Victoria Transcultural Clinical Center, LLC

Employee Handbook

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 Table of Contents
NO. POLICY TITLE EFFECTIVE DATE
1. INTRODUCTION  
1.1 Handbook Disclaimer
08-01-2022

1.2 Welcome Message 08-01-2022

1.3 Changes in Policy 08-01-2022
1.4 Company Goals, Values, and Beliefs 08-01-2022

2. GENERAL EMPLOYMENT  
2.1 At-Will Employment 08-01-2022
2.2 Immigration Law Compliance 08-01-2022
2.3 Equal Employment Opportunity 08-01-2022
2.4 Equal Employment Opportunity (Virginia Employees) 08-01-2022
2.5 Employee Grievances 08-01-2022
2.6 Internal Communication 08-01-2022
2.7 Outside Employment 08-01-2022
2.8 Anti-Retaliation and Whistleblower Policy 08-01-2022
2.9 Conflict of Interest 08-01-2022
2.10 Licensing and Certification 08-01-2022
2.11 Open Door Policy 08-01-2022
2.12 08-01-2022
Employee Badges
3. EMPLOYMENT STATUS & RECORDKEEPING  
3.1 Employment Classifications 08-01--2022
3.2 Personnel Data Changes 08-01-2022
3.3 Expense Reimbursement 08-01-2022
3.4 Termination of Employment 08-01-2022
4. WORKING CONDITIONS & HOURS  
4.1 Emergency Closing 08-01-2022
4.2 Parking 08-01-2022
4.3 Workplace Safety 08-01-2022
4.4 Security 08-01-2022
4.5 Meal & Break Periods 08-01-2022
4.6 Break Time for Nursing Mothers 08-01-2022
4.7 Company Hours 08-01-2022
5. EMPLOYEE BENEFITS  
5.1 Health Insurance 08-01-2022
5.2 Health Insurance Continuation 08-01-2022
5.3 Holidays 08-01-2022
5.4 Paid Time Off (PTO) 08-01-2022
5.5 Employee Referral Program 08-01-2022
5.6 Family and Medical Leave 08-01-2022
5.7 Military Leave 08-01-2022
5.8 Military Leave (Virginia Employees) 08-01--2022
5.9 Jury Duty 08-01-2022
5.10 Jury Duty Leave (Virginia Employees) 08-01-2022
5.11 Workers' Compensation 08-01-2022
5.12 Crime Victims Leave (Virginia Employees) 08-01-2022
5.13 Election Duty Leave (Virginia Employees) 08-01-2022
6. EMPLOYEE CONDUCT  
6.1 Standards of Conduct 08-01-2022
6.2 Disciplinary Action 08-01-2022
6.3 Confidentiality 08-01-2022
6.4 Personal Appearance 08-01-2022
6.5 Workplace Violence 08-01-2022
6.6 Drug & Alcohol Use 08-01-2022
6.7 Sexual & Other Unlawful Harassment 08-01--2022
6.8 Telephone Usage 08-01-2022

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 6.9 Personal Property 08-01-2022
6.10 Use of Company Property 08-01-2022
6.11 Visitors in the Workplace 08-01-2022
6.12 Computer, Email & Internet Usage 08-01-2022
6.13 Company Supplies 08-01-2022
6.14 Smoking 08-01-2022
6.15 Cell Phones and Mobile Devices 08–01-2022
6.16 Training and Professional Development 08-01-2022
6.17 Company-Sponsored Events 08-01-2022
7. TIMEKEEPING & PAYROLL  
7.1 Attendance & Punctuality 08-01-2022
7.2 Timekeeping 08-01-2022
7.3 Paydays 08-01-2022
7.4 Payroll Deductions 08-01-2022
7.5 Direct Deposit 08-01-2022
7.6 Pay Corrections 08-01-2022
8. ORGANIZATIONAL DEVELOPMENT  
8.1 Required Training 08-01-2022
8.2 Augmentative Training 08-01-2022
8.3 Quarterly Counseling 08-01-2022
8.4 Punitive Counseling 08-01-2022
8.5 Bonuses 08-01-2022

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1. Introduction
1.1 Employee Handbook Disclaimer

The contents of this employee handbook (“Handbook”) supersede any prior handbook.  Neither this Handbook nor any other policy or practice
creates an employment contract or an implied or express promise of continued employment with the Company.  Employment with Victoria
Transcultural Clinical Center, LLC is "AT-WILL.” This means employees or Victoria Transcultural Clinical Center, LLC may terminate the
employment relationship at any time, for any reason, with or without cause or advance notice. As an at-will employee, it is not guaranteed, in
any manner, that you will be employed with Victoria Transcultural Clinical Center, LLC for any set period. 

This Handbook may provide a summary of employee health benefits; however, actual coverage will be determined by the express terms of the
benefit plan documents. If there are any conflicts between the Handbook or summaries provided and the plan documents, the plan documents
will be controlled. The Company reserves the right to amend, interpret, modify or terminate any employee benefits programs without prior
notice to the extent allowed by law.  

The Company also has the right, with or without notice, in an individual case or generally, to change any of the policies in this Handbook, or
any of its guidelines, policies, practices, working conditions, or benefits at any time.  No one is authorized to provide any employee with an
employment contract or special arrangement concerning terms or conditions of employment unless the contract or arrangement is in writing
and signed by either the Chief of Operations or the President and the employee. 

1.2 Welcome Message

Dear Valued Employee,

Welcome to Victoria Transcultural Clinical Center, LLC! We are pleased with your decision to join our team.

Victoria Transcultural Clinical Center, LLC is committed to providing superior quality and unparalleled customer service in all aspects of our
business. We believe each employee contributes to the success and growth of our Company.

This employee Handbook contains general information on our policies, practices, and benefits. Please read it carefully. If you have questions
regarding the Handbook, please discuss them with your supervisor or the Human Resources Department.

Welcome aboard. We look forward to working with you!

1.3 Changes in Policy

Change at Victoria Transcultural Clinical Center, LLC is inevitable. Therefore, we expressly reserve the right to interpret, modify, suspend,
cancel, or dispute, with or without notice, all or any part of our policies, procedures, and benefits, including those in this Handbook, at any time
with or without prior notice. Changes will be effective on the dates determined by Victoria Transcultural Clinical Center, LLC, and after those
dates, all superseded policies will be null and void.

No individual supervisor or manager has the authority to alter the preceding. Any employee unclear on any policy or procedure should consult a
supervisor or the Human Resources Department.

1.4 Company Goals, Values, and Beliefs

Our goal at Victoria Transcultural Clinical Center, LLC is simple: exceptional service delivery. We accomplish this by observing a common set
of values and by collaborating with all levels of professionals and organizations that have the finest reputation for quality. There are no
shortcuts; we believe that our goals are accomplished only with a real commitment from every employee.

Our values and beliefs require that we:

● Treat each employee fairly, providing opportunities to enhance how we improve our service.
● Treat employees and colleagues with respect; Victoria Transcultural Clinical Center, LLC does not tolerate discrimination.

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● Encourage all managers and supervisors to involve employees in creative problem-solving. When issues arise, an essential part of
dealing with them is understanding how to avoid them in the future.
● Provide consistent leadership and competent on-the-job training.
● Maintain an open-door policy that encourages interaction and discussion; promote ideas to improve the workplace and increase
productivity.
● Provide effective and efficient corrective action to resolve customer service issues, ensure complete customer satisfaction, and
avoid the recurrence of those issues.
● Deliver competitive, outstanding customer service and partner with vendors who share that goal.
● Make "Do It Right the First Time" our team attitude to ensure continued growth and prosperity.
● Display a high level of pride in the work that we do to support our community

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2. General Employment
2.1 At-Will Employment

Employment with Victoria Transcultural Clinical Center, LLC is "at will." This means employees are free to resign at any time, with or without
cause. Victoria Transcultural Clinical Center, LLC may terminate the employment relationship at any time, with or without cause or advance
notice. As an at-will employee, it is not guaranteed, in any manner, that you will be employed with Victoria Transcultural Clinical Center, LLC for
any set pre-period. The policies set forth outlined in Handbook are the policies that are in effect at the time of publication. They may be
amended, modified, or terminated at any time by Victoria Transcultural Clinical Center, LLC, except for the policy on at-will employment, which
may be modified only by a signed, written agreement between the COO or President and the employee at issue. Nothing in this Handbook may
be construed as creating a promise of future benefits or a binding contract between Victoria Transcultural Clinical Center, LLC and any of its
employees.

2.2 Immigration Law Compliance

Victoria Transcultural Clinical Center, LLC is committed to employing only candidates who are authorized to work in the United States.

