ECS DRIVING POLICY

(08/01/2019)

PURPOSE AND GOAL

ECS is committed to protecting the safety of our employees while reducing ECS’ exposure and liability as a
result of auto accidents. The purpose of this policy is to identify on a regular basis unsafe drivers by
restricting or eliminating their ability to put ECS at risk. By reducing or eliminating driving privileges, the
potential for accidents, associated costs, and injury to our employees is reduced.

For the purpose of this policy an ECS Vehicle is defined as any vehicle owned or leased by ECS or any
vehicle rented on ECS’ behalf and/or in ECS’ name and is covered under our insurance policies. Personal
vehicles are defined as any vehicle owned, leased, rented or borrowed by an employee that is used under the
control and discretion of the employee, and is not covered by ECS’ insurance policies.

MOTOR VEHICLE RECORD DISCLOSURE AND RELEASE

Upon application or employment, all individuals who drive their own vehicles on behalf of ECS, or who drive
ECS vehicles 1, will be subject to reviews of their driving record. The applicant or employee will be required to
sign the MOTOR VEHICLE RECORD DISCLOSURE AND RELEASE (EXHIBIT 1) and provide evidence of a
valid driver’s license (and personal automobile insurance if driving their own vehicle on behalf of ECS).
Driver’s license records will be checked at time of hire then at least annually for employees who drive their
own vehicles on behalf of ECS. Drivers of ECS vehicles will have their driving records monitored by a vendor
engaged by ECS. All checks of driving records will be performed by ECS Corporate Services Human
Resources department. .

Some states do not allow third party driving checks; others allow individuals to restrict access to their records.
Additionally, some states do not record or accept driving record information from other states. To preclude
incomplete records, the following requirements must be followed:

• Employees must provide information for countries and/or states in which they have held driver’s
licenses for the previous five years. Access to such information is incorporated into the MOTOR
VEHICLE RECORD DISCLOSURE AND RELEASE.
• Individuals who have driving records in a country, state or states that restrict individual driving records
to third parties shall provide such records upon request.
Employees shall immediately report all driving tickets, violations, convictions, suspensions, restrictions, or
loss of automobile insurance coverage to their supervisor. Individuals with a provisional license or
learners permit (or any license that restricts driving to include a licensed driver in the car), suspended
or revoked license, or without personal automobile insurance, will not be permitted to drive an ECS
vehicle, or personal vehicle on behalf of ECS regardless of the ECS driver’s point total. Supervisors
shall report such information to the local Office Manager, local HR Administrator, and the Director of
Corporate Safety. Disciplinary actions may be taken, up to and including termination of employment
(of the employee or employee’s supervisor) for withholding such information.

Employees driving their own vehicles on behalf of ECS shall notify their insurance company that their
vehicle is being driven for work purposes. The personal auto insurance company can refuse to provide
coverage in the event of an auto accident which occurs while driving on behalf of ECS. Furthermore, ECS’
automobile insurance provides no coverage for the employee or the employee’s vehicle. The mileage

1
Includes vehicles rented on behalf of ECS and/or under ECS’ name

ECS Driving Policy_2019 Page 1 of 8 Updated: 08/01/2019

reimbursement paid to employees considers increased insurance costs for employees driving their own
vehicle on behalf of ECS.

Each ECS office shall establish a control system to ensure that proof of personal automobile insurance is
current for each employee. Employees must provide proof of insurance upon policy renewal, which is
typically every 6 months.

INCIDENT NOTIFICATION
Employees driving their personal vehicle for ECS business or an ECS owned, leased or rented vehicle for
ECS business or personal reasons shall notify their supervisor or ECS Corporate Safety
(safety@ecslimited.com) as soon as practical, but not more than four hours later of any accident or citation
involving their personal vehicle while being used for ECS business an ECS vehicle driven for any purpose..
Failure to notify either their supervisor or ECS Corporate Safety within four hours may result in disciplinary
action, up to and including revocation of ability to drive an ECS vehicle or termination of employment.

Employees driving an ECS vehicle or their personal vehicle are solely responsible for the payment of any fine
or penalty associated with a driving citation or ticket. This includes but is not limited fines or penalties
associated with all moving and non-moving violations, an accident, parking, and toll violations. Fines or
penalties received by ECS for ECS vehicles will be passed to the employee driving the vehicle and may be
deducted from the employee’s pay.

