StrataTech Education

Group

EMPLOYEE HANDBOOK

Fiscal Year 2018

Table of Contents
ABSENCES AND TARDINESS, 31
ANTI-HARASSMENT, 8
APPEARANCE AND ATTIRE, 9
BENEFITS CONTINUATION, 37
BENEFITS GENERAL
INFORMATION, 36
BEREAVEMENT LEAVE, 32
BRAND LOGO USAGE, 10
BUSINESS EXPENSES -TRAVEL, 10
CELLULAR PHONE/MOBILE DEVICE
USAGE, 11
COMPLAINT PROCEDURE, 13
CONDUCT BY EMPLOYEE, 14
CONFIDENTIALITY, 12
CONFIDENTIALITY OF
INFORMATION RELATING TO
STUDENTS OR CUSTOMERS, 14
CONFLICT OF INTEREST, 12
CONFLICT RESOLUTION/EMPLOYEE
RELATIONS, 13
CORE VALUES, 6
CRIMINAL HISTORY BACKGROUND
CHECKS AND DRUG TESTING, 17
DRUG AND ALCOHOL TESTING
POLICY, 15
DRUG AND ALCOHOL USE, 15
ELECTRONIC MEDIA USAGE, 18
EMPLOYEE ASSISTANCE PROGRAM
(EAP), 37
EMPLOYEE HOTLINE, 23
EMPLOYEE REFERRAL PROGRAM,
23
EMPLOYMENT OF RELATIVES, 23
EMPLOYMENT REFERENCES AND
INFORMATION REQUESTS, 18
EMPLOYMENT TYPES, 28
EQUAL EMPLOYMENT
OPPORTUNITY, 8
ERRORS IN PAY, 30
EXEMPT EMPLOYEE REDUCTION OF
SALARY, 29
EXIT INTERVIEWS, 26
FAMILY AND MEDICAL LEAVE, 32
FINAL PAY, 30
2
FRATERNIZATION, 9
GIFTS, 13
HOURS OF WORK, 29
IMMIGRATION REFORM AND
CONTROL ACT, 5
INCLEMENT WEATHER, 30
INDIVIDUALS WITH DISABILITIES,
8
INTEGRATION CLAUSE AND THE
RIGHT TO REVISE, 5
INTERNAL
TRANSFERS/PROMOTIONS, 23
INTERNET CODE OF CONDUCT, 19
INTRODUCTION, 5
INTRODUCTORY PERIOD, 5
JOB POSTINGS, 23
JURY DUTY, 32
MEAL AND REST PERIODS, 31
MILITARY FAMILY LEAVE, 34
OTHER LEAVES, 35
OUR COMPANY HISTORY, 7
OUTSIDE EMPLOYMENT AND
ACTIVITIES, 13
OVERTIME, 30
PAID HOLIDAYS, 35
PAID TIME OFF, 35
PAY DAY, 30
PAYROLL DEDUCTIONS, 30
PERFORMANCE IMPROVEMENT
ACTION PLANS, 24
PERFORMANCE MANAGEMENT, 24
PERSONAL BELONGINGS, 25
PERSONAL LEAVE AND/OR NON-
FMLA MEDICAL LEAVE, 34
PERSONAL PHONE CALLS AND
BUSINESS, 25
PERSONAL VEHICLES, 25
PERSONNEL RECORDS, 25
PROFESSIONAL DEVELOPMENT, 25
PROGRESSIVE DISCIPLINE, 24
RECEIPT OF EMPLOYEE HANDBOOK
AND AGREEMENT FOR AT-WILL
EMPLOYMENT, 38
RECORDING TIME WORKED, 31
REEMPLOYMENT, 26 STATEMENT OF AT-WILL
REMOTE ACCESS, 23 EMPLOYMENT STATUS, 5
RESIGNATION/TERMINATION OF SUGGESTIONS, 27
EMPLOYMENT, 26 TOBACCO AND VAPE USE, 27
RETURN OF COMPANY PROPERTY, VOTING, 36
26 WEAPONS, 27
ROMANTIC RELATIONSHIP, 9 WELCOME, 4
SAFETY, 26 WORK MADE FOR HIRE, 28
SEARCHES, 26 WORKERS' COMPENSATION
SOCIAL MEDIA POLICY, 21 INSURANCE, 37
SOLICITATION, 27 WORKPLACE VIOLENCE, 28

3
WELCOME
MESSAGE FROM THE PRESIDENT
Welcome to StrataTech Education Group! We are pleased you
have joined StrataTech Education Group and have made it your
next career choice. We value each team member and are
committed to ensuring success amongst our members and
students.

We value a work environment in which everyone has the

opportunity to contribute, learn and grow. We treat each other
with respect and value honesty and integrity. Please become
familiar with our I-CARE values. They will serve to guide you in
every work-related decision you make, and in building positive,
productive relationships with others.

We have written this Employee Handbook to offer you information

regarding many employment areas. My hope is that you will read
this Handbook thoroughly and keep it ready as a reference. All
employees are required to acknowledge receipt of the
handbook. When you are prompted, please certify that you have
read the company policy.

Remember, you can make the difference and can help our
students realize their dreams while enabling our staff to work in a
rewarding and enjoyable environment.

Mary Kelly
President and CEO
StrataTech Education Group

4

INTRODUCTION
This Handbook is designed to acquaint you with the
policies, practices, and procedures of StrataTech.
Please understand that this Handbook is not
intended to be a contract, either express or implied,
nor is it intended to create any legally enforceable
obligations on the part of StrataTech. Employment
at StrataTech is at-will. The Company reserves the
right to terminate an employee with or without
cause, and with or without notice, at any time.
Likewise, employees have the same right.
The Handbook is a set of informational guidelines,
and the policies, procedures, and benefits set forth in
the Handbook may be modified, revoked, changed,
or deleted at any time without notice. The
Handbook describes the benefit plans currently
maintained by StrataTech. Employees should refer
to the actual plan documents if they have specific
questions regarding the benefit plan. These
documents are controlling. The plan documents are
not contractual in nature and do not guarantee any
continuation of benefits.
STATEMENT OF AT-WILL
EMPLOYMENT STATUS
As indicated above, employment at StrataTech is at-
will. Employment at-will means that the employee
or StrataTech can terminate the employment
relationship with or without cause, and with or
without notice, at any time. Nothing in this
Handbook or in any document or statement by any
Company employee shall limit the right to terminate
employment at-will. StrataTech also retains the
right to change an employee's position at-will. In
other words, StrataTech may demote an employee
or change his or her position with or without cause
and with or without notice.
No employee or representative of the Company has
any authority to make any oral or implied agreement
that changes or contradicts the at-will nature of your
employment. The at-will nature of your employment
can only be modified by an express written
agreement signed by the President of StrataTech.
IMMIGRATION REFORM AND
CONTROL ACT
Federal law requires all employers to verify each new
employee’s identity and legal authority to work in
the United States. All offers of employment are
conditioned upon the receipt of satisfactory evidence
of an employee’s identity and legal authority to work
in the United States.
This Handbook is the property of StrataTech, and is
intended for your personal use and reference.
5
Circulation of this Handbook outside of StrataTech
requires prior written approval from management.
INTRODUCTORY PERIOD
All new and rehired employees will be considered
introductory employees for the first ninety (90)
calendar days after their date of (re)hire. The
introductory period is intended to give new
employees the opportunity to demonstrate their
ability to achieve a satisfactory level of performance
and to determine whether the new position meets
their expectations. The Company uses this period to
evaluate employee capabilities, work habits, and
overall performance.
If the Company determines that the designated
introductory period does not allow sufficient time to
thoroughly evaluate the employee’s performance or
if the employee is not performing satisfactorily, the
introductory period may be extended at the
Company’s discretion for a specified period upon
written notification by the Company to the
employee. The employee will be notified of the
length of the extension and the areas that need to
be improved.
Employment is not guaranteed for the entire ninety
(90) day period of the introductory period and either
party may terminate the employment relationship
during the introductory period or extended
introductory period for any reason, with or without
cause, with or without notice, without further
obligation or liability.
Upon satisfactory completion of the introductory
period, employees will be considered "regular"
employees. Completion of the introductory period
does not, however, change or invalidate the at-will
provisions of employment described above.
INTEGRATION CLAUSE AND THE
RIGHT TO REVISE
This Handbook contains the employment policies and
practices of StrataTech in effect at the time of
publication. Obviously, it is not possible to anticipate
every situation that may arise in the workplace or to
provide information that answers every possible
question. Undoubtedly, circumstances may require
StrataTech to change its policies, practices, and
benefits described herein from time to time.
Accordingly, StrataTech reserves the right to revise,
modify, delete, or add to any and all policies,
procedures, work rules, or benefits stated in this
Handbook or in any other document, except for the
policy of at-will employment, at any time. For this
reason, the Company urges employees to contact
the Human Resources Department to obtain current
information regarding the status of any policy or
practice or benefit.
 CORE VALUES I-CARE
. iIIF I Integrity – We perform our duties with integrity and honesty, and in doing
so we comply with all necessary regulatory and legal
requirements.

C Communication – We expect direct respectful two-way communication. We

collaborate to proactively address issues and opportunities.

A Accountability – We take responsibility for our actions, individually and

collectively. We honor our commitments and expect the
same of others.

R Respect – We treat each other with respect. We value diversity and recognize
the accomplishments of others.

Excellence -
E We strive for personal and organizational excellence embracing
innovation and continuous improvement in the performance
of the internal and external processes.

From time to time, we are challenged with situations where decisions and the right
path seem unclear. In situations like this, consulting this Handbook or talking to
someone may not be possible. It is during these times when you should call upon our
I-CARE values to guide you. Our values are the basis of all our decisions. They call
forth action and personal behavior.

6
 OUR COMPANY HISTORY
TWS Acquisition Corporation doing business as StrataTech Education Group currently maintains a corporate office
and operates four schools:

StrataTech Education Group

120 N. 44th Street, Suite 230
Phoenix, AZ 85034
602-490-3450
http://stratatech.com/

The Refrigeration School, Inc.