In compliance with the Immigration Reform and Control Act of 1986, as amended, each new employee must complete the Employment
Eligibility Verification Form I-9 and present documentation establishing identity and employment eligibility. Former employees who are rehired
must complete a new I-9 with Victoria Transcultural Clinical Center, LLC.

Victoria Transcultural Clinical Center, LLC may participate in the federal government's electronic employment verification system, known as “E-
Verify.” Under E-Verify, Victoria Transcultural Clinical Center, LLC provides the Social Security Administration and, if necessary, the
Department of Homeland Security with information from each new employee's Form I-9 to confirm work authorization.

2.3 Equal Employment Opportunity

Victoria Transcultural Clinical Center, LLC is an Equal Opportunity Employer. Employment opportunities at Victoria Transcultural Clinical
Center, LLC are based upon one's qualifications and capabilities to perform the essential functions of a particular job.  All employment
opportunities are provided without regard to race, religion, sex, pregnancy, childbirth or related medical conditions, national origin, age, veteran
status, disability, genetic information, or any other characteristic protected by law.

This Equal Employment Opportunity policy governs all aspects of employment, including, but not limited to, recruitment, hiring, selection, job
assignment, promotions, transfers, compensation, discipline, termination, layoff, access to benefits and training, and all other conditions and
privileges of employment.

The Company will provide reasonable accommodation as necessary and where required by law so long as the accommodation does not pose
an undue hardship to the business.  The Company will also accommodate its employees' sincerely held religious beliefs to the extent that
accommodation does not pose an undue hardship to the business. If you would like to request accommodation or have any questions about
your rights and responsibilities, contact your Human Resources Department. This policy is not intended to afford employees any greater
protections than those which exist under federal, state, or local law.

Victoria Transcultural Clinical Center, LLC strongly urges reporting all instances of discrimination and harassment and prohibits retaliation
against any individual who reports discrimination, harassment or participates in an investigation of such report. Victoria Transcultural Clinical
Center, LLC will take appropriate disciplinary action, up to and including immediate termination, against any employee who violates this policy.

2.4 Equal Employment Opportunity (Virginia Employees)

Victoria Transcultural Clinical Center, LLC is an Equal Opportunity Employer. Employment opportunities at Victoria Transcultural Clinical
Center, LLC are based upon one's qualifications and capabilities to perform the essential functions of a particular job. All employment
opportunities are provided without regard to race, color, religion, sex, pregnancy, childbirth or related medical condition, national origin, marital
status, age, veteran status, disability, genetic information, or any other characteristic protected by law.

This Equal Employment Opportunity policy governs all aspects of employment, including, but not limited to, recruitment, hiring, selection, job
assignment, promotions, transfers, compensation, discipline, termination, layoff, access to benefits and training, and all other conditions and
privileges of employment.

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Victoria Transcultural Clinical Center, LLC strongly urges reporting all instances of discrimination and harassment and prohibits retaliation
against any individual who reports discrimination, harassment or participates in an investigation of such report. Victoria Transcultural Clinical
Center, LLC will take appropriate disciplinary action, up to and including immediate termination, against any employee who violates this policy.

2.5 Employee Grievances

It is the policy of Victoria Transcultural Clinical Center, LLC to maintain a harmonious workplace environment. Victoria Transcultural Clinical
Center, LLC encourages employees to express concerns about work-related issues, including workplace communication, interpersonal conflict,
and other working conditions.

Employees are encouraged to raise concerns with their supervisors. If not resolved at this level, an employee may submit, in writing, a signed
grievance to the Human Resources Department.

After receiving a written grievance, Victoria Transcultural Clinical Center, LLC may hold a meeting with the employee, the immediate
supervisor, and any other individuals who may assist in the investigation or resolution of the issue. All discussions related to the grievance will
be limited to those involved who can assist with solving the issue.

Complaints involving alleged discriminatory practices shall be processed per Victoria Transcultural Clinical Center, LLC's Sexual and other
Unlawful Harassment Policy.

Victoria Transcultural Clinical Center, LLC assures that all employing a grievance or complaint can do so without fear of retaliation or reprisal.

2.6 Internal Communication

Effective and ongoing communication within Victoria Transcultural Clinical Center, LLC is essential. The Company maintains systems through
which important information can be shared among employees and management.

Bulletin boards are posted in designated workplace areas to display important information and announcements. In addition, Victoria
Transcultural Clinical Center, LLC uses the Intranet and email to facilitate communication and share access to documents. For information on
relevant email and Internet usage, employees may refer to the Computer, Email, and Internet Usage polPolicyo avoid confusion, employees
should not post or remove any material from the bulletin boards.

All employees are responsible for checking internal communications frequently and regularly. Employees should consult their supervisor with
any questions or concerns on information disseminated.

2.7 Outside Employment

Employees may hold outside jobs as long as they meet the performance standards of their position with Victoria Transcultural Clinical Center,
LLC.

Unless an alternative work schedule has been approved by Victoria Transcultural Clinical Center, LLC, employees will be subject to the
Company's scheduling demands, regardless of any existing outside work assignment, including overtime availability when necessary.

Victoria Transcultural Clinical Center, LLC's property, office space, equipment, materials, trade secrets, and any other confidential information
may not be used for purposes relating to outside employment.

2.8 Anti-Retaliation and Whistleblower Policy

This policy protects employees and addresses Victoria Transcultural Clinical Center, LLC's commitment to integrity and ethical behavior. Under
anti-retaliation and whistleblower protection regulations, Victoria Transcultural Clinical Center, LLC will not tolerate any retaliation against an
employee who:

● Makes a good faith complaint or threatens to make a good faith complaint regarding the suspected Company or employee violations
of the law, including discriminatory or other unfair employment practices;
● Makes a good faith complaint or threatens to make a good faith complaint regarding accounting, internal accounting controls, or
auditing matters that may lead to incorrect or misrepresentations in financial accounting;

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 ● Makes a good faith report, or threatens to make a good faith report, of a violation that endangers the health or safety of an
employee, patient, client or customer, environment, or the general public;
● Objects to, or refuses to participate in, any activity, policy, or practice which the employee reasonably believes is a violation of the
law;
● Provides information to assist in an investigation regarding violations of the law; or
● Files testify, participate, or assist in a proceeding, action, or hearing concerning alleged law violations.

Retaliation includes any adverse employment action against an employee, including, but not limited to, refusal to hire, failure to promote,
demotion, suspension, harassment, denial of training opportunities, termination, or discrimination in any manner in the terms and conditions of
employment.

Anyone found to have engaged in retaliation or violation of law, policy, or practice will be subject to discipline, up to and including termination of
employment.  Employees who knowingly make a false report of a violation will be subject to disciplinary action, up to and including termination.

Employees who wish to report a violation should contact their supervisor or the Operations Officer directly. Employees should also review their
state and local requirements for additional reporting guidelines.

Victoria Transcultural Clinical Center, LLC will promptly and appropriately investigate and, if necessary, address any reported violation.

Employees with questions or concerns regarding this policy and related reporting requirements should contact their supervisor, the Human
Resources Department, or any state or local agency responsible for investigating alleged violations.

2.9 Conflict of Interest

A conflict of interest occurs when an employee’s interests interfere or appear to interfere with their ability to make sound business decisions on
behalf of the Company. Victoria Transcultural Clinical Center, LLC employees are responsible for avoiding any actual or potential conflicts of
interest as outlined in the guidelines below.

Conflict of interest includes, but is not limited to, the following scenarios:

● An actual or potential conflict of interest may occur when an employee can influence a decision or have business dealings on behalf
of Victoria Transcultural Clinical Center, LLC that might result in a personal gain for the employee or for one of the employee’s
relatives or friends.
● A conflict of interest may also occur when an employee has a financial interest in a business or venture that may conflict with
Victoria Transcultural Clinical Center, LLC’s interests.

While Victoria Transcultural Clinical Center, LLC does not automatically assume that there is a conflict of interest when an employee has a
relationship with another company, by informing us that there is the possibility of an actual or potential conflict of interest, we can establish
safeguards to protect everyone involved. All inquiries will be kept confidential to the maximum extent possible.

Violation of this policy may result in disciplinary action, including termination of employment.

This policy is not intended to restrict an employee’s right to discuss or act together to improve wages, benefits, and working conditions with co-
workers or in any way limiting’ rights under the National Labor Relations Act.

Questions or concerns regarding this policy should be directed toward your supervisor or the Human Resources Department.

