ability and to act in ways reflecting favorably on the organization, other staff, and yourself.

At-Will Employee Status

Our offices are in states that promote employment-at-will. Employment at-will means that WXY does not guarantee employment for any period unless it violates the law, and staff is free to separate at any time and for any reason. There is no contractual obligation. No manager, Advisor Mentor, or employee of WXY has any authority to enter into an agreement for employment for any specified period or to make any agreement for work other than at-will. If an employment agreement is necessary, only the Principals have the authority to make any such agreement, and only in writing.

Furthermore, nothing in this handbook is intended to modify this at-will relationship or create a contract of any kind unless directed, dictated, and signed by the Principals.

EEOC Statement

WXY is an Equal Opportunity Employer and prohibits discrimination and harassment of any kind. WXY is committed to the principle of equal employment opportunity for all Employees and to providing Employees with a work environment free of discrimination and harassment.

All employment decisions at WXY are based on business needs, job requirements, and individual qualifications, without regard to race, color, religion or creed, nationality, social or ethnic origin, citizenship status, sex (including pregnancy), age, physical, mental or sensory disability, HIV Status, sexual orientation, gender identity and/or expression, marital, civil union or domestic partnership status, past or present military service, family medical history or genetic information, family or parental status, sexual and other reproductive health decisions, hairstyle and texture, or any other status protected by the laws or regulations in the locations where WXY operate.

WXY will not tolerate discrimination or harassment based on any of these characteristics.

Diversity Statement

At WXY, we believe in equality for all people regardless of race, class, gender, religion, sexual orientation, color, creed, sex, age, disability, citizenship status, marital status, and national origin. It is represented through our commitment to building equitable communities here in New York City and across the US. The complexity of addressing inequity in our society requires a diverse set of ideas, skills, perspectives, and viewpoints, which can then lead to innovative and ground-breaking solutions. Our approach requires a diverse set of people from a range of backgrounds and disciplines, making people our biggest asset. And so, it is our mission to build a work environment that fosters inclusivity, values ideas, and debate, and where employees feel empowered.

How We Work

We are focused on creating a supportive work environment for staff. As such, WXY has established a structure where each staff member will have an “Advisor Mentor.” Advisor Mentor assignments are in the Fall 2023 Organization Chart located at “M:\0_office\0_WXYNET\01_HR\02_POLICY & PROCEDURE\230906_ OrgChart_FALL 2023_v2.pdf.“

ADVISOR MENTOR ROLES AND RESPONSIBILITIES

As leaders in the office, Advisor Mentors play both a mentoring and guidance role for staff. Advisor Mentors will serve as the point person for staff on any questions regarding office policy, professional development, and advancement, as well as any general concerns. This organizational structure is meant to provide greater clarity around general workplace practices and policies, and it is meant to strengthen working relationships across the office, and to encourage greater familiarity, collaboration, and collegiality.

Advisor Mentors will meet individually, at least quarterly, with the staff they are managing in order to get to know each of them and learn their goals, concerns, and interests. discuss progress, professional development, any HR or other office procedural questions, mentorship and other employee concerns. Our HR representative will provide training and administrative support for Advisor Mentors and employees to strengthen and grow the employee feedback and mentorship structure.

ORGANIZATIONAL STRUCTURE V. PROJECT STRUCTURE

The Advisor Mentor relationships in the Organization Chart are not for purposes of Project Management. These relationships will help to broaden connections across disciplines in the office. All staff will work on many different teams during their time at WXY. Procedures and protocols for portfolio and project management will be articulated and addressed in a different series of communications and meetings. Policies and procedures, performance reviews and PTO approvals will be articulated through the Advisor Mentors.

PTO REQUESTS

All requests for PTO (Personal Time-Off) must be cleared with all of your Project Managers (for a Project Manager requesting PTO – contact your Portfolio Managers). After this confirmation, the employee will email the HR Representative and the Managing Principal to confirm accrued benefits are aligned with the request. At this time, the employee shall key the request into Prestige, and share an Outlook Event invite for the duration of the scheduled PTO to office@ wxystudio.com (office calendar). When an employee is off, they will use an Outlook Auto reply that directs the sender to a prearranged alternate point of contact during their absence. Advance notice is important and courteous to all your colleagues - please make every effort to commence PTO approval process a month or more in advance of departure.

REFERRING INQUIRIES AND CONCERNS

For personal or confidential topics, staff should continue to be in touch directly with the HR representative. For Advisor Mentors, if any questions fall outside of your working knowledge and resources you can access, do not hesitate to be in touch with the HR representative.

Our HR representative will provide each Advisor Mentor with training and support for the administration of the written review process.

OFFICE ATTENDANCE POLICY

Since its inception, WXY has done the best work when engaging directly with others - from interns to collaborators to clients/stakeholders. The immediacy of collaborating in a multi-disciplinary studio atmosphere is key to innovation, creative solutions, and individual professional development. We believe that the studio and work “in the field” - working alongside colleagues and clients - is the best learning environment to develop professional expertise and leadership. WXY has committed to creating a flexible, multi-disciplinary, in-person work environment that enhances our ability to deliver high quality work to the clients and communities we serve. Since WXY’s work revolves around the built environment, we are focused as a firm on learning what works and does not work from lived experiences – and this includes our work environment. The inoffice work expectation is that all professional staff living in the tri-state area will work from the office full-time with a structure that allows for eight hours / one day remote “flex” time, reflecting the need for professionals that have multiple projects and client responsibilities to manage their own time. When a staff member is working remotely, they should put this in the office calendar by sending an invite to offce@wxystudio.com.

DEFINITIONS

• “In-office” Besides being at the office, you may occasionally be required to be on a job site, which would be considered “in-office.”

• Workday Work hours should overlap with the standard business hours expectations of clients, consultants, and contractors on your projects. Normal working hours are 9:00 am to 6:00 pm EST. Staffing needsWork hours should overlap with the standard business hours expectations of clients, consultants, and contractors on your projects. Normal working hours are 9:00 am to 6:00 pm EST. Staffing needs and operational demands may necessitate variations in starting and ending times, as well as variations in total hours that may be scheduled each day and week. If a staff member expects to be away from the office during normal working hours, the staff member must notify their Advisor Mentor in advance and indicate the reason for, and the period of absence. However, all staff must try to be in office no later than 10am Monday through Friday.

• New Staff In the first three months of hire staff is expected to be “In-office” all days.

• Weekly Remote Flex Hours For professional staff beyond their initial 3 months up to 8 hours per week can be performed remotely (at your primary place of residences or some other location with high-speed internet access). This is a guide, remote hours are not tallied or banked to be carried over to subsequent weeks. If PTO time is taken in the week (Vacation, Personal Day, Sick Day, Holidays) then remote flex hours would not apply on top of that.

• In-Studio Meetings If there are critical in-person meetings with team members, consultants or clients, there is an expectation that you will be in the office for those meetings.

---

Planned Remote Annual Allowance

Each year, we will allow a total of 4 weeks of work remotely. This can be used with the following limitations:

• The maximum time to work remotely is four continuous weeks unless there is an unusual circumstance time that has been approved by the Principals.
• Staff have the option of working two weeks remotely combined with two weeks of vacation - this would allow this staff member to work another two weeks remotely at a different time of the year (this second remote travel allowance should not be taken within 6 months of the initial period).
• To clarify - staff cannot work remotely for four weeks combined with any other PTO which would result in more than 20 consecutive business days away from the NYC studio.
• Before scheduling extended remote work, staff are expected to receive approvals from Principals, Associate Principals, and Project Manager who they are working with.
• When working remotely in non-Eastern Time zones, staff are expected to work during regular hours of the main office so that timely collaboration can be maintained, unless otherwise agreed upon with principals, project managers, and peers.
• Planned Remote Work can only be authorized with confirmation that you will have access to high-speed internet for the duration of the Remote work. High-Speed internet is defined as bandwidth required for full access to files and software needed to perform your work including participation in voice and video calls.

As noted above, when a staff member is working remotely, they should put this in the office calendar by sending an invite to office@wxystudio.com.

Office attendance policy as outlined above will only be changed by either an emergency shift alert or with 60-day notice as we learn more from our evolving work culture.

ALL OFFICE ENGAGEMENT

• Currently, Mondays are prioritized for office gathering, coordination and announcements. External meetings are to be booked at other times if possible.
• One or two Thursdays each month will be reserved for whole office-gathering and presentations.
• Lunch & Learns will typically occur at least twice a month.
• Weekly news and announcements will be shared on the Internal Newsletters (& eventually an Intranet Portal).

RECORDING HOURS WORKED

The timely completion of a timesheet is required for project accounting and client billing purposes. It is important that our staff recognizes that diligent reporting on timesheets is to the benefit of the office as a whole. If staff work more than 40 hours a week, it is important that this time is recorded. Staff must show at least 40 hours a week in the Ajera system for every week. All staff must complete and submit timesheets for review by Project Managers through Ajera, no later than COB on Friday at the end of EVERY week. Any corrections requested by Project Managers must be addressed so that the timesheet can be resubmitted no later than Friday of the following week. For some projects, an additional timesheet may also be required. Please refer to your Advisor Mentor with any questions about this process. Failure to comply or falsification of timesheets will result in disciplinary action. Before departure for any PTO, staff must enter their time through the end of the scheduled PTO.

Employment Categories

Our employee classification outlines the different categories of Employment at WXY. It states the different types and statuses that an Employee may acquire once the firm hires them. It is rendered necessary for the administration of benefits.

Employee classification is established as part of the Fair Labor Standards Act (FLSA). WXY will observe any legal guidelines that apply to the classification of Employees. Its categories will be formulated in a manner that does not contradict any rule mandated by law, and the benefits will be administered accordingly.

EXEMPT

An individual who is exempt from the overtime provisions of the Fair Labor Standards Act (FLSA) because they are classified as an executive, professional, administrative, or outside sales Employee and meets the specific criteria for the exemption.

NON-EXEMPT

An individual who is not exempt from the overtime provisions of the FLSA and is therefore entitled to overtime pay for all hours worked beyond 40 in a workweek (as well as any state overtime provisions).

REGULAR FULL-TIME EMPLOYEE (FT)

They are regularly scheduled to work 30 hours or more during the five-day workweek. FT Employees are eligible for benefits described in this handbook.

REGULAR PART-TIME EMPLOYEE (PT)

They are regularly scheduled to work less than 30 hours per week. PT Employees are eligible for applicable holiday and earned sick time per NYC’s Paid Sick Leave Policy.

INTERNS

WXY hosts a variety of internships. Interns may be FT or PT and are eligible for sick and personal days dependent on the length of stay.

TEMPORARY

Temporary Employees are those whose contract is valid for a definite amount of time and must be renewed to retain Employee status. Those Employees can be fulltime or part-time. Interns, for example, are considered temporary part-time while interims are classified as temporary full-time. They don’t have benefits.

**Each Employee is either exempt or non-exempt from overtime.

**Exempt Employees are paid not for hours worked but rather for the work that WXY is committed to having a diverse team of competent professionals in our planning and design work. Therefore, WXY is intentional in our hiring practices and seeks out opportunities to match our professional needs with a more diverse set of candidates through collaboration with local AIA and APA diversity chapter committees on recruitment.

All applicants for a posted vacancy will be considered based on their qualifications and ability to perform the job successfully. The HR committee will appoint a Hiring Team for each job opening. The associated Hiring Team will screen applications and resumes for the role before scheduling interviews. Initial interviews are generally conducted by the Hiring Team and the manager using behavior-based interview questions and a structured interview process. Candidate evaluation forms will be completed after each interview and retained with the application. Job openings are posted on https://www.wxystudio.com/jobs.

Review and Compensation Philosophy

Performance Reviews

Annual reviews will be conducted in two or three different cycles through Prestige. Cycle 1 to be held in May for staff with anniversary dates between January 1– June 30 and Cycle 2 to be held in November for staff with anniversary dates between July 1 and December 31. Each staff member will have one written performance review completed by the Advisor Mentor following a one-on-one inperson meeting.

The performance review process begins with the Advisor Mentor selecting two (or more) Peer reviewers in consultation with a Principal. Once Peer Review questionnaires have been completed, the EMPLOYEE will complete their selfevaluation. After a review of PEER and SELF evaluations, the Advisor Mentor will seek additional input (if required) and complete the Supervisor Review form provided by HR (through Clear Company). Once all questionnaires have been completed and reviewed again with a Principal, the Advisor Mentor schedules the in-person review. After the review, notes are shared with the staff member, including the list of goals for the year ahead. The annual review is intended to focus on a review of performance, including areas of success, improvement, and opportunities to build better collaboration and communication. Such discussions are an opportunity to talk about and agree on future objectives and goals that are in alignment with the overall strategic goals of WXY. Included in these discussions are professional development plans that will assist staff in defining their future career path at WXY.

It is not the intention of the annual review for the Advisor Mentor and staff member to discuss salary and promotion.

The HR representative will provide each employee with training and support for the administration of the written review process and management of the annual review platform.

Compensation and Advancement

SALARY BANDS

WXY utilizes salary bands to determine compensation based on job title and responsibility and to benchmark standards relative to the broader planning, urban design, and architecture fields. These salary bands are made available to all employees, please refer to the Professional Development Bands file located at “M:\0_office\Employee Handbook\Professional Development Bands.”

PROMOTIONS AND SALARY CHANGES

Promotions and compensation adjustments will be determined by the Principals on an annual basis.

At the close of each year, Principals will determine whether the business conditions enable the award of salary increases to staff. These conditions include analyzing the firm’s labor costs relative to other firm expenses relative to the firm’s revenues, as well as reviewing the firm’s backlog of contracts. From this analysis, the Principals determine the overall percentage increase in labor costs that makes sense for the firm’s sustainability and for the well-being of the staff. The approach of WXY is to provide compensation that is fair, reasonable, and consistent with compensation paid in the sector for positions of comparable complexity and responsibility within the parameters of WXY’s financial well-being. If salary increases are possible, Principals will conduct a review of individual employees, utilizing all available organizational information, to determine an increase. The office will be moving toward making salary adjustments all at one time during the calendar year.