4210 East Washington Street
Phoenix, AZ 85034
(602) 275-7133
http://www.refrigerationschool.com

Tulsa Welding School Tulsa

2545 East 11th Street
Tulsa, OK 74104
(918) 587-6789
http://www.weldingschool.com

Tulsa Welding School Jacksonville

3500 Southside Boulevard
Jacksonville, FL 32216
(904) 646-9353
http://www.weldingschool.com

Tulsa Welding School and Technology Center Houston

243 Greens Road
Houston, TX 77060
(281) 975-0500
http://www.weldingschool.com

7

EMPLOYMENT PRACTICES AND
GUIDELINES
EQUAL EMPLOYMENT
OPPORTUNITY
StrataTech is firmly committed to a policy of equal
opportunity for all applicants and employees. This
means StrataTech does not unlawfully discriminate
as to any condition of employment including
recruiting and hiring, promotion, compensation,
benefits, discipline, termination, and other
employment actions. StrataTech’s policy prohibits
unlawful discrimination based on race, color, creed,
sex (including pregnancy), gender identity, marital
status, religion, age, national origin, ancestry,
physical or mental disability, medical condition,
genetic information/ predisposition or carrier status,
or any other consideration made unlawful by federal,
state, or local laws.
StrataTech’s commitment applies to all persons
involved in the operations of the Company and
prohibits unlawful discrimination by any employee of
the Company, including the Owners and co-workers.
The Company expects all employees to show respect
and sensitivity toward all other employees and to
follow its equal opportunity objectives.
Employees should promptly report any incident of
discrimination directly to the Human Resources
Department or to any other member of
management, without fear of retaliation or reprisal.
INDIVIDUALS WITH
DISABILITIES
The Americans with Disabilities Act (ADA) of 1990,
as amended, prohibits discrimination on the basis of
disability and protects otherwise qualified applicants
and employees with disabilities from discrimination
in hiring, promotions, pay, training, employment
termination and all other terms and conditions of
employment. The ADA also requires, under certain
circumstances, covered entities to provide qualified
applicants and employees with disabilities, as defined
by the Act, with reasonable accommodation if such
accommodation does not impose undue hardship on
the Company. The Company will comply with federal,
state and local regulations regarding the hiring and
employment of individuals with disabilities. A
reasonable accommodation may include changes in
the work environment or in the way a job is
performed that enables a person with a disability to
enjoy equal employment opportunities.
If you require an accommodation, you must inform
your supervisor and Human Resources that there is
a need for an adjustment or change at work for a
reason related to a disability. We will respond
promptly and to the best of our ability to
accommodate the needs of all employees.
8
ANTI-HARASSMENT
StrataTech is committed to providing a work
environment free of unlawful harassment. Company
policy prohibits sexual harassment and harassment
because of race, religion, creed, color, national origin
or ancestry, physical or mental disability, medical
condition, marital status, age, sex (including
pregnancy), or any other basis protected by federal,
state, or local law or ordinance or regulation. All
such harassment is unlawful. StrataTech’s anti-
harassment policy applies to all persons involved in
the operation of the Company and prohibits unlawful
harassment by any employee of StrataTech,
including supervisors and co-workers.
Sexual harassment, whether verbal, physical, or
environmental, is unacceptable, and will not be
tolerated regardless of whether it occurs in Company
facilities, or in other work-related settings, including
travel and Company-related social events. Sexual
harassment includes unwelcome written or verbal
sexual advances and the written or verbal solicitation
of sexual favors from an unwilling subordinate or co-
worker in return for promotions, increased wages,
and continued employment. Other verbal, written,
and/or physical conduct of a sexual nature made to
an employee when submission to such conduct is
made, either explicitly or implicitly, a condition of an
individual's employment, or has the purpose or effect
of creating an intimidating, hostile, or offensive
working environment, is prohibited as well.
Examples of unlawful harassment include, but are
not limited to, unwelcome conduct of the following
types:
1. Verbal conduct such as epithets,
derogatory jokes or comments, slurs
or unwanted sexual advances,
invitations, or comments;
2. Visual conduct such as derogatory
and/or sexually-oriented posters,
photography, cartoons, drawings, or
gestures;
3. Physical conduct such as assault,
unwanted touching, blocking normal
movement, or interfering with work
because of sex, race, or any other
protected basis;
4. Threats and demands to submit to
sexual requests as a condition of
continued employment, or to avoid
some other loss, and offers of
employment benefits in return for
sexual favors; and
5. Retaliation for having reported or
threatened to report harassment.
This policy covers all employees. The Company will
not tolerate harassment, whether engaged in by
fellow employees, supervisors, managers, temporary
employees, or non-employees who conduct business
or otherwise interact with the Company.
The Company encourages individuals who believe
they are being harassed to firmly and promptly
notify the offender that his or her behavior is
unwelcome. Individuals who believe they have been
subjected to harassment, or who have knowledge
that others may have been harassed, should
immediately report such incidents to their supervisor
and to the Human Resources Office. The Company
encourages the prompt reporting of complaints so
that a rapid response and appropriate action may be
taken. Any allegation of harassment brought to the
attention of a supervisor or the Human Resources
Office, will be promptly, objectively, and thoroughly
investigated with an effort to protect the privacy of
persons involved. Confidentiality will be maintained
throughout the investigatory process to the extent
practical and appropriate under the circumstances.
Upon completing the investigation of a harassment
complaint, the Company will communicate its
intended actions to the complainant and to the
alleged harasser. If the Company finds that
harassment occurred, the harasser will be subject to
appropriate disciplinary action, up to and including
termination. If an investigation results in a finding
that the complainant knowingly made a false
accusation of harassment, the complainant will be
subject to disciplinary action, up to and including
termination.
The Company will not in any way retaliate against an
individual who makes a good faith report of
harassment, or who participates in a harassment
investigation. Nor will the Company permit any
person to engage in retaliation. Retaliation is a
serious violation of this harassment policy, and
should be reported immediately. Any person found
to have retaliated against another individual for
reporting harassment will be subject to disciplinary
action, up to and including termination.
FRATERNIZATION
To promote excellent relations with our students,
employees must represent the Company in a positive
and professional manner. Accordingly, employees
are strictly prohibited from becoming socially
involved with students or entering into business
relationships with students including, but not limited
to, the buying and selling of goods and services.
Employees are also prohibited from engaging in
improper fraternization with students online. This
includes interacting or engaging in personal
communications on social networking sites.
Interactions with students must be restricted to
those that have a work or Company-related purpose.
Fraternization with students compromises the
professional reputation and credibility of our
organization. Violations of this policy will not be
9
tolerated and will result in disciplinary action, up to
and including employment termination.
ROMANTIC RELATIONSHIP
The Company desires to avoid misunderstandings,
actual or potential conflicts of interest, complaints of
favoritism, possible claims of sexual harassment,
and the employee morale and dissension problems
that can potentially result from romantic
relationships involving managerial and supervisory
employees in the Company or certain other
employees in the Company, or with
students/customers of the Company.
Accordingly, managers and supervisors are not
allowed to date employees who report to them
directly or indirectly. Additionally, all employees,
both managerial and non-managerial, are
discouraged from becoming romantically involved
with other employees, when, in the opinion of the
Company, their personal relationships may create a
conflict of interest, cause disruption, create a
negative or unprofessional work environment, or
present concerns regarding supervision, safety,
security, or morale.
Not only does the manner in which employees treat
each other impact the overall success of the
Company, but the conduct and interaction of
employees with our students must also be at all
times positive, productive and professional.
Fraternization with students is not allowed and could
result in termination. Employees should always
maintain a professional and courteous distance from
students.
An employee who becomes romantically involved
with a fellow employee MUST immediately and fully
disclose the relevant circumstances to the Human
Resources Director so that a determination can be
made as to whether the relationship presents an
actual or potential conflict of interest. If an actual or
potential conflict exists, the Company may take
whatever action appears appropriate according to
the circumstances, up to and including transfer or
discharge. Failure to disclose facts may lead to
disciplinary action, up to and including termination.
Employees are expected to behave in a professional
manner in the workplace and keep their personal
relationships out of the work environment.
Employees should also remember that the Company
maintains a strict policy against unlawful harassment
of any kind, including sexual harassment. The
Company will vigorously enforce this policy
consistent with all applicable federal, state, and local
laws.
APPEARANCE AND ATTIRE
All employees should use good judgment with regard
to dress and appearance. Employees are expected
to dress in a clean and neat manner, appropriate for
their respective job responsibilities and business
environment. While it is the intent of the Company
that all employees dress for their own comfort during
work hours, the professional image of our
organization is maintained, in part, by the image our
employees present to customers, vendors, and other
visitors. The personal appearance, quality of service
and positive attitude of StrataTech Education Group
employees are essential to creating and maintaining
a favorable public image.
Employees working in office areas should dress
conservatively and professionally. Regular business
dress is required. Skirts and dresses should not be
any shorter than three inches above the knee. Dress
slacks are acceptable. Blue Jeans, T-shirts and
sweat suits are not appropriate office attire, except
as noted below.
Employees will not be permitted in classroom or
laboratory / shop areas without a shirt or shoes.
Sandals are prohibited. Proper clothing, footwear,
safety glasses and other safety equipment
appropriate to your work environment must be used,
especially when performing operations which
produce flying particles that could endanger your
eyes or skin. Failure or refusal to wear appropriate
safety attire will be a basis for disciplinary action, up
to and including termination of employment.
On approved casual days, employees may dress in
casual clothing, including blue jeans and T-shirts,
although dress standards still require a neat, clean
appearance. Employees meeting with customers
must wear appropriate business attire. Certain
positions can wear jeans due to the nature of the
position at the discretion of the Campus President.
Please contribute to a positive work environment by
maintaining high standards of neatness, grooming
and personal hygiene. Also, please keep in mind that
some individuals may be allergic to such things as
perfumes, colognes and lotions. If you use such
items, use them in moderation and with
consideration for those around you.
Employee attire should always be professional and in
good taste; it should promote a business-like
attitude and image consistent with the employee’s
specific job. Clothing, hairstyles or personal hygiene
should not pose a safety hazard or create an
unacceptable appearance. StrataTech Education
Group supervisors have the discretion to insist that
employees dress professionally and appropriately for
their positions.
Examples of attire that are not appropriate include,
but are not limited to:
 Clothing adorned with obscene, offensive or
foul language, slogans or images
10
 Athletic, beach or aerobic wear (i.e.,
sweatpants, sweat suit, flip flops, exercise
outfits)
 Tight, revealing or transparent fabric
 Shorts or short skirts/dresses
 Jeans in any color except for approved
casual days
 Tank tops, halter tops, spaghetti straps, or
muscle shirts
 Low-cut blouses or clothing which exposes
the midriff
 Torn clothing or clothing with holes
 Hats or headbands worn indoors
 Observable body piercing, other than in ears
Facial hair is permitted as long as it is neat and well
trimmed. Earrings through the nose, eyebrow,
tongue, or body parts other than the ear lobe that
are visible to the public may not be worn while
working. Ear gauges may be subject to covering.
Tattoos are permitted at our discretion. Employees
are expected to be conservative in the application of
makeup, scented products, and hairstyles.
The items listed are not all-inclusive, and employees
should check with their supervisors (and/or Human
Resources Office at each location) for specific
guidelines regarding their location.
StrataTech Education Group will comply with
applicable federal and state regulations when
enforcing this policy. Reasonable accommodations
will be made for employees' religious beliefs and
disabilities whenever possible, consistent with the
business necessity to present a favorable public
image.
BRAND LOGO USAGE
StrataTech Education Group believes its corporate
image is its identity; it reflects the Company’s goals,
people and way of doing business. StrataTech
Education Group’s brand logo(s) are designed to
position the organization as the leader in technical
education. StrataTech Education Group is proud of
the organization and seeks opportunities to
communicate, promote and advertise through the
brand image and logo(s). To maintain that image
and promote brand identity, it is essential that the
Company logo(s) be used in the proper content and
context, utilizing the correct graphic standards.
Request for logo usage should be directed to the Vice
President of Marketing of the Company.
BUSINESS EXPENSES -TRAVEL
The Company will reimburse employees for
reasonable business-related expenses incurred while
on assignments away from the normal work location.
All business-related expenses must be approved in
advance by your supervisor. Employees are required
to submit all original receipts to their immediate
supervisor with the expense claim form.