2.10 Licensing and Certification

Victoria Transcultural Clinical Center, LLC is required by law to attain the certification of any employee whose duties require federal, state, or
agency licensing. Therefore, all individuals that fall under this category must be able to present verifiable before their starting date that such
requirements have been met and as may be requested after that.

Employees must also agree that their licenses and certifications will be maintained and kept current for their employment with the Company.
Failure to present or retain certification may result in disciplinary action, up to and including employment.

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Questions regarding this policy should be directed to the Human Resources Department.

2.11 Open Door Policy

Victoria Transcultural Clinical Center, LLC welcomes the opportunity to discuss business-related concerns and suggestions.  To this end, our
policy is to maintain an open the door to employees. Employees should feel free to discuss any questions, problems, complaints, or
suggestions with their supervisors or any member of management.

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3. Employment Status & Recordkeeping
3.1 Employment Classifications

For salary administration and eligibility for overtime payments and employee benefits, Victoria Transcultural Clinical Center, LLC classifies
employees as either exempt or non-exempt. Non-exempt employees are entitled to overtime pay by federal and state overtime provisions.
Exempt employees are exempt from federal and state overtime laws and generally pay a fixed amount of compensation for each workweek in
which work is performed.

If you change positions during your employment with Victoria Transcultural Clinical Center, LLC, or if your job responsibilities change, you will
be informed by the Human Resources Department of any change in your classification status.

In addition to your designations, either exempt or non-exempt, you also belong to one of the following employment categories:

Full-Time:
Full-time employees are regularly scheduled to work greater than or equal to 30 hours per week. For clinical staff, the obtainment of 30 or more
hours may be impacted by client availability. Full-time employees will maintain a full-time employment status when the primary reason for not
obtaining the minimum about of work hours is due to client availability, and not the employees a Generally, regular full-time employees are
eligible for Victoria Transcultural Clinical Center, LLC's benefits, subject to each benefit program's terms, conditions, and limitations.

Part-Time:
Part-time employees are regularly scheduled to work less than 30 hours per week. Regular part-time employees may be eligible for some
Victoria Transcultural Clinical Center, LLC benefit programs, subject to the teach benefit program's terms, conditions, and limitations
temporary:

Temporary employees include those hired for a limited time to assist in a specific function or in the completion of a particular task, generally are
not entitled to Victoria Transcultural Clinical Center, LLC benefits but are eligible for statutory benefits to the extent required by
law. Employment beyond any initially stated period does not in any way imply changes in employment status or classification. Temporary
employees retain temporary status unless and until they are notified, in writing, by Victoria by Victoria Transcultural Clinical Center, LLC
Management, in writing Data Changes

It is the responsibility of each employee to promptly notify the office or the Human Resources Department of any changes in personal data.
Such changes may affect your eligibility for benefits and your receipt of important company information.

If any of the following has changed or will change in the coming future, contact the main office or the Human Resources Department as soon
as possible:

● Legal name
● Mailing address
● Telephone number(s)
● Change of beneficiary
● Exemptions on your tax forms
● Emergency contact(s)
● Training certificates
● Professional licenses
● Driver’s license

3.3 Expense Reimbursement

Victoria Transcultural Clinical Center, LLC reimburses employees for necessary expenditures and reasonable costs incurred while doing their
jobs. Expenses incurred by an employee must be approved in advance by the Human Resources Department to qualify for reimbursement.

Some expenses that may warrant reimbursement include, but are not limited to, the following: air or ground transportation costs, lodging, meals
to carry out company business, and any other reimbursable expenses as required by law. Employees are expected to make a reasonable effort
to limit business expenses to economical options.

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To be reimbursed, employees must submit expense reports to the Human Resources Department for approval. The report must be
accompanied by receipts or other documentation substantiating the expenses. Questions regarding this policy should be directed to your
supervisor.

3.4 Termination of Employment

Termination of employment is an inevitable part of personnel activity within any organization, and many reasons for termination are routine.
Common circumstances under which work is terminated include the following:

● Resignation - Voluntary employment termination initiated by an employee.

● Termination - Involuntary employment termination initiated by Victoria Transcultural Clinical Center, LLC.
● Layoff - Involuntary employment termination initiated by Victoria Transcultural Clinical Center, LLC for non-disciplinary reasons.
● Retirement - Voluntary employee termination upon eligibility for retirement.

Employees who intend to terminate employment with Victoria Transcultural Clinical Center, LLC, are asked to provide Victoria Transcultural
Clinical Center, LLC with at least two weeks of written notice. Such notice is intended to allow the Company time to adjust to the employee's
departure without placing undue stress on the children we provide services for or to prevent burdening those employees who may be required
to fill in before a replacement can be found.

Since employment with Victoria Transcultural Clinical Center, LLC is based on mutual consent, both the employee and Victoria Transcultural
Clinical Center, LLC have the right to terminate employment at will, with or without cause, at any time.

In the case of employee termination, the employee will receive their accrued pay to all federal, state, and local laws.,

Any employee who terminates employment with Victoria Transcultural Clinical Center, LLC shall return all files, records, keys, and any other
materials that are the property of Victoria Transcultural Clinical Center, LLC.

Employee benefits will be affected by employment termination in the following manner:

● All accrued vested benefits that are due and payable at termination will be paid per applicable federal, state, and local laws.
● Some benefits, such as healthcare coverage, may be continued at the employee's expense if the employee elects to do so.
● The employee will be notified of the benefits that may be continued and of the terms, conditions, and limitations of such
continuation.

If you have any questions or concerns regarding this policy, direct them to the Human Resources Department.

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4. Working Conditions & Hours
4.1 Emergency Closing

Emergencies such as severe weather, fires, or power failures can disrupt company operations. In extreme cases, these circumstances may
require the closing ability. The decision to close or delay regular operations will be made by Victoria Transcultural Clinical Center,
LLC management.

When a decision is made to close the office, employees will receive an official notification from their supervisor.

4.2 Parking

Victoria Transcultural Clinical Center, LLC does not maintain private parking facilities for employees. Employees must park in municipal or
private parking facilities and are responsible for related costs. Victoria Transcultural Clinical Center, LLC employees are expected to comply
with all local parking regulations and will be responsible for any fines incurred for violations.

4.3 Workplace Safety

Victoria Transcultural Clinical Center, LLC is committed to providing a clean, safe, and healthful work environment for its employees.
Maintaining a safe work environment, however, requires the continuous cooperation of all employees. Victoria Transcultural Clinical Center,
LLC and all employees must comply with all occupational safety and health standards and regulations established by the Occupational Safety
and Health Act and state and local regulations. In addition, all employees are expected to obey safety rules and exercise caution and common
sense in all work activities.

Complaint and Reporting Procedure:

Employees should immediately report any unsafe conditions to their supervisor without fear of reprisal. In the case of an accident that results in
injury, regardless of how seemingly insignificant the injury may appear, employees must notify their supervisor. If you believe it would be
inappropriate to report the matter to your supervisor, you can report it directly to:

Chief Operations Officer

3541 Chain Bridge Rd Ste 204
Fairfax, VA 22030
(703) 218-6599

Employees who violate safety standards, cause hazardous or dangerous situations, or fail to report or, where appropriate, remedy such
situations may be subject to disciplinary action, up to and including termination of employment.

Retaliation Prohibited:
Victoria Transcultural Clinical Center, LLC expressly prohibits retaliation against anyone who reports unsafe working conditions or work-related
accidents, injuries, or illnesses. Any form of retaliation will be subject to disciplinary action, up to and including termination of employment.

Questions or concerns regarding this policy should be directed to your supervisor or the Human Resources Department.

4.4 Security

The purpose of Victoria Transcultural Clinical Center, LLC's security policy is to protect Company assets and to maintain a safe working
environment for all employees. The Company does utilize video monitoring to assist in the observation of company-related events and
activities.

Facility Access:

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All regular Victoria Transcultural Clinical Center, LLC employees will be issued a key or a code to gain access to Victoria Transcultural Clinical
Center, LLC facilities. Employees who are issued keys are responsible for their safekeeping. All lost or stolen keys must be reported to your
supervisor as soon as possible.

Upon separation from Victoria Transcultural Clinical Center, LLC, and at any other time upon Victoria Transcultural Clinical Center, LLC's
request, all keys must be returned to your supervisor.

Closing Procedures:

The last employee, or a designated employee, who leaves the office at the end of the business day assumes the responsibility to ensure that:
all doors are securely locked, and all appliances and lights are turned off with the exception of the lights normally left on for security purposes.

Employees are not permitted on company property after hours without prior written authorization from the Human Resources Department.

4.5 Meal & Break Periods

In accordance with state and local laws, non-exempt employees will be provided with meals and break periods. Break periods of less than 20
minutes will be paid. Break periods lasting longer than 20 minutes will be unpaid.