Principals determine promotions once a staff member is meeting the criteria and standards for advancement set out for each level within the salary bands table and in discussion with senior leadership. A Principal or an Associate Principal will meet with a staff member to tell them when they are being promoted.

Promotions to a new job title will typically include a salary increase commensurate with the salary band for the position and in place of any other increase. Senior promotions, in particular, require significant contributions to the organization in the form of mentorship and leadership in areas of technical expertise, project management and business development and a strong presence within the office.

PROFIT SHARING

After several years of working at the Associate Principal level, staff may be invited to participate in a profit-sharing plan, in the form of bonus compensation, which is determined and distributed on an annual basis. This participation is in place of other form of salary adjustments.

As with advancement decisions, Principals will evaluate the profit-sharing plan on an annual basis and will weigh business issues such as profitability, targeted growth and other organizational dynamics to determine viability, plan economics and participation. This form of bonus compensation may allow Associate Principals who have reached an upper cap on their salary to earn a bonus increase.

BONUSES

In addition to regular compensation, employees may be eligible to receive discretionary bonus based on WXY’s financial performance and individual performance. The bonus, when and if it occurs, is discretionary. Among other requirements, employees eligible to earn and receive a bonus must be employed and have not given notice before or on the payment date to be eligible to earn a bonus, subject to applicable law.

PAY DAY

WXY compensates its employees on a semi-monthly basis on the 15th of the month (covering the period from the 1st of the month to the 15th) and the last day of the month (covering the period from the 16th of the month to the end of the month). Each paycheck will include earnings for all work performed through the end of the pay period. Adjustments from the prior pay period will also be included on the paycheck. If a scheduled payday falls on a weekend or Holiday, paychecks will normally be issued on the prior business day. Paychecks are issued by Prestige.

Training & Development

WXY is committed to the training and development of all employees. While many opportunities exist daily for learning on the job, WXY makes opportunities available to staff to attend courses on specific topics. Employees will be compensated for time spent attending any mandatory training and WXY will pay the costs associated with such mandated training. Upon completion of training regardless of whether internal or external, it must be logged in Ajera, and a copy of the certificate must be sent to the staff member’s Advisor Mentor and HR to be added to their HR file.

Effective January 1, 2023* (and moving forward on a calendar year basis) all professional staff are entitled and encouraged to make use of up to $1,000 in reimbursed expenses for professional development items, including: licensing exams with a passing grade, professional development courses, NCARB fees, CE classes, conference fees/travel expenses, professional association fees, and licensure renewal.

Staff are also entitled and encouraged to use up to two days (16 hours) of paid professional development time. This time can be used for conference attendance. For conference attendance, staff must submit a request for approval to their Advisor Mentor at least one month in advance for approval.

If passed tests exceed this allowance in one year these exams will be covered above the annual allowance. This can also be used for equipment that makes work easier like headphones, peripherals. If this allowance is already used up employees can request the headphones or specific equipment for approval beyond this allowance.

Note: If the staff member has already submitted expenses since January 1, 2023, there will be a spent report issued to them in September to reflect remaining balance.

For staff invited to participate in professional convenings as a speaker and/or panelist, WXY will provide support in the form of PTO and expense funding. Approvals must be obtained from Principals prior to participation.

If there are special requests for equipment (e.g. such as construction boots required for construction sites), staff can send information to their Advisor Mentor, and the Advisor Mentor will pass this on to a Principal (the AM should use the org chart to determine which Principal).

ACCREDITATION BONUSES

Staff who successfully gain professional licensure/certification can earn a onetime bonus of $2,000 paid in the first pay period of the new calendar year after licensure/certification.

TEACHING AND GUEST CRITIC INVITATIONS

Teaching during work hours is open to those in the role of Senior Architectural/ Urban Designer and above, with exceptions made on a case-by-case basis for those not at that level. The expectation is that staff member will maintain the same level of production in their WXY work.

All Guest Critic Invitations during work hours should be arranged with their Advisor Mentor and should be limited to two half days per semester.

Corporate Immigration Policy

This immigration policy applies to those foreign nationals working with WXY or who are already working with WXY and subject to U.S. immigration laws. WXY complies with all immigration laws. This policy aims to guide how WXY will handle certain specific scenarios. WXY reserves the right to make further exceptions and to alter this policy over time.

Offers of employment are contingent upon an individual’s ability to secure and maintain the legal right to work at the company, including obtaining work authorization. All employees are required to complete and satisfy all I-9 requirements within three (3) days of beginning work for WXY. If WXY is unable to validate work authorization or complete I-9 requirements, the offer of employment is withdrawn with no liability to the company for any expenses incurred, time spent, or other inconvenience to the job applicant. It is WXY’s general practice to pursue immigration sponsorship and to assist with the financial costs associated with such sponsorship, as outlined in this policy, for the purpose of hiring and ensuring legal employment authorization in the United States.

The process for sponsoring employment visas for Foreign Nationals is complex and sometimes lengthy. Success in obtaining approval for an employment visa depends on the law, regulation, and procedures of the U.S. Citizenship and Immigration Services (USCIS). U.S. immigration laws are complex and change frequently. Thus, WXY cannot guarantee the approval of a visa application the “Visa Petition”. However, WXY will support the application process for prospective employees who are Foreign Nationals, as outlined in this Policy.

WXY will assist with immigration sponsorship costs for required applications allowing the foreign national employee to obtain valid work authorization to begin employment. No fees are covered for dependent family members (spouse and children under the age of 21) Foreign national employee and dependent family members may work with WXY’s designated immigration law firm to process such applications, ensuring the most efficient and often the most cost-effective immigration processing.

The need for Premium Processing (expedited government processing) filings will be considered by WXY on a case-by-case basis. If a business need exists, WXY will cover such Premium Processing fees. If WXY decides that a business need does not support premium Processing, foreign national employees may still request such a filing and pay such fee where legally permitted.

A summary of immigration service fees covered by WYX is listed below. Note that this list is not meant to be a complete listing of fees covered and may be modified by WXY at any time without notice:

• Initial Non-immigrant work authorization (ex. H-1B, H-1B1, E-3, L-1A or L-1B, TN, F1, J-1, O-1)
• Non-immigrant work authorization extensions (ex. H-1B, H-1B1, E-3, L-1A or L-1B, TN, J-1, O- 1)
• Non-immigrant status amendments due to material changes in employment such as job title, duties, and/or location
• Non-immigrant visa application fees and costs for the employee if travel is required for business purposes. If travel is not required or related to WXY business, then the foreign national employee will be responsible for all visa processing consular fees.

Although WXY will maintain records, it is the foreign national employee’s responsibility to ensure that government documentation, including electronic I-94 entry documentation, is accurate and complete. The employee is also responsible for notifying WXY six months ahead of any immigration status expiration to ensure that WXY has sufficient time to prepare and file any extension applications. WXY will also track such dates, but this is the employee’s ultimate responsibility to ensure the possibility of continued employment. Note that the Immigrant Visa process’s initiation is not guaranteed to any employee and may not apply to all positions.

If Employees are terminated, WXY will work with the immigration law firm and is liable for the reasonable return transportation costs, including a return plane ticket. WXY will not be liable for the return transportation costs of the employee’s family members or belongings. WXY is not obligated for costs of return transportation if the employee terminates the employment.

This policy does not alter the nature of at-will employment.

Healthcare Benefits

Benefits at WXY are available to permanent full-time Employees and renewed annually (November 1, 2023). Information on plans may be found on Prestige, with multiple options to fit the staff member’s needs at any given time. Please refer to the benefits plan located at “M:\0_office\Employee Handbook\Health Plans\2023 “ for more detailed information.

Retirement Plan

WXY has a tax-qualified 401(k) plan with Principal Financial Group. Employees’ taxable income is reduced by the amount the staff member contributes pre-tax through salary deferral. This allows an employee to reduce their taxable income. The retirement plan is for all Employees over 21 years old who have completed thirteen months of service with the organization in which they worked at least 1,000 hours. After meeting this qualification, Employees may enter, exit, and change their contributions at any time.

For all participants, WXY matches employee contributions according to a standard QACA Safe Harbor matching schedule. As such, WXY will make a 1% matching contribution for the first 1% of participant’s contribution, plus half of the next 5% of pay, for a maximum match of 3.5% to participant’s first 6% contribution. WXY matching contributions are vested on a 2-Year Cliff Schedule - meaning, after 2 years, employees have access to the full amount contributed by WXY. Employees are always 100% vested in their own contributions; those contributions can never be forfeited.

Employee Deferral	WXY Contribution
0.0%	0.0%
1.0%	1.0%
2.0%	1.5%
3.0%	2.0%
4.0%	2.5%
5.0%	3.0%
6.0%	3.5%
>6.0%	3.5%

WXY may make additional discretionary contributions at the end of the plan year. Qualifying Employees must be active participants on the last day of the plan year and have worked at least 1,000 hours during the latest accrual service period ending on or before that date. Such discretionary employer contributions are separate from the pay deferral match program and are vested on a 5-Year Graded Vesting Schedule.

For further details about the retirement plan, contact Amy Hau or Principal Financial Group.

Citi Bike Benefit

Biking in NY is a convenient and fun way for Employees to get to work. Citi Biking makes people happier and helps in the sustainability of the environment. For these reasons, WXY offers a discounted annual membership for Citi Bike for $102.50 (this is subject to change annually).

If a staff member would like to enroll in Citi Bike benefits, they should speak to the HR representative for more info.

Holidays

WXY observe the following standard holidays and provide all full-time Employees time off with pay unless otherwise provided in this policy.

FOR US BASED EMPLOYEES

• New Year’s Day
• MLK Day
• Memorial Day
• Juneteenth
• Independence Day
• Labor Day
• Thanksgiving Day
• Friday after Thanksgiving Day
• Christmas Day

FOR CANADIAN EMPLOYEES

• New Year’s Day
• Family Day
• Good Friday
• Victoria Day
• Canada Day
• Labor Day
• Thanksgiving Day
• Christmas Day
• Boxing Day

All Employees will receive a listing of the year’s holiday at the beginning of the new calendar year. Holidays falling on a Saturday or Sunday are usually observed on the preceding Friday or the following Monday, respectively. Holidays that occur during an employee’s vacation time are not to be counted as vacation days taken. These holidays must be clearly entered into staff timesheets to avoid PTO confusion.

FLOATING HOLIDAYS

WXY recognizes and values the diverse cultural background of our staff. To help meet the needs of our employee population, in addition to recognized holidays when the office is closed, WXY provides 3 floating holidays which can be used like personal days throughout the year. Floating holidays are not meant to be used in conjunction with other PTO time.

Floating holidays are available at the beginning of each calendar year for all current employees with at least 3 months of service at WXY.

Employees must specify the event for which they are requesting to use a floating holiday. The request must be scheduled and approved in advance by the employee’s Project or Portfolio Manager.

Floating holidays will not be carried over to the next calendar year, nor may they be cashed out if not taken or paid upon termination of employment.

It is critical that staff clearly enter Floating Holidays in timesheets.

Paid Vacation Time

WXY believes that Vacation Time is essential to the health and well-being of our Employees and encourages all Employees to utilize their vacation days. WXY strives to balance the amount of time WXY spends delivering our services with the need to replenish and refresh. For that reason, WXY provides the following tiered Vacation Time, so that time to replenish and refresh continues to grow as the staff member continues to dedicate their time, values, and expertise to WXY.

ELIGIBILITY

Employees who are regularly scheduled to work at least 40 hours per week are eligible for Vacation each year. Employees who are not eligible for Vacation include interns, seasonal, and part-time employees who are regularly scheduled to work less than 40 hours per week.

Accruals are based on years of service listed below:

YEARS OF SERVICE	ANNUAL ACCRUAL*	ACCRUAL RATE
Years 1 – 2 (Up to first 24 months)	10 days/80 hours	3.33 hours/pay period
Years 3 – 5 (After 24 months / entering Year 3)	15 days/120 hours	5 hours/pay period
Year 5+ (After 48 months / entering Year 5)	20 days/160 hours	6.66/pay period

Calculated annually based on the first day of full-time employment

Vacation days start accruing on the first day of employment and are accrued on a per pay period basis. All new Employees may request vacation time after their three-month probationary period. Employees may schedule vacation days in full day (8 hour) or half day (4 hour) increments.

Vacation may not be accrued more than the Annual Accrual allotment, which is the maximum accrual cap. Once an employee’s unused and accrued Vacation reaches the maximum cap, the employee will not become eligible for any additional time except to the extent that the employee’s accrued unused balance falls below the annual allotment maximum cap.

CARRYOVER

On December 31st of each year, up to 40 hours of accrued unused vacation hours** may be carried over to the following year and used before April 1st. Hours in excess of the 40 hour limit are forfeited without further compensation – as is the case with any Carryover Vacation hours that are not used before April 1st.

** The “accrued unused vacation hours” refers to both unused hours through the staffmember’s annual “start date” and unused hours accrued until the end of the calendar year.

VACATION AND LEAVE OF ABSENCE

When an employee is on FMLA, Paid Family Leave, or unpaid leave, they will not accrue any vacation time. Vacation accrual resumes when the employee returns from leave.

VACATION PAY OUT

An Employee who provides a two-week notice of resignation will be paid unused accrued vacation time. An Employee who resigns within 60 days of their start date will not receive paid unused accrued vacation time.

Paid Sick Time

All Employees are entitled to five days (40 hours) of sick time per year to cover time missed due to illness or appointments related to illness or mandated by state regulations. Part-time employees accrue an hour of paid sick time for every thirty hours worked. Unused sick time is not paid out upon resignation or termination. Sick leave that is unused by an employee over the course of the year will be carried over to the next calendar year.