When approved, the actual costs of travel, meals,
lodging, and other expenses directly related to
accomplishing business travel objectives will be
reimbursed by the Company as specified in the
Travel and Entertainment Policy. Employees are
expected to limit expenses to reasonable amounts.
Employees who are involved in an accident while
traveling on business must promptly report the
incident to their immediate supervisor. Vehicles
owned, leased, or rented by the Company may not
be used for personal use without prior approval.
Employees should contact their Supervisor for
guidance and assistance on procedures related to
travel arrangements, travel advances, expense
reports, reimbursement for specific expenses, or any
other business travel issues.
Abuse of this business expenses policy, including
falsifying expense reports to reflect costs not
incurred by the employee, will be grounds for
disciplinary action, up to and including
termination of employment. The procedure and
policy and other details such as allowable and
disallowable expenses, and the expense form are
available from the accounting department.
CELLULAR PHONE/MOBILE
DEVICE USAGE
It is the policy of the Company and its subsidiaries to
provide a cellular phone and/or hands-free devices
for business use to certain individuals. Such cellular
phones and/or hands-free devices are the property
of the Company and their use must be properly
documented. Accordingly, these guidelines must be
followed when using a cellular phone issued by the
Company.
 Cellular phones and/or hands-free devices will
be assigned only to those employees who
have a job-related need for them.
 Employees provided with cellular phones and/or
hands-free devices for business use will be
expected to carry and use such equipment as
directed by their supervisor.
 Employees are not permitted to use any cellular
phones or hands-free devices issued by the
Company for personal use without prior,
written approval of their supervisor. The
Company accesses and monitors electronic
communication / Company cell phone usage
and there should be no expectation of
privacy.
 Employees are responsible for lost or stolen
cellular phones and hands-free devices and
must report such losses immediately.
11
Upon termination of employment for any reason, the
employee must return the cellular phone and/or any
hands-free devices to the Company.
Safety and Legal Issues for Cellular Phone Use
The Company values the safety of its employees and
third parties. Safety must come before all other
concerns. Regardless of the circumstances, including
slow or stopped traffic, employees are strongly
encouraged to pull off to the side of the road and
park the vehicle in a safe location before placing or
accepting a call. Drivers are prohibited from using a
telephone while driving unless the driver is using a
hands-free device. Texting while driving is strictly
prohibited. Employees whose job responsibilities
include regular or occasional driving and who are
issued a cellular phone for business use are expected
to refrain from using their phone while driving.
If acceptance of a call is unavoidable and pulling
over is not an option, employees should keep the call
short, use hands-free equipment, refrain from
discussion of complicated or emotional topics, and
keep their eyes on the road. Special care should be
taken in situations where there is heavy or erratic
traffic, inclement weather or the employee is driving
in an unfamiliar area.
Employees whose job responsibilities do not
specifically include driving as an essential function,
but who are issued a cell phone and/or hands-free
device for business use, are also expected to abide
by the provisions above. Under no circumstances
shall employees place themselves or others at risk to
fulfill business needs.
Employees who are charged with traffic violations
resulting from the use of their phone while driving
will be solely responsible for all fines and liabilities
that result from such actions.
Any violation of the above guidelines by an employee
will be subject to disciplinary action, up to and
including termination of employment. In all cases,
employees shall comply with Federal, State and local
laws pertaining to the operation of motor vehicles
while using a cellular phone or other mobile device.
Employees are responsible for knowing and abiding
by the laws of the various states in which the
employee drives. Use of a mobile device during
inclement weather or heavy traffic conditions is
strongly discouraged.
The Company will not be responsible to the
employee or any other party, for payment of fines
due to violation of Federal, State or local law, or
claims arising out of a motor vehicle accident which
has been determined to be caused by a violation of
the law. Employees who violate the law by using a
cellular phone or other mobile device while operating
a motor vehicle on Company business may be
subject to disciplinary action up to and including
termination of employment.
CONFIDENTIALITY
It is the guideline of the Company that the general
internal business affairs of the organization should
not be discussed with anyone outside the
organization except as may be required in the
normal course of business. Information designated
as confidential is to be discussed with no one outside
the organization and only discussed within the
organization on a “need-to-know” basis.
In the course of employment, an employee’s
assigned duties may require that s/he be granted
access to confidential Company information.
Confidential Company information may include but is
not limited to:
 Internal financial documents or statements,
sales or statistical reports or related memos
 Employee and student records
 Information obtained from or contained in an
employee or student information system
 Computer passwords.
 Information related to strategic planning,
initiatives and/or goals.
 Company handbooks, manuals, policies,
procedures or business methods.
 Information regarding the Company’s
customers, prospective customers or
suppliers.
 Company ideas, inventions, improvement
plans or trade secret information.
All employees have a responsibility to avoid
unnecessary disclosure of non-confidential internal
information about the Company, its
customers/students, and its suppliers and to comply
with FERPA. This responsibility is not intended to
impede normal business communications and
relationships, but is intended to alert employees to
their obligation to use discretion to safeguard
internal company affairs. Employees who have
authorized access to confidential information are
responsible for its security.
This policy seeks to protect the Company’s
confidential business information and other internal
information. This policy does not intend to restrict
any statutory right for employees to discuss their
wages, hours, and other terms and conditions of
employment for their mutual aid or protection.
The unauthorized use or disclosure of confidential
information at any given time during or after
employment for personal use, gain or any purpose
other than conducting Company business is strictly
prohibited and may result in disciplinary action, up to
and including employment termination.
CONFLICT OF INTEREST
An actual or potential conflict of interest occurs when
an employee is in a position to influence a decision
12
that may result in a personal gain for that employee
or for a relative as a result of the Company’s
business dealings. For the purpose of this policy, a
relative is any person who is related by blood or
marriage, or whose relationship with the employee is
similar to that of persons who are related by blood or
marriage.
The mere existence of a relationship with outside
firms does not necessarily create a conflict of
interest. However, if employees have any influence
on any transactions including purchases, contracts or
leases, it is imperative that they disclose to an
officer of the Company as soon as possible the
existence of the relationship, so that safeguards may
be established to protect all parties. Employees are
expected to act ethically, honestly and with the
highest standard of personal integrity at all times in
the performance of their job responsibilities. In all
situations, all employees are expected to conduct the
Company’s business in accordance with applicable
laws and regulations.
Employees should not engage in any activity,
practice or conduct which conflicts with, or appears
to conflict with, the interests of the Company, its
customers or suppliers. Employees dealing with
customers, suppliers, contractors, competitors,
students, or any person doing or seeking to do
business with the Company are to act in the best
interests of the Company regardless of personal
preference, and must not create the perception of
personal advantage.
No employee shall solicit or accept for personal use,
or for the use of others, any gift, favor, loan,
gratuity, reward, promise of future employment, or
any other thing of monetary value that might create
a conflict or appear to create a conflict, or that might
influence or appear to influence the judgment or
conduct of the employee in the performance of their
job. Gifts are discussed in further detailed below.
If you are uncertain as to the applicability of this
policy to your work, you must seek guidance from
Human Resources .
Examples of behaviors or situations that may violate
this policy include, but are not limited to:
 Holding outside employment with any
organization that does business or
competes with the Company (discussed
further below)
 Offering, promising or giving anything of
material value to any student or
prospective student
 Engaging in any activity or conduct, either
on the job or off, that is disruptive to,
competes with or causes damage to the
Company or the Company’s image.
Employees must disclose any financial interest or
relationship of influence they or their immediate
family members have with any organization that
does business or competes with the Company.
Additionally, employees must disclose potential
conflicts of interest to the appropriate supervisor.
Failure to do so and/or violating the above guidelines
may result in disciplinary action, up to and including
employment termination.
OUTSIDE EMPLOYMENT AND
ACTIVITIES
StrataTech has no desire to regulate what an
employee does outside of working hours. However,
if you are a full-time employee, the Company will not
tolerate any outside employment that involves a
conflict of interest or hinders employee performance.
No employee should work on any basis for any of
StrataTech's competitors or vendors.
GIFTS
In order to avoid a conflict of interest or the
appearance of a conflict of interest, at no time
should an employee solicit or accept personal gifts
from current or potential vendors, contractors or
their agents, local businesses, University
departments, or others with whom there is a
potential or ongoing business or professional
relationship. Employees may accept ordinary
business courtesies, such as routinely-distributed
advertising novelties of insignificant value, or
payment for a modest meal or event which have a
value less than $150.00. If the value of the gift is
undetermined, it should be returned.
Any gift that is not an advertising novelty should be
reported to the employee’s supervisor and Human
Resources. Gratuities or gifts of money to the
employee, including gift certificates, cannot be
accepted at any time and should be returned
immediately to the donor.
All employees are responsible for becoming familiar
with and adhering to this policy. Additionally,
supervisors are responsible for ensuring that this
policy is known by their employees and that all
employees are following it.
In the decision as to whether or not to accept any
gift, employees should use proper business
judgment and avoid in all cases any actual conflict of
interest or the appearance of any conflict.
Employees are encouraged to discuss proposed gifts
with the Human Resources Director if they are
unsure of the appropriateness of the gift in question.
CONFLICT
RESOLUTION/EMPLOYEE
RELATIONS
Misunderstandings or conflicts can arise in any
organization. To ensure effective working relations, it
13
is important that such matters be resolved quickly
and fairly before serious problems develop. The
Company believes a critical component of issue
resolution is effective communication between
employees and supervisors. Most incidents resolve
themselves naturally; however, should a situation
persist that you believe is detrimental to your
employment with the Company, you should follow
the procedure described below for bringing your
complaint to management's attention.
Step One. In the first instance, discussion of the
problem with your immediate supervisor is
encouraged. If, however, you do not believe a
discussion with your supervisor is appropriate,
you may proceed directly to Step Two.
Step Two. If your problem is not resolved after
discussion with your supervisor or if you feel
discussion with your supervisor is inappropriate,
you are encouraged to request a meeting with the
Human Resources Office. In an effort to resolve
the problem, the director will consider the facts
and may conduct an investigation.
Step Three. If your problem is not resolved or
not satisfied after discussion with the Human
Resources Office you are encouraged to request a
meeting with the President of the Company.
The Company does not tolerate any form of
retaliation against employees availing themselves of
this procedure. The procedure should not be
construed, however, as preventing, limiting or
delaying the Company from taking disciplinary action
against any individual, up to and including
termination, in circumstances (such as those
involving problems of overall performance, conduct,
attitude or demeanor) where the Company deems
disciplinary action appropriate.
COMPLAINT PROCEDURE
The Company provides its employees with a
convenient and reliable method for reporting
incidents of alleged unlawful harassment, including
sexual harassment. Any employee, who believes
that he or she has been or is being harassed or
discriminated against, is encouraged to immediately
inform the alleged harasser that the behavior is
unwelcome. In some instances, the person is
unaware that their conduct is offensive and when so
advised can easily and willingly correct the conduct
so that it does not recur. If the informal discussion
with the alleged harasser is unsuccessful in
remedying the problem, or if such an approach is
either not possible or comfortable for the employee,
the employee should immediately report the
complaint to their immediate supervisor and /or
manager. Please refer to the Anti-Harassment Policy
in this Handbook for additional information on the
Company’s complaint procedure.
The Company strives to find solutions representative
of our values and in support of our high performance
culture. However, the Company maintains its
authority as an at-will employer and may resolve
work-related issues at its discretion.
CONDUCT BY EMPLOYEE
As a Company team member, employees are
expected to accept certain responsibilities, follow
acceptable business principles in matters of conduct,
and exhibit a high degree of integrity at all times.
This not only involves respect for the rights and
feelings of others, but also demands that employees
refrain from any behavior that might be harmful to
themselves, co-workers, the Company, or that might
be viewed unfavorably by current or potential
customers or by the public at large. Employee
conduct reflects on the Company. Therefore
employees must observe the highest standards of
professionalism at all times.
Behavior and conduct that the Company prohibits
include, but are not limited to, the following:
 Falsifying employment or other Company
records;
 Violating the Company's Anti-Harassment
Policy;
 Violating state, federal or local laws and
regulations;
 Violating security or safety rules or failing to
observe safety rules or Company safety
practices; failing to wear required safety
equipment; tampering with the Company’s
equipment or safety equipment;
 Exhibiting excessive or unexcused
absenteeism or tardiness;
 Possessing firearms, weapons or explosives
on Company property without authorization,
in violation of Company policy or while on
duty (rules are further specified in the
weapons section of this handbook);
 Using Company property and supplies,
particularly for personal purposes in an
excessive, unnecessary or unauthorized way;
 Engaging in criminal conduct or acts of
violence, or making threats of violence
toward anyone on Company premises or
when representing The Company; fighting or
provoking a fight on Company property, or
negligent damage of property;
 Reporting to work under the influence of
drugs or alcohol, and/or illegally
manufacturing, possessing, using, selling,
distributing or transporting drugs;
 Committing theft or unauthorized possession
of Company property or the property of
fellow employees; possessing or removing
any Company property, including
documents, from the premises without prior
permission from management; using
Company equipment or property for personal
reasons without proper authorization; using
Company equipment for personal profit;
14
 Giving confidential or proprietary Company
information to competitors or other
organizations, or to unauthorized Company
employees; working for a competing
business while an employee of the Company;
breaching confidentiality of personnel
information;
 Using obscene, abusive or threatening
language or gestures;
 Acting in an insubordinate manner;
 Spreading malicious gossip and/or rumors;
engaging in behavior which creates discord
and lack of harmony; interfering with
another employee on the job; restricting
work output or encouraging others to do the
same;
 Sleeping or loitering during working hours;
 Soliciting during working hours and/or in
work areas; selling merchandise or collecting
funds of any kind for charities or others
without authorization during business hours,
or at a time or place that interferes with the
work of another employee on Company
premises;
 Posting, removing or altering notices on any
bulletin board on Company property without
the permission of the Human Resources
Office or in violation of procedures related to
same;
 Smoking in restricted areas or at non-
designated times, in accordance with
Company policy.
Should an employee’s performance, work habits,
overall attitude, conduct or demeanor become
unsatisfactory based on violations either of the
above or of any other Company policies, rules or
regulations, the employee will be subject to
disciplinary action, up to and including termination.
CONFIDENTIALITY OF
INFORMATION RELATING TO
STUDENTS OR CUSTOMERS
Employees must keep information confidential
related to business operation, financial and other
related matters of the Company and should not
divulge such information to any third party.
Additionally all employees are charged with
safeguarding and maintaining the confidential
information of students and customers. In
safeguarding student information, all employees
must be aware of and comply with the Family
Education Rights and Privacy Act (FERPA) and the
Gramm-Leach Bliley Act (GLBA). Additional
information on these Acts can be found by visiting
their websites at
http://www.ed.gov/policy/gen/guid/fpco/ferpa/index
.htmland
http://www.ftc.gov/privacy/glbact/glbsub1.htm.
Failure to adhere to the tenets set forth by these
acts may be grounds for disciplinary action, up to
and including termination.
DRUG AND ALCOHOL USE
The policy of the Company is to provide a safe,
efficient and healthy workplace for all of its
employees and also to hire and retain the most
qualified and productive people for its available job
positions. Accordingly, the Company maintains a
drug-free workplace. As a condition of continued
employment, all Company employees must comply
with this policy. The term “workplace” is defined as
Company property, any Company sponsored activity
or any other site where the employee is performing
work for the Company or representing the Company
including any campus or Company location, including
parking lots, Company leased space (including
storage facilities and Company owned/leased
vehicles) and customer facilities. The term “drug” as
used in this policy includes alcoholic beverages and
prescription drugs, as well as illegal inhalants and
illegal drugs and/or controlled substances as defined
in schedules I through V of the Controlled
Substances Act, 21 U.S.C. Sec. 812, 21 C.F.R. Sec
1308, and the state and local law of the jurisdiction
where the workplace is located, including, but not
limited to, marijuana, opiates (e.g., heroin,
morphine), cocaine, phencyclidine (PCP), and
amphetamines. An employee who engages in an
activity prohibited by this policy shall be subject to
disciplinary action, up to and including immediate
termination of employment. Moderate use of alcohol
at certain Company-sponsored functions may be
permitted.
Prohibited activities under this policy include the
possession, use, sale, attempted sale, distribution,
manufacture, purchase, attempted purchase,
transfer or cultivation of drugs, as defined above, in
the workplace, as defined above. Employees are
also prohibited from being at the workplace with a
detectable amount of drugs in their system.
However, the use and/or possession of prescription
drugs, when taken as directed and obtained with a
valid prescription, shall not be a violation of this
policy.
This policy is not intended to replace or otherwise
alter applicable U.S. Department of Transportation
obligations or any other federal, state or local
agency drug testing regulations related to a
particular industry.
A violation of the policy may result in disciplinary
action up to and including immediate termination.
DRUG AND ALCOHOL TESTING
POLICY
Drug and/or alcohol testing may be conducted under
various circumstances which include, but are not
limited to: pre-employment, pre-promotion, post-
accident, safety, reasonable suspicion, random,
return-to-work, mandatory follow-up, general and
periodic. Drugs tested for include, but are not limited
to: alcohol, amphetamines, barbiturates,
15
benzodiazepines, cocaine, marijuana, methadone,
methaqualone, opiates, phencyclidine (PCP), and
propoxyphene.
Refusal to participate in required drug and alcohol
testing or refusal to accept the terms and conditions
of testing as specified is a violation of the Company
policy and may result in termination of employment.
DEFINITIONS
1. Legal Drugs.
"Legal drugs” means prescribed or over-the-
counter drugs that are legally obtained by the
employee and used for the purpose(s) for which
they were prescribed, or in the case of over-the-
counter medications, intended by the
manufacturer.
For Arizona-based employees only, the Arizona
Medical Marijuana Act (the “Act”) recognizes
marijuana, if obtained in certain limited amounts
and used for authorized medical purposes, is a
legal drug. The Drug and Alcohol Use Policy and
this policy are intended to follow the requirements
of the Act. However, even if an employee’s use of
marijuana may be otherwise permissible under the
Act, the possession, smoking or consumption of
marijuana in the workplace (defined in the Drug
and Alcohol Use Policy) or while on duty (defined
below) is strictly prohibited. Also, notwithstanding
otherwise permissible use of marijuana under the
Act, being impaired (defined below) by marijuana
while on or in Company property, equipment,
machinery, and vehicles or while on duty is strictly
prohibited.
2. On Duty.
“On duty” means all working hours, as well as meal
periods and break periods, regardless of whether
on Company premises, and all hours when an
employee represents Company in any capacity.
3. Impairment.
The term “impairment” means symptoms that a
prospective employee or employee may be under
the influence of drugs or alcohol that may decrease
or lessen the employee’s performance of the duties
or tasks of the employee’s job position, including,
but not limited to, symptoms of the employee’s
speech, walking, standing, physical dexterity,
agility, coordination, actions, movement,
demeanor, appearance, clothing, odor, irrational,
or unusual behavior, negligence or carelessness in
operating equipment, machinery or production or
manufacturing processes, disregard for the safety
of the employee or others, involvement in an
accident that results in serious damage to
equipment, machinery or property, disruption of a
production or manufacturing process, any injury to
the employee or others or other symptoms causing
a reasonable suspicion of the use of drugs or
alcohol.
4. Safety Sensitive.
The term “safety sensitive” means any job
designated by the Company as a safety-sensitive
position or any job that includes tasks or duties
that the Company in good faith believes could
affect the safety or health of the employee
performing the task or others.
LEGAL DRUGS
An employee who has reason to believe that the
legal use of drugs, such as those prescribed by a
physician, may pose a safety risk to any person or
interfere with the employee’s performance of his or
her job must immediately advise their direct
supervisors in writing of the possible effects of such