Non-exempt employees must be fully relieved of their job responsibilities and are not permitted to work during unpaid breaks and meal periods
of more than 20 minutes. If for any reason, a non-exempt employee does not take the applicable meal and rest period that they are provided,
the employee must notify his or her supervisor immediately.

Victoria Transcultural Clinical Center, LLC will schedule meal and break periods in order to accommodate Company operating requirements.

4.6 Break Time for Nursing Mothers

Victoria Transcultural Clinical Center, LLC accommodates employees who wish to express breast milk during the workday by providing
reasonable break times to do so. The Company will provide a designated room, other than a bathroom, that is shielded from view, free from
intrusion from coworkers and the public, and follows all other applicable laws for this purpose.

Employees who use regularly scheduled rest breaks to express breast milk will be paid for the break time.  If the lactation break does not run
concurrently with the employee’s regularly scheduled compensated break, the lactation break time will be unpaid. 

For questions related to this policy, please contact the Human Resources Department.

4.7 Company Hours

Victoria Transcultural Clinical Center, LLC's administrative office is open from

● Mon - Fri 08:30 AM to 08:00 PM

● Sat 09:00 AM to 3:30 PM

This excludes holidays recognized by Victoria Transcultural Clinical Center, LLC.

Clinical Staff schedules vary depending on the client's availability. The employee’s supervisor will notify the employee of their upcoming
monthly schedule. The VTCC scheduler will advise employees of modifications to their scheduled shifts, including new dates and starting and
ending times. Business needs may necessitate a variation in your starting and ending times as well as in the total hours you may be scheduled
to work each day and each week. Please check your schedule on a daily basis and communicate any changes immediately to your supervisor
and scheduler.

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5. Employee Benefits
5.1 Health Insurance

Victoria Transcultural Clinical Center, LLC reserves the right to offer eligible employees health insurance benefits through plan coverage.
Health insurance benefits are intended to protect you and your family from financial loss resulting from the hospital, surgical, or other health-
related expenses.

Eligible employees may elect to begin health insurance benefits on the first day of the month after completing their 90-day probation period.

This policy provides a summary of the benefits, which may be provided at the Company’s discretion. Actual coverage is determined by the
express terms of the plan documents. At such times that health benefits are offered to you, we encourage both you and your family to review
the plan's Summary Plan Description (SPD) materials carefully.

For further details on health insurance available through Victoria Transcultural Clinical Center, LLC, contact the Human Resources
Department.

5.3 Holidays

Victoria Transcultural Clinical Center, LLC observes the following paid holidays:

● New Year's Day

● Memorial Day
● Juneteenth Day
● Independence Day
● Labor Day
● Thanksgiving Day
● The Day after Thanksgiving Day
● Christmas Day

Due to the nature of our business, Victoria Transcultural Clinical Center, LLC may require employees to work on a holiday. Employees required
to work on holidays will be paid in accordance with applicable laws.

5.4 Paid Time Off (PTO)

Paid Time Off (PTO) is an all-purpose time off policy for eligible employees to use for vacation, illness, injury, or personal business. PTO
combines traditional vacation and sick leave plans into one flexible, inclusive policy. PTO is payable in the same manner as the regular salary
and is subject to the same withholding elections.

Employees in the following employment classification(s) are eligible to earn and use PTO as described in this policy: Full-time and part-time
employees

Upon entering an eligible employment classification, employees will begin to earn PTO according to the following schedule:

● 1-4 years (s) of service employees are eligible for 10 PTO Days.
● 5-9 years (s) of service employees are eligible for 15 PTO Days.
● 10+ years (s) of service employees are eligible for 20 PTO Days.

Unless Victoria Transcultural Clinical Center, LLC is required by state or local law to carry over unused PTO to the following year, employees
must use their earned time prior to December 31 of the calendar year in which it is earned. Otherwise, the time will be forfeited. For details on
carryover or other provisions of this policy, contact the Human Resources Department. 

Paid time off is paid at your base pay rate at the time of the absence. It does not include overtime or any special forms of compensation such
as incentives, commissions, bonuses, or shift differential.

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Employees with an unexpected need (i.e., sudden illness or emergency) to request PTO should notify their direct supervisor as early as
possible. Employees must also contact their direct supervisor on each additional day of absence.

Work-related accidents and illness are covered by Workers' Compensation Insurance, pursuant to the requirements of the laws in the state(s)
in which Victoria Transcultural Clinical Center, LLC operates. The PTO policy outlined above does not apply to those illnesses or injuries that
are covered by an applicable Workers' Compensation policy.

5.5 Employee Referral Program

Victoria Transcultural Clinical Center, LLC offers an employee referral program to encourage employees to recommend qualified candidates.
Our referral program provides employees with a referral bonus for successful hires made based upon an employee's recommendation. If a
recommended candidate is hired and completes 90 days of service, the employee who provided the referral will be entitled to a one time
bonus.

All referred candidates will be considered and evaluated based on experience and qualifications and will be subject to the same pre-
employment standards as all other candidates.

A bonus of $150 will be awarded for technician or administrative candidate who are hired and completes 90 days of service. A bonus of $1000
will be awarded for Virginia Licensed Behavior Analysts and Virginia Licensed Assistant Behavior Analysts who are hired and completes
90 days of service with VTCC.

Questions regarding this policy should be directed to the Human Resources Department.

5.6 Family and Medical Leave

Victoria Transcultural Clinical Center, LLC Employees, may be entitled to a leave of absence under the Family and Medical Leave Act (FMLA).
This policy provides information regarding FMLA eligibility and administration. Questions regarding FMLA should be directed to the Human
Resources Department.

Eligibility Requirements:

Employees eligible for leave under the FMLA are those who: (1) have worked at least 12 months for Victoria Transcultural Clinical Center, LLC;
(2) have worked for at least 1,250 hours during the 12-month period immediately preceding the start date of the requested leave; and (3) are
employed at a worksite where 50 or more employees are located within 75 miles of the worksite.

Note: A covered company is one that employed 50 or more employees for at least 20 workweeks in the current or preceding calendar year.

Basic FMLA Leave Entitlement:

The FMLA grants up to 12 weeks of unpaid leave to eligible employees for the following reasons: (1) to care for the employee's child following
birth or placement for adoption or foster care; (2) to care for the employee's spouse, son, daughter or parent (but not in-law) who has a serious
health condition; (3) for the employee's own serious health condition (including any period of incapacity due to pregnancy, prenatal medical
care, or childbirth) that makes the employee unable to perform one or more of the essential functions of the employee's job; or (4) because of
any qualifying exigency arising out of the fact that an employee's spouse, son, daughter, or parent is a covered military member who is a
member of a regular component of the Armed Forces on active duty or who has been notified of an impending call or order to active duty status
for deployment to any foreign country in the regular or reserve components of the Armed Forces, including the National Guard or Reserves.

A serious health condition is an illness, injury, impairment, or physical or mental condition that involves either an overnight stay in a medical
care facility or continuing treatment by a health care provider for a condition that either prevents the employee from performing the functions of
the employee's job or prevents the qualified family member from participating in school or other daily activities. Subject to certain conditions,
the continuing treatment requirement may be met by a period of incapacity of more than three consecutive calendar days combined with at
least two visits to a health care provider or one visit and a regimen of continuing treatment, or incapacity due to pregnancy, or incapacity due to
a chronic condition. Other conditions may meet the definition of continuing treatment.

Qualifying exigencies may include attending certain military events, arranging for alternative childcare, addressing certain financial and legal
arrangements, attending certain counseling sessions, and attending post-deployment reintegration briefings.

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Additional Military Family Leave Entitlement:

In addition to the basic FMLA leave entitlement discussed above, an eligible employee who is the spouse, son, daughter, parent, or next of kin
of a covered servicemember is entitled to take up to 26 weeks of leave during a single 12-month period to care for the servicemember with a
serious injury or illness. Leave to care for a service member shall only be available during a single 12-month period and, when combined with
other FMLA-qualifying leave, may not exceed 26 weeks during the single 12-month period. The single 12-month period begins on the first day
an eligible employee takes leave to care for the injured service member.