Sick time can be used for the following reasons: - The Employee’s mental or physical illness, injury, or health condition. - The Employee’s need for medical diagnosis, care, or treatment of mental or physical illness, injury, or health condition - The Employee’s need for preventive medical care. - Care of a family member who needs medical diagnosis, care, or treatment of an illness, injury, or health condition, or who needs preventive medical care. “Family member” is defined as the Employee’s child, grandchild, spouse, domestic partners, parent, grandparent, child or parent of an employee’s spouse or domestic partner, sibling (including a half, adopted, or stepsibling), aunt or uncle. - Closure of Employee’s place of business due to a public health emergency (as declared by the Commissioner of the New York City Department of Health and Mental Hygiene or the Mayor). - The Employee needs to care for a child whose school or childcare provider is closed due to a public health emergency. - Employees who have been victims of domestic violence, a sexual offense, stalking or human trafficking, or who have a family member who has been the victim of one of the above offenses, may take sick leave to take actions necessary to maintain, improve, or restore the physical, psychological, or economic health or safety of the Employee or the Employee’s family member or to protect those who associate or work with the Employee.

An employee who is unable to report to work because of injury or illness must notify their Advisor Mentor prior to the scheduled starting time. For absences of more than 3 consecutive days due to illness or injury not connected with employment, a certification from a healthcare provider must be submitted. The certification must state that the employee was under the provider’s care or treatment for the days in question and that it is the provider’s recommendation that the employee remain out of work. A healthcare provider’s certification may also be required in other circumstances.

Paid Personal Time

Full-time Employees can take up to three (3) planned or unplanned single days off each year as personal days. Personal days can be taken in either half (4 hours) or full-day increments and cannot be taken in succession to each other.

Personal time is accrued, starting from Employee date of hire. All new Employees may request personal days after three-month of their probationary period.

Personal time is not eligible to be carried over. Therefore, it will reset every calendar year. Unused paid personal time is not paid out upon resignation or termination.

Deadline Hours Policy

The Fair Labor Standards Act states that full-time salaried employees are exempt from the overtime requirements. As a result, all full-time WXY employees do not receive overtime pay and are paid on a salaried basis. Employees are required to enter the additional hours worked in their timesheet on the days that the time was worked.

There is sometimes a need for full-time staff to meet deadlines to fulfill client commitments, and the office retains the right to require staff to work additional time. When a Project Manager and a staff member agree that the staff member will require significant additional time to meet a deadline, the Project Manager will pre-approve Deadline Hours with authorization from a Principal. These approved Deadline Hours can be taken as time by the staff member, typically within a onemonth period following the end of the Deadline Hours workweek. Consideration will be made for when the time is taken to ensure that time off works with project schedules.

Deadline Hours are typically limited to 20 hours per deadline and cannot be accrued, paid out, or carried over like other PTO.

When a staff member takes their approved time off after doing Deadline Hours, they should then move the Deadline Hours on their timesheet from when they were worked to the time that they are taking this time off (This will require deleting the time from when they were performed and re-entering the time with a note into Ajera.)

Interns are entitled to overtime pay if they work more than 40 hours in a single week. Overtime for interns must be authorized in advance by a Portfolio Manager or a Principal.

MEALS AND TAXIS DUE TO WORKING LATE

Meals ordered in the office and taxis home for late working must be approved in advance by Project Managers.

Paid Bereavement Time

WXY believes that loss can impact everyone in different ways, and if any WXY staff should be impacted by the loss of a loved one, WXY is here to sympathize and empathize. WXY offers five (5) days of bereavement leave so that a staff member can mourn, attend a service, be with family and friends, or take care of necessary estate documents. Bereavement leave may be requested due to the death of an immediate family member. The immediate family is defined as the Employee’s spouse/ domestic partner, parent, child, or sibling; the Employee’s grandparents or grandchildren; the Employee’s spouse/partner’s parent, child, or sibling; and the Employee’s child’s spouse.

Time Off to Vote

WXY encourages Employees to fulfill their civic responsibilities by participating in elections. As a registered voter, a staff member may take off up to 3 hours, without loss of pay, to allow time to vote. All Employees, including part-time and hourly Employees, can take time off at the beginning or the end of their day, to be mutually agreed upon. It is important to be forthcoming and communicative by providing notification to the Advisor Mentor no less than two days before the election that the staff member will take time off to vote.

Jury and Witness Duty Leave

Employees are granted leave to serve on a jury or to appear in court as a witness according to a subpoena, as the victim of a crime, or out of civic responsibility, such as an eyewitness. A staff member should notify their Advisor Mentor of their potential jury duty or witness duty as soon as the notice is received.

Full-time Employees will receive regular pay for the duration of the selection and/ or trial period of up to 10 days.

Upon completion of jury duty, Employees must obtain a certificate of jury service from the court and provide a copy to WXY.

Paid Family Leave – State and WXY

Employees who meet eligibility requirements may be entitled to a paid leave of absence under the New York Paid Family Leave (“NYPFL”) law when they need time off to care for a family member, bond with a child, for a close relative with a serious health condition, or assist with a family situation when a family member is deployed abroad or active military services. Benefits under this policy are funded through payroll deductions. This policy provides necessary information concerning PFL (Paid Family Leave) entitlements and obligations.

Note: When an employee works and resides in a state or city that offers less than the NY PFL benefit, WXY will allow the employee to enjoy the greater of the benefits (i.e., NY vs. DC) For questions regarding PFL, employees should contact the HR representative.

NY ELIGIBILITY

A regular schedule of 20 or more hours per week; and (2) have been employed for at least 26 consecutive weeks before the date PFL begins, OR (b) (1) a regular schedule of fewer than 20 hours per week; and (2) worked at least 175 days before the date PFL leave begins.

An Employee has the option to file a waiver of PFL and therefore not be subject to deductions when the regular employment schedule is: (i) 20 or more hours per week but the Employee will not work 26 consecutive weeks; or (ii) less than 20 hours per week and the Employee will not work 175 days in a 52 consecutive week period.

PFL provides eligible Employees 12 weeks of paid leave within any 52 consecutive week period.

The 52 consecutive week period is determined retroactively concerning each day for which PFL benefits are currently being claimed.

DC ELIGIBILITY

An employee must have worked for an employer in DC before they experienced a covered event and work in DC 50% of the time. PFL provides eligible employees: - 2 weeks for prenatal leave - 8 weeks to bond with a new child - 6 weeks to help care for a family member with a serious illness - 2 weeks to care for an employee’s own serious health condition.

No matter how many different types of leave a staff member may take, they can only receive a total of 8 weeks of Paid Family Leave benefits within any 52 consecutive week period. The 52 consecutive week period begins on the first date of the approved leave.

Parental Leave can be taken intermittently in increments of at least one full day or on a reduced leave schedule or can be taken consecutively.

An Employee may only take intermittent or reduced leave to care for a family member with a serious health condition where it is shown to be medically necessary. Employees must provide notice as soon as is practicable before each day or intermittent leave.

PAY DURING LEAVE FOR NY

PFL paid benefits are financed solely through Employee contributions via payroll deductions. The weekly benefits are 67% of the Employee’s average weekly wage capped at the same percentage of the New York State Average Weekly Wage.

An Employee who is eligible for both NY statutory short-term disability benefits and NYPFL during the same period of 52 consecutive calendar weeks may not receive more than 26 total weeks of disability and NYPFL benefits during that time. Statutory short-term disability benefits and NYPFL benefits cannot be used concurrently.

PAY DURING LEAVE FOR DC

PFL benefits are financed solely through the employer. The benefits are calculated based on the average for the last 4 quarters of the employees’ reported payroll.

PROTECTION OF GROUP HEALTH INSURANCE BENEFITS

During NYPFL leave, Employees are entitled to continue group health plan coverage under the same conditions as if they had continued to work. Unless WXY notifies Employees of other arrangements, whenever Employees are receiving pay from WXY during NYPFL, WXY will deduct the Employee portion of the group health plan premium from the Employee’s paycheck in the same manner as if the Employee was actively working.

WXY’s obligation to maintain health care coverage ceases if an Employee’s premium payment is more than 30 days late. If an employee’s payment is more than 15 days late, WXY will send a letter notifying the Employee that coverage will be dropped on a specified date unless the payment is received before that date.

If an Employee’s premium payment is more than 30 days late, WXY may retroactively cease coverage to the date the unpaid premium payment was due. COORDINATION WITH OTHER POLICIES

WXY will run PFL concurrently with all state and federal leave programs, if applicable, or other WXY Leave Policies whenever permissible under the law.

NO RETALIATION

All Employees of WXY are protected from retaliatory action or from being subjected to any adverse action for exercising or attempting to exercise their rights to use Sick Leave for any of the mentioned purposes. If WXY Employees believe they are subjected to retaliation in connection with such leave, the Employee should report the action immediately to the HR representative. WXY will promptly investigate any claims of retaliatory action and take corrective action where appropriate.

If a staff member has questions regarding this NYPFL policy, please contact the HR representative. WXY is committed to complying with the NYPFL and, whenever necessary, shall interpret and apply this policy in a manner consistent with the NYPFL.

WXY Paid Parental Leave

WXY will provide up to 12 weeks of salary continuation (or “top up” in Canada) during parental leave to employees following the birth of an employee’s child or the placement of a child with an employee in connection with adoption or foster care. The purpose of paid parental leave is to enable the employee to care for and bond with a newborn or a newly adopted or newly placed child. This policy will run concurrently with any PFL policy and will be in effect for births, adoptions or placements of foster children occurring on or after January 1st, 2023.

ELIGIBILITY

Eligible employees must meet the following criteria: - Have been employed with the company for at least 12 months (the 12 months do not need to be consecutive). - Have worked at least 1,250 hours during the 12 consecutive months immediately preceding the date the leave would begin. - Be a full- or part-time, regular employee (temporary employees and interns are not eligible for this benefit).

In addition, employees must meet one of the following criteria: - Have given birth to a child. - Be a spouse or committed partner of a person who has given birth to a child. - Have adopted a child or been placed with a foster child (in either case, the child must be age 17 or younger). The adoption of a new spouse’s child is excluded from this policy.

AMOUNT, TIME FRAME AND DURATION OF PAID PARENTAL LEAVE

Eligible employees will receive a maximum of 12 weeks of paid parental leave per birth, adoption, or placement of a child/children. The fact that a multiple birth, adoption, or placement occurs (e.g., the birth of twins or adoption of siblings) does not increase the 12-week total amount of paid parental leave granted for that event. In addition, in no case will an employee receive more than 12 weeks of paid parental leave in a rolling 12-month period, regardless of whether more than one birth, adoption or foster care placement event occurs within that 12-month time frame.

Each week of paid parental leave is compensated at 100 percent of the employee’s regular, straight-time weekly pay. Paid parental leave will be paid on a biweekly basis on regularly scheduled pay dates. No employee is eligible to receive more than 100 percent of their regular weekly pay. Approved paid parental leave may be taken at any time during the 12-month period immediately following the birth, adoption, or placement of a child with the employee. Paid parental leave may not be used or extended beyond this 12-month time frame.

In the event of a female employee who herself has given birth; the 12 weeks of paid parental leave will commence at the conclusion of any short-term disability leave/benefit provided to the employee for the employee’s own medical recovery following childbirth.

Upon termination of the individual’s employment at the company, they will not be paid for any unused paid parental leave for which they are eligible.

COORDINATION WITH OTHER POLICIES

Paid parental leave taken under this policy will run concurrently with leave under the FMLA; thus, any leave taken under this policy that falls under the definition of circumstances qualifying for leave due to the birth or placement of a child due to adoption or foster care, the leave will be counted toward the 12 weeks of available FMLA leave per a 12-month period. All other requirements and provisions under the FMLA will apply. In no case will the total amount of leave—whether paid or unpaid—granted to the employee under the FMLA exceed 12 weeks during the 12-month FMLA period. Please refer to the Family and Medical Leave Policy for further guidance on the FMLA.

After the paid parental leave (and any short-term disability leave for employees giving birth) is exhausted, the balance of FMLA leave (if applicable) will be compensated through employees’ accrued sick, vacation, and personal time. Upon exhaustion of accrued sick, vacation, and personal time, any remaining leave will be unpaid leave. Please refer to the Family and Medical Leave Policy for further guidance on the FMLA.

The company will maintain all benefits for employees during the paid parental leave period just as if they were taking any other company paid leave such as paid vacation leave or paid sick leave.

If a company holiday occurs while the employee is on paid parental leave, such day will be charged to holiday pay; however, such holiday pay will not extend the total paid parental leave entitlement.

An employee who takes paid parental leave that does not qualify for FMLA leave will be afforded the same level of job protection for the period that the employee is on paid parental leave as if the employee was on FMLA-qualifying leave.

RETURNING TO WORK

WXY will allow accommodation when a parent returns to work, in the form of flexibility in schedule or part-time hours. Please speak with HR and a Principal to make arrangements.

ONTARIO MATERNITY AND PARENTAL LEAVE

Employees who reside in Ontario, Canada may be entitled to a paid maternity and parental leave under the Employment Insurance Act and the Canada Labour Code. To be eligible, employees must have worked at least 600 hours in the previous year and their weekly earnings must have decreased by more than 40% for at least 1 week.

Maternity leave: Pregnant employees or those who have recently given birth are eligible for up to 15 weeks of maternity leave. This leave can begin as early as 12 weeks before the expected due date and must end no later than 17 weeks after the birth. During this period, the employee is entitled to receive benefits equal to 55% of their average weekly earnings, up to a maximum amount of $650 a week. Eligible employees can apply for both maternity and parental leave at the same time.

Parental leave: new parents, biological or adoptive, can select either standard or extended parental leave. Parents must choose the same option and can take leave at the same time or one after another. Once selected, it cannot be changed. - Standard parental leave is up to 40 weeks which can be shared between parents, but one parent cannot receive more than 35 weeks of standard benefits. During this period, the employee is entitled to receive benefits equal to 55% of their average weekly earnings, up to a maximum amount of $650 a week. - Extended parental leave is up to 69 weeks which can be shared between parents, but one parent cannot receive more than 61 weeks of extended benefits. During this period, the employee is entitled to receive benefits equal to 33% of their average weekly earnings, up to a maximum amount of $390 a week. Note: The number of weeks of maternity or parental benefits does not change, even if there are multiple births (twins, triplets, etc.) or if a staff member adopts more than 1 child at the same time.