DRIVING CRITERIA
Employees must hold a valid driver’s license in their current state of residence.
• Employees whose address does not match the state shown on their driver’s license will be
required to obtain a driver’s license with the correct address within 30 days of relocation or
their hire date. Failure to obtain a valid driver’s license as stated above shall result in the
employee being immediately removed from any job assignment requiring them to drive on
ECS’ behalf. The local HR Administrator shall track all employees whose address does not match
their state of residence and advise local management when the 30 day grace period has expired.
No employee under the age of 18 shall be allowed to drive an ECS vehicle or their personal vehicle while on
company business.

Individuals with a learners permit (in some states also called a Provisional License) will not be permitted to
drive any vehicle on ECS’ behalf

ECS uses an internal points system (EXHIBIT 2) to evaluate an employee’s driving history and to determine
the eligibility of that employee to drive on ECS’ behalf. This point system is separate from and has no
correlation to points assigned by any state, jurisdiction or insurance company.

• EXHIBIT 2 shall be used to assign points to an individual for violations or failure to comply with ECS
policy. An employee may have up to 8 points (maximum permissible points) to retain the ability of the
employee to drive their own vehicle on behalf of ECS. An employee with 9 or more points may
not drive their own vehicle on behalf of ECS, an ECS vehicle, or a vehicle rented on behalf of
ECS.

• An employee may have up to 4 points (maximum permissible points) to retain the ability to drive an
ECS vehicle. An employee with 5 or more points may not drive an ECS vehicle or a vehicle
rented on behalf of ECS.

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 • A plea of nolo contender or no contest is treated as a conviction. The Director of Corporate Safety
(and/or administrative designee) shall use reasonable judgment and discretion in the assignment of
violation points.

Employees with restricted driving privileges will be notified via memo from Corporate. Appeal of a decision by
the Director of Corporate Safety can be made by sending a written appeal to the Corporate Services Chief
Operating Officer. The appeal shall include the reason(s) an appeal is warranted, and shall be approved by
the employee’s supervisor, Office Manager, and Subsidiary President prior to submission.

PROBATIONARY DRIVING STATUS

A current employee who loses driving privileges as a result of exceeding the maximum permissible points by
no more than 3 points, and who has not completed an approved defensive driving course within the last year,
may request in writing probationary driving status for up to 30 days from the Director of Corporate Safety.
Probationary driving status will not be granted to applicants or employees with less than six months of service
with ECS. Once probationary status has been granted, proof of enrollment in an ECS-approved defensive
driving course (at employee’s expense) shall be provided to the Director of Corporate Safety within 10 days of
notification of loss of driving privileges.

Proof of successful completion of an approved defensive driving course shall be provided to the Director of
Corporate Safety within the 30 day probationary period. Successful completion of an ECS-approved
defensive driving course will result in a credit of 3 points being applied to the employee’s point total, and the
removal of probationary driving status, provided the employee’s point total is less than the maximum
permissible, and that a previous defensive driving course has not been credited within the last year.

If a defensive driving course is not successfully completed within 30 days of notification of exceeding the
maximum permissible point total(s), driving privileges will be revoked in accordance with the applicable
driving criteria(s).

DEFENSIVE DRIVING COURSE

Credit for a maximum of one ECS-approved defensive driving course will be given in any one year period. An
employee who wishes to be proactive and take a defensive driving course at their expense will be credited for
successful completion of the course, and can have a negative point total of up to -3 points. Additional
defensive driving courses are encouraged, but credit will be given to no more than one course in any one
year period. All costs incurred will be the responsibility of the employee. The employee will not be paid for
the time required to take the course, and mileage and tuition will not be reimbursed. The National Safety
Council Defensive Driving Class (4-hr format) (http://www.nsc.org/learn/Safety-Training/Pages/defensive-
driving-course-online.aspx) and the Driving University class for the employee’s state of licensure
(www.drivinguniversity.com) are the only ECS pre-approved courses.
The point reduction resulting from the successful completion of the approved defensive driving class will only
apply for one year after the date of the certificate of completion. The Defensive Driving Class will need
to be repeated for any subsequent years in which the employees point total exceeds the maximum
permissible points.

A supervisor has the right to require that the on-line course is completed in the local office with oversight by
an ECS employee approved by the local Safety Officer.

Successful completion of the course is demonstrated by an official certificate from the training program
selected.

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REINSTATEMENT OF DRIVING PRIVILEGES
Reinstatement of driving privileges is not automatic. It is the employee’s responsibility to request
reinstatement of driving privileges upon proof of having a point total equal to, or less than, the maximum
permissible points, a valid driver’s license, and personal automobile insurance (if driving personal vehicle on
behalf of ECS).