A covered servicemember means a member of the Armed Forces, including a member of the National Guard or Reserves, and/or a veteran of
the Armed Forces, including a veteran of the National Guard or Reserves, who is undergoing medical treatment, recuperation, or therapy, is
otherwise in outpatient status, or is on the temporary retired list, for a serious injury or illness. Such a veteran is considered a covered
servicemember if he/she was a member of the Armed Forces, including the National Guard and Reserves, at any time during the five-year
period preceding the date on which the veteran undergoes medical treatment, recuperation, or therapy.
Intermittent Leave and Reduced Leave Schedules:

FMLA leave usually will be taken for a period of consecutive days, weeks, or months. However, employees also are entitled to take FMLA to
leave intermittently or on a reduced leave schedule when medically necessary due to a serious health condition of the employee or covered
family member or the serious injury or illness of a covered servicemember.

Protection of Group Health Insurance Benefits:

During FMLA leave, if available, eligible employees are entitled to receive group health plan coverage on the same terms and conditions as if
they had continued to work.

Restoration of Employment and Benefits:

At the end of FMLA leave, subject to some exceptions, including situations where job restoration of “key employees” will cause the Company
substantial and grievous economic injury, employees generally have a right to return to the same or equivalent positions with equivalent pay,
benefits, and other employment terms. The Company will notify employees if they qualify as “key employees” if it intends to deny reinstatement
and of their rights in such instances. Use of FMLA will not result in the loss of any employment benefit that accrued prior to the start of an
eligible employee's FMLA leave.

Notice of Eligibility for, and Designation of, FMLA Leave:

Employees requesting FMLA leave are entitled to receive written notice from Victoria Transcultural Clinical Center, LLC telling them whether
they are eligible for FMLA to leave and, if not eligible, the reasons why they are not eligible. When eligible for FMLA leave, employees are
entitled to receive written notice of: (1) their rights and responsibilities in connection with such leave; (2) the Company's designation of leave as
FMLA-qualifying or non-qualifying, if not FMLA-qualifying, and the reasons why; and (3) the amount of leave, if known, that will be counted
against the employee's leave entitlement.

Victoria Transcultural Clinical Center, LLC may retroactively designate leave as FMLA leave with appropriate written notice to employees,
provided the Company's failure to designate leave as FMLA-qualifying at an earlier date did not cause harm or injury to the employee. In all
cases where leaves qualify for FMLA protection, Victoria Transcultural Clinical Center, LLC, and the employee can mutually agree that leave is
retroactively designated as FMLA leave.

Notice of the Need for Leave:

Employees who take FMLA leave must timely notify Victoria Transcultural Clinical Center, LLC of their need for FMLA leave where the need is
reasonably foreseeable. The following describes the content and timing of such employee notices.

Content of Employee Notice:

To trigger FMLA leave protections, employees must inform the Human Resources Department of the need for FMLA-qualifying leave and the
anticipated timing and duration of the leave, if known. Employees may do this by either requesting FMLA leave specifically or explaining the
reasons for leaving so as to allow the Company to determine that the leave is FMLA-qualifying.

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If employees fail to explain the reasons for FMLA leave, the leave may be denied. When employees take sick leave due to FMLA-qualifying
reasons for which the Company has previously provided FMLA-protected leave, they must specifically reference the qualifying reason for the
leave or the need for FMLA leave.

Timing of Employee Notice:

Employees must provide 30 days' advance notice of the need to take FMLA leave when the need is foreseeable. When 30 days’ notice is not
possible, or the approximate timing of the need for leave is not foreseeable, employees must provide the Company with notice of the need for
leave as soon as practicable under the facts and circumstances of the case. Employees who fail to give 30 days’ notice for foreseeable leave
without a reasonable excuse for the delay or otherwise fail to satisfy FMLA notice obligations may have FMLA leave delayed or denied.

Medical Certifications:

Depending on the nature of FMLA leave sought, employees may be required to submit medical certifications supporting their need for FMLA-
qualifying leave. It is the employee's responsibility to provide Victoria Transcultural Clinical Center, LLC with timely, complete, and sufficient
medical certifications. Employees must provide the requested certifications within 15 calendar days following the Company's request unless it
is not practicable to do so. Where Victoria Transcultural Clinical Center, LLC informs an employee that the certification is incomplete or
insufficient, Victoria Transcultural Clinical Center, LLC will give the employee at least seven days to cure the deficiencies. Victoria Transcultural
Clinical Center, LLC may deny FMLA leave to employees who fail to timely cure deficiencies or otherwise fail to timely submit requested
medical certifications.

Employees requesting leave because of their own, or a covered relation's, serious health condition or to care for a covered servicemember,
must supply medical certification supporting the need for such leave from their health care provider or, if applicable, the health care provider of
their covered family or service member. If employees provide at least 30 days’ notice of medical leave, they should submit the medical
certification before leave begins.

With the employee’s permission, Victoria Transcultural Clinical Center, LLC may contact the employee’s health care provider to authenticate or
clarify completed medical certifications. If the employee fails to authorize such contact and medical certification remains unclear, Victoria
Transcultural Clinical Center, LLC may deny FMLA leave. If Victoria Transcultural Clinical Center, LLC has reason to doubt the employee’s
initial medical certification, Victoria Transcultural Clinical Center, LLC may require the employee to obtain a second opinion at Victoria
Transcultural Clinical Center, LLC’s expense.

Recertification:

Depending on the circumstances and duration of FMLA leave, Victoria Transcultural Clinical Center, LLC may require the employee to provide
recertification of the medical condition giving rise to leave. Victoria Transcultural Clinical Center, LLC will notify the employee if recertification is
required, and the employee will have at least 15 calendar days to provide recertification.

Return to Work:

Unless Victoria Transcultural Clinical Center, LLC advises otherwise, employees returning to work from FMLA leave taken because of their own
serious health conditions must provide medical certification that they are able to return to work and perform the essential functions of their job,
with or without accommodation.

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Certifications Supporting Need for Military Family Leave:

Upon request, the first time employees take sick leave due to qualifying exigencies arising out of the active duty or call to active duty status of a
covered military member; the Company may require employees to provide: (1) a copy of the covered military member's active duty orders or
other documentation issued by the military indicating the covered military member is on active duty or call to active duty status and the dates of
the covered military member's active duty service; and (2) certification from the employee setting forth information concerning the nature of the
qualifying exigency for which leave is requested. Employees shall provide a copy of new active-duty orders or other documentation issued by
the military for leaves arising out of qualifying exigencies arising out of a different active duty or call to the active-duty status of the same or a
different covered military member.

When leave is taken to care for a covered servicemember with a serious injury or illness, Victoria Transcultural Clinical Center, LLC may
require employees to obtain certifications completed by an authorized health care provider of the covered servicemember.

Health Insurance Continuation:

During FMLA leave, employees are entitled to continue group health plan coverage under the same terms and conditions as if they had
continued to work; however, they may be responsible for their portion of the group health premium. Contact your Human Resources
Department to determine your benefits, rights, and responsibilities while on FMLA leave.

Substitution of Paid Leave for Unpaid FMLA Leave:

Employees must use any accrued Paid Time Off (“PTO”) while taking unpaid FMLA leave. The substitution of PTO for unpaid FMLA leave time
does not extend the length of FMLA leaves; the PTO will run concurrently with an employee's FMLA entitlement.

Leaves of absence taken in connection with a disability leave plan or workers' compensation injury/illness shall run concurrently with any FMLA
leave entitlement.

Coordination of FMLA Leave with Other Leave Policies:

The FMLA does not affect any federal, state, or local law prohibiting discrimination or supersede any State or local law which provides greater
family or medical leave rights. For additional information concerning leave entitlements and obligations that might arise when FMLA leave is
either not available or exhausted, please contact the Human Resources Department.

No Retaliation:

Victoria Transcultural Clinical Center, LLC will not interfere with, restrain or deny the exercise of any right provided under the FMLA. Victoria
Transcultural Clinical Center, LLC will not discharge or discriminate against any individual for opposing any practice made lawful by the FMLA
or for being involved in any proceeding relating to the FMLA. Contact your supervisor or HR Administrator immediately if you feel your rights
under this policy have been violated. Victoria Transcultural Clinical Center, LLC will conduct a prompt and thorough investigation of any FMLA
complaint and take appropriate remedial action, up to and including termination.

5.7 Military Leave

Victoria Transcultural Clinical Center, LLC grants employees unpaid time off for service, training, and other obligations in the uniformed
services in accordance with the Uniformed Services Employment and Reemployment Rights Act (USERRA) and any other applicable state law.

All employees requesting time off for military service must provide advance notice to their immediate supervisor unless military necessity
prevents such notice or it is otherwise impracticable. Continuation of health insurance benefits is available during military leave subject to the
terms and conditions of the group health plan and applicable law.

Employees are eligible for reemployment for up to five years from the date their military leave began. The period an individual has to apply for
reemployment or report back to work after military service is based on time spent on military duty and on applicable law. For reinstatement
guidelines, contact the Human Resources Department.