REQUESTS FOR PAID PARENTAL LEAVE

The employee will provide their Advisor Mentor with notice of the request for leave at least 30 days prior to the proposed date of the leave (or if the leave was not foreseeable, as soon as possible). The employee must complete the necessary forms and provide all documentation to substantiate the request.

As is the case with all company policies, the organization has the exclusive right to interpret this policy.

FMLA

As an Employee of WXY, a staff member may be eligible to take unpaid family and medical leave under the federal law, the Family and Medical Leave Act (FMLA). This policy introduces the rights and provisions of the federal FMLA.

ELIGIBILITY

Eligible employees must meet the following criteria: - Have been employed by WXY for at least 12 months. - Have worked at least 1,250 hours during the 12 months. - Work in an office where 50 or more employees are employed within 75 miles of that office.

Amount, Time Frame and Duration of Leave:

• Eligible Employees may take up to a total of 12 weeks of FMLA leave within a rolling 12-month period, measured backward from the date an Employee uses any FMLA leave, for any combination of the following reasons:

  • The birth of an employee’s newborn child or the placement of a child with the Employee for adoption or foster care.
  • To care for the Employee’s spouse, child, or parent with a severe health condition
  • The Employee has a critical health condition that makes the Employee unable to perform the functions of their job.
  • A qualifying exigency that arises because the Employee’s spouse, child or parent is a covered military member on covered active duty (or has been notified of an impending call or order to covered active duty)
  • To care for a covered service member with a serious injury or illness
  • Where leave is taken to care for a covered servicemember who is undergoing medical treatment, recuperation, or therapy, is in outpatient status or is otherwise on the temporary disability retired list for a severe injury or illness, a spouse, child, parent or next of kin may take up to 26 weeks of unpaid FMLA leave during a single 12-month period.

• Spouses employed by the WXY are jointly entitled to a combined total of 12 weeks of leave for the birth of a newborn child, for the placement of a child for adoption or foster care and to care for a parent who has a severe health condition. The federal FMLA does not cover care for parents-in-law.

• Spouses employed by the WXY are jointly entitled to a combined total of 26 weeks of leave to care for a covered service member with a serious injury or illness.

Military Leave

Employees who work an average of 20 or more hours per week and who are also the spouse to a member of the armed forces of the United States, the national guard or military reserve and who are deployed during a period of military conflict to a combat theater or combat zone are entitled up to 10 days of unpaid leave.

An employee is entitled to this leave when their military spouse is on leave from military service.

This leave is available to any spouse who is an active member of the armed forces of the United States, the National Guard, or military reserves immediately. Military spouses also have leave available to them by using FMLA and NYPFL.

Military Spouse Leave

Employees who work an average of 20 or more hours per week and who are also the spouse to a member of the armed forces of the United States, the national guard or military reserve and who are deployed during a period of military conflict to a combat theater or combat zone are entitled up to 10 days of unpaid leave.

An employee is entitled to this leave when their military spouse is on leave from military service.

This leave is available to any spouse who is an active member of the armed forces of the United States, the National Guard, or military reserves immediately. Military spouses also have leave available to them by using FMLA and NYPFL.

Blood Donor Leave

WXY Employees who work an average of 20 or more hours per week will be granted an unpaid leave of absence if they seek to donate blood.

Eligible Employees will be granted up to three hours of leave per calendar year to donate blood off-site. Except in emergencies, Employees who seek leave under this policy must give reasonable notice to their Advisor Mentors of at least three working days. WXY may require Employees to show proof of their blood donation in the form of notice of blood donation or a good-faith effort at blood donation from the blood bank or some other proof sufficient to the purpose. An Employee may elect to us any applicable paid leave for which they are eligible under WXY policy for off-premises blood donation, and such leave will run concurrently with the leave afforded under this policy.

Unused leave under this policy does not carry over into the next calendar year.

Bone Marrow Donor Leave

WXY Employees who work an average of 20 or more hours per week will be granted an unpaid leave of absence if they seek to donate bone marrow. Employees may take leave to donate bone marrow as well as to recover from the procedure and for resulting medical care. The Employee must provide medical documentation detailing the purpose and length of the requested bone marrow donation leave. The Employee’s physician will determine the amount of leave required by the Employee. The leave should not exceed 24 work hours unless additional leave is agreed to by the WXY. Except in emergencies, Employees who seek leave under this policy must give reasonable notice to their Advisor Mentor of at least three working days. An Employee may elect to us any applicable paid leave for which they are eligible under WXY policy for bone marrow donation, and such leave will run concurrently with the leave afforded under this policy. Unused leave under this policy does not carry over into the next calendar year.

Crime Victim and Witness Leave

All Employees who are victims of a crime or who are subpoenaed as a witness in a criminal proceeding are eligible for this unpaid leave.

VICTIMS INCLUDE

• The aggrieved party
• The aggrieved party’s next of the kin if the aggrieved party died because of the crime.
• The victim’s representative (e.g., an attorney, guardian, or parent of a minor)
• Good Samaritans
• Any person is applying for or seeking to enforce an order of protection under the criminal procedure law or family court act.

ELIGIBLE EMPLOYEES ARE ELIGIBLE FOR LEAVE TO

• Appear as witnesses.
• Consult with the district attorney.
• Exercise other rights under the law
• Employees who are crime victims or subpoenaed as a witness at a criminal proceeding must provide at least one day notice to the Advisor Mentor before taking leave. The amount of unpaid leave granted to the crime victims or subpoenaed as a witness at a criminal proceeding will depend on the approval of the Principals. WXY may require proof that the Employee attended or testified at a criminal proceeding.

Volunteer Emergency Responder Leave

Any WXY Employee who volunteers as a firefighter or who is enrolled member of the volunteer ambulance service is eligible for unpaid time leave when called to perform their duties in a declared state of emergency.

The Employee must provide the Operations Manager with written notice from the head of the Employee’s volunteer fire department or a member of the volunteer ambulance service.

The number of unpaid leave granted to volunteer emergency responders will depend on the Operations Manager.

An Employee may elect to us any applicable paid leave for which they are eligible under WXY policy to their time away from work serving as an emergency responder.

Intermittent Leave or a Reduced Work Schedule

Employees may take FMLA leave in one consecutive block of time, may use the leave intermittently (take a day periodically when needed over the year) or, under certain circumstances, may use the leave to reduce the workweek or workday, resulting in a reduced hour schedule. In all cases, the leave may not exceed a total of 12 workweeks (or 26 workweeks to care for an injured or ill service member) in a 12-month period.

SCHEDULING FMLA

Generally, an application for leave must be completed for all leave taken under this policy. The need to take non-emergency leave should usually be requested from the Advisor Mentor at least 30 days in advance. In cases of emergency, verbal notice should be given as soon as possible (or by a staff member’s representative if they are incapacitated), and the application form should be completed as soon as practical.

Staff members must provide sufficient information regarding the reason for absence for WXY to know that protection may exist under this policy. Within five business days after the employee has provided this notice, the HR representative will complete and provide the employee with a Notice of Eligibility and Rights and request a medical certification or other supporting documentation as necessary.

MEDICAL CERTIFICATION PROCESS

In addition to an application for leave, Employees will be required to complete a medical certification form when leave is for a family member’s or their serious health condition. The certification form needs to be signed by the health care provider. The short-term disability certification may be sufficient where the information required is duplicative. These forms are available from the HR representative. Second or third certifications from health care providers and periodic recertification may be required under certain circumstances.

WXY may also require periodic reports during federal FMLA leave regarding employment status and intent to return to work.

MILITARY FAMILY LEAVE CERTIFICATIONS

In addition to an application for leave, the Employee will be required to complete a Certification of Qualifying Exigency for Military Family Leave form. A copy of the military member’s active-duty orders or other military documentation may also be required to substantiate their need for FMLA leave.

If a staff member requests leave to care for a covered service member with a serious injury or illness, they will be required to complete a medical certification form, which must be signed by the service member’s health care provider. The certification form will request additional information, such as information regarding the relationship between the staff member and the covered service member, to substantiate their need for FMLA leave.

COORDINATION WITH OTHER POLICIES

WXY will run PFL, and Short-Term Disability concurrently with FMLA or Organization Leave Policies whenever permissible under the law. When an Employee is absent due to a work-related illness or injury that meets the definition of a severe health condition, the absence will be counted against the Employee’s entitlement under this policy. In other words, the Employee is using FMLA leave concurrently with the workers’ compensation absence. An Employee is not required to substitute paid time off for an absence covered under workers’ compensation.

RETURNING TO WORK

If the reason for FMLA leave is for Employee’s serious health condition, the Employee will be required to present a fitness-for-duty certification immediately upon return to work.

If the Employee wishes to return to work before the scheduled expiration of FMLA leave, the Employee must notify WXY of the changing circumstances as soon as possible but no later than two working days before their desired return date. If a staff member exhausts all leave under this policy and are still unable to return to work, their situation will be reviewed to determine what rights and protections might exist under other Organization policies.

RIGHTS UPON RETURN FROM LEAVE

Upon return from Family or Medical Leave, the Employee will be returned to the position they held immediately before the leave if the position is vacant. Certain exceptions exist for Key Employees as defined by law. If the position is not vacant, Employee will be placed in an equivalent employment position with equivalent pay, benefits, and other terms and conditions of employment. The law provides that an Employee has no greater rights upon a return from leave than the Employee would have if the Employee had continued to work. Therefore, a staff member may be affected by a layoff, termination, or other job change, if the action would have occurred, had they remained actively at work.

For additional information:

1-866-4US-WAGE (1-866-487-9243) TTY: 1-877-889-5627

WWW.WAGEHOUR.DOL.GOV

Covered employers must inform Employees requesting leave whether they are eligible under FMLA. If they are, the notice must specify any additional information required as well as the Employees’ rights and responsibilities. If they are not eligible, the employer must provide a reason for the ineligibility.

Covered employers must inform Employees if leave is designated as FMLAprotected and the amount of leave counted against the Employee’s leave entitlement. If the employer determines that the leave is not FMLA-protected, the employer must notify the Employee.

Reasonable Accommodations

Qualified Employees and applicants with disabilities are protected from employment discrimination based on disability by Section 501 of the Rehabilitation Act of 1973, as amended.

WXY will provide reasonable accommodation for known physical or mental limitations of qualified Employees and applicants with disabilities, Employees who are pregnant, have given birth, or have a medical condition related to pregnancy or childbirth, and religious practices, for their needs as a victim of domestic violence, stalking, or sexual offenses, unless to do so, would cause undue hardship. That is, it would require significant difficulty or expense.

Employees are encouraged to bring any request for accommodation to the HR representative from Arabella Advisors Partners.

Even though the Employee provides input concerning the accommodation process, Arabella Advisors Partners with WXY will determine what constitutes reasonable accommodation upon request and review. WXY reserves the right to request additional independent medical examinations, evaluations, or other appropriate information as needed.

Cooperative Dialogue about Accommodation Needs

WXY will engage in a cooperative dialogue with an Employee who requests reasonable accommodation.

The cooperative dialogue requires WXY to engage in a good-faith conversation with the Employee (or applicant for employment) concerning the individual’s accommodation needs, potential accommodations (including alternatives to the accommodation proposed by the Employee), and any difficulties that the proposed accommodation could pose for WXY.

This cooperative dialogue continues until accommodation is granted or denied. After the cooperative dialogue, WXY will provide the Employee with a written final determination of the accommodation that was either granted or denied. Without providing a written final determination, WXY’s actions could be deemed as a failure to engage in the required cooperative dialogue.

Accommodation of Current and Prospective Employees (Religion)

WXY respects the religious beliefs and practices of all Employees and will make, on request, accommodation for such observances when reasonable accommodation is available that does not create an undue hardship on WXY operations.

An Employee whose religious beliefs or practices conflict with their job, work schedule, or with WXY policy or practice on dress and appearance, or with other aspects of employment, and who seeks a religious accommodation must submit a written request for the accommodation to their immediate Advisor Mentor. The written request will include the type of religious conflict that exists and the Employee’s suggested accommodation.

The HR representative (Arabella Advisors Partners) and the Advisor Mentor will evaluate the request, considering whether a work conflict exists due to a sincerely held religious belief or practice and whether an accommodation is available that is reasonable and that would not create an undue hardship on WXY operation. Accommodation may be a job change, using paid leave or leave without pay, allowing an exception to the dress and appearance code that does not affect the safety or uniform requirements, or other employment aspects. Depending on the type of conflict and suggested accommodation, the Advisor Mentor may consult with the Partners.

The Advisor Mentor and Employee will meet to discuss the request and decision on accommodation. If the Employee accepts the proposed religious accommodation, the immediate Advisor Mentor will implement the decision. If the Employee rejects the proposed accommodation, they may appeal following the WXY’s general grievance procedure.

Accommodation of Current and Prospective Employees (Disability)

WXY is committed to equal opportunity in employment for persons with disabilities and complies with the Americans with Disabilities Act of 1990 (ADA), as amended, and any other applicable state and federal laws.

Accordingly, WXY will not discriminate against qualified individuals with disabilities regarding the application, hiring, advancement, discharge, compensation, training, or other terms, conditions, and employment privileges.

WXY’s policy is to provide reasonable accommodations in employment to qualified individuals with disabilities so that they can perform the essential functions of the job unless the accommodation would impose an undue hardship on WXY operations or would change the essential functions of the position.

With any questions or requests for accommodation, the Employee should contact the HR Representative (Arabella Advisors Partners) and Advisor Mentor. After a request for an accommodation is received, the Advisor Mentor will engage in the interactive process with the Employee, and any other relevant and necessary parties until a determination can be reached upon whether a reasonable accommodation can be made for the Employee.

Employees are required to cooperate fully with WXY in the procurement of medical records so that WXY can fully comply with applicable law. Employees are required to supply WXY with any documents that WXY lawfully requests as part of the interactive process and to execute any medical authorizations or release forms provided by WXY or a medical care provider. All medical information will be maintained consistent with applicable privacy policies.