medication regarding their job performance and
physical and/or mental capabilities. The Company
shall then determine whether any work restriction
or limitation is indicated. Failure to report the legal
use of a drug that may pose a safety risk to the
employee or to others may result in disciplinary
action. Improper use of “legal drugs” or working
while impaired by the use of legal drugs is
prohibited and may result in disciplinary action up
to and including termination.
The Company may exclude an employee from
performing a safety-sensitive position if the use of
a legal drug could cause an impairment or
otherwise decrease or lessen the employee’s job
performance or ability to perform the employee’s
job duties.
SPECIMEN COLLECTION AND TESTING
PROCEDURES
Testing will normally occur during or immediately
before or after a regular work period, and testing
time constitutes compensable time for salary and
benefits purposes. The Company will pay the cost of
testing, including transportation costs, for current
employees. Testing methods and collection
procedures will follow the guidelines of the
Company-assigned laboratory as follows:
1. All samples will be collected under
reasonable and sanitary conditions.
2. Sample collections will be documented
according to procedures that include both
appropriate labeling to preclude the
possibility of misidentification and an
opportunity for the person to be tested to
give notice of any information that may be
considered relevant to the test.
3. Collection, storage and transportation
procedures will be reasonably designed to
preclude the possibility of sample
contamination, adulteration or
16
misidentification.
4. All testing will comply with scientifically
accepted analytical methods and
procedures; drug testing will be conducted
at a laboratory approved or certified by the
U.S. Department of Health and Human
Services, the College of American
Pathologists or the Department of Health
Services.
TEST RESULTS AND CONFIDENTIALITY
To the extent required and allowed by law, the
Company will communicate test results to test
subjects. Any test subject may request a copy of
his or her test result report.
The Company will make reasonable attempts to
keep the results of any positive drug or alcohol test
confidential by releasing the test results only to
authorized representatives and agents, and to the
extent authorized by law.
CONFIRMED POSITIVE TEST RESULTS AND THE
RIGHT TO EXPLAIN TEST RESULTS
Minimum levels of any tested substance necessary
to establish a confirmed positive test result shall be
determined at the discretion of the Company. Any
test subject who tests positive on a confirmatory
test on any drug and/or alcohol test required by the
Company may submit additional information to the
Company’s Human Resources manager, in a
confidential setting, to provide an explanation for
the confirmed positive test result.
CONSEQUENCES OF CONFIRMED POSITIVE
TEST
Any employee who tests positive on a confirmatory
test on any drug or alcohol test required by the
Company and does not timely and successfully
explain the test results will be subject to
appropriate disciplinary action, at the sole discretion
of the Company, up to and including immediate
termination. If the employee is discharged on the
basis of a positive test result, the employee may be
disqualified from receiving unemployment benefits.
Similarly, any employee who tests positive on a
confirmatory test on any drug and/or alcohol test
required by the Company after a work-related
accident or injury and does not timely and
successfully explain the test results may be
disqualified from receiving workers’ compensation
benefits in connection with the injury, to the extent
permitted by law.
INSPECTION OF PROPERTY, EQUIPMENT, AND
VEHICLES
All persons on Company property or who are
performing services for the Company, and all
property, equipment, and vehicles on Company
property or being used in connection with the
performance of work for the Company are subject to
unannounced inspection by the Company.
Employees should not expect that any property or
items that they bring to work or use at work are
private or subject to any right of privacy.
Employees who refuse to permit inspections or who
fail to cooperate with inspections may be subject to
discipline, up to and including immediate
termination.
STATEMENT ON MEDICAL MARIJUANA
Because of its obligations under federal law, the
Company has and will continue to prohibit marijuana
possession and use in the workplace for any
purpose. Under Federal legislation entitled The Drug
Free Workplace Act of 1988, and The Drug Free
Schools and Communities Act of 1989, “no institution
of higher education shall be eligible to receive funds
or any other form of financial assistance under any
federal program, including participation in any
federally funded or guaranteed student loan
program, unless it has adopted and has implemented
a program to prevent the use of illicit drugs and
abuse of alcohol by students and employees.”
Federal law, entitled The Controlled Substances Act,
prohibits the possession, use or production of
marijuana, even for medical use. Therefore, the
Company will continue to enforce its current policies
prohibiting the unlawful manufacture, distribution,
dispensation, possession or use of a controlled
substance in the workplace or as part of any of its
activities.
Employees who violate the Company’s policy
prohibiting the use or possession of medical
marijuana or illegal drugs in the workplace will be
terminated.
CRIMINAL HISTORY
BACKGROUND CHECKS AND
DRUG TESTING
Conditional Job Offers
All job offers are conditional upon successful
completion and approval of the criminal history
background check and drug test. Any positions hired
which have access to institutional funds, accounts, or
credit cards may be subject to a credit check.
Consent
Any applicant or employee being considered for
employment, transfer, or promotion, will be
requested to submit to drug and/or alcohol testing.
The individual must sign a consent form prior to the
test. Such consent will allow the laboratory to send
the results to the company for its use in evaluating
17
the applicant or employee for initial or continued
employment.
Definitions Relating to Criminal History
Background Checks
“Conviction” means a finding of guilt or acceptance
by the court of a plea of guilty or no contest (nolo
contendere).
Criminal History Background Checks
Under authority of the Fair Credit Reporting Act,
Stratatech shall require a criminal history
background check for any individual applying or
being considered for work with the company, This
includes applicants for employment, employees
under consideration for internal transfer or
promotion, volunteers, and independent contractors
and their employees that do business with
Stratatech.
Stratatech may deny employment, transfer, or
promotion to an applicant or employee, and may
refuse to enter into a relationship with an
independent contractor/contractor’s employee, or
volunteer, for such positions, if the individual or
independent contractor fails to provide a complete
Criminal History Background Check authorization
form.
Stratatech shall not employ, transfer, or promote a
person, contract with an independent
contractor/contractor’s employee, or enlist a
volunteer who has been convicted (to include
probated sentences and deferred adjudication) of a
felony or misdemeanor involving any type of sexual
contact with a child or abuse of a child that includes,
but is not limited to, indecency with a child, injury to
a child, or endangerment of a child.
Stratatech reserves the right to refuse to employ,
transfer or promote a person, contract with an
independent contractor/contractor’s employee, or
enlist a volunteer who has been convicted (to include
probated sentences and deferred adjudication) of a
felony, or of a misdemeanor involving (1) theft,
burglary, or robbery (2) the use or possession of an
unlawful weapon or firearm, or (3) any other serious
offense as determined by Stratatech.
Applicants and potential independent
contractors/contractors’ employees and volunteers
shall disclose such convictions to Stratatech before
entering into an employment or other relationship
with the company. Failure to disclose this
information shall be grounds for denial or
termination of the relationship.
Background check results may affect an employment
decision or a decision regarding the relationship
between the company and an independent
contractor/contractor’s employee, or volunteer. All
job and other offers are conditional upon successful
completion and approval of the criminal history
background check.
Notice to Applicants
For all posted positions, the Human Resources
Department shall ensure that all advertisements
include the following phrase or similar language:
“Applicants selected for employment may be
required to undergo a pre-employment criminal
history background check and possibly a pre-
employment drug test.” For all non-posted positions,
the department that is filling the position shall notify
applicants selected for employment, transfers or
promotions about the company’s pre-employment
criminal history background check and drug testing
policy prior to being appointed and tested.
Application Requirements
Before an applicant is considered for a position,
he/she must fully and truthfully complete an
employment application. Upon acceptance of an offer
of employment, an applicant must provide the
company written consent to perform a criminal
history background check and pre-employment drug
testing. If an applicant refuses to sign the
employment application and the consent to
submitting to a pre-employment criminal background
check and a drug test, if appropriate, the
employment process will be terminated.
Discrepancies in Criminal History Background
The failure of an applicant, independent
contractor/contractor’s employee, or volunteer, to
fully disclose his/her complete adult criminal history
record as required, which includes any convictions
where the applicant was tried as an adult before the
age of 17, is grounds to deny or terminate
employment or other relationships.
Confidentiality of Pre-Employment Criminal
History Background and Drug Test Information
All information collected under these procedures
shall be used for the exclusive purpose of evaluating
the individual for employment or other relationship
with the company. The information shall remain
confidential and shall not be released or otherwise
disclosed, except to persons involved in gathering
and reviewing the information, and except as
required by law. Any employee who releases
information or causes information to be released in
violation of this procedure may be subject to
disciplinary action up to and including termination.
Inaccurate or Incomplete Results
Anyone who believes his/her results from the drug
test or background check are inaccurate or
incomplete has the sole responsibility of coordinating
and following the procedures as indicated by the lab
and/or as set forth in the required FCRA notice. The
company is not obligated to hold a position or an
offer open.
18
Notification of Conviction
An employee must notify his or her Director and the
Human Resources department of any dishonesty or
breach of trust offenses (theft, fraud, embezzlement,
forgery, money laundering), drug-related offenses
(possession, intent to sell, operating a motor vehicle
under the influence of a drug or alcohol), or violent
offenses (aggravated battery, assault, bodily harm,
attempted murder, murder, burglary, burglary of a
vehicle, homicide, rape, child abuse, sexual assault,
or other violent crimes) no later than five days after
such conviction. A criminal conviction may include
the following dispositions: Convicted, Nolo
Contendre/No Contest, or Guilty.
Failure to notify the immediate Director and the
Human Resources department may lead to
disciplinary action up to and including termination of
employment. A conviction record will not
automatically result in termination. All conviction
records will be evaluated on a case-by-case basis in
accordance with StrataTech Education Group’s
policies and procedures and handled accordingly.
EMPLOYMENT REFERENCES AND
INFORMATION REQUESTS
Company managers, supervisors, and employees
shall not provide references or other information
regarding past, present, or potential employees to
any third party. Should a reference or other
information be requested, the individual should be
instructed to contact the Human Resources
Department directly at 602-249-7510 or
human.resources@stratatech.com.
StrataTech’s policy as to references for current and
former employees is to disclose only the dates of
employment and the title of the last position held. If
authorization for disclosure is received in writing,
StrataTech will also provide information regarding
ending salary or wage.
ELECTRONIC MEDIA USAGE
It is the intent of the Company to provide the
communication systems necessary to successfully
conduct its business. Employees are expected to
adhere to proper use of all communication systems.
These include, but are not limited to, the telephone,
electronic mail (e-mail), cell phone, BlackBerry,
facsimile, Internet, corporate intranet, voice mail,
computers, modems, systems and other software.
Employees are permitted use of Company property
and must comply with Company policies and
procedures regarding its use.
The communication systems are owned and operated
by the Company and are to be used for the business
of the Company. Employees should have no
expectation of privacy of any correspondence,
messages or information in the systems, regardless
of the content or purpose of the same.
The Company has the right to review, monitor and
access all electronic content and messages sent or
received for any purpose, regardless of whether
messages are transmitted/received via the
Company’s e-mail system or the employee’s
personal e-mail account(s) if that transmission is
done via a company device. All such messages,
regardless of content or the intent of the sender, are
a form of corporate correspondence, and are subject
to the same internal and external regulation, security
and scrutiny as any other corporate correspondence.
E-mail communications must be written following
customary business communication practices as are
used in Company correspondence. E-mail
communications are official internal Company
communications, which may be subject to disclosure
in legal proceedings. Work-related messages should
be directed to the affected employee(s) rather than
sending a global message to all employees. It is the
employee’s obligation to notify any third parties
affected by this policy of the Company regarding
monitoring employee communications.
Unless authorized by the Human Resources Director
and the Campus President, employees shall not
attempt to gain access to another employee’s
personal communications system and messages.
The Company, however, reserves the right to access,
and may access an employee’s messages and other
electronic data at any time, without notice to the
employee.
It is the Company’s intent to provide each employee
with appropriate computing devices and software
that make them effective in their jobs. Employees
must not bring their own devices (e.g. computer,
keyboards, monitors, wireless routers, mice,
printers, etc.) or software into the workplace. If the
job requires special equipment or software, and you
don’t currently have it, contact your supervisor so
that appropriate steps can be taken to acquire it.
Any violation of these guidelines may result in
disciplinary action, up to and including termination.
INTERNET CODE OF CONDUCT
Access to the Internet has been provided to staff
members for the benefit of the organization and its
clients. It allows employees to connect to
information resources around the world. Every staff
member has a responsibility to maintain and
enhance the Company’s public image and to use the
Internet in a productive manner. To ensure that all
employees are responsible, productive Internet users
and are protecting the Company’s public image, the
following guidelines have been established for using
the Internet.
Occasional personal use of the Company’s computing
and network resources is acceptable provided that
such use does not interfere with the employee’s or
other employees’ legitimate business tasks or
otherwise hinder the conduct of business operations.
19
Employees are responsible for exercising good
judgment regarding the reasonableness of personal
use. If there is any uncertainty, employees should
consult their supervisor for clarification on what is
acceptable as personal use.
Acceptable Use of the Internet
Employees accessing the Internet are representing
the Company. All communications and access
should be for professional reasons. Employees are
responsible for seeing that the Internet is used in an
effective, ethical and lawful manner for the purpose
of business. Instant Messaging Systems or
applications are not currently allowed. Databases
may be accessed for information as needed. E-mail
may be used for business contacts.
Unacceptable Use of the Internet
The Internet should not be used for personal gain or
advancement of individual views or to visit
pornographic or other inappropriate sites.
Solicitation of non-Company business or any use of
the Internet for personal gain is strictly prohibited.
Use of the Internet must not disrupt the operation of
the Company network or the productivity of other
users. It must not interfere with your productivity.
Communications
Each employee is responsible for the content of all
text, audio or images that he/she places or sends
over the Internet including, but not limited to, any
Web-based sites or programs utilized through the
Company. Fraudulent, harassing or obscene
messages are prohibited. All messages
communicated on the Internet should have your
name attached. No messages will be transmitted
under an assumed name. Users may not attempt to
obscure the origin of any message. Information
published on the Internet should not violate or
infringe upon the rights of others. No abusive,
profane or offensive language may be transmitted
through the system. Employees who wish to express
personal opinions on the Internet are to use non-
Company Internet systems and should refrain from
making any representations that would somehow
attribute their personal opinions to the Company.
Software
To ensure that we are legally licensed for software,
as well as prevent computer viruses or other
malware from being transmitted through the system,
there will be no unauthorized downloading of any
software including shareware. All software
downloads require prior management approval.
Copyright Issues
Staff members, while using the Internet, may not
transmit copyrighted materials belonging to entities
other than the Company. One copy of copyrighted
material may be downloaded for use in research.
Users are not permitted to copy, transfer, rename,
add or delete information or programs belonging to
other users unless given express permission to do so
by the owner. Failure to observe copyright or license
agreements may result in disciplinary action from
the Company, up to and including immediate
termination or legal action by the copyright owner.
Passwords
While our systems may accommodate the use of
passwords for security, the reliability of such for
maintaining confidentiality cannot be guaranteed.
Individual passwords may not prevent others from
accessing your files.
You should never disclose your password to anyone.
If access is needed to your account while you are
absent, a supervisor can request that an
administrator change your password to
accommodate that access. You will then be required
to reset your password upon your return.
Passwords should:
 Be changed periodically to ensure that the
data you have access to is protected.
 Never be shared.
 Never be written down.
Employees must not attempt to gain access to
another employee’s computer, e-mail or voice mail
messages. However, the Company reserves the
right to access an employee’s messages at any time,
without notice to the employee.
Security
All messages created, sent or retrieved over the
Internet using company devices are the property of
the Company. The Company accesses and monitors
all messages and files on the computer system as
deemed necessary and appropriate. Internet
messages are public communication and are not
private. All communications including text and
images can be disclosed to law enforcement or other
third parties without prior consent of the sender or
the receiver.
Harassment
Harassment of any kind is prohibited. Messages with
derogatory or inflammatory remarks about an
individual or group’s race, color, national origin,
religion, sex, marital status, age, disability, or any
other status protected by federal, state or local law
will not be permitted.
Violations
Violations of any guidelines listed herein may result
in disciplinary action, up to and including immediate
termination. If necessary, the Company will advise
appropriate legal officials of any illegal violations.
Unacceptable Use: The lists provided below are not
exhaustive, but attempt to provide a framework for
types of activities that fall into the category of
unacceptable use.
20
 Under no circumstances is an employee
authorized to engage in any activity that is
illegal under local, state, federal or
international law while using the Company
owned resources.
 Under no circumstances will an employee
transmit and reveal Company confidential
information, student data, customer private
data, employee private data or trade secrets
outside the Company network unless express
consent from the supervisor.
 Employees must not store, display,
distribute, or print any kind of image or
document that may be construed as sexual
harassment or harassment because of race,
color, national origin, religion, sex, marital
status, age, disability, or other protected
bias on any computer system.
 Any sexually explicit use, whether visual or
textual is strictly prohibited. Employees shall
not view, transmit, retrieve, save, or print
any electronic images or files which may be
deemed as sexually explicit.
 The Company uses a Web content filtering
application that prevents access to certain
inappropriate Web sites. These sites may
include shopping sites, e-bay, gambling
sites, pornographic sites, hacking sites, etc.
Attempted access to these restricted sites by
employees is logged and periodically
reviewed.
System and Network Activities: The following
activities are strictly prohibited, with no exceptions.
 Violations of the rights of any person or
company protected by copyright, trade
secret, patent or other intellectual property,
or similar laws or regulations including, but
not limited to, downloading, installing, or
distributing "pirated" software products that
are not appropriately licensed for use by the
Company.
 Unauthorized copying of copyrighted
material including, but not limited to,
publications, digitization and distribution of
photographs from magazines, books or other
copyrighted sources, and copyrighted music.
 Uploading or transmitting any software
licensed by the Company or data owned or
licensed by the Company without proper
authorization by management.
 Exporting software, technical information,
encryption software or technology, in
violation of international or regional export
control laws.
 Intentionally introducing malicious software
into the network or computing environment
(e.g., spyware, viruses, worms, Trojan
horses, keyloggers, packet sniffers, etc).
  Revealing your account password to others
or allowing use of your account by others.
This includes family and other household
members when work is being done at home.
 Using the Company computing asset to
actively engage in procuring, storing, or
transmitting material that is in violation of
sexual harassment or hostile workplace laws.
 Making fraudulent offers of products, items,
or services originating from any the
Company account.
 Intentionally disabling or overloading any
computer system, application or network, or
circumventing any system which protects the
privacy and security of another the Company
information asset or employee.
 Effecting security breaches or disruptions of
network communication. Security breaches
include, but are not limited to, accessing
data of which the employee is not an
intended recipient or logging into a server or
account that the employee is not expressly
authorized to access, unless doing so is
within the scope of the employee’s regular
duties. For purposes of this section,
“disruption” includes, but is not limited to,
network sniffing, ping floods, packet
spoofing, denial of service, and forged
routing information for malicious purposes.
 Port scanning or network probing is
expressly prohibited unless approved by the
IT team.
 Attempting to log into another user’s account
with their password or by guessing their
password.
 Using any program/macro/script/command,
or sending messages of any kind, with the
intent to interfere with, or disable, another
user's session, via any means, locally or via
the Internet.
 Under certain, pre-authorized circumstances,
employees may be exempted from these
restrictions during the course of their