Employees who qualify for reemployment will return to work at a pay level and status equal to that which they would have attained had they not
taken military leave. They will be treated as though they were continuously employed for the purpose of determining benefits based on length
of service.

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Victoria Transcultural Clinical Center, LLC complies with all rights and protections under all applicable state laws granting time off for service,
training, and other obligations in uniformed services. This includes, but is not limited to, benefits entitlement and continuation, notice and
recertification requirements, and reemployment application requirements.

Questions regarding this policy should be directed to the Human Resources Department.

5.8 Military Leave (Virginia Employees)

An employee who is a member of the Virginia National Guard, Virginia State Defense Force, or naval militia may be eligible to take reasonable
leave when he or she is ordered to active duty or military duty under applicable state and federal law.

Employees must be prepared to provide Victoria Transcultural Clinical Center, LLC with certification from the proper military authority to verify
the employee's eligibility for military leave.  Group insurance and any other benefits with premium payments will be continued during leave,
provided the employee pays 100% of the premium during leave.

Upon honorable release from active duty, an employee must apply for re-employment in writing within:

● 14 days of his or her release from duty or from hospitalization if the length of the employee's absence does not exceed 180 days; or
● 90 days of his or her release from duty or from hospitalization if the length of the employee's absence exceeds 180 days.

When possible, Victoria Transcultural Clinical Center, LLC will restore the employee to the position held by the employee when he or she was
ordered to active duty.  If the position no longer exists, the employee will be reinstated to a position of like seniority, status, and pay or to a
comparable vacant position for which the employee is qualified, unless to do so would be unreasonable.

Military leave is unpaid; however, employees may opt to use accrued paid time off for this purpose. 

5.9 Jury Duty

Victoria Transcultural Clinical Center, LLC encourages employees to fulfill their civic responsibilities when called upon to serve as a juror.
Employees must provide their immediate supervisor with a copy of their jury summons as soon as possible so that the supervisor may decide
to accommodate their absence.

Employees on jury duty must report to work on workdays or parts of workdays when they are not required to serve. Either Victoria Transcultural
Clinical Center, LLC or the employee may request an excuse from jury duty if it is determined that the employee's absence would create
serious operational difficulties.

Jury duty will be paid if required by applicable state law. If paid, jury duty pay will be calculated on the employee's base pay rate times the
number of hours the employee would otherwise have worked on the day of absence. If exempt employees miss work because of jury duty, they
will receive their full salary unless they miss the entire workweek. However, Victoria Transcultural Clinical Center, LLC may offset any jury-duty
fees received by an exempt employee against the salary due for that workweek.

5.10 Jury Duty Leave (Virginia Employees)

Victoria Transcultural Clinical Center, LLC encourages employees to fulfill their civic responsibilities when called upon to serve as a juror.
Employees must provide their immediate supervisor with a copy of their jury summons as soon as possible so that the supervisor may decide
to accommodate their absence. Either Victoria Transcultural Clinical Center, LLC or the employee may request an excuse from jury duty if it is
determined that the employee's absence would create serious operational difficulties.

An employee who is summoned and appears for jury duty for four or more hours in one day, including travel time, will not be required to start
any work shift that begins on or after 8:00 p.m. on the day of his or her appearance for jury duty or begins before 3:00 a.m. on the day following
the day of his or her appearance for jury duty.

Jury duty leave is unpaid; however, employees may opt to use accrued paid time off for this purpose.

5.11 Workers' Compensation

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Employees who are injured on the job at Victoria Transcultural Clinical Center, LLC are eligible for Workers' Compensation benefits. Such
benefits are provided at no cost to employees and cover any injury or illness sustained in the course of employment that requires medical
treatment.

Lost time or medical expenses incurred as a result of an accident or injury which occurred while an employee was on the job will be
compensated in accordance with workers' compensation laws. This protection is paid for in full by Victoria Transcultural Clinical Center, LLC.
No premium is charged to the employee for this coverage, and no individual enrollment is required. Victoria Transcultural Clinical Center, LLC
will provide medical care and a portion of lost wages through our insurance carrier.

All job-related accidents or illnesses must be reported to an employee's supervisor immediately upon occurrence. Supervisors will then
immediately contact the Human Resources Department to obtain the required claim forms and instructions.

Injured employees may request information from the Human Resources department regarding the Company’s Return-to-Work policy. This
policy outlines how an injured employee may be able to return to work in a limited status to reduce some adverse impacts on the employee’s
finances.

5.12 Crime Victims Leave (Virginia Employees)

An employee may be entitled to a reasonable amount of leave if the employee is a victim of a crime. Such leave may be taken to attend all
criminal proceedings related to the crime.

Except in cases of imminent danger to the health or safety of the employee, or unless impractical, an employee requesting crime victims' leave
must provide notice to his or her supervisor regarding the need for leave as soon as practical.

Employees must be prepared to provide Victoria Transcultural Clinical Center, LLC with certification to verify the employee's eligibility for the
leave requested, such as a police report, a court order, or evidence that they appeared in court.

Crime victim's leave is unpaid; however, employees may use accrued paid time off for this purpose.

5.13 Election Duty Leave (Virginia Employees)

An employee who serves as an officer of an election will be granted leave in order to perform the duties of the position to which they have been
appointed. The leave is unpaid; however, employees may opt to use accrued paid time off for this purpose.

An employee who serves for four or more hours, including travel time, will not be required to start any work shift that begins on or after 5:00
p.m. on his or her day of service or before 3:00 a.m. on the day following service.

To the extent possible, employees must provide reasonable advance notice of their need for leave under this policy. Requests must be
submitted to the employee's supervisor.

Employees must be prepared to provide Victoria Transcultural Clinical Center, LLC with certification to verify the employee's eligibility for the
leave requested.

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6. Employee Conduct
6.1 Standards of Conduct

Victoria Transcultural Clinical Center, LLC's rules and standards of conduct are essential to a productive work environment. As such,
employees must familiarize themselves with, and be prepared to follow, the Company’s rules and standards.

While not intended to be an all-inclusive list, the examples below represent behavior that is considered unacceptable in the workplace.
Behaviors such as these, as well as other forms of misconduct, may result in disciplinary action, up to and including termination of employment:

● Theft or inappropriate removal/possession of the property

● Falsification of any company records (timesheet, client notes, parent signature…etc.)
● Violation of HIPPA
● Fraudulent billing
● Transporting a client in a personal vehicle without prior written authorization from company management
● Possession, distribution, sale, transfer, manufacture, or use of alcohol or illegal drugs in the workplace
● Fighting or threatening violence in the workplace
● Making maliciously false statements about co-workers and clients
● Threatening, intimidating, coercing, or otherwise interfering with the job performance of fellow employees or visitors
● Negligence or improper conduct leading to damage of company-owned or customer-owned property
● Violation of safety or health rules
● Sexual or other unlawful or unwelcome harassment
● Excessive absenteeism and tardiness
● Refusing to work a full work schedule
● Refusing to perform duties to the company’s expectations
● Unauthorized use of telephones, computers, or other company-owned equipment during working hours. Working time does not
include break periods, mealtimes, or other specified periods during the workday when employees are not engaged in performing
their work tasks.
● Unauthorized disclosure of any “business secrets” or other confidential or non-public proprietary information relating to the
Company’s products, services, customers, or processes.

This policy is not intended to restrict an employee’s rights under the National Labor Relations Act.

Other forms of misconduct not listed above may also result in disciplinary action, up to and including termination of employment. If you have
questions regarding Victoria Transcultural Clinical Center, LLC's standards of conduct, please direct them to your supervisor or the Human
Resources Department.

6.2 Disciplinary Action

Disciplinary action at Victoria Transcultural Clinical Center, LLC is intended to fairly and impartially correct behavior and performance problems
early on and prevent a recurrence.

Disciplinary action may involve any of the following: verbal warning, written warning, suspension with or without pay, and termination of
employment, depending on the severity of the problem and the frequency of occurrence. Victoria Transcultural Clinical Center, LLC reserves
the right to administer disciplinary action at its sole discretion and based upon the circumstances.

Victoria Transcultural Clinical Center, LLC recognizes that certain types of employee behavior are serious enough to justify termination of
employment without observing other disciplinary actions first.