All Employees are required to comply with WXY safety standards. Deviation from WXY safety standards places an undue burden upon WXY. WXY shall not undertake to accommodate any individual if that accommodation causes a direct threat to the safety of that individual or others in the workplace, including colleagues and students. Individuals who are currently using illegal drugs are excluded from coverage under this policy.

WXY will not tolerate any form of retaliation against an applicant or Employee based on a disability, a request for a disability accommodation, or participation in a complaint or investigation of disability discrimination.

Accommodation of Employees (Pregnancy and childbirth)

WXY will not discriminate against qualified individuals with pregnancy regarding the application, hiring, advancement, discharge, compensation, training, or other terms, conditions, and privileges of employment. If someone is temporarily unable to perform their job due to a medical condition related to pregnancy or childbirth, WXY will treat her in the same way as it treats any other temporarily disabled Employee. For example, WXY shall provide light duty, alternative assignments, disability leave, or unpaid leave to pregnant Employees if it does so for other temporarily disabled Employees.

Additionally, impairments resulting from pregnancy (for example, gestational diabetes or preeclampsia, a condition characterized by pregnancy-induced hypertension and protein in the urine) may be disabilities under the Americans with Disabilities Act (ADA). The Employee, with any questions or requests for accommodation, should contact the HR representative (Arabella Advisors Partners) and the Advisor Mentor. After a request for an accommodation is received, the Advisor Mentor will engage in the interactive process with the Employee, and any other relevant and necessary parties until a determination can be reached upon whether a reasonable accommodation can be made for the Employee. Employees are required to cooperate fully with WXY in the procurement of medical records so that WXY can fully comply with applicable law. Employees are required to supply WXY with any documents that WXY lawfully requests as part of the interactive process and to execute any medical authorizations or release forms provided by WXY or a medical care provider. All medical information will be maintained consistent with applicable privacy policies.

Accommodation of Employees (Victims of domestic violence, sex offenses, and stalking)

WXY provides reasonable accommodation to Employees who are victims of domestic violence, sex offenses, and stalking unless doing so would cause undue hardship.

Reasonable accommodations may include modifications or adjustments that allow an Employee who is a victim of domestic violence, sex offenses, or stalking to satisfy the job’s essential requisites.

Depending on the circumstances, the accommodation also may include *time off from work for reasons such as: - seeking medical attention for injuries caused by domestic violence, including for a child who is a victim of domestic violence (provided that the Employee is not the perpetrator of the domestic violence against the child). - obtaining services from a domestic violence shelter, program, or rape crisis center because of domestic violence. - receiving psychological counseling related to an incident or incidents of domestic violence, including for a child who is a victim of domestic violence (provided that the Employee is not the perpetrator of the domestic violence against the child). - participating in safety planning and taking other actions to increase safety from future incidents of domestic violence, including temporary or permanent relocation; or - obtaining legal services, assisting in the prosecution of the offense, or appearing in court concerning the incident or incidents of domestic violence.

*Such time off may run concurrently with time off taken for the same purpose under the other applicable laws.

Upon learning that an Employee requires accommodation due to domestic violence, sex offense, or stalking, WXY shall engage in a cooperative dialogue with the Employee. The purpose of the cooperative dialogue is to understand the Employee’s needs and based on the circumstances, identify any reasonable accommodations. Upon reaching a final determination after the cooperative dialogue, WXY will provide the Employee with a written final determination identifying any accommodation granted or denied.

Employees may be required to provide confirming documentation to WXY within a reasonable time. Such may include: - documentation from an Employee, agent, or volunteer of a victim services organization, an attorney, a member of the clergy, or a medical or another professional service provider from whom the Employee (or the Employee’s family or household member) has sought assistance in addressing domestic violence, sex offenses or stalking and the effects of the violence or stalking (e.g., documentation from a medical professional, domestic violence advocate, health care provider, or counselor that the Employee or their child was undergoing counseling or treatment for physical or mental injuries or abuse resulting in victimization from an act of domestic violence); - a police report (e.g., a police report indicating that the Employee or their child was a victim of domestic violence). - a court record (e.g., a court order protecting or separating the Employee or their child from the perpetrator of an act of domestic violence); or - other corroborating evidence (e.g., other evidence from the court or prosecuting attorney that the Employee appeared in court).

All information provided to WXY according to this process shall be kept in the strictest confidence, except to the extent that the Employee requests or consents to disclosure in writing, or except as otherwise required by applicable federal, state, or local law.

The HR representative is responsible for implementing this policy, including requests for and resolution of reasonable accommodations, safety, direct threat determinations, and undue hardship issues. All requests for reasonable accommodation should be presented to the HR department and manager. For comprehensive information on the ADA and full text of the law, please visit https://www.ada.gov/.

For definitions of the terms used in this policy, please visit https://adata.org/ glossary-terms.

Lactation Accommodation Policy

As part of our family-friendly policies and benefits, WXY supports breastfeeding employees by accommodating an employee who needs to express breast milk during the workday. For up to three years after the child’s birth, any Employee who is breastfeeding her child will be provided with reasonable break times as needed to express breast milk for her baby.

• As required by law, WXY has designated the Privacy room near the library to express breastmilk to ensure the right to a safe, private, and supported space. The designated room is a sanitary and clean place, free from intrusion, contains an electrical outlet, a chair, a flat surface on which to place a breast pump or other items, and is near running water.

• A small refrigerator suitable for the storage of breast milk is in the kitchenette and is within reasonable proximity to Employee work areas. Any breast milk stored in the refrigerator must be labeled with the name of the Employee and the date of expressing the breast milk. Please note that any nonconforming products stored in the refrigerator may be disposed of. Employees storing milk in the refrigerator assume all responsibility for the safety of the milk and the risk of harm for any reason, including improper storage, refrigeration, and tampering.

• Employees who wish to make use of this benefit should reserve their breaks and the room in advance by updating the appropriate calendar [Privacy room] within the scheduler to better manage expectations. Employees who work at client sites will be accommodated with a break time as necessary. Employees who work at client sites should request information about lactating spaces from their respective clients. If there are two nursing requests at the same time, WXY will have timely, good faith discussions with each nursing mother to work out the logistics, including providing additional accommodations as needed and available. If a request poses an undue hardship for WXY, WXY will engage in a cooperative dialogue with the Employee. Employees are encouraged to reach out to their HR representative if they have any questions regarding this policy.
• Remote Employees are entitled to take lactation breaks on the same basis as if they were working onsite. Remote Employees have a right to be shielded from view during a pump break. This means that they must be free from observation, including any WXY on camera meeting, when they are pumping. No employee shall be discriminated against for breastfeeding or expressing milk during the work period, and reasonable efforts will be made to assist employees in meeting their infant feeding goals while at work.

Political Activity Policy

WXY encourages Employees to participate in political activities. Participating in these activities must be conducted on the Employee’s own time. WXY will not discriminate against Employees because of political activities that take place while off-duty, outside WXY premises, and without the use of WXY equipment. An exception is provided for political activities that result in a material conflict of interest with WXY business interests. An Employee may request vacation leave to conduct such activities.

The following activities are prohibited from being performed while working or while at WXY premises:

• Demonstrating.
• Counting or recounting votes.
• Circulating petitions.
• Soliciting votes or contributions at any time in any working area of a WXY facility.
• Conducting or participating in opinion polls.
• Fundraising.
• All other activities not considered part of the Employee’s regular duties

Technology, Office Resources, and Acceptable Use Policy

The office internet connection and email should serve the goal of making us more creative, productive, and informed as architects, designers, and planners. To that end, WXY needs to limit certain activities that put our hardware, data, and office at risk and hamper productivity.

WXY may monitor Internet use, including reviewing the list of sites accessed by any individual terminal. A staff member’s internet use is not private. No Employee should have any expectation of privacy regarding Internet usage. WXY reserves the right to inspect an employee’s computer at any time or to use monitoring software to monitor the Internet and computer use.

If a staff member opts to listen to music with headphones, kindly keep the volume low so that they can still hear if someone is calling out to catch their attention. Below is a list of activities that are not acceptable and can result in disciplinary actions.

Downloading and installing software without a Principal’s permission. Customization of computers should be strictly limited to what is necessary for the firm’s work. If a staff member is instructed to download/install software, they must be sure to return all serial numbers and registration materials to the office manager when the installation is complete.

All software licenses and files are the property of WXY (i.e., Adobe Creative Suite, etc.). They cannot be used by staff for personal reasons and must be turned over at the time of termination or voluntary separation from employment. Web Surfing sites that are inappropriate in an office setting (including but not limited to pornography, gambling, gaming, and file sharing). Downloading files from file sharing sites and P2P sites (with exceptions for commonly used project file sharing sites).

• Any illegal activity is forbidden.
• Other activities not spelled out above that violate the spirit of this guideline and general common sense and caution, are forbidden.
• Using Office Email Server and Office Contract Database for the broadcast of the mass email (or spam) is forbidden
• Using Office internet for massive file transfer (upload and download) for personal use;
• Keeping personal email accounts (Gmail, Yahoo, etc.) open on the desktop in the background hampers productivity.

All @wxystudio.com emails are the property of WXY Architecture + Urban Design. Any content exchanged on software applications and/or subscriptions paid for by WXY are the property of the firm. All usernames and passwords must be provided to the Managing Principal for billing and maintenance purposes. WXY reserves the right to wipe all phones and computers to remove all WXY related information from personal devices; Repeated abuse of the office internet for personal use except as permitted by this policy statement is grounds for dismissal.

It is up to everyone that all our internet security requires collective vigilance and smart/safe behavior – here are some key things to keep in mind:

• Frequently change email and desktop log-in passwords (at least monthly)
• Do not open attachments to unfamiliar emails.
• Be suspicious – even familiar seeming emails often exhibit anomalies that flag it as a phishing email – poor grammar, weird font formatting, misspellings, unusual greetings.
• But most importantly - Avoid clicking on hyperlinks (AS IN NEVER CLICK ON THEM unless the sender has been verified)
• Questions are always welcome regarding this policy. When in doubt, please ask! If a staff member would like the office to consider the purchase of new software, they should submit their recommendation and pricing to one of the Principals.
• Common sense and professionalism should ALWAYS govern the use of technology—a lot can go wrong quickly if a staff member does not observe the protocols listed above.

Client Communications Policy

At WXY, good communication is vital to the success of our client engagements. This policy is to establish expectations and provide guidance that will be helpful in managing and coordinating client engagements, facilitating internal communication & collaboration, enhancing engagement knowledge, and improving implementation & service. Timely communication is important in maintaining client relationships along with team communication and collaboration. Our role and position as outsourced accountants, human resource specialists and consultants requires us to communicate with internal team members and external client staff effectively and efficiently. Client engagements require active participation and team ownership. The nature of this work involves communicating activities to the client and internally to WXY team members. Such communication is vital to enhancing all participants’ awareness of the engagement status, provides documented support for work performed, and allows for tracking progress of professional development. Establishing good communication between a staff member and their client is also essential to building a good partnership. The client and other WXY team members should be aware of the status of their work: what they are working on and what is still outstanding. This could be done via Teams or any other form of communication at least once a week.

All communication devices should be checked twice daily at a minimum to account for matters that are urgent.

All client and WXY staff inquiries, whether in person, via e-mail or telephone, will be responded to as soon as practicable. The WXY standard is 1 business day. If a staff member cannot provide resolution to the inquiry, an acknowledgment of receipt is courteous.

It is expected that following up on requested items, in either direction, is done on a timely and consistent basis.

It is best practice to be proactive and not wait until the day a task is due to report that a deadline will be missed. Ensuring that realistic deadlines and expectations are set with the client requires active participation from all WXY members. If any client issues cannot be resolved, or deadlines cannot be met within the defined time frame, a staff member should collaborate with their team and determine a solution immediately, and/or communicate and set a new deadline date with the client. Exercise best judgment in what communication method should be used when handling an issue as options can be: through a status memorandum, an email, Teams, a phone call, or an in-person meeting. As always, when communicating and sending documents, all WXY and client proprietary information must be kept confidential and sent through a secure mail system.

If a staff member feels that the team is not responding to their needs and issues in a timely manner, they should contact or email their Advisor Mentor.

WEEKLY/MONTHLY PROCEDURES

Weekly: Update the Client Team specifically about the work performed and outstanding items via Teams. As part of our work as Advisor Mentors, WXY requires that all time, whether client related or internal, be submitted every Wednesday by end of day for the prior week. This ensures that we can communicate with our clients the work performed and bill in a timely manner. As this is integral to our operations, and health as an organization, failure to meet this expectation may lead to further disciplinary actions in accordance with KPI’s Employee Handbook.

Monthly: The Client Manager will set up monthly Consulting Advisor Mentory Services (CAS) meetings with the client to go over financial reporting and other priorities. The Client Manager will also set up monthly internal WXY staff client meetings, prior to the CAS client meetings, to go over the month-end closing and communicate other important information and issues. This time could serve as an opportunity to discuss any client concerns and/or issues (examples include, but are not limited to, negative client feedback, out-of-scope work, unrealistic deadlines).

OTHER PROCEDURES

When on vacation or out of the office, a staff member should communicate this information to all the people they work with. Also, a staff member set their email to auto reply. The message should indicate that the staff member is out of the office and when their return date is. When at a conference or daylong meeting, a staff member should set their email to auto reply indicating that they will have limited availability and will reply upon their return. - All communication, including email, must be concise, professional, respectful, positive, and objective. - All emails should contain subject matter. - Below are some best practices observed by WXY. - Keep the content of email short, direct, and to the point. - Run spell check. - Review the “To:” field before sending the email to be sure that it includes the right recipients. - Use tone and language appropriate for the subject of the communication and the intended audience. - Utilize the WXY standard email signature to provide contact information. - Include when a response or deliverable is needed by, if known. - Avoid using email as a platform to negotiate. It is more appropriate to be done in person, and then over the phone if that option is not available. - Use HTML or Rich Text Format for routine emails, (ex. try to adhere to the standard font, format of WXY set by I.T.) - Avoid using the “Reply to All” option when the response is directed at one person, or the reverse, forget to “Reply to All” when a group should get the response.