UNSAFE DRIVING PRACTICES

This policy is intended to encourage ECS employees to drive safely. This includes proper driving practices
and obeying all federal, state and local driving laws, avoiding driving distractions that impair a driver’s ability
to concentrate on the task of driving, and driving defensively.

In addition it is ECS’ policy that driving distractions must be controlled. Distractions can be physical, visual,
and mental, or a combination of distractions. Until public policy provides clear guidance, ECS’ requires that
driving distractions be handled as follows:

PROHIBITED Activities While Driving - Applies to both ECS owned vehicles and personal vehicles (when
driven for ECS business purposes):
• Using wired and wireless communication and entertainment devices (other than a mobile phones
voice function)
• Using a mobile phones key pad to enter a phone number in order to initiate a call
• Reading or sending text messages and email
• All forms of social media activity
• Reading written materials (including maps and directions)
• Programming navigation devices
• Operating a camera or video recording device
• Operating built-in vehicle driver information screens
• Personal hygiene activities
• Any activities that may contribute to distracted driving that are not on the PROHIBITED and
STRONGLY DISCOURAGED lists (except for phone use as permitted by this policy)
• Also prohibited are any of the following STRONGLY DISCOURAGED activities when driving in
heavy traffic conditions, congested areas, areas with numerous intersections, and/or adverse
weather conditions exist

STRONGLY DISCOURAGED Activities While Driving:

• Mobile phone use – including device and vehicle hands free systems
• Eating, smoking, and drinking

Local, state or federal laws that are more stringent than this policy shall be followed by employees driving in
those locations.

ECS at its discretion may install and/or require the use of software on company issued cell phones that
monitor the phone’s location and restrict some functions of the phone while the phone is in motion such as
when in a moving vehicle.

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INITIAL AND REFRESHER DRIVER TRAINING
Driver safety training is required for all ECS employees on a periodic basis. New employees are required to
participate in and complete the ECS Safe Driving Class including a review of the ECS Driving Policy before
they will be allowed to drive an ECS vehicle, their own vehicle on ECS’ behalf, or rent a vehicle on ECS’
behalf.

The ECS Driver Safety training module available through the ECS’ Learning Management System (LMS) will
be used to satisfy the initial and any refresher training requirement.

ON-GOING DRIVER IMPROVEMENT

ECS wants to reduce the number and severity of driving-related injuries for our employees. It does not matter
if the employee is injured while on the job or while on personal time, the goal is to reduce injuries.

Although, safety behaviors on project sites can be observed and discussed, the driving behaviors of
employees go largely unmonitored with the exception of the occasional complaint or compliment received via
the 1-800 driving hotline.

To help facilitate a more efficient and immediate means of monitoring our employees driving behaviors, ECS
may utilizes various hardware and software systems including GPS tracking units to monitor the location and
driving behavior of our employees when they drive an ECS owned or leased vehicle. ECS may also elect to
use data obtained from company issued cell phones to assess an employee’s location and driving behavior
while driving their personal vehicle on ECS business.

Employees are advised that these monitoring systems allows for real-time tracking of the vehicle location as
well as provide alerts for unsafe events such as excessive speed, high acceleration, hard braking, and phone
usage while the vehicle is in motion, and in some cases odd-hours usage.

Information gathered from these devices or systems may be used in determining an employee’s eligibility to
continue to drive an ECS owned or leased vehicle and may be used as a basis for disciplinary action up to
and including termination of employment when the driver’s behavior demonstrates a serious violation of law,
disregard for safety or protection of ECS property. ECS may take these actions even if no traffic citation or
conviction by a court has been issued.

Tampering with, disabling or removal of any electronic vehicle monitoring equipment including associated
wiring, vehicle signage installed in or on an ECS owned or leased vehicle or disabling software installed on
company issued cell phones shall be cause for accelerated disciplinary action, up to and including termination
of employment.

It is not ECS’ intention to monitor an employee’s travels and driving behaviors when an employee is on
personal time. However, when driving on behalf of ECS as an employee the driving behaviors demonstrated
reflect directly upon ECS’ reputation and may have a direct impact the employee’s safety during work hours.

Other than for legitimate business purposes no employee of ECS shall use any electronic monitoring device
or software to monitor an employee during off hours. Any employee guilty of unauthorized monitoring of
another employee’s activities using any of ECS’ monitoring systems shall be subject to disciplinary action, up
to and including immediate termination of employment.