These violations include but are not limited to:

● Workplace violence
● Harassment
● Theft of any kind
● Insubordinate behavior

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 ● Vandalism or destruction of company property
● Presence on company property during non-business hours
● Use of company equipment and/or company vehicles without prior authorization
● Indiscretion regarding personal work history, skills, or training
● Divulging Victoria Transcultural Clinical Center, LLC business practices or any other confidential information
● Any misrepresentation of Victoria Transcultural Clinical Center, LLC to a customer, a prospective customer, the general public, or an
employee

6.3 Confidentiality

Victoria Transcultural Clinical Center, LLC takes the protection of Confidential Information very seriously.  “Confidential Information” includes,
but is not limited to, computer processes, computer programs and codes, customer lists, customer preferences, customers’ personal
information, company financial data, marketing strategies, proprietary production processes, research and development strategies, pricing
information, business and marketing plans, vendor information, software, databases, and information concerning the creation, acquisition or
disposition of products and services.

Confidential Information also includes the Company’s intellectual property and information that is not otherwise public. Intellectual property
includes, but is not limited to, trade secrets, ideas, discoveries, writings, trademarks, and inventions developed through the course of your
employment with Victoria Transcultural Clinical Center, LLC and as a direct result of your job responsibilities with Victoria Transcultural Clinical
Center, LLC.

To protect such information, employees may not disclose any confidential or non-public proprietary information about the Company to any
unauthorized individual. If you receive a request for Confidential Information, you should immediately refer the request to your supervisor.

The unauthorized disclosure of Confidential Information belonging to the Company and not otherwise available to persons or companies
outside of Victoria Transcultural Clinical Center, LLC, may result in disciplinary action, up to and including termination of employment, or in
appropriate legal action. If you leave the Company, you may not disclose or misuse any Confidential Information.

This policy is not intended to restrict an employee’s rights under the National Labor Relations Act.

Questions regarding this policy should be directed to the Human Resources Department.

6.4 Personal Appearance

The purpose of Victoria Transcultural Clinical Center, LLC's personal appearance policy is to ensure a safe and sanitary workplace for all
employees.  Victoria Transcultural Clinical Center, LLC strives to maintain a professional working environment that promotes efficiency and
positive employee morale and promotes a professional image.  During business hours or when representing Victoria Transcultural Clinical
Center, LLC, employees are expected to use common sense and good judgment in order to meet the goals of this policy.
 
Generally, employees should wear appropriate clothing, observe high standards of personal hygiene, and dress and groom themselves
according to the requirements of their positions. While not intended to be an all-inclusive list, the examples below are considered appropriate
workplace attire:

Appropriate Inappropriate
● Khaki pants ● Flats or sandals
● Jeans ● Wedges or Heels
● Cargo or Bermuda Shorts ● Hoop earrings or Long earrings
● Closed shoes ● Facial Jewelry & Necklace
● Long fingernails (exceed a length of ¼ inch as measured from the tip of the
finger)
● Short Shorts, Dresses, or Skirts
● Deep V-neck dresses or tops

If management designates "casual days," an employee's casual dress must still be clean and neat and project a professional image.

Those employees working full-time inside of the clinic shall be required to wear the designated company uniform. Lost, damaged, or stolen
uniforms must be replaced at the expense of the employee.

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Generally, employees should maintain a clean and neat appearance and should refrain from wearing stained, wrinkled, frayed, or revealing
clothing to the workplace. Employees are urged to use their discretion when determining what is appropriate to wear to work. Employees who
wear inappropriate attire to work may be sent home to change their clothing.

Victoria Transcultural Clinical Center, LLC understands that in certain situations, the Company may need to make exceptions to this policy
based on an employee’s religion, disability, or other characteristics protected under federal, state, or local law.  In accordance with all
applicable laws, the Company will make every effort to provide reasonable accommodation as necessary unless doing so would cause undue
hardship to Victoria Transcultural Clinical Center, LLC.

Questions regarding appropriate workplace attire should be directed to your supervisor or the Human Resources Department.

6.5 Workplace Violence

Victoria Transcultural Clinical Center, LLC strictly prohibits workplace violence, including any act of intimidation, threat, harassment, physical
violence, verbal abuse, aggression, or coercion against a coworker, vendor, customer, or visitor.

Prohibited actions include but are not limited to the following examples:

● Physically injuring another person

● Threatening to injure another person
● Engaging in behavior that subjects another person to emotional distress
● Using obscene, abusive, or threatening language or gestures
● Bringing an unauthorized firearm or other weapons onto company property
● Threatening to use or using a weapon while on company premises, on company-related business, or during job-related functions
● Intentionally damaging property

All threats or acts of violence should be reported immediately to your supervisor or security personnel. Employees should warn their
supervisors or security personnel of any suspicious workplace activity that they observe or that appears problematic.  Employee reports made
pursuant to this policy will be investigated promptly and will be kept confidential to the maximum extent possible. Victoria Transcultural Clinical
Center, LLC will not tolerate any form of retaliation against any employee for making a report under this policy.  

Victoria Transcultural Clinical Center, LLC will take prompt remedial action, up to and including immediate termination, against any employee
found to have engaged in threatening behavior or acts of violence.

6.6 Drug & Alcohol Use

Victoria Transcultural Clinical Center, LLC is committed to maintaining a workplace free of substance abuse. No employee or individual who
performs work for Victoria Transcultural Clinical Center, LLC is allowed to consume, possess, sell, purchase, or be under the influence of
alcohol or illegal drugs, as defined by federal law, on any property owned by or leased on behalf of Victoria Transcultural Clinical Center, LLC,
or in any vehicle owned or leased on behalf of Charlie Company or while on Company business.

The use of over-the-counter drugs and legally prescribed drugs is permitted if they are used in the manner for which they were prescribed and
provided that such use does not hinder an employee's ability to safely perform his or her job. Employees should inform their supervisor if they
believe their medication will impair their job performance, safety, or the safety of others or if they believe they need reasonable accommodation
when using such medication.

Victoria Transcultural Clinical Center, LLC will not tolerate employees who report for duty while impaired using alcohol or drugs. All employees
should report evidence of alcohol or drug abuse to their supervisor or the Human Resources Department immediately. In cases in which the
use of alcohol or drugs creates an imminent threat to the safety of persons or property, employees are required to report the violation. Failure
to do so may result in disciplinary action, up to and including termination of employment.

As a part of our effort to maintain a workplace free of substance abuse, Victoria Transcultural Clinical Center, LLC employees may be asked to
submit to a medical examination and/or clinical testing for the presence of alcohol and/or drugs. Within the limits of federal, state, and local
laws, Victoria Transcultural Clinical Center, LLC reserves the right to require the following tests:

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 ● Pre-employment: Only applicants whose position requires a mandatory drug screening must pass a drug test before beginning work
or receiving an offer of employment. Refusal to submit to testing will result in disqualification of further employment consideration.

● Reasonable suspicion: Employees are subject to testing based on observations by a supervisor of apparent workplace use,
possession, or impairment. Human Resources must be consulted before sending an employee for reasonable suspicion testing.

● Post-accident: Employees are subject to testing when they cause or contribute to accidents that seriously damage a company
vehicle, machinery, equipment, or property and/or result in an injury to themselves or another employee requiring off-site medical
attention. In any of these instances, the investigation and subsequent testing must take place within two (2) hours following the
accident, if not sooner.

● Follow-up: Employees who have tested positive or otherwise violated this policy are subject to discipline up to and including
discharge.

● Inspections: Troika reserves the right to inspect all portions of its premises for drugs or other contraband. All employees, contract
employees, and visitors may be asked to cooperate in inspections of their persons, work areas, and property that might conceal a
drug or other contraband. Employees who possess such contraband or refuse to cooperate in such inspections are subject to
appropriate discipline up to and including discharge.

As a condition of your employment with Victoria Transcultural Clinical Center, LLC, employees must comply with this Drug & Alcohol Use
Policy. Be advised that no part of the Drug & Alcohol Use Policy shall be construed to alter or amend the at-will employment relationship
between Victoria Transcultural Clinical Center, LLC and its employees.

Employees found in violation of this policy may be subject to disciplinary action, up to and including termination of employment.

6.7 Sexual & Other Unlawful Harassment

Victoria Transcultural Clinical Center, LLC is committed to a work environment in which all individuals are treated with respect. Victoria
Transcultural Clinical Center, LLC expressly prohibits discrimination and all forms of employee harassment based on race, color, religion, sex,
pregnancy, national origin, age, disability, military or veteran status, or status in any group protected by state or local law.

Sexual harassment is a form of discrimination and is prohibited by law. For purposes of this policy, sexual harassment is defined as unwelcome
sexual advances, requests for sexual favors, and other verbal or physical conduct of a sexual nature when this conduct explicitly or implicitly
affects an individual's employment, unreasonably interferes with an individual's work performance, or creates an intimidating, hostile, or
offensive work environment. Unwelcome sexual advances (either verbal or physical), requests for sexual favors, and other verbal or physical
conduct of a sexual nature constitute sexual harassment when: (1) submission to such conduct is made either explicitly or implicitly a term or
condition of employment; (2) submission or rejection of the conduct is used as a basis for making employment decisions; or, (3) the conduct
has the purpose or effect of interfering with work performance or creating an intimidating, hostile, or offensive work environment.