legitimate job responsibilities.
E-mail and Communications Activities: The
following activities are prohibited when conducted
from Company accounts, networks or computing
resources.
 Transmitting financial, medical, or personally
identifiable information outside the Company
unencrypted via e-Mail, FTP or other
unsecure methods.
 Transmitting encrypted sensitive data
outside the company without proper
approval and assistance from the IT
department.
 Sending unsolicited e-mail, "junk mail" or
text messages, including other advertising
material to individuals who did not
specifically request such material.
21
 Sending e-mail or text messages containing
language that may be construed as
disparagement, slander or libel of others,
harassment based on race, color, national
origin, religion, sex, marital status, age,
disability, or other protected category.
 Causing any form of internal or external
harassment via e-mail, telephone or paging,
whether through language, frequency, or
size of messages.
 Unauthorized use or forging of e-mail header
information.
 Creating or forwarding "chain letters" or
"pyramid schemes" of any type.
Social Media Policy
The Company understands that social media can be a
fun and rewarding way to share your life and opinions
with family, friends and co-workers around the world.
However, use of social media also presents certain
risks and carries with it certain responsibilities. To
assist you in making responsible decisions about your
use of social media, we have established these
guidelines for appropriate use of social media.
This policy applies to all associates of StrataTech
Education Group and its subsidiaries (hereinafter
referred to as “Company”.
Guidelines
In the rapidly expanding world of electronic
communication, social media can mean many things.
Social media includes all means of communicating or
posting information or content of any sort on the
Internet, including to your own or someone else’s web
log or blog, journal or diary, personal web site, social
networking or affinity web site, web bulletin board or
a chat room, whether or not associated or affiliated
with the Company, as well as any other form of
electronic communication.
The same principles and guidelines found in Company
policies and these basic beliefs apply to your activities
online. Ultimately, you are solely responsible for what
you post online. Before creating online content,
consider some of the risks and rewards that are
involved. Keep in mind that any of your conduct that
adversely affects your job performance, the
performance of fellow associates or otherwise
adversely affects members, customers, suppliers,
people who work on behalf of the Company or the
Company’s legitimate business interests may result in
disciplinary action up to and including termination.
Know and Follow the Rules
Carefully read these guidelines as well as all other
company policies and procedures, and ensure your
postings are consistent with these policies.
Inappropriate postings that may include
discriminatory remarks, harassment, and threats of
violence or similar inappropriate or unlawful conduct
will not be tolerated and may subject you to
disciplinary action up to and including termination.
Be Respectful
Always be fair and courteous to fellow associates,
customers, members, suppliers or people who work
on behalf of the Company. Also, keep in mind that you
are more likely to resolve work-related complaints by
speaking directly with your co-workers or by utilizing
our Open Door Policy than by posting complaints to a
social media outlet. Nevertheless, if you decide to
post complaints or criticism, avoid using statements,
photographs, video or audio that reasonably could be
viewed as malicious, obscene, threatening or
intimidating, that disparage customers, members,
associates or suppliers, or that might constitute
harassment or bullying. Examples of such conduct
might include offensive posts meant to intentionally
harm someone’s reputation or posts that could
contribute to a hostile work environment on the basis
of race, sex, disability, religion or any other status
protected by law or company policy.
Be Honest and Accurate
Make sure you are always honest and accurate when
posting information or news, and if you make a
mistake, correct it quickly. Be open about any
previous posts you have altered. Remember that the
Internet archives almost everything; therefore, even
deleted postings can be searched. Never post any
information or rumors that you know to be false about
the Company, fellow associates, members,
customers, suppliers, people working on behalf of the
Company or competitors
Post Only Appropriate and Respectful Content
 Maintain the confidentiality of Company trade
secrets and private or confidential
information. Trades secrets may include
information regarding the development of
systems, processes, products, know-how and
technology. Do not post internal reports,
policies, procedures or other internal
business-related confidential
communications.
 Respect financial disclosure laws. It is illegal
to communicate or give a “tip” on inside
information to others so that they may buy or
sell stocks or securities. Such online conduct
may also violate the Insider Trading law.
 Do not create a link from your blog, website
or other social networking site to a Company
website.
 Express only your personal opinions. Never
represent yourself as a spokesperson for the
22
Company. If the Company is a subject of the
content you are creating, be clear and open
about the fact that you are an associate and
make it clear that your views do not represent
those of the Company, fellow associates,
members, customers, suppliers or people
working on behalf of the Company. If you do
publish a blog or post online related to the
work you do or subjects associated with the
Company, make it clear that you are not
speaking on behalf of the Company. 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 StrataTech Education
Group and its subsidiaries.”
 Employees are not authorized to use their
personal social media sites to conduct
Company business (i.e., recruiting potential
students).
Using Social Media at Work
Refrain from using social media while on work time or
on equipment we provide, unless it is work-related as
authorized by your manager or consistent with the
Company Equipment Policy. Do not use Company
email addresses to register on social networks, blogs
or other online tools utilized for personal use.
Retaliation is Prohibited
StrataTech Education Group prohibits taking negative
action against any associate for reporting a possible
deviation from this policy or for cooperating in an
investigation. Any associate who retaliates against
another associate for reporting a possible deviation
from this policy or for cooperating in an investigation
will be subject to disciplinary action, up to and
including termination.
Media Contact
Employees should not speak to the media on the
Company’s behalf without contacting the Marketing
Department. All media inquiries should be directed to
them.
If you have questions or need further guidance, please
contact your HR representative.
Prohibition of Fraternization with Students
Online
Employees are prohibited from engaging in improper
fraternization with students online. This includes
interacting or engaging in personal communications
on social networking sites.
Violations
To the extent permitted by law, employees who
violate this policy will be subject to disciplinary
action, up to and including termination. If you have
questions about this policy, you should consult with
your supervisor.
REMOTE ACCESS
Employees are permitted access to the Company
network from locations other than the traditional
workplace in order to accomplish Company related
work. Access to Company systems and applications
requires compliance with Company policies,
procedures, and guidelines, including, but not limited
to, its IT security policies. In addition, employees
must follow these requirements.
 For non-exempt employees, in any given
work week, non-exempt employees must
receive prior manager approval before
remotely connecting to the Company’s
network.
 With the exception of the Company-issued
workstations/laptops, all equipment used to
access the Company's systems shall be the
sole responsibility of the employee and must
be approved by the IT Operations and
Security team prior to connecting.
The Company information cannot be stored at any
non-Company location – transmitting or storing
sensitive (information as discussed in this policy)
using a non-Company device is strictly prohibited.
System access information (logon ID and password)
shall be used solely as authorized and shall not be
shared with or by others to gain unauthorized access
to the Company's computer systems.
EMPLOYEE REFERRAL PROGRAM
The Company believes that current employees, who
know our culture and understand our needs, can
often be a great asset in helping find new em-
ployees. Accordingly, both full and part-time em-
ployees may be eligible to participate in the em-
ployee referral program. This program pays specific
monetary awards to current employees who refer
candidates for open positions, provided that the can-
didate is selected for employment and meets specific
employment requirements. Additional terms and
conditions may apply. Not all employees are eligible,
and the award varies by position posted. Please
contact the Human Resources Office for more
information.
EMPLOYEE HOTLINE
The Company’s anonymous reporting hotline is a
resource for all employees to anonymously and/or
confidentially report workplace concerns, including
suspected violations of Company policies or the Code
of Conduct and federal or state laws. The hotline
does not replace other resources available to all
employees, including supervisors and directors.
However, it is an alternative channel available 24
hours a day, 365 days a year. It is operated on
company’s behalf by Lighthouse Services, Inc., an
independent firm. The hotline number is 877-472-
2110. All calls are confidential and the identity of the
caller will remain anonymous.
23
Alternatively the website address:
http://www.lighthouse-services.com/stratatech
EMPLOYMENT OF RELATIVES
For purposes of this policy, "relative" is defined as a
spouse, domestic partner, child, parent, sibling,
grandparent, grandchild, aunt, uncle, first cousin, or
corresponding in-law or "step" relation. It is the
Company’s policy to restrict hiring practices to non-
relatives only. Our previous policy allowed relatives
to be hired as long as there was no supervisory
relationship amongst them. Those employees are
grandfathered in as long as the non-supervisory
relationship continues to exist.
This policy applies to all categories of employment at
the Company, including regular, temporary and part-
time classifications.
INTERNAL
TRANSFERS/PROMOTIONS
An employee must generally be in his/her current
position for six months in order to be eligible to
apply for an internal transfer or promotion.
Additionally, the employee’s application to apply for
an internal transfer or promotion must be approved
by their current supervisor. The Company
recognizes there are times when a compelling
business need may warrant an exception. If both
the current supervisor and hiring manager agree
that the Company’s needs would be better served by
permitting an employee to transfer before the six
month employment anniversary, the current
supervisor has the discretion to waive the waiting
period for a transfer/promotion. Such exceptions
must be reviewed with the Human Resources
Director and Campus President prior to final approval
being granted.
To be eligible for an early transfer/promotion, the
employee must be in good standing with the
Company and not have a contingent plan related to
performance.
JOB POSTINGS
The Company is committed to attempting to provide
opportunities to employees who have demonstrated
exemplary job performance.
In an effort to advise current employees of available
job openings, the Human Resources Office will
publicize announcements regarding open positions
on a monthly basis. Vacant positions are not neces-
sarily reserved or held exclusively for internal candi-
dates. The Company reserves the right to hire the
candidate it determines is best qualified for any
available position.
PERFORMANCE MANAGEMENT
Employees will be evaluated with respect to the
specific job that they are performing. To ensure that
employees perform their jobs to the best of their
ability, it is important they be recognized for good
performance and receive appropriate guidance,
feedback and coaching from their supervisors. As
you demonstrate the ability to take on additional
responsibilities, your talents will be utilized in the
manner deemed most suitable to your demonstrated
ability and the needs of the Company.
A written performance evaluation of each employee
may be performed periodically. The evaluation will
be conducted by your supervisor and will be
reviewed with you. Any areas of specific
achievement or in need of improvement will be
noted and discussed with you.
A positive performance review does not guarantee
either an increase in compensation or continuing
employment. Raises, if given, may be based on a
number of factors, such as the Company
performance and profitability, department or group
performance and individual performance.
Additionally, employees are scheduled to receive a
formal, written performance appraisal, once per
year. The annual appraisal provides an employee
with performance feedback on job responsibilities,
and technical and behavioral performance
expectations. It also provides an opportunity for the
employee to collaborate with his/her supervisor on a
career development plan.
Performance will be evaluated and rated by the
supervisor and then discussed with the employee.
After the supervisor provides the performance
appraisal, the employee will be provided an
opportunity to respond, in writing if desired. The
employee must then sign the appraisal document,
which confirms the review has been delivered.
PERFORMANCE IMPROVEMENT
ACTION PLANS
In addition to the annual appraisal, supervisors are
responsible for providing interim performance
feedback any time an employee needs to be advised
of performance or behavior concerns that could
potentially affect his/her success and employment
with the Company. Depending on the nature of the
concern, this may be accomplished through the use
of a Performance Improvement Plan (PIP). At times,
it may also become necessary to terminate
employment, depending on the performance or
behavior concern.
Decisions to discipline through the use of a PIP,
suspend or terminate employment are at the sole
discretion of the Company. Decisions will be made
in compliance with applicable federal and state
regulations. In order to ensure the integrity of the
24
decision-making process related to discipline,
suspension and employment termination, all such
employment action should have the approval of the
Human Resources Director and the appropriate
manager of the affected employee’s department.
The Company maintains its status as an at-will
employer, and the choice to discipline, suspend or
terminate employment does not alter that status.
PROGRESSIVE DISCIPLINE
Discipline may be initiated for various reasons
including, but not limited to, violations of Company
standards of conduct and/or poor job performance.
Before or during imposition of any discipline,
employees may be given (at the Company’s sole
discretion) an opportunity to relate their version of
the incident or problem at issue and provide any
explanation or justification they consider relevant.
Where appropriate and as circumstances may
dictate, supervisors will follow a process of
progressive employee discipline. Examples of
employee discipline include:
Verbal Counseling - "Verbal counseling" is a
verbal communication to an employee that
his/her conduct is unacceptable, and that
repeated or continued failure to conform conduct
or performance to the Company standards will
result in more severe disciplinary action. A
record of the notice of verbal counseling may be
made and retained in the employee's personnel
file.
Written Counseling - “Written counseling"
describes the unacceptable conduct or
performance of the employee and specifies
needed changes or improvements. A copy of the
written counseling will be retained in the
employee's personnel file.
Suspension - Suspension of the employee's
employment may, at the sole discretion of the
Company, be used prior to termination. The
length of the suspension may vary based upon
such factors as the severity of the offense, the
employee's performance and the employee's
disciplinary record. An employee may be
suspended for repeated instances of minor
misconduct, failure to conform his/her conduct or
performance to the standards of his/her position,
or for a single serious offense. A record of the
suspension will be retained in the employee's
personnel file.
Termination - If an employee fails to conform
his/her conduct or performance to the standards
required by the Company, the Company may, in
its sole discretion, terminate the employee's
employment.
Notwithstanding the potential for less severe
discipline before termination, the Company reserves
the right to administer discipline in such a manner as
it deems appropriate to the circumstances, and may,
in its sole discretion, terminate an employee without
prior discipline or without following a particular order
of discipline.
PERSONAL BELONGINGS
The Company welcomes employees to personalize
their work areas for added fun and comfort. The
Company is not responsible for the loss or damage of
items such as pictures, posters, calendars and
personal mementos. These are generally acceptable
to display; however, the following general guidelines
will be observed:
 Items that are harassing, discriminatory,
offensive to reasonable individuals or that
create an unprofessional image are not
permitted.
 Items that create distraction, disruption or
hinder work efforts are not permitted.
 Items that pose a safety risk or interfere
with job safety are not permitted.
The Company, in its sole discretionary judgment,
may determine that an item is not appropriate for
display and require the employee to remove it from
the workplace. The Company will comply with
applicable federal and state regulations in enforcing
this policy.
PERSONAL PHONE CALLS AND
BUSINESS
During business hours, you are requested to keep
personal calls, including personal cell phone calls, to
an absolute minimum. No long distance or toll calls,
such as directory assistance, other than Company
business calls, are to be made from Company
telephones. If it is absolutely necessary that you
make a toll call from work, you must charge it to
your personal calling card, home number or use your
personal cell phone. Telephone records are subject
to periodic review by management.
If you need to leave the worksite to conduct personal
business, you must first obtain permission from your
immediate supervisor. This will allow us to make
modifications to the work schedule if necessary and
will keep us aware of your activities during the day.
Personal visits of friends and family members to the
worksite are discouraged.
PERSONNEL RECORDS
The Company maintains a personnel file on each
employee. You may review your personnel file upon
request and in the presence of authorized personnel.
If you are interested in reviewing your file, contact
the Human Resources Director to make
25
arrangements. The Company will follow state law if
it differs from this policy.
To ensure that your personnel file is up-to-date at all
times, notify the Human Resources Office of any
changes in your name, telephone number, home
address, marital status, withholding instructions,
number of dependents, beneficiary designations,
scholastic achievements, the individuals to notify in
case of an emergency and so forth.
If an employee wishes to dispute information
contained in the personnel record, s/he may do so
by submitting a written statement to the Human
Resources Director for inclusion in the personnel
record. Personnel records are the property of the
Company and may not be removed from the
premises. Current and/or future supervisors,
Company executives or other individuals with a
“need to know” should contact the Human Resources
Office if they wish to view a personnel record.
Confidentiality is maintained as required by law.
PERSONAL VEHICLES
Use of personal vehicles for the purpose of business
are generally discouraged however there will be
circumstances where employees may use their
personal vehicles on official company business
provided prior approval has been obtained from their
supervisor. A mileage rate based on acceptable and
current company guidelines will be paid to an
employee who uses his personal vehicle on official
company business. For reimbursement guidelines
details, the Travel and Entertainment Policy is
available from the accounting department. Minimum
insurance requirements as specified by the Company
must be in effect at the time the employee’s
personal vehicle is used and the employee may be
required to provide proof of insurance and valid
driver’s license.
PROFESSIONAL DEVELOPMENT
The Company supports and encourages employee
participation in professional development activities,
including membership in professional associations,
attending training and seminars and pursuing
professional certification or licensure related to
his/her position. Approval of all professional
development activities is at the discretion of the
Company. Additionally, it is the employee’s
responsibility to ensure that professional
development does not interfere with or deter from
performance of his/her job
responsibilities. Employees interested in pursuing
professional development opportunities during work
time should discuss such pursuits with their
supervisor, who will determine if business needs
permit the employee to engage in the desired
activity.
REEMPLOYMENT
Individuals whose employment was involuntarily
terminated are not generally eligible for rehire.
Individuals who left in good standing may reapply
but will have to go through the new hire process
again and will not get credit for previous work
experience.
RESIGNATION/TERMINATION
OF EMPLOYMENT
An employee may be separated from employment
either voluntarily or involuntarily by retirement,
resignation, lack of work or termination.
To help ensure efficient business operations,
employees desiring to resign voluntarily from em-
ployment with the Company are requested to submit
notification of resignation in writing, either to the
appropriate supervisor or Human Resources Office at
least 2 weeks before the resignation date.
Supervisors are responsible for immediately
forwarding resignation notices to the Human
Resources Office.
The Company is not obligated to accommodate an
employee’s request to revoke a resignation, either
verbal or written, and may, in its sole discretion,
accept or reject such a request.
EXIT INTERVIEWS
Management may conduct an exit interview to
discuss your reasons for leaving and any other
impressions that you may have about the Company.
During the exit interview, you can provide insights
into areas for improvement for the Company and
your specific position.
RETURN OF COMPANY
PROPERTY
Any property issued to you by the Company, such as
software, computer equipment, databases, files, cell
phone, pager, keys, parking passes or credit card(s),
and ID badges must be returned at the time of your
termination. You will be responsible for any lost or
damaged items and all outstanding debts paid on or
before the last day of work.
Supervisors are responsible for ensuring the above
has occurred and for completing the appropriate
paperwork to arrange for employee’s final pay. This
should occur as soon as practicable after notice is
given.
SAFETY
It is the policy of the Company to provide its
employees a safe and healthy workplace and to
follow procedures intended to safeguard all
employees. Accident prevention and efficiency in
production go together; neither should be given
priority over the other.
26
Safety is everyone's responsibility. Every supervisor
is expected to devote the time and effort necessary
to ensure the safety of employees at all times.
Employee Responsibilities Include:
 Obeying the safety rules.
 Following safe job procedures and not taking
shortcuts.
 Keeping work areas clean and free from
slipping or tripping hazards.
 Using prescribed personal protective
equipment.
 Immediately reporting all malfunctions to a
supervisor.
 Using care when lifting and carrying objects.
 Observing restricted areas and all warning
signs.
 Knowing emergency procedures.
 Reporting unsafe conditions to supervisors.
 Promptly reporting every accident and injury
to one’s supervisor.
 Following the care prescribed by the
attending physician when treated for an
injury or illness.
 Attending all employee safety meetings.
 Participating in accident investigations,
serving on safety committee or other loss
control activities as needed.
 When in the lab and maintenance shop,
employees must wear closed toe shoes.
Heels must not be over one inch while in
these areas.