Social Media Policy

WXY understands that social media can be a fun and rewarding way to share with family, friends, and co-workers around the world. However, the use of social media also presents certain risks and carries specific responsibilities. To assist in making responsible decisions about the use of social media, WXY has established these guidelines for the appropriate use of social media.

Express opinions as personal. Never represent yourself as a spokesperson for WXY. If WXY is a subject of the content you are creating, be clear and open about the fact that you are an associate and clarify that your views do not represent those of WXY, fellow associates, members, customers, and suppliers, or people working on behalf of WXY. If you publish a blog or post online related to the work you do or subjects associated with WXY, make it clear that you are not speaking on behalf of WXY. It is best to include a disclaimer such as “The postings on this site are my own and do not necessarily reflect the views of WXY.” Do not disclose any confidential or proprietary information to WXY or to any third party that has disclosed information to the organization.

On all platforms, uphold WXY’s value of respect for the individual and avoid making defamatory statements about the organization’s Employees, clients, or anyone affiliated with WXY. Employees shall not post complaints or criticism using statements, photographs, video, or audio that reasonably could be viewed as malicious, obscene, threatening or intimidating, that disparage WXY, colleagues, allied organizations, members, or any other persons or entities with which WXY interacts, or that might constitute harassment or bullying.

Examples of such conduct include offensive posts or images meant to harm someone’s reputation intentionally, or posts that could contribute to a hostile work environment based on race, sex, disability, religion, or any other status protected by law or WXY’ policy.

Do not (under any circumstances) add the WXY trademarks, logos, other graphic images, etc. to your posts.

Be aware that Internet usage, postings, and/or blogs may be monitored by senior management.

Nothing in this or any other WXY policy limits an employee’s ability to discuss or to act together to address issues of workplace concern.

It is not WXY’s policy to monitor social media, and the name and password of your personal accounts will not be requested. Should you run or post on a WXY social media account, names and passwords may be requested for the purpose of an investigation of Employee misconduct.

Regarding social media accounts operating under the WXY name, logo, or trademark, any Employee must relinquish control of said account upon termination or change of job description. Business social media accounts often contain pertinent and valuable information that is the property of WXY. All account information, communications, and contacts may not be used upon the termination of employment.

External Communications

Lobbying

No Employee should speak or make representation to any city, state, or government agencies on behalf of the firm. WXY has designated a select few Employees as its representatives. When attending community board meetings or any other place where our opinion may sway the convening body’s decision on a particular matter, please refrain from using the WXY name unless you have been given that authority. The federal government, state government, and certain localities have laws requiring registration and reporting by lobbyists. Lobbying activity generally includes attempts to influence the passage or defeat of legislation. An Employee may not engage in any lobbying activities. If you are not sure whether your activities would be considered lobbying activities, please contact the Principals.

Office Communications and Representations

No Employee shall represent clients and/or WXY in any formal government proceedings without express permission from the partners. Furthermore, no staff member shall speak with the press on behalf of clients and/or WXY regarding projects without express permission from the partners. All requests for the firm comment must be immediately directed to the partners.

Code of Conduct

Utilizing etiquette in the workplace can ensure that everyone feels comfortable while being productive. The following information is intended to highlight a few main areas in which etiquette should be considered.

• Reach the office on time. While WXY does provide flexible scheduling, once you commit to a designated time, please try your best to adhere to that.
• Keep your cell phones in silent mode to avoid disturbing others sitting around you. Loud ring tones at the workplace can be disruptive. Avoid long personal calls during office hours.
• Respect each other’s privacy. Do not open mail, email or documents not intended for you.
• Try to keep your work area neat and tidy.
• Avoid the use of profanity while in the office or attending meetings.
• If you use the last of anything, replenish/replace it
• Be respectful to all, no matter what their title.
• Return messages, emails, and letters as soon as possible
• Load dirty dishes into the dishwasher. If the dishwasher is running, wash the dishes by hand and place those dishes into the drying rack.

Smoking

WXY is a non-smoking environment, and as such smoking is not permitted at any time anywhere on premise, including all shared spaces, enclosed rooms or on roof areas; including the use of all tobacco-related products, including but not limited to, smoking, the use of chewing tobacco and the use of e-cigarettes or other vapors. Compliance with this policy is mandatory for all employees and persons visiting WXY, with no exceptions. Staff who violate this policy are subject to disciplinary action. Any disputes involving smoking and any employee with questions should discuss their issues/concerns to HR.

Event Policy

There may be certain times or events where the Employees of WXY will get together for certain organization events where alcohol is provided. It is the intention of WXY that all Employees behave in a professional manner during these events, as all policies in this handbook are still active and maintained during organizational events. Employees are expected to drink moderately, within legal limits, and conduct themselves in a manner that maintains the professional reputation of WXY. Nor may the Employee report to work under the influence of alcohol or be impaired due to alcohol during the workday.

Dress Code

WXY dress code policy is designed to help us all provide a consistent professional appearance to our customers and colleagues. Our appearance reflects on ourselves and the organization. The goal is to be sure that we maintain a positive appearance and not to offend customers, clients, or colleagues. All staff are expected to always look and dress professionally and presentably.

Personal Devices and Personal Calls

Staff should only engage in personal phone calls and communications during nonworking time, including breaks.

Care of Office Space and Equipment

WXY welcomes visitors to our office, it is each employee’s responsibility to assure that their workspace is neat and orderly. Care to prevent spills should be taken when eating or drinking around drawings, documents, and equipment. Items left in public areas may be removed and/or disposed of. Employees should be mindful of the material, photographs, documents, etc., they display in their workspace. Employees may not display anything that violates WXY policies, including policies prohibiting harassment, and the firm reserves the right, at its sole discretion, to require removal of items, subject to applicable law.

All public/shared spaces such as conference rooms, phone booths meeting areas, workshop and kitchen are to be always left neat and tidy. In addition, special care should be taken that the kitchen area is left clean with used dishes loaded into the dishwasher, no food is left out and spills are cleaned up promptly. Employees must remove and dispose of food from the refrigerator every Friday.

Security Precautions

When working before or after hours on weekdays and anytime on weekends and holidays, whether alone or with others, the glass door by the elevator must be kept closed. All staff with UI access can gain entry with door access panel. All visitors must be identified before entering the office. Do not leave wallets in coat pockets and do not leave handbags or other valuables visible and unattended. WXY is not responsible for personal property. All personal property is the employee’s responsibility and is not covered by the firm’s insurance.

No Solicitation

While WXY wishes to be a place to foster cohesiveness and community, WXY is to be respectful of each other’s time; therefore, WXY prohibits the solicitation, distribution, and posting of materials on or at Organization property by any Employee or non-Employee, except as may be permitted by this policy. The sole exceptions to this policy are charitable and community activities supported by WXY management and organization-sponsored programs related to WXY products and services.

Non-Employees may not solicit Employees or distribute literature of any kind on WXY’s premises at any time. Employees may only admit non-Employees to work areas with management approval or as part of an organization-sponsored program. These visits should not disrupt the workflow. The WXY Employee must always accompany the non-Employee. Former Employees are not permitted onto organization property except for official Organization business.

Employees may not solicit other Employees during work times, except in connection with an organization approved or sponsored event. Employees may not distribute literature of any kind during work times or in any work area at any time, except in connection with an organization-sponsored event. The posting of materials or electronic announcements is permitted with approval from the HR representative.

The violation of this policy should be reported to the HR representative.

Conflict of Interest and Outside Employment

Except with the written consent of WXY management, employees shall not during their employment be directly or indirectly engaged, concerned, or interested in any other business competing in any material respect with the business of WXY. In circumstances that pose a conflict of interest between an employee’s duties to WXY and the employee’s personal interests, an employee and their immediate family may not own or hold any significant interest in a supplier, customer, or competitor of WXY, except where such ownership or interest consists of securities in a publicly owned company and that securities are regularly traded on the open market. Employees must notify WXY promptly in writing of any interest they have in any business other than WXY and all circumstances in which there is or may be a conflict of interest between staff members and WXY. Employees must also inform WXY if they are already employed part-time by another party, or should they decide to take an additional job with another party which may pose an actual or potential conflict of interest. WXY must approve such outside employment as a condition of continued employment with the firm. An employee may be required to cease any outside employment which may pose an actual or potential conflict of interest. Approval will be granted unless the activity conflicts with WXY’s interest.

In general, outside work activities are not allowed when they: - Prevent an employee from fully performing work for which they are employed at WXY. - Involve organizations that are doing or seek to do business with WXY including actual or potential vendors or customers, are in violation of provisions of law of WXY policies or rules.

Employees who accept outside work even with WXY’s approval must recognize that WXY does not assume professional liability or responsibility for such work.

Staff are advised that neither they nor their families are to solicit, accept or keep a personal benefit from any client of the firm, or any individual or organization seeking to do business with the firm. In this context, a personal benefit is any type of gift, gratuity, favor, service, loan, fee, compensation or anything of monetary value. A specific exception to this prohibition is made if there is not, and appears to be no, reasonable likelihood of improper influence in the performance of the duties on behalf of the firm, and if the personal benefit falls into one of the following categories:

• normal business courtesies, such as a meal, involving no more than ordinary amenities.
• paid trips or guest accommodation which involve a form of representation of the firm.
• non-cash gifts of nominal value, such as might be received at holiday time.
• gifts received because of kinship, marriage, or social relationships entirely beyond and apart from any business relationship.

Employees must exercise special care in determining whether a personal benefit is permissible considering these exceptions.

Any questions as to whether any conduct poses an actual or potential conflict of interest must be referred promptly to an Advisor Mentor or HR. A violation of this policy will result in immediate and appropriate discipline, up to and including immediate termination.

Conduct Standards and Disciplinary Procedures

WXY expects every employee to adhere to the highest standards of job performance and personal conduct, including individual involvement with the Organization’s personnel and outside business contacts. We seek to build an environment where employees can thrive. When an employee does not perform at a satisfactory level, WXY will directly inform the employee of the gap between expectation and performance.

WXY reserves the right to discipline any full-time or part-time employee or independent contractor for any violation of New York State, New York City or Federal law, rule or regulation, or any violation of the Company’s processes, policies or procedures contained in this Handbook. Additionally, WXY reserves the right to determine the severity of the discipline.

Accordingly, employees should use the information below as a guide, rather than a mandatory procedure.

The following disciplinary procedure may be used for employees who commit minor offenses (as described below): - First infraction: verbal and/or written warning. - Second infraction: suspension from employment, with or without pay. - Third infraction: additional suspension, with or without pay or termination.

The following list is intended to give you notice of our expectations and standards. However, it does not include every type of unacceptable behavior that can or will result in disciplinary action. Be aware that WXY retains the right to determine the nature and extent of any discipline based upon the circumstances of each individual case.

While it is not possible to list all the forms of behavior that are considered unacceptable in the workplace, the following list includes some examples of infractions of rules of conduct that may result in disciplinary action, up to and including termination of employment. This list should not be viewed as allinclusive, and other conduct not included on this list may be subject to discipline, up to and including termination. Employees may be disciplined or terminated for poor job performance, including, but not limited to the following:

• Unsatisfactory quality or quantity of work.
• Lateness to client or team meetings.
• Continuous Lateness without explanation to the office.
• Failing to follow instructions or Company procedures.
• Failing to follow established safety regulations.
• Falsifying an employment application or any other Company records or documents.
• Failing to record working time accurately or recording a co-worker’s time record.
• Insubordination or other refusal to perform.
• Using vulgar, profane, or obscene language, including any communication or action that violates our policy against harassment and other unlawful forms of discrimination.
• Misusing, destroying, or stealing WXY property or another person’s property.
• Violating conflict of interest rules.
• Disclosing or using confidential or proprietary information without authorization.
• Being convicted of a crime that indicates unfitness for a job or presents a threat to the WXY or its employees in any way.
• Working under the influence of alcohol or illegal drugs.
• Fighting or threatening violence in the workplace.
• Negligence or improper conduct leading to damage of employer-owned property.
• Smoking in prohibited areas.
• Sexual or other unlawful harassment or discrimination.
• Possession of dangerous or unauthorized materials, such as explosives or firearms in the workplace.
• Excessive absenteeism, tardiness, or any absences without notice.
• Unauthorized use of telephones, mail system, or other employer-owned equipment
• Violation of personnel policies and IT policies.
• Unsatisfactory performance or conduct.

If an employee commits an offense greater than the above, the employee may be subject to termination.

Harassment

WXY is committed to providing a workplace free of sexual harassment (see Policy Against Sexual Harassment below), as well as harassment based on race, color, creed, religion, national origin, ancestry, age, physical disability, mental disability, medical condition, marital status, sexual orientation, family-care or medicalleave status, or veteran status. WXY strongly disapproves of and will not tolerate harassment of Employees by managers, Advisor Mentors, or coworkers. Similarly, WXY will not tolerate harassment by its Employees or non-Employees with whom WXY has a business or professional relationship.

Harassment includes verbal, physical, and visual conduct that creates an intimidating, offensive or hostile working environment or that interferes with work performance. Such conduct constitutes harassment when (1) submission to the conduct is made either an explicit or implicit condition of employment; (2) submission to or rejection of the conduct is used as the basis for an employment decision; or (3) the harassment interferes with an employee’s work performance or creates an intimidating, hostile or offensive work environment.

Harassing conduct can take many forms and includes, but is not limited to, the following: slurs, jokes, statements, gestures, sexual favors, assault, impeding or blocking another’s movement, or otherwise physically interfering with regular work, pictures, drawings, or cartoons based upon an Employee’s sex, race, color, national origin, religion, age, physical disability, mental disability, medical condition, ancestry, marital status, sexual orientation, family-care or medical-leave status, or veteran status.

Sexually harassing conduct includes all these prohibited actions as well as other unwelcome conduct such as requests for sexual favors, conversation containing sexual comments and unwelcome sexual advances, or any other visual, verbal, or physical contact of a sexual nature (see Policy Against Sexual Harassment below).