Sexual and unlawful harassment may include a range of behaviors and may involve individuals of the same or different gender. These
behaviors include, but are not limited to:

● Unwanted sexual advances or requests for sexual favors.

● Sexual or derogatory jokes, comments, or innuendo
● Unwelcome physical interaction
● Insulting or obscene comments or gestures
● Offensive email, voicemail, or text messages
● Suggestive or sexually explicit posters, calendars, photographs, graffiti, or cartoons
● Making or threatening reprisals after a negative response to sexual advances
● Visual conduct that includes leering, making sexual gestures, or displaying sexually suggestive objects or pictures, cartoons, or
posters
● Verbal sexual advances or propositions
● Physical conduct that includes touching, assaulting, impeding, or blocking movements
● Abusive or malicious conduct that a reasonable person would find hostile, offensive, and unrelated to the Company’s legitimate
business interests
● Any other visual, verbal, or physical conduct or behavior deemed inappropriate by the Company

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Harassment based on any other protected characteristic is also strictly prohibited.

Complaint Procedure:

Victoria Transcultural Clinical Center, LLC strongly encourages the reporting of all instances of discrimination, harassment, or retaliation. If you
believe you have experienced or witnessed harassment or discrimination based on race, color, religion, sex, pregnancy, national origin, age,
disability, military or veteran status, or status in any group protected by state or local law, promptly report the incident to your supervisor. If you
believe it would be inappropriate to discuss the matter with your supervisor, you may bypass your supervisor and report it directly to:

Operations Officer
3541 Chain Bridge Rd Ste 204
Fairfax, VA 22030
(703) 218-6599
Any reported allegations of harassment or discrimination will be investigated promptly, thoroughly, and impartially.

Any employee found to be engaged in any form of sexual or other unlawful harassment may be subject to disciplinary action, up to and
including termination of employment.

Retaliation Prohibited:

Victoria Transcultural Clinical Center, LLC expressly prohibits retaliation against any individual who reports discrimination or harassment or
assists in investigating such charges. Any form of retaliation is considered a direct violation of this policy and, like discrimination or harassment
itself, will be subject to disciplinary action, up to and including termination of employment.6.8 Telephone and iPad Usage

Victoria Transcultural Clinical Center, LLC telephones and iPads are intended for the sole use of conducting company business. Personal use
of the Company's telephones and individually owned cell phones during business hours should be kept to a minimum or for emergency
purposes only. When an employee receives a personal call during client time, the employee must excuse themselves and stop billing for the
duration of the personal call. We ask that personal calls only be made or received outside of client/working hours, including during lunch or
break time. Long-distance phone calls which are not strictly business-related are expressly prohibited.

Any employee found in violation of this policy will be subject to disciplinary action, up to and including termination of employment.

6.9 Personal Property

Employees should use their discretion when bringing the personal property into the workplace. Victoria Transcultural Clinical Center, LLC
assumes no risk for any loss or damage to personal property.

Additionally, employees may not possess or display any property that may be viewed as inappropriate or offensive on Victoria Transcultural
Clinical Center, LLC premises.

6.10 Use of Company Property

Company property refers to anything owned by the company: physical, electronic, intellectual, or otherwise. The use of company property is for
business necessity only.

When materials or equipment are assigned to an employee for business, it is the employee's responsibility to see that the equipment is used
properly and cared for properly. However, at all times, equipment assigned to the employee remains the property of the Company and is
subject to reassignment and/or use by the Company without prior notice or approval of the employee. This includes, but is not limited to,
computer equipment and data stored thereon, voicemail, records, and employee files.

Victoria Transcultural Clinical Center, LLC has created specific guidelines regarding the use of company equipment. Below is a list of employee
responsibilities and limitations with regard to company property.

Personal use of company property:

Company property is not permitted to be taken from the premises without proper written authorization from company management.

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Company Tools:

All necessary tools are furnished to employees in order to assist them in their required duties. Each employee is, in turn, responsible for these
tools. Tools damaged or stolen as a result of an employee's negligence will, to the extent permitted by federal, state, and local law, be charged
to the employee.

Care of Company Property:

Office areas should be kept neat and orderly, and all equipment should be well-maintained. Theft, misappropriation, or unauthorized removal,
possession, or use of company property or equipment is expressly prohibited.

Any action in contradiction to the guidelines set herein may result in disciplinary action, up to and including termination of employment.

6.11 Visitors in the Workplace

To ensure the safety and security of Victoria Transcultural Clinical Center, LLC, clients, and its employees, only authorized visitors are
permitted on Company premises, clients’ homes, and in Company facilities.

All visitors are required to check in at the front desk and stay in the reception area. Authorized visitors will be escorted to their destination and
must always be accompanied by a representative of the Company.

6.12 Computer, Email & Internet Usage

Computers, email, and the Internet allow Victoria Transcultural Clinical Center, LLC employees to be more productive. However, it is important
that all employees use good business judgment when using Victoria Transcultural Clinical Center, LLC’s electronic communications systems
(ECS).

Standards of Conduct and ECS

Victoria Transcultural Clinical Center, LLC strives to maintain a workplace free of discrimination and harassment. Therefore, Victoria
Transcultural Clinical Center, LLC prohibits the use of the Company’s ECS for bullying, harassing, discriminating, or engaging in other unlawful
misconduct in violation of the Company’s policy against discrimination and harassment.

Copyright and other Intellectual Property

Respect all copyright and other intellectual property laws. For the Company's protection as well as your own, it is critical that you show proper
respect for the laws governing copyright, fair use of copyrighted material owned by others, trademarks, and other intellectual property, including
the Company's own copyrights, trademarks, and brands. Employees are also responsible for ensuring that, when sending any material over the
Internet, they have the appropriate distribution rights.

Victoria Transcultural Clinical Center, LLC purchases and licenses the use of various computer software for business purposes and does not
own the copyright to this software or its related documentation. Unless authorized by the software developer, Victoria Transcultural Clinical
Center, LLC does not have the right to reproduce such software for use on more than one computer. Employees may only use the software
according to the software license agreement. Victoria Transcultural Clinical Center, LLC prohibits the illegal duplication of software and its
related documentation.

ECS Guidelines

The following behaviors are examples of previously stated or additional actions and activities under this policy that are prohibited:

● Sending or posting discriminatory, harassing, or threatening messages or images about coworkers, supervisors, or the
Company that violates the Company’s policy against discrimination and harassment.
● Stealing, using, or disclosing someone else's code or password without authorization.
● Pirating or downloading Company-owned software without permission.

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 ● Sending or posting the Company’s confidential material, trade secrets, or non-public proprietary information outside of the
Company. Wages and other conditions of employment are not considered confidential material.
● Violating copyright laws and failing to observe licensing agreements.
● Participating in the viewing or exchange of pornography or obscene materials.
● Sending or posting messages that threaten, intimidate, coerce, or otherwise interfere with the job performance of fellow employees.
● Attempting to break into the computer system of another organization or person.
● Refusing to cooperate with a security investigation.
● Using the Internet for gambling or any illegal activities.
● Sending or posting messages that disparage another organization's products or services.
● Passing off personal views as representing those of Victoria Transcultural Clinical Center, LLC.

Privacy and Monitoring

Computer hardware, software, email, Internet connections, and all other computer, data storage, or ECS provided by Victoria Transcultural
Clinical Center, LLC is the property of Victoria Transcultural Clinical Center, LLC. Employees have no right to personal privacy when using
Victoria Transcultural Clinical Center, LLC’s ECS. To ensure the productivity of employees, compliance with this policy and with all applicable
laws, including harassment and anti-discrimination laws, computer, email, and Internet usage may be monitored.

This policy is not intended to restrict an employee’s right to discuss or act together to improve wages, benefits, and working conditions with co-
workers or in any way restrict employees’ rights under the National Labor Relations Act.

Violations of this policy may result in disciplinary action, up to and including termination of employment. Questions or concerns related to this
policy should be directed to your supervisor or the Human Resources Department.

6.13 Company Supplies

Only authorized persons may purchase supplies in the name of Victoria Transcultural Clinical Center, LLC. No employee whose regular duties
do not include purchasing shall incur any expense on behalf of Victoria Transcultural Clinical Center, LLC or bind Victoria