Failure to observe these guidelines may result in
disciplinary action, up to and including termination of
your employment.
Workplace Accidents
All accidents, injuries, potential safety hazards,
safety suggestions and health and safety-related
issues must be reported immediately to your
supervisor and Human Resources. An accident
report must be completed. If you or another
employee is injured, you should contact outside
emergency response agencies, if needed.
Disregarding the Company safety rules and
procedures may result in disciplinary action, up to
and including employment termination.
SEARCHES
In an effort to ensure the safety and welfare of
employees and invitees, The Company reserves the
right, on reasonable suspicion that Company policy is
being violated, to conduct searches or inspections
which includes, but is not limited to, employee’s
work area, desks, computer systems, emails and any
other property located on Company premises or
worksites. Entry on Company premises or worksites
constitutes consent to searches or inspections.
SOLICITATION
It is the intent of the Company to provide to all
employees a comfortable work environment that is
free from distractions or disturbances that reduce
the ability to perform at an optimum level and
prevent interference with work and inconvenience to
others from solicitations and/or distribution of
literature.
For that reason, the Company prohibits unapproved
or non-Company sponsored solicitation of any type
and for any purpose during work time; this includes
work time of the employee doing the soliciting and
the one being solicited.
Use of Company electronic media, including
telephone/fax, copy machine and computer, for
purposes of solicitation or distribution of non-work
related material is also prohibited.
Group meetings for solicitation purposes, distributing
literature, circulating petitions in work or sales areas
is prohibited unless it is approved by the onsite
supervisor as a Company-sponsored event. The
following guidelines will apply throughout the
Company:
 Employees will not engage in any solicitation
of other employees for any purpose
whatsoever during working hours or in work
areas. Working hours do not include lunch
or break period or before or after work.
 The Company’s facilities may not be used as
a meeting place that involves solicitation
and/or distribution of literature.
 In order to maintain good customer relations
and preserve the professional work
environment, employees may not wear any
insignia, badge or button on their person,
nor display any insignia, badge or button on
their desk or in their work area, excluding
professional designation awards, except as
allowed by law.
 Management will approve and post all
information that is displayed on the
Company’s bulletin board or made available
for review or distribution to employees.
Trespassing, soliciting or distributing literature by
non-employees is prohibited on Company premises.
Violation of this policy may result in disciplinary
action, up to and including employment termination.
SUGGESTIONS
The Company is committed to working in partnership
with employees and encourages all employees to
bring forward their suggestions and good ideas about
how our Company can be made a better place to
27
work, our systems improved, and our services
enhanced. When you see an opportunity for
improvement, please talk it over with your manager.
All suggestions are valued and listened to. When a
suggestion from an employee has particular merit,
we provide for special recognition of the individual(s)
who had the idea.
TOBACCO AND VAPE USE
In order to maintain a safe and comfortable working
environment and to ensure compliance with
applicable laws, it is our policy to provide a “tobacco-
free” environment for our students, staff, faculty,
and visitors. The use of tobacco products is
prohibited within the facilities. You should familiarize
yourself with those areas throughout the premises
where the use of tobacco products is either
permitted or prohibited. The term “tobacco-free”
should be interpreted to mean all forms of smoking
tobacco, such as cigarettes, cigars and pipes, as well
as smokeless tobacco products, such as chewing
tobacco. Because the Company may be subject to
criminal and civil penalties for violations of applicable
smoking laws, we must insist on strict adherence to
this policy. Employees using tobacco products in any
restricted area may bFe subject to disciplinary
action, up to and including termination. Please
contact the Human Resources Department if you
have any questions regarding the tobacco policy.
Complaints regarding violations of this policy may be
filed under the Company's complaint resolution
procedure, which is described elsewhere in this
handbook.
In addition, vaping is prohibited in all restricted
areas. Vaping refers to the use of electronic nicotine
delivery systems or electronic smoking devices.
These are commonly called e-cigarettes, e-pipes, e-
hookahs, and e-cigars.
WEAPONS
It is the intent of the Company to provide a safe and
secure workplace for employees, clients, customers
of clients, visitors and others with whom we do
business. The Company has “zero tolerance” for,
and expressly forbids the possession of, while on
Company property, any type of weapon, firearm,
explosive, and/or ammunition. Company property
includes any Company owned or leased parking lot.
The Company strictly prohibits the unlawful carrying
or possession of any weapon in a parking facility or
parking area, including in employee-owned vehicles
parked on Company property; provided, however,
employees and other third-party invitees are
permitted to possess legally-owned firearms that are
either locked inside or locked to a personal vehicle
and not visible from the outside when the employee
or invitee is lawfully on Company property.
With the limited exception for legally-owned firearms
set out above, the possession of firearms or other
weapons on Company property may be cause for
discipline including, but not limited to, immediate
termination of employment. In enforcing this policy,
the Company reserves the right to request
inspections of any employee and their personal
effects (excepting personal vehicles), while on
Company property. Any employee who refuses to
allow such an inspection will be subject to the same
disciplinary action as having been found in
possession of firearms or other weapons.
Employees within the Company share the
responsibility of identifying violators of this policy.
An employee who either witnesses or suspects
another individual of violating this policy should
immediately report this information to Human
Resources.
WORK MADE FOR HIRE
The Company encourages innovation and
creativity by all of its employees, regardless of
their primary job responsibilities. Accordingly,
employees may voluntarily, or upon request,
become directly or indirectly involved in
conceptualizing, designing, developing, producing,
and/or marketing and selling existing and future
courses, products and applications as part of their
employment duties.
All work and products, (whether patentable or
not), created by employees during work hours for
the Company, using the Company’s premises or
any of its equipment or supplies; or which relate
to, or result from the actual or demonstrable
anticipated business, work or research in
development of the Company; or are suggested
by any tasks that employees perform for the
Company, are “work made for hire” under
applicable law and remain the Company’s
property. The Company may require employees
to execute instruments or documents, (both
during and after the employee’s employment with
the Company), to completely vest in the
Company, all ownership rights in such ideas,
concepts, products, processes and applications.
Certain employees may be required to sign an
agreement that details the confidentiality terms
and ownership of work they create and develop
for the Company.
WORKPLACE VIOLENCE
It is the intent of the Company to provide a safe
workplace for employees and to provide a
comfortable and secure atmosphere for customers
and others with whom we do business. The
Company has zero tolerance for violent acts or
threats of violence.
The Company expects all employees to conduct
themselves in a non-threatening, non-abusive
manner at all times. No direct, conditional or veiled
threat of harm to any employee or Company
28
property will be considered acceptable behavior.
Acts of violence or intimidation of others will not be
tolerated. Any employee who commits or threatens
to commit a violent act against any person while on
Company premises will be subject to immediate
discharge. If an employee, while engaged in
Company business off the premises, commits or
threatens to commit a violent act, that employee will
be subject to immediate discharge.
Employees within the Company share the
responsibility in identifying and alleviating
threatening or violent behaviors. Any employee who
is subjected to or threatened with violence, or who is
aware of another individual who has been subjected
to or threatened with violence, should immediately
report this information to Human Resources.
Employees must assume that any threat is serious.
If you as an individual feel threatened and need
protection, do not hesitate to report the situation to
Human Resources. The Company will carefully
investigate all reports, and employee confidentiality
will be maintained to the fullest extent possible.
The Company’s prohibition against threats and acts
of violence applies to all persons involved in the
Company’s operation, including, but not limited to,
personnel, contract and temporary workers, and
anyone else on Company property. Violations of this
policy by any individual on Company property will
lead to disciplinary action, up to and including
termination and/or legal action as appropriate.
Examples of behavior that may violate this policy
may include, but are not limited to:
 Injuring or threatening to injure another
individual
 Engaging in behavior that creates a
reasonable fear of injury in another
individual
 Engaging in behavior that subjects another
to extreme emotional distress
 Possessing, brandishing or using any type of
weapon while on Company property or
engaged in Company business, unless and
only as allowed by State or Federal law
PAY PRACTICES AND HOURS
OF WORK
EMPLOYMENT TYPES
Positions at the Company are categorized for
purposes of salary administration and regulatory
compliance. Jobs are classified as either “exempt” or
“non-exempt,” based on guidelines outlined in the
Fair Labor Standards Act (FLSA). The FLSA, among
other things, establishes minimum wage and
provides the criteria for determining whether or not
a position is eligible for overtime compensation.
Full-time Regular Employees -- Employees hired
to work a normal, full-time workweek of thirty (30)
hours or more on a regular basis. Such employees
may be "exempt" or "nonexempt" as defined below.
Part-time Regular Employees -- Employees hired
to work fewer than thirty (30) hours per week on a
regular basis. Such employees may be "exempt" or
"nonexempt" as defined below.
Temporary Employees -- Employees engaged to
work full time or part time with the understanding
that their employment will be terminated no later
than upon completion of a specific project or
assignment. The duration of a temporary assignment
shall not exceed six (6) months, unless extended in
writing by a mutual agreement. A temporary
employee may be offered, and may accept, a new
temporary assignment and thus still retain
temporary status. Such employees may be "exempt"
or "nonexempt" as defined below. Individuals
contracted from temporary employment agencies for
specific assignments are considered employees of
the respective agency and are not considered
employees of the Company. Temporary agency
employees are paid by the respective agency and
should not be on the Company payroll.
Nonexempt Employees  Non-exempt employees
are covered by the overtime provisions of the FLSA.
Non-exempt employees are entitled to overtime pay
for all hours worked in excess of forty (40) hours per
week. See Overtime Policy.
Exempt Employees Exempt employees include all
regular employees who are classified by StrataTech
as exempt from the overtime provisions of the Fair
Labor Standards Act ("FLSA") and any applicable
state law. Such employees include employees who
qualify as executive, administrative, or professional
employees.
EXEMPT EMPLOYEE REDUCTION
OF SALARY
Exempt employees are paid on a salary basis and, in
general, must be paid their full salary for week in
which they perform work. Their salary may be
reduced only in the following circumstances:
Employees who are absent from work for at least a
full day for personal reasons other than sickness or
disability will not be paid for that day unless they
have accrued paid time off under the Company paid
time off, vacation or sick policy, if any.
Exempt employees who are absent for at least a full
day because of sickness or disability will not be paid
for that day unless they have accrued paid time off
under the Company paid time off, vacation, sickness
29
or disability policy and the absence qualifies for pay
under such policy.
Employees who are absent from work for jury duty,
attendance as a witness or military leave may have
their salary reduced by the amount of payment they
receive in the form of jury fees, witness fees or
military pay. Their salary will not be reduced by the
number of hours or days they are absent unless they
perform no work during a given week.
Employees may be suspended without pay for
various types of workplace misconduct, but only in
full day increments. This refers to suspensions
imposed according to a written policy applicable to
all employees regarding serious misconduct,
including, but not limited to, workplace harassment,
violence, drug and alcohol violations, legal violations,
etc. The possibility of such unpaid suspensions is
hereby incorporated into all such policies.
Employees who work less than forty (40) hours
during their first and/or last week of employment will
be paid a proportionate part of their full salary for
the time actually worked.
Employees who take leave under the Family and
Medical Leave Act will not be paid for that time
unless they have accrued paid time off under the
Company paid time off, vacation, sickness or
disability policy, if any.
This policy is subject to applicable law. The Company
will follow the state law regarding reduction of
exempt employees’ salaries if the state law is more
favorable to employees.
If an exempt employee believes there has been an
improper deduction or reduction in his or her salary,
the employee should immediately report it to his or
her supervisor or to the Human Resources Office.
The Company will investigate and if an error has
been made, the employee will be promptly
reimbursed for any salary reduction. In addition, the
Company will take steps to insure that such
improper deductions do not happen again in the
future.
HOURS OF WORK
By being ready, willing and able to serve customers
efficiently at any time and competing fairly in the
marketplace and producing a quality product, we
increase the opportunity for maintaining a steady
flow of work. Therefore, normal operating hours for
employees may vary. Supervisors will arrange lunch
and rest break schedules. In order to facilitate the
smooth flow of business and to adequately cover the
phones, lunch breaks may be staggered and may
change to meet the needs of The Company. The
Company’s normal workweek begins on Sunday and
ends on Saturday of each week. Actual hours of
work will vary by location, position and business
needs. Supervisors are responsible for providing
employees with specific working hours based on
departmental and local needs. Variations from
established work schedules must be approved by the
appropriate supervisor.
INCLEMENT WEATHER
Company locations are generally considered to be
officially open during normal business hours, which
at most locations is 8 a.m. to 5 p.m. If hazardous
weather conditions or a building maintenance
emergency occurs during the workday, the Campus
President or appropriate senior manager may decide
to close the location early. In the event that this
occurs, employees will be paid for the remainder of a
normal workday, based on their specific position.
This is considered non-worked hours for purposes of
calculating overtime.
If, before the start of the workday, hazardous
weather conditions or a building maintenance
emergency occurs, the Campus President or
appropriate senior manager may decide to close the
location for the day. It is the employee’s
responsibility to contact his/her supervisor if s/he
has a question about whether or not to report to
work. Non-exempt employees will be paid for the
first day of such closure, but not for subsequent
days. If a campus is closed, non-exempt employees
will be paid for eight (8) hours or the standard daily
shift, whichever is less, at their regular rate for the
first day of closure. Employees must call in daily to
see if the campus remains closed, but will not be
paid for subsequent days.
OVERTIME
The Company will pay overtime to all non-exempt
employees at the rate of time and one-half for all
hours worked in excess of forty (40) per workweek.
If state law differs, you will be paid according to the
state law. For overtime pay calculation purposes for
nonexempt employees, the work day at StrataTech
begins at 12:01 a.m. and ends at midnight. The
work week begins at 12:01 a.m. on Sunday and
ends on the following Saturday for all employees.
Exempt employees do not receive overtime
compensation.
For purposes of determining which hours constitute
overtime, only those hours that are actually worked
are added together to determine an employee's
overtime pay. Hours paid for time not worked such
as holidays, personal holidays, and paid time off, for
example, are not hours worked, and therefore are
not counted in making overtime calculations.
Overtime hours are distributed as fairly as practical
among qualified employees regularly performing
those jobs scheduled for overtime. When it is
necessary to schedule overtime, employees
performing jobs during regularly scheduled working
hours will normally be expected to work the overtime
hours on the same jobs. As much notification as
30
possible of overtime requirements will be given in
advance.
You must always have the authorization and
approval of your supervisor prior to performing the
work. Failure to obtain approval before working
overtime or refusal to work overtime may result in
disciplinary action, up to and including termination.
PAYROLL DEDUCTIONS
StrataTech is required by law to make deductions
from employees’ pay for federal income tax, social
security and Medicare, state taxes, and legal
garnishments or levies. The amount deducted for
each item is shown on the stub of each employee’s
paycheck. Each year, every employee will receive a
W-2 form showing his or her total earnings for the
year and the amount of taxes withheld from the
employee’s paycheck. Any other deduction from an
employee's paycheck must be authorized by the
employee.
PAY DAY
All employees will be paid on a regular basis. For
paydays falling on a bank holiday or weekend, you
will be paid the prior business day.
If you are absent on payday and someone else is to
pick up your check, it will not be released without a
signed, handwritten note from you authorizing the
named person to pick it up. The person designated
to pick up your check will be asked to produce
identification satisfactory to management;
otherwise, your check will not be released. Any
deviations from this procedure must have prior
approval from an officer of the Company.
You may also authorize the Payroll Department to
directly deposit your paycheck to a bank of your
choice.
ERRORS IN PAY
Once you receive your paycheck or proof of payment
from your supervisor, please examine it carefully to
ensure that the amount is correct. Every effort is
made to avoid errors in your paycheck. If you
believe an error has been made, contact the campus
Human Resources. The Company will take the
necessary steps to research the problem and to
assure that any necessary correction is made
promptly.
FINAL PAY
Employees separated from employment, voluntarily
or involuntarily, will be paid for all time worked
through the final day of employment. Final pay will
be issued on the next regularly scheduled payday or
in accordance with state regulations, whichever is
sooner. Accrued but unused PTO will be included in
final pay. Employees are responsible for repayment
of debt to the Company on or before the last day of
work, in accordance with applicable law.
RECORDING TIME WORKED
If you are an hourly employee, you must record your
hours on a daily basis by clocking in at the start of
each shift; clocking out for lunch; clocking in upon
returning from lunch; and clocking out at the end of
each shift.
You are responsible for your time card. No one else
may record hours worked on your time card. Any
error(s) on your time card needs to be corrected by
your supervisor.
Altering, falsifying, removing, or destroying any
time-keeping record is strictly prohibited. Engaging
in any of these practices may result in disciplinary
action, up to and including termination.
Failure to follow time keeping policies and/or
procedures may result in disciplinary action, up to
and including termination.
SHIFT PREFERENCES AND WORK SCHEDULES
All employees are required to work on any shift
assigned, and are expected to be at their desks or
work stations at the start of their scheduled shifts,
ready to perform their work.
Exchanging work schedules with other employees is
not allowed without the prior authorization of both
employees’ supervisors. Authorization will not be
granted if the exchange interferes with the
Company’s operations.
StrataTech reserves the right to change an
employee’s work schedule, including start and end
times, and to assign employees to jobs and shifts
other than their usual assignments, with or without
notice.
MEAL AND REST PERIODS
MEAL PERIODS
Each employee scheduled to work more than 5 hours
a day is required to take an unpaid meal period.
Non-exempt employees should clock out when
leaving for the meal period and clock in when
returning to work. Directors can schedule the meal
period to be a minimum of 30 minutes, but may
schedule it to be longer if necessary for scheduling
purposes. If there is a business reason which
prevents an employee from taking an unpaid meal
period during their shift, the opportunity to take a
break will be provided to that employee. This
situation must be pre-approved by the Director.
Employees may not leave early or extend their meal
periods without the prior authorization of their
supervisors. Employees who are tardy when
returning from a meal period may be subject to
disciplinary action, up to and including termination.
31
REST PERIODS
Each employee receives a fifteen (15) minute paid
rest period for every four (4) hours of work or major
portion thereof. Employees should not clock out for
rest periods. Employees are not permitted to leave
the premises during rest periods, and may not take
more than fifteen (15) minutes for each rest period.
Employees who are tardy when returning from a rest
period may be subject to disciplinary action, up to
and including termination.
TIME AWAY
FROM WORK
ABSENCES AND TARDINESS
Each employee is expected to report promptly for
work as scheduled. Tardiness and/or absences
cause problems for fellow employees and for the
members of management. When you are absent for
any reason, it creates a hardship on your co-workers
and makes it difficult to operate effectively. This
hurts business as customers may not be properly
served, and other employees may have to perform
your job functions in addition to their own. For these
reasons, the Company has established the following
attendance policy:
EXPECTED ABSENCE
You must notify your supervisor at least two (2) days
in advance of any expected absence. The Company
will make reasonable efforts to grant your request.
However, the Company reserves the right to
schedule time off for employees in its sole discretion.
UNEXPECTED ABSENCE
You must personally call your immediate supervisor
as soon as possible in case of an unexpected
absence. Specifically, you should call as least
two (2) hours before the beginning of the work shift
and advise your supervisor of your need to be absent
and when you expect to return to work. However,
this doesn't mean that the absence will be
considered excused.
In all cases of absence or tardiness, employees must
provide a reason or explanation satisfactory to the
Company. Employees also must inform their
supervisor of the expected duration of any absence,
and must call both on the first day and on each
subsequent day of unscheduled absences. If an
employee is absent from work due to sickness or
injury for three (3) consecutive days or more, the
employee must provide a doctor’s note certifying
that he or she is fit to return to work.
An employee who is absent from work for two (2)
consecutive days without notifying his or her
supervisor or obtaining permission for such absence
will be considered to have voluntarily terminated
employment.