Any incident of harassment, including work-related harassment by any WXY team member or client Employees, should be reported promptly to the immediate Advisor Mentor or Principal (or to any other member of management) or to HR (Arabella Advisors Partners), who is responsible for investigating the matter. Managers who receive complaints or who observe harassing conduct should inform HR representative (Arabella Advisors Partners), immediately. WXY emphasizes that an Employee is not required to complain first to their Advisor Mentor or manager, if that Advisor Mentor or manager is the individual who is harassing the Employee. Every reported complaint of harassment will be investigated thoroughly, promptly, and in a confidential manner. Also, WXY will not tolerate retaliation against any Employee for cooperating in an investigation or for making a complaint to HR or any other manager. In the case of WXY Employees, if harassment is established, WXY will discipline the offender. Disciplinary action for a violation of this policy can range from verbal or written warnings up to and including immediate termination depending upon the circumstances. Regarding acts of harassment by customers or vendors, corrective action will be taken after consultation with the appropriate customer/vendor personnel.

Sexual Harassment

Sexual harassment is a form of sex discrimination and is unlawful under federal, state, and (where applicable) local law. Sexual harassment includes harassment based on sex, sexual orientation, self-identified or perceived sex, gender expression, gender identity, and the status of being transgender. Sexual harassment includes unwelcome conduct that is either of a sexual nature or which is directed at an individual because of that individual’s sex when:

• Such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile, or offensive work environment, even if the reporting individual is not the intended target of the sexual harassment.
• Such conduct is made either explicitly or implicitly a term or condition of employment; or
• Submission to or rejection of such conduct is used as the basis for employment decisions affecting an individual’s employment.
• A sexually harassing hostile work environment includes, but is not limited to, words, signs, jokes, pranks, intimidation, or physical violence that are of a sexual nature or which are directed at an individual because of that individual’s sex. Sexual harassment also consists of any unwanted verbal or physical advances, sexually explicit derogatory statements, or sexually discriminatory remarks made by someone which are offensive or objectionable to the recipient, which cause the recipient discomfort or humiliation, which interfere with the recipient’s job performance.
• Sexual harassment also occurs when a person in authority tries to trade job benefits for sexual favors. This can include hiring, promotion, continued employment, or any other terms, conditions, or privileges of employment. It is also called “quid pro quo” harassment.

Any Employee who feels harassed should report so that any violation of this policy can be corrected promptly. Any harassing conduct, even a single incident, can be addressed under this policy.

EXAMPLES OF SEXUAL HARASSMENT:

The following describes some of the types of acts that may be unlawful sexual harassment and that are strictly prohibited.

Physical acts of a sexual nature, such as:

• Touching, pinching, patting, kissing, hugging, grabbing, brushing against another Employee’s body, or poking another Employee’s body.
• Rape, sexual battery, molestation, or attempts to commit these assaults.
• Unwanted sexual advances or propositions, such as:
  • Requests for sexual favors accompanied by implied or overt threats concerning the target’s job performance evaluation, a promotion, or other job benefits or detriments.
  • Subtle or overt pressure for unwelcome sexual activities
  • Sexually oriented gestures, noises, remarks or jokes, or comments about a person’s sexuality or sexual experience, which create a hostile work environment.
  • Sex stereotyping occurs when conduct or personality traits are considered inappropriate simply because they may not conform to other people’s ideas or perceptions about how individuals of a particular sex should act or look.

• Sexual or discriminatory displays or publications anywhere in the workplace, such as:

  • Displaying pictures, posters, calendars, graffiti, objects, promotional material, reading materials, or other materials that are sexually demeaning or pornographic. It includes such sexual displays on workplace computers or cell phones and sharing such displays while in the workplace.

• Hostile actions were taken against an individual because of that individual’s sex, sexual orientation, gender identity, and the status of being transgender, such as:

  • Interfering with, destroying, or damaging a person’s workstation, tools or equipment, or otherwise interfering with the individual’s ability to perform the job.
  • Sabotaging an individual’s work
  • Bullying, yelling, name-calling

WHO CAN BE A TARGET OF SEXUAL HARASSMENT?

Sexual harassment can occur between any individual, regardless of their sex or gender. New York Law protects Employees, paid or unpaid interns, and non- Employees, including independent contractors, and those employed by companies contracting to provide services in the workplace. Harassers can be a superior, a subordinate, a coworker, or anyone in the workplace, including an independent contractor, contract worker, vendor, client, customer, or visitor.

WHERE CAN SEXUAL HARASSMENT OCCUR?

Unlawful sexual harassment is not limited to the physical workplace itself. It can occur while Employees are traveling for business or at employer sponsored events or parties. Calls, texts, emails, and social media usage by Employees can constitute unlawful workplace harassment, even if it occurs away from the workplace premises, on personal devices, or during non-work hours.

REPORTING SEXUAL HARASSMENT

Preventing sexual harassment is everyone’s responsibility. WXY cannot prevent or remedy sexual harassment unless it knows about it. Any Employee paid or unpaid intern, or non-employee who has been subjected to behavior that may constitute sexual harassment is encouraged to report such behavior to an Advisor Mentor, manager, or HR (Arabella Advisors Partners). Anyone who witnesses or becomes aware of potential instances of sexual harassment should report such behavior to an Advisor Mentor, manager, or HR representative (Arabella Advisors Partners).

There are five standard methods of bystander intervention that can be used when anyone witnesses harassment or discrimination and wants to help.

• A bystander can interrupt the harassment by engaging with the individual being harassed and distracting them from the harassing behavior;
• A bystander who feels unsafe interrupting on their own can ask a third party to help intervene in the harassment;
• A bystander can record or take notes on the harassment incident to benefit a future investigation;
• A bystander might check in with the person who has been harassed after the incident, see how they are feeling and let them know the behavior was not ok; and
• If a bystander feels safe, they can confront the harassers and name the behavior as inappropriate. When confronting harassment, physically assaulting an individual is never an appropriate response.

Though not exhaustive, and dependent on the circumstances, the guidelines above can serve as a brief guide of how to react when witnessing harassment in the workplace.

Reports of sexual harassment may be made verbally or in writing. A form for submission of a written complaint can be obtained from Human Resources, and all Employees are encouraged to use this complaint form. Employees who are reporting sexual harassment on behalf of other Employees should use the complaint form and note that it is on another Employee’s behalf.

Employees, paid or unpaid interns, or non-Employees who believe they have been a target of sexual harassment may also seek assistance in other available forums, as explained below in the section on Legal Protections.

COMPLAINT AND INVESTIGATION OF SEXUAL HARASSMENT

An investigation of any complaint, information, or knowledge of suspected sexual harassment will be prompt and thorough, commenced immediately, and completed as soon as possible. Please refer to Appendix ii. for a model complaint form. The investigation will be kept confidential to the extent possible. All persons involved, including complainants, witnesses, and alleged harassers will be accorded due process, as outlined below, to protect their rights to a fair and impartial investigation.

Any Employee may be required to cooperate as needed in an investigation of suspected sexual harassment. WXY will not tolerate retaliation against Employees who file complaints, support another’s complaint or participate in an investigation regarding a violation of this policy.

While the process may vary between incidents, investigations should be done in accordance with the following steps:

• Upon receipt of the complaint, Human Resources will conduct an immediate review of the allegations and take any interim actions (e.g., instructing the respondent to refrain from communications with the complainant), as appropriate. If the complaint is verbal, encourage the individual to complete the “Complaint Form” in writing. If they refuse, prepare a Complaint Form based on the verbal reporting.
• If documents, emails, or phone records are relevant to the investigation, take steps to obtain and preserve them.
• Request and review all relevant documents, including all electronic communications.
• Interview all parties involved, including any relevant witnesses;
• Create a written documentation of the investigation (such as a letter, memo, or email), which contains the following:
  • A list of all documents reviewed, along with a detailed summary of relevant documents;
  • A list of names of those interviewed, along with a detailed summary of their statements;
  • A timeline of events.
  • A summary of prior relevant incidents reported or unreported; and
  • The basis for the decision and final resolution of the complaint, together with any corrective action(s)
• Keep the written documentation and associated documents in a secure and confidential location;
• Promptly notify the individual who reported and the individual(s) about whom the complaint was made of the final determination and implement any corrective actions identified in the written document;
• Inform the individual who reported the right to file a complaint or charge externally as outlined in the next section.

RETALIATION PROHIBITION

No person covered by this policy shall be subject to adverse action because the employee reports an incident of sexual harassment, provides information, or otherwise assists in any investigation of a sexual harassment complaint. WXY will not tolerate such retaliation against anyone who, in good faith, reports or provides information about suspected sexual harassment.

Any employee of WXY who retaliates against anyone involved in a sexual harassment investigation will be subjected to disciplinary action, up to and including termination. All employees paid or unpaid interns, or non-employees working in the workplace who believe they have been subject to such retaliation should inform a Advisor Mentor, manager, or HR (Arabella Advisors Partners). All employees paid or unpaid interns, or non-employees who believe they have been a target of such retaliation may also seek relief in other available forums, as explained below in the section on Legal Protections.

ADVISOR MENTOR RESPONSIBILITIES

Sexual harassment is offensive, is a violation of our policies, is unlawful, and may subject Arabella Advisors Partners to liability for harm to targets of sexual harassment. Harassers may also be individually subject to liability. Employees of every level who engage in sexual harassment, including managers and Advisor Mentors, also known as Advisor Mentors, who engage in sexual harassment or who allow such behavior to continue, will be penalized for such misconduct.

All Advisor Mentors and managers who receive a complaint or information about suspected sexual harassment, observe what may be sexually harassing behavior or for any reason suspect that sexual harassment is occurring are required to report such suspected sexual harassment to HR representative (Arabella Advisors Partners).

In addition to being subject to discipline if they engaged in sexually harassing conduct themselves, Advisor Mentors and managers will be subject to discipline for failing to report suspected sexual harassment or otherwise knowingly allowing sexual harassment to continue.

Advisor Mentors and managers will also be subject to discipline for engaging in any retaliation.

LEGAL PROTECTIONS AND EXTERNAL REMEDIES

Sexual harassment is also prohibited by state, federal, and local law. Aside from the internal process at WXY, Employees may also choose to pursue legal remedies with the following governmental entities. While a private attorney is not required to file a complaint with a governmental agency, you may seek the legal advice of an attorney. In addition to those outlined below, employees in specific industries may have additional legal protections.

The Human Rights Law (HRL), codified as N.Y. Executive Law, art. 15, § 290 et seq., applies to all employers in New York State about sexual harassment and protects Employees, paid or unpaid interns, and non-Employees, regardless of immigration status. A complaint alleging violation of the Human Rights Law may be filed either with the Division of Human Rights (DHR) or in New York State Supreme Court

STATE HUMAN RIGHTS LAW (HRL)

Complaints with DHR may be filed any time within one year of the harassment. If an individual did not file at DHR, they could sue directly in state court under the HRL within three years of the alleged sexual harassment. An individual may not file with DHR if they have already filed an HRL complaint in state court. Complaining internally to WXY does not extend your time to file with DHR or in court. The one year or three years is counted from the date of the most recent incident of harassment.

You do not need an attorney to file a complaint with DHR, and there is no cost to file with DHR.

DHR will investigate your complaint and determine whether there is probable cause to believe that sexual harassment has occurred. Probable cause cases are forwarded to a public hearing before an administrative law judge. If sexual harassment is found after a hearing, DHR has the power to award relief, which varies but may include requiring your employer to take action to stop the harassment, or redress the damage caused, including paying of monetary damages, attorney’s fees, and civil fines.

DHR’s primary office contact information is the NYS Division of Human Rights, One Fordham Plaza, Fourth Floor, Bronx, New York 10458. You may call (718) 741- 8400 or visit: www.dhr.ny.gov.

Contact DHR at (888) 392-3644 or visit dhr.ny.gov/complaint for more information about filing a complaint. The website has a complaint form that can be downloaded, filled out, notarized, and mailed to DHR. The website also contains contact information for DHR’s regional offices across New York State.

CIVIL RIGHTS ACT OF 1964

The United States Equal Employment Opportunity Commission (EEOC) enforces federal anti-discrimination laws, including Title VII of the 1964 federal Civil Rights Act (codified as 42 U.S.C. § 2000e et seq.). An individual can file a complaint with the EEOC anytime within 300 days from the harassment. There is no cost to file a complaint with the EEOC. The EEOC will investigate the complaint and determine whether there is reasonable cause to believe that discrimination has occurred, at which point the EEOC will issue a Right to Sue letter permitting the individual to file a complaint in federal court.

The EEOC does not hold hearings or award relief but may take other action, including pursuing cases in federal court on behalf of complaining parties. Federal courts may award remedies if discrimination is found to have occurred. In general, private employers must have at least 15 Employees to come within the jurisdiction of the EEOC.

An Employee alleging discrimination at work can file a “Charge of Discrimination.” The EEOC has district, area, and field offices where complaints can be filed. Contact the EEOC by calling 1-800-669-4000 (TTY: 1-800-669-6820), visiting their website at www.eeoc.gov or via email at info@eeoc.gov.

If an individual filed an administrative complaint with DHR, DHR would file the complaint with the EEOC to preserve the right to proceed in federal court.

LOCAL PROTECTIONS

Many localities enforce laws protecting individuals from sexual harassment and discrimination. An individual should contact the county, city, or town in which they live to find out if such a law exists. For example, Employees who work in New York City may file complaints of sexual harassment with the New York City Commission on Human Rights. Contact their main office at Law Enforcement Bureau of the NYC Commission on Human Rights, 40 Rector Street, 10th Floor, New York, New York; call 311 or (212) 306-7450, or visit www.nyc.gov/html/cchr/html/home/home.shtml.

LOCAL PROTECTIONS

If the harassment involves unwanted physical touching, coerced physical confinement or coerced sex acts, the conduct may constitute a crime. Contact the local police department.