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 EXHIBIT 1

MOTOR VEHICLE RECORD

DISCLOSURE AND RELEASE

In connection with my application for employment or my ongoing employment, should I have or secure a
position with ECS, I understand that motor vehicle records, which contain public record information, may be
requested in accordance with the ECS Driving Policy. I further understand that such report(s) will contain
personal information and public record information concerning my driving record from federal, state, and other
agencies that maintain such records, as well as independent services that provide driving record information.

I authorize, without reservation, any party or agency contacted to furnish the above mentioned information to
ECS or its agent.

I hereby authorize procurement of my motor vehicle report(s). If hired, this authorization shall remain on file
and shall serve as ongoing authorization for ECS to procure such reports at any time during my employment.
I also authorize ECS’ commercial auto insurer and agent to use this information in conjunction with loss
control and safety efforts.

If requested, a copy of the driver’s license shall be provided to your local HR department.

_______________________________ _____________________
Driver’s License Number State of Issuance

_______________________________ _____________________
Full Legal Name (include middle initial) Date of Birth

_______________________________ _____________________
Signature Date

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 EXHIBIT 2

ECS DRIVING POINTS ASSIGNMENT

Employees are cautioned to review footnotes where they are indicated
VIOLATION LOOK BACK
POINTS1,2 PERIOD (YRS.)4 VIOLATION DESCRIPTION

5 5 Conviction for driving under the influence of alcohol (DUI), drugs, or

similar convictions8
5 5 Testing positive for alcohol/drugs after an auto accident while using a
personal vehicle on behalf of ECS or while driving an ECS vehicle, and
including refusing to submit to alcohol/drug testing, or admission of
guilt7,8
5 1 Suspension or revocation of driver’s license5, driving on a suspended
or revoked license, or driving without current personal automobile
insurance
5 2 At-fault accidents1,6,8
5 2 Providing false information regarding license or insurance status, 4
1 Reckless driving conviction or similar convictions
4 1 Speeding conviction of 20 MPH or more over speed limit
3 1 Speeding conviction of less than 20 MPH over speed limit
3 1 Traffic Violation Related to Improper or Unsafe Equipment
3 3 Pattern of unsafe behavior and/or convictions3,8
3 1 Other moving violation
3 1 Seatbelt violation
3 1 Verifiable and plausible “Hot Line” Complaint
4 1 GPS indicated speed of 86 MPH or greater at any time in an ECS
owned or leased vehicle or during work hours in a personal vehicle
3 1 2 separate events9 (where employee has been notified) of GPS
indicated speeding10 of 20 MPH over the posted speed limit within any
90 day period
1 1 Non-moving vehicle violations (improper equipment, parking violation,
etc.)
-3 1 Successful completion of an ECS approved defensive driving course at
employee’s expense
1
Violation points may be assigned for accidents involving ECS vehicles or personal vehicles when driven for ECS business purposes
even if the accident does not appear on the employee’s driving record.
2
Where multiple violations are associated with a single event (e.g. speeding and seatbelt use), points are assessed only for the violation
with the highest point value and/or the longest look back period. However, points for each violation are assessed and totaled for those
items above denoted by Footnote 8.
3
Typically “pattern points” are assigned for any combination of three or more 800 number or hotline complaints, minor infractions, moving
violations, license suspensions, or revocations, appearing on the employee’s driving record within a 36 month period. Pattern points are
assigned using reasonable judgment and discretion by the Director of Corporate Safety.
Date of conviction is used where an official ruling on a violation is provided by a court; otherwise the date of the incident is used. Date of
4

conviction allows for charges which are dropped, reduced, or otherwise modified.

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5
No points shall be assessed for license suspensions or revocations where the suspension is due to non-vehicular administrative
actions. However an employee is prohibited from driving their personal vehicle for ECS, or driving an ECS vehicle while the employee’s
license is suspended or revoked for any reason.
6
Minor at-fault accidents without a citation and without any injuries to any person involved in the accident and resulting in damages of
$3,000 or less may be treated as any other moving violation at the discretion of the Director of Corporate Safety.
7
See ECS’ Substance Abuse and Drug-Free Workplace policy for additional restrictions and consequences related to the ability to drive
an ECS vehicle after any positive test for alcohol/drugs or refusing to submit to alcohol/drug testing.
8
Subject to assessment and totaling of points for each violation where multiple violations are associated with a single event (e.g.,
speeding and DUI).
9
Separate events are defined as GPS Speeding events that occur on different days.
10
GPS Speeding is defined as exceeding the posted speed for a continuous period of at least 4 minutes at any time while driving an ECS
owned, leased or rented vehicle or while driving a personal vehicle on ECS company business.

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