Excessive absenteeism (excused or not) may result
in disciplinary action, up to and including
termination.
TARDINESS
An employee who arrives late to work or who leaves
work early is considered “tardy.” “Late” means any
length of time after the work shift is scheduled to
begin, and “early” means any length of time before
the work shift is scheduled to end. Arriving
excessively late or leaving excessively early may be
counted as a full day’s absence.
Excessive tardiness (excused or not) may be
grounds for discipline, up to and including
termination.
BEREAVEMENT LEAVE
The Company provides bereavement leave as
follows: An employee who has a death in the
immediate family will be eligible for up to three
(3) days of excused absence with pay at straight
time (excluding shift premiums). Immediate family
includes the employee's spouse or significant other,
parent, stepparent, grandparent, child, stepchild, or
sibling. The employee will be granted up to two (2)
days off from work with pay for the death of the
employee's spouse's parent, spouse’s grandparent,
spouse’s sibling or a sibling’s spouse; employee’s
aunt, uncle, niece, nephew, cousin, grandparents or
grandchildren. This excused absence will be granted
to you under the following conditions:
1. The period of excused absence shall
occur between the day of death in
the family and the day following the
funeral.
2. Pay for the absence will be made for
actual time lost from work. If the
period of absence occurs at a time
when you are not scheduled to work,
payment will not be made for such
time.
3. An excused absence for the death of
a family member may not be
retroactive, postponed, or split.
4. Consideration will be given to
exceptions to the above rules only in
the most unusual instances. All such
exceptions must be approved by the
Company.
Employees may wish to request additional time off,
and use of paid time off is permitted. Supervisors
are expected to use their discretion and, to the
greatest extent possible, act with the best interest of
the employee in mind when coordinating an
employee's time off after the death of a family
32
member. The Company reserves the right to require
verification of the death if paid time off is requested
or granted.
JURY DUTY
The Company recognizes it is a civic responsibility to
report for jury duty when selected. If a full time non-
exempt employee is summoned to jury duty, the
Company will continue his/her pay for up to two
(2) working days of jury service per calendar year. If
a full-time non-exempt employee is required to
serve more than two (2) working days of jury service
in a calendar year, he/she will be allowed additional
time off without pay to complete the jury
service. The Company will pay a non-exempt
employee for jury duty in excess of two (2) days
only to the extent required under applicable law. If
an exempt employee reports for a full workweek of
jury duty and does no work for the Company, the
Company will pay him/her for up to two working
days. However, if the exempt employee does any
work for the Company, the exempt employee is
considered to have worked during the workweek and
is entitled to a full week of pay. If state laws differ,
we will pay according to state law. Employees must
notify their supervisor as soon as it is known jury
duty will be extended. An employee is also permitted
to retain the allowance he/she receives from the
court for such service.
All employees are allowed unpaid time off if
summoned to appear in court as a witness. To
qualify for either jury or witness duty leave, an
employee must submit to his/her supervisor a copy
of the summons as soon as it is received. In
addition, the employee must also submit to the
employee's supervisor a related proof of service
when the period of jury or witness duty is
completed. No adverse employment action will be
taken against employees due to their service as
either a juror or witness in state or federal courts.
If the requirement of jury duty comes at a critical
time as far as the operations of the department or
Company and/or the employee's absence would be a
detriment, s/he should request, in writing, to be
excused from jury duty. Employees must report to
work immediately upon dismissal from jury duty.
LEAVES OF ABSENCE
FAMILY AND MEDICAL LEAVE
The Company’s medical leave policy complies with
the Family Medical Leave Act ("FMLA"). The FMLA
requires that all employers with fifty (50) or more
employees provide all eligible employees with unpaid
leaves of absence for the purposes described below.
Employee Eligibility
Any employee who has completed at least twelve
(12) months of service and has worked at least
1,250 hours of service during the twelve (12)-month
period preceding the date a leave would begin may
request an unpaid family and medical leave of
absence. An employee must also work within a
seventy-five (75)-mile radius of fifty (50) or more
employees of the organization in order to be eligible
for a leave under this policy. Subject to the
conditions of this policy, eligible employees may
request up to twelve (12) weeks family and medical
leave during a twelve (12)-month period. The twelve
(12)-month period used to measure the twelve (12)-
week limitation commences on the first day that the
employee’s first FMLA leave begins.
Permissible Purposes of a Family and Medical
Leave
An eligible employee may request a family and
medical leave for any of the following reasons:
(1) the birth of the employee's child; (2) the
placement of a child with the employee in connection
with an adoption or foster care; (3) to care for a
child, parent, or spouse who has a serious health
condition; (4) due to a serious health condition that
prevents the employee from performing the
functions of his or her position; or (5) because of
any qualifying exigency arising out of the fact that
the spouse, or a son, daughter, or parent of the
employee is on active duty (or has been notified of
an impending call or order to active duty) in the
Armed Forces in support of a contingency operation;
or an eligible employee may request up to twenty-six
(26) workweeks of leave during a single 12-month
period to care for a covered servicemember with a
serious injury or illness if the eligible employee is the
servicemember’s spouse, son, daughter, parent, or
next of kin (military caregiver leave).
To the maximum extent permitted by law, any leave
of absence that is granted to an employee under this
policy or any other policy for a purpose specified
above shall be credited against the twelve (12)
and/or twenty-six (26) week limit contained in this
policy.
Integration with Other Benefits
Employees are not paid by StrataTech during a
family and medical leave of absence, and must
exhaust their accrued but unused PTO as a condition
of their leaves. These benefits are integrated so that
employees do not receive over one hundred (100)
percent of their regular pay. PTO will not accrue
during a leave of absence.
Health Insurance Benefits During Family and
Medical Leave
Health insurance benefits provided by the Company,
and for which the employee is otherwise eligible, will
be continued during the period of the leave. The
Company will continue to pay its share of the
premiums for the period of the leave, up to a
maximum of twelve (12) weeks. The employee must
pay the share of the premiums he or she was paying
prior to the leave by making timely payments to the
Company at the same time as such payments would
be made if they were paid via payroll deductions.
The employee should make arrangements with
33
management or his or her designee to pay the costs
of such coverage.
Notification Rules
An employee must provide proper notification as a
condition of eligibility for a leave. The employee
must notify the Human Resources Department in
writing of the need for such a leave, the date it will
commence, and the anticipated duration of the
leave. If the employee knows of the event that
necessitates the leave more than thirty (30) calendar
days in advance of the date the leave is needed, the
employee must provide such notice in writing a
minimum of thirty (30) days before the leave will
begin. If the employee learns of the event less than
thirty (30) days before the date the leave must
begin, the employee must provide as much advance
notice as practicable. A failure to comply with these
notice rules may result in a denial or postponement
of the requested leave until the employee complies
with these rules. However, if the need for a family
and medical leave results from an emergency or is
otherwise unforeseeable, the leave will not be denied
simply because an employee fails to provide advance
notice.
Certification by Health Care Provider
If an employee requests a leave due to a serious
health condition of the employee or a family
member, the employee must support the request
with a certification issued by the health care provider
of the individual with the serious health condition.
The certification should include the following
information: (1) the date, if known, on which the
serious health condition commenced; (2) the
probable duration of the condition; (3) an estimate
of the amount of time that the health care provider
believes that the employee needs to care for the
individual requiring the care; and (4) a statement
that the serious health condition warrants the
participation of a family member to provide care
during a period of the treatment or supervision of
the individual requiring care. If an employee
requests intermittent leave for planned medical
treatment, the certification should specify the dates
on which such treatment is expected to be given and
the duration of such treatment. If the time
estimated by the health care provider specified
above expires, the employee must submit a re-
certification if the employee desires additional leave.
In addition, extensions will not be granted that cause
the total period of the leave to exceed the twelve
(12) week limitation identified above.
Intermittent Leave
If an employee requests an intermittent leave, it
may be necessary for the Company to temporarily
transfer the employee to another position for which
he or she is qualified, that has equivalent pay and
benefits, and that better accommodates an
intermittent or reduced time leave.
Employee Status
Employees will retain their employee status during
the period of a family and medical leave. Moreover,
their absence shall not be considered a break in
service for purposes of determining their longevity or
seniority. Once an employee returns from a leave,
the employee will be credited with all seniority and
service accrued before the leave of absence
commenced.
Re-employment Privileges
Except where the law authorizes a different result,
an employee who complies with the provisions of this
policy will be guaranteed re-employment upon
expiration of an approved leave, provided that the
total period of the leave does not exceed twelve (12)
weeks. The employee will be re-employed in the
same or an equivalent position as that which he or
she occupied when the leave commenced. An
employee who takes a leave because of his or her
own serious health condition must provide a medical
certification verifying that he or she is able to return
to work in the same manner as employees who
return from other types of medical leave. If an
employee fails to return for work immediately after
the period of the approved leave expires, the
employee will be considered to have voluntarily
separated from employment.
Please contact the Human Resources Department for
detailed information regarding the Company's
policies and procedures for Family and Medical
Leave.
MILITARY FAMILY LEAVE
Military Caregiver Leave
Under the new regulations, eligible employees who
are family members of covered service members are
able to take up to 26 workweeks of leave in a “single
twelve-month period” to care for a covered service
member who: (1) is on the temporary disability
retired list; (2) has a serious injury or illness
“incurred in the line of duty on active duty” for which
he or she is undergoing medical treatment,
recuperation or therapy; or (3) is otherwise on
outpatient status. For purposes of calculating leave
entitlement, the regulation provides that the single
twelve-month period “begins on the first day the
eligible employee takes FMLA leave to care for a
covered service member,” regardless of the method
used by the employer to determine the employee’s
twelve workweeks of leave entitlement for other
FMLA-qualifying reasons.”
Qualifying Exigency Leave
The new regulations also address the second type of
new military family leave entitlement. Specifically,
the regulations provide the normal twelve
workweeks of FMLA job-protected leave to eligible
employees with a covered military member serving
in the National Guard or Reserves to use for any
“qualifying exigency” arising out of the fact that such
member is on active duty or called to active duty
34
status. The regulations define “qualifying exigencies”
to include the following eight items (with various
caveats): (1) short-notice deployment; (2) military
events and related activities; (3) childcare and
school activities; (4) financial and legal
arrangements; (5) counseling; (6) rest and
recuperation; (7) post-deployment activities; and (8)
“additional activities” not addressed in the other
categories, provided that both the employer and the
employee agree to the timing and duration of such
leave.
StrataTech complies with all military laws under
USERRA. Please contact the Human Resources
Department for additional information regarding
Military Family Leave.
PERSONAL LEAVE AND/OR NON-
FMLA MEDICAL LEAVE
Leaves may be granted in situations where an
employee needs time away from work to attend to
issues of a personal nature. Up to six weeks of leave
may be requested under this policy.
A leave of absence under this policy is an absence
without pay. An employee must use all accrued PTO
at the beginning of a leave.
The Company’s decision for granting or denying a
request for a leave of absence under this policy will
be based on such factors as the reason for the
request; the anticipated impact of the leave on the
Company; the Company’s ability to replace you or
reassign your duties during your absence; your
performance, conduct, attendance, and responsibility
level; your length of employment; as well as other
relevant factors.
Approval of medical and personal leave is at the sole
discretion of the Company.
• Employee Notification: If the need for leave is
foreseeable, the employee is required to formally
request the leave through his/her supervisor.
Personal leave is granted approval by the Human
Resources Director.
• Benefits: An employee who takes leave under this
policy will receive the same benefits plan coverage
s/he would have if s/he were working, with one
exception: employees do not accrue PTO during the
leave. The Company will continue to make its
contributions to maintain the employee's health and
dental coverage, as well as the base-level life,
accidental death and dismemberment, and short-
and long-term disability coverage, provided the
employee payments are received on a timely basis
and in full to accounting.
During leave, employees must utilize paid time off to
cover the leave period. After exhaustion of paid
leave, employees must make payments for their
portion of the medical and dental plan coverage, as
well as any other voluntary benefits they wish to
maintain. Payments are due on the first day of the
month for which coverage is desired. If payments
are not timely, benefit plan coverage may be
terminated.
The employee's performance appraisal and related
merit increase date is not affected by a leave of
absence of less than 30 calendar days.
• Job Protection: Personal and/or non-FMLA medical
leave is not a job protected leave; therefore the
Company cannot guarantee that a position will be
held for an employee who utilizes this leave, but a
reasonable attempt will be made to place the
employee in the same or a similar position at the
end of an approved leave.
If a position held by an employee on leave is deemed
critical to the Company and a replacement is sought
for the employee’s position while s/he is out on
personal leave, s/he will be notified of this action and
his or her employment will be terminated at such
time as a candidate is identified for the employee’s
position. The employee on leave will be eligible to
apply for any open position with the Company once
s/he is ready to return from leave.
OTHER LEAVES
Other state and federal laws may require that the
Company allow Employees to take leave time. The
Company will comply with all state and federal laws.
For more information, contact your Human
Resources representative.
PAID HOLIDAYS
Listed in the following paragraph are the Company's
paid holiday days for the remainder of 2017 and the
2018 calendar year. Regular full-time employees are
eligible for paid holidays during each calendar year.
To receive holiday pay, a non-exempt employee
must have completed 30 calendar days of service.
In addition, employees are required to work their
regularly scheduled work day before and after the
holiday, unless they have an excused absence. An
employee with an unexcused absence immediately
prior to or immediately after a designated holiday
will not be paid for the holiday.
If an eligible non-exempt employee works on a
company-observed holiday as outlined below, the
employee will receive holiday pay plus wages at their
straight time rate for the hours worked on the
holiday. Holiday pay is not considered time actually
worked for purposes of calculating overtime.
Holiday pay is equivalent to eight hours' pay or the
standard daily shift, whichever is less, based on the
employee's specific position.
If an exempt employee works on a paid holiday, s/he
will be granted an alternate day off.
35
The Company observes the following holidays:
Remaining 2017 Paid Holidays
November 23 & 24-17 – Thanksgiving Day and
the Friday after
December 25, 2017 – Winter Holiday
Two Floating Holidays*
*Use of the two floating holidays must occur during
2017 and must be pre-approved by your supervisor
for scheduling purposes.
Calendar Year 2018 Paid Holidays
January 1, 2018 – New Year’s Day
January 15, 2018 – Martin Luther King, Jr. Day
May 28, 2018 – Memorial Day
July 4, 2018 – Independence Day
September 3, 2018 – Labor Day
November 12, 2018 – Veteran’s Day
November 22 & 23, 2018 – Thanksgiving Day and
The Friday after
December 24 & 25, 2018 – Winter Holidays
PAID TIME OFF
Paid Time Off (PTO) is provided by the Company for
employees to be away from work due to vacation,
illness, or other personal requirements. All full-time
regular employees are eligible for PTO on a pro-rated
anniversary year basis. The established PTO period
is from the employee’s anniversary date.
Employees will begin accruing PTO as of their date of
hire. Employees may begin using PTO time after
completing 30 days of continuous service. All year-
end transactions will occur on the last pay period of
the Company’s fiscal year ending September 30th.
Employees will not earn PTO while on any type of
leave.
The PTO earned will accrue each pay period. PTO
earned and used is calculated and tracked through
our payroll time keeping system. If you feel there is
an error in the accrued PTO hours you have available
as reflected on your paystub, please contact Human
Resources immediately.
All accrued paid time off must be taken before
unpaid time is taken. Employees may allow their
PTO balance to go negative but only with Human
Resources and their Campus President’s prior
approval and not in a manner that exceeds 80 hours.
Negative PTO will only be allowed if the negative
amount will be accrued back prior to the end of the
fiscal year. There will be no carry over of negative
PTO to the new fiscal year. Upon termination of
employment, PTO used but not accrued at the time
employment ends will be deducted from the
employee’s final paycheck to the extent permitted by
law.
Employees who provide less than two weeks written
notice of termination of employment will not receive
a PTO payout.
issue, whether or not PTO is used, to the extent
permitted by law.
PTO time does not accrue during an unpaid leave of
absence and is paid out upon employment
termination. PTO may not be used to extend an
employment termination date.