Employee Whistleblower Policy

Whistleblower policies are critical tools for protecting individuals who report activities believed to be illegal, dishonest, unethical, or otherwise improper. The organization will not retaliate against a whistleblower. It includes, but is not limited to, protection from retaliation in the form of an adverse employment action such as termination, compensation decreases, or poor work assignments and threats of physical harm. Any whistleblower who believes he/she is being retaliated against must contact Amy Hau or the HR representative immediately. The right of a whistleblower for protection against retaliation does not include immunity for any personal wrongdoing that is alleged and investigated.

Whistleblower protections are provided in two critical areas: confidentiality and retaliation.

Insofar as possible, the confidentiality of the whistleblower will be maintained. However, identity may have to be disclosed to conduct a thorough investigation, to comply with the law, and to provide accused individuals their legal rights of defense.

Individuals protected include:

• the Employee, or a person acting on behalf of the Employee, who reports to a public body or is about to report to a public body a matter of public concern; or
• the Employee who participates in a court action, an investigation, a hearing, or an inquiry held by a public body on a matter of public concern.
• The organization may not discharge, threaten, or otherwise discriminate against an Employee regarding the Employee’s compensation, terms, conditions, location, or privileges of employment.
• The organization may not disqualify an Employee or other person who brings a matter of public concern or participates in a proceeding connected with a matter of public concern, before a public body or court, because of the report or participation, from eligibility to bid on contracts with the organization; receive land under a district ordinance; or receive another right, privilege, or benefit.

Retaliation

WXY will not tolerate any form of retaliation against an applicant or employee based on a request for accommodation or participation in a complaint or investigation of discrimination.

Grievance Policy

Employees may have occasional problems or issues affecting their work-related activities, and it is vital to resolve these as soon as possible. WXY encourages Employees to resolve disagreements respectfully through informal, frank, and open discussion. HR (Arabella Advisors Partners) and the Advisor Mentors are two resources available to assist with informal resolutions. However, WXY also recognizes that occasionally more formal processes are needed.

The WXY grievance process establishes procedures for the fair, orderly, and timely resolution of problems or complaints using a thorough review process. The following principles will serve as the foundation for the WXY grievance process:

• WXY will deal with grievances expeditiously and fairly.
• Grievances and the proceedings under this policy will be treated with the highest degree of confidentiality possible. However, limitations on confidentiality may include the WXY’s obligations to investigate grievance allegations, provide individuals accused of misconduct an opportunity to respond, inform appropriate individuals of the imposition of corrective action, or to fulfill duties imposed by law.
• WXYs are protected from discrimination and retaliation in connection with exercising rights under this grievance policy

Open Door Policy

WXY recognizes that Employees may have suggestions for improving our workplace, as well as complaints about the workplace. WXY feels that the most satisfactory solution to a job-related problem or concern is usually reached through a prompt discussion with an employee’s Advisor Mentor. Employees should feel free to contact their Advisor Mentor with any suggestions and/or complaints. If Employees do not feel comfortable contacting their Advisor Mentor or are not satisfied with their Advisor Mentor’s response, they should contact Arabella Advisors Partners Human Resources.

Ethics Policy

Employees will maintain the highest ethical standards in the conduct of WXY affairs. The intent of this policy is that each associate will conduct business with integrity and comply with all applicable laws in a manner that excludes considerations of personal advantage or gain.

Employees shall not seek or accept any gifts, favors, entertainment, or payments without a legitimate business purpose, nor shall they seek or accept personal loans other than conventional loans at market rates from lending institutions from any persons or business organizations that do or seek to do business with or is a competitor of the organization.

Employees may accept for themselves, and members of their family’s common courtesies usually associated with customary business practices.

Gifts of small value from vendors such as calendars, pens, pads, knives, etc. Tickets to events (such as sports, arts, etc.) are acceptable if offered by the vendor, and the vendor accompanies the associate to the event. These are not to be solicited by the organization associate and must be approved by the appropriate organization officer.

Overnight outings are acceptable under the condition that individuals from either other companies or the vendor are in attendance. The associate must have prior approval from the appropriate organization officer.

The receipt of alcoholic beverages is discouraged.

Gifts of perishable items usually given during the holidays, such as hams, cookies, nuts, etc., are acceptable.

CONFLICTS OF INTEREST

Employees should avoid any situation which involves or may involve a conflict between their interest and the interest of the Organization. As in all other facets of their duties, employees dealing with customers, suppliers, contractors, competitors, or any person doing or seeking to do business with the organization are to act in the best interest of the organization. Each employee shall make prompt and full disclosure in writing to their manager of any potential situation which may involve a conflict of interest.

CONFIDENTIAL INFORMATION

The revelation or use of any confidential product information, data on decisions, plans, or any other information which might be contrary to the interest of the Organization without prior authorization, is prohibited. The misuse, unauthorized access to, or mishandling of confidential information, mainly personnel information, is strictly prohibited and will subject an associate to the Discipline Policy up to and including immediate discharge.

COMPLIANCE

Any violation of this policy will subject the employee to disciplinary action or immediate discharge. Any employee knowing any violation of the policy shall promptly report such violation to the appropriate level of management. Each Advisor Mentor is responsible for compliance with this policy. When questions arise concerning any aspect of this policy, contact the Advisor Mentor.

Confidentiality of Information

WXY’s confidentiality policy refers to the disclosure of valuable information that the organization holds. During everyday business, Employees will unavoidably receive and handle personal and private information about clients, partners, and WXY. This policy is designed to set the rules that will protect this information from exposure. This policy affects all Employees and others that may have access to confidential information.

Information that the organization considers confidential and proprietary is undisclosed, valuable, expensive and/ or not easily replicated. More specifically, information that is classified as confidential includes:

• Customer lists (existing and prospective)
• Data of Customers/Partners/Vendors
• Trade secrets
• Private deals; the existence and contents of agreements
• Product research and development
• Unpublished financial information; including WXY pricing and rates.
• Processes, methods, and know-how
• Patents, formulas, or new technologies
• Pricing/marketing and other undisclosed strategies or tactics
• Unpublished goals, forecasts, or initiatives that are marked as confidential.
• Data entrusted to the organization by external parties.
• Databased, photographs, drawings, diagrams, computer code or programs, videos, video animations, computer aided design (CAD) files, building information modeling (BIM) files, physical models, computer models/ simulations, prototypes, documentation, algorithms, and renderings.
• Documents, processes, or other elements explicitly marked as confidential.
• Any other knowledge acquired by Employees during their employment that is not otherwise publicly available.

All these types of information must be protected for different reasons – some may be legally binding (e.g., sensitive data), and some constitute the backbone of the business and give it a competitive advantage (e.g., business processes). The disclosure of some kinds of information may expose the organization to increased risk, such as specific trade secrets. In contrast, for others, the result could be the loss of essential partners or reputation.

In the course of their employment, Employees will have various levels of authorized access to confidential information to conduct their business. When they do so, the following rules strictly apply:

• No amount of information will be disseminated to anyone outside of the organization except as necessary to complete job-related tasks.
• The disclosure of information inside the organization will be limited to those with authorized access and legitimate reason to require that information.
• The information will not be used for the personal benefit or profit of the Employee or any other except the organization.
• The Employee will have access only to the amount and type of information required for the completion of their job responsibilities and no more.
• Employees must limit to a minimum the occasions when they take confidential information out of the office.
• When perusing or sharing information through electronic means, all precautionary safety measures must be in effect.
• Confidential information must not be left unattended or unlocked.
• Unauthorized replication of information is prohibited.
• All copies of confidential documents must be shredded when no longer needed.
• Upon separation of employment, all confidential information must be returned or deleted from the Employee’s electronic devices.
• The organization will take measures to ensure that confidential information is well protected. Those measures include but are not limited to:
• Electronic information will be encrypted.
• Databases will be protected with all available security measures.
• Paper documents will be safely stored and locked.
• Authorization of access will be carefully controlled.
• Employees may need to sign non-compete and/or non-disclosure agreements (NDAs)

Confidential information, as described above, may occasionally have to be disclosed for legitimate reasons, e.g., upon request of a regulatory body or for business purposes. In such cases, a strict procedure must be followed that includes the explicit consent of the parties involved (unless they are faced with criminal charges) and the disclosure of only relevant information and no more. The organization places great importance on this policy. Any non-conformity will bring about disciplinary and, possibly, legal action. The organization is prepared to terminate any Employee who willfully or regularly breaches the confidentiality guidelines for personal profit. Serious offenses such as theft of information, illegal disclosure of sensitive data etc. will be grounds for immediate for-cause dismissal and may also involve legal consequences. Any unintentional breach of this policy will be thoroughly investigated and will be punished appropriately, depending on its magnitude and seriousness.

This policy is binding even after the separation of employment.

Ending Employment

WXY Employees are employed on an at-will basis. The employment relationship is at the mutual consent of the Employee and the Organization. Employment atwill may be terminated with or without cause and with or without notice at any time by the Employee or the Organization. Nothing in this handbook or individual compensation agreements constitutes a contract of employment nor limits the right to terminate at-will employment. No Manager, Advisor Mentor, or Employee of the organization has any authority to make any agreement for employment on other than at-will terms.

Violation of policies and rules of WXY may warrant disciplinary action. The organization may, in its sole discretion, utilize whatever form of discipline is deemed appropriate under the circumstances, up to, and including, termination of employment. The Organization’s policy of discipline in no way limits or alters the at-will employment relationship.

Employees who voluntarily resign from the Organization are asked to provide at least two weeks’ advance notice of their resignation. This notice should be in writing and should briefly state the reason for leaving and the anticipated last day of work. WXY will consider you to have voluntarily terminated your employment if you resign from the organization, fail to return from an approved leave of absence on the date specified, or fail to report to work or call in for one or more consecutive workdays.

All requests for employment references or verification of employment must be directed to the Principals. Advisor Mentors or Employees are not authorized to release information for current or former Employees. WXY does not respond to verbal requests for references or verification of employment; all such requests must be made in writing. By policy, WXY discloses only the dates of employment, the job title of the last position held. Authorization to disclose this information must be in writing.

PAY AND BENEFITS UPON SEPERATION

Final wages will be paid in accordance with applicable law. WXY will pay in full for any unused and accrued vacation time upon termination and based on the semi-monthly payday schedule. If staff are overdrawn on their vacation balance, they will be required to repay WXY from their final pay. Sick leave, personal leave and holidays will not be paid upon termination.

RETURN OF FIRM PROPERTY

Employees are required to return all WXY Property that is in their possession or control in the event of termination of employment, resignation, retirement, or layoff or immediately upon request. No information belonging to WXY can be supplicated. We may also take all action deemed appropriate to recover or protect WXY property.

CONTINUATION OF BENEFITS

Staff who are covered by WXY’s medical, dental and vision plan may be entitled to extend their coverage at their cost beyond their employment at WXY. This coverage is referred to as COBRA (the Consolidated Omnibus Budget Reconciliation Act of 1985). Information regarding COBRA will be provided by Prestige upon separation.

EXIT INTERVIEWS

As part of WXY’s continuous improvement process and to provide employees with an opportunity to voice their opinions, exiting staff are encouraged to participate in an exit interview to be conducted by HR. During the exit interview, final paperwork, including confirmation of staff mailing address and benefit information, and any outstanding issues will be addressed.

---

ACKNOWLEDGMENT

The purpose of the Office Policies and Procedures Manual is to provide the staff with the firm’s operating goals, policies, and procedures. The policies, procedures, and benefits herein are guidelines.

I understand that I should consult with my Advisor Mentor or manager regarding any questions not answered in the Handbook. I have voluntarily entered into my employment relationship with WXY and acknowledged that there is no specified length of employment. Accordingly, either WXY or I can terminate the relationship at will, with or without cause, at any time.

Since the information, policies, and benefits described here are necessarily subject to change. I acknowledge that policy exceptions and changes may be made and/or authorized by the partners of WXY, except for WXY’s policy of employment at will, which can only be modified in a written agreement signed by a partner. Health and other benefits are currently administered through Prestige, an organization dedicated to human resource services. Employees should consult the Prestige Worksite Employee Handbook for additional firm policies and procedures.

I acknowledge that I read and fully understand all policies, including the Harassment and Social Media policies and the Prestige Worksite Employee Handbook. Furthermore, I acknowledge that this Handbook is not a contract of employment. I have received the Handbook and understand that it is my responsibility to read and comply with the Handbook policies and any revisions made to it.

---

CONFIDENTIALITY AGREEMENT

As an employee of WXY, I understand that I will be exposed to confidential information including, but not limited to information about WXY’s and its client’s policies and strategies; information or material that has or could have commercial value or other utility in the business; and sensitive, non-public information about employees (“Confidential Information”). My exposure to such Confidential Information may be in any form, including but not limited to, written, electronic, or oral communication. Such information may or may not be marked as being privileged, confidential, or proprietary. I will protect Confidential Information by agreeing to:

• Use Confidential Information only as needed to fulfill my employment responsibilities and in a manner, that is consistent with WXY’s intended purposes and not for any other purpose;
• Obtain the approval of my supervisor or a WXY Partner before I disclose Confidential Information to any third party or use any Confidential Information, except as may be required in the ordinary course of performing my work obligations;
• Consult my supervisor or a WXY Partner if I am not sure of WXY’s intended purposes for any Confidential Information that I receive;
• Make no unauthorized copies of Confidential Information;
• Store Confidential Information in a secure place within the WXY office and in a secure place at home when working remotely and properly dispose of materials containing Confidential Information when no longer needed (subject to record retention requirements);
• Take appropriate care when using electronic means (such as email, fax machines, and wireless phones) for communicating Confidential Information; and
• Set up a password on my remote computer/laptop/tablet and cell phone and not share this information with anyone.

In the event that I inadvertently disclose Confidential Information, I will immediately notify my supervisor and will cooperate in retrieving the Confidential Information or taking other reasonable steps to prevent further unauthorized disclosure. I understand that nothing in this agreement or any other WXY policy limits my ability to discuss, or to act together to address, workplace issues, such as salaries, bonuses and benefits, hours, working conditions or other issues of workplace concern. I understand that violation of this agreement may result in the immediate termination of employment and could result in civil and criminal penalties.