Employees entitled to PTO will, with due

PTO Cash-Out and PTO Carry Over
consideration of the scheduling needs of the
company, be permitted to take their PTO at the Accrued, but unused, PTO will not be carried over
requested time provided that a time off request has from one fiscal year end to the next fiscal year;
been submitted in a timely manner and approved by however, based on the number of years you have
the employee’s supervisor. been with the Company, you may be eligible to be
paid out unused PTO according to the schedule
Non-exempt employees can request PTO in below. This payment will be received after the close
increments compatible with their time-keeping of the fiscal year.
system. Exempt employees PTO will be deducted in
full and half day increments. Length of PTO Payout
Service
Employees hired prior to October 3, 2014, unless 1st year No PTO Payout
otherwise noted in the employee’s employment Year 2- 5 Payout up to 1 week
agreement, PTO is as follows: Year 6 – 20 Payout up to 2 weeks
Year 20+ Payout up to 3 weeks
Length of Service
In the event that your state has adopted an act in
Length of PTO Per Year Maximum
regards to earned paid sick time, you will be
Service Accrual
provided notification of such act and your rights.
Year 0-1 3 “weeks” PTO
Year 2- 5 4 “weeks” PTO
Year 6 – 20 5 “weeks” PTO VOTING
Year 20+ 6 “weeks” PTO It is the policy of the Company to permit employees
Maximum level of PTO to be absent from work to vote in local, state or
accrual is set at 240 hours. national elections. Employees who cannot reach
No additional PTO accrual their polling place outside of work hours will be
after 20 years of service. permitted paid time off to vote. The time off to vote
may not exceed three (3) hours. Evidence of voting
Employees hired on or after October 3, 2014, unless may be required.
otherwise noted in the employee’s employment
agreement, PTO is as follows:

Length of Service
BENEFITS
Length of PTO Per Year Maximum GENERAL INFORMATION
Service Accrual The Company seeks to provide eligible employees
Year 0-1 2 “weeks” PTO with balanced and competitive benefits plans.
Year 2- 5 3 “weeks” PTO Below is a summary of our benefits package.
Year 6 – 20 4 “weeks” PTO
Year 20+ 5 “weeks” PTO
Medical, Dental and Vision Insurance
Maximum level of PTO
accrual is set at 200 hours. Short Term Disability
No additional PTO accrual Long Term Disability
after 20 years of service. Life Insurance
AD&D
Voluntary Life Insurance
A “week” equals the average number of hours
Voluntary Cancer, Critical Illness,Whole Life &
worked per week for those employees entitled to
Accident Plans
PTO.
Flexible Spending Account
The Company reserves the right to request a 401(k)
doctor's notice for any absence for which an Tuition Reimbursement
employee reports an absence is due to a medical

36
During new hire orientation, employees will be
provided with comprehensive information regarding
all health and welfare benefits and afforded the
opportunity to enroll in those plans for which they
are eligible. Benefit plan coverage, unless otherwise
specified, begins on the first day of the month
following 30 days of employment for eligible
employees.
EMPLOYEE ASSISTANCE
PROGRAM (EAP)
Unlimited free telephonic consultation with an
Employee Assistance Program counselor is available
24/7 and includes up to three sessions free of charge
with local counselors. The program includes help
with education, dependent care and care giving,
legal and financial, lifestyle and fitness management,
and working smarter. Contact the local campus
representative for more information.
BENEFITS CONTINUATION
In accordance with the requirements of the
Consolidated Omnibus Budget Reconciliation Act
(“COBRA”), eligible employees and their family
members may continue participation in StrataTech’s
group health insurance program following certain
“qualifying events.” These “qualifying events”
include an employee’s termination, resignation,
reduction in hours, divorce, legal separation, death,
Medicare entitlement, and certain other events.
A notice that contains information regarding COBRA
rules is presented to employees when they become
eligible for participation in the Company’s group
health plan and, again, when they experience a
“qualifying event” that triggers the right to continue
participation in the group health plan. The notice
contains important information regarding employees’
rights and obligations under COBRA.
2. Seek medical treatment and follow-up care if
required;
3. Complete a written Employee's Claim
Form and return it to your Human
Resources within one business day of the
injury; and
4. Provide StrataTech with a certification from
your health care provider regarding the need
for workers' compensation disability leave
and your ability to return to work from the
leave.
Upon submission of a medical certification that you
are able to return to work, you will be offered the
same position held at the time of leaving, unless the
job has been filled in order to avoid undermining the
Company’s ability to operate safely and efficiently, or
you are not capable of performing the essential
functions of the job upon return. If your former
position is not available, a substantially similar
position will be offered unless there is no
substantially similar position available, or filling the
available position would substantially undermine the
Company’s ability to operate safely and efficiently, or
you are not capable of performing the job
responsibilities. If, after returning from workers'
compensation disability leave, you are unable to
perform the essential functions of the job because of
a physical or mental condition, StrataTech’s
obligations to you may include reasonable
accommodation, as governed by the Americans with
Disabilities Act.
Please see the Human Resources Department for
further information.

If you would like additional information, please

contact Human Resources.

WORKERS' COMPENSATION
INSURANCE
StrataTech is in full compliance with the law
requiring insurance coverage to protect its
employees who may be injured or become ill in the
course of performing their work. The Company pays
100% of the premiums on the insurance as required
by the State Workers' Compensation Act.

To ensure that you receive any workers'

compensation benefits to which you may be entitled,
you will need to:

1. Immediately report any work-related injury

to your supervisor and the Human Resources
department;

37
 RECEIPT OF EMPLOYEE HANDBOOK AND AGREEMENT FOR AT-
WILL EMPLOYMENT
I, the undersigned, hereby acknowledge receipt of the Employee Handbook of StrataTech. I acknowledge
and understand that it is my responsibility to read this Handbook and to ask Human Resources or any member of
management any questions that I may have about StrataTech’s policies, rules, or practices. I agree to accept the
policies, rules and procedures promulgated by StrataTech from time to time, as a condition of my employment.

I understand and recognize that this Handbook is not to be construed as a contract of employment, either
for an indefinite or fixed period of time. I recognize that StrataTech and I are both able to terminate the employment
relationship with or without cause, with or without notice, at any time.

I also recognize that there are no other agreements, either express or implied, with regard to the at-will
nature of the employment relationship, and that this agreement constitutes the entire understanding between me
and StrataTech with regard to the at-will nature of the employment relationship. This agreement for at-will
employment may not be modified, altered, amended, or changed except by an instrument in writing, signed by the
President.

I understand that the policies and practices set forth in the Handbook, other than the at-will status of my
employment, may be changed at any time at the sole discretion of StrataTech.

I also recognize that the existence of the policies and procedures set forth in the Handbook and the following
of those policies or procedures by StrataTech, shall not, and does not, alter the basic at-will status of this
employment relationship.

I acknowledge that it is my responsibility to read, understand and adhere to Company policies and to
familiarize myself with the contents of the Handbook.

Violations of any guidelines listed herein may result in disciplinary

action, up to and including immediate termination. If necessary, the
Company will advise appropriate legal officials of any illegal
violations.

Employee Signature Date

XXX - XX -

Print Name Last Four Digits of Social Security Number

Please sign and keep this acknowledgment for your records.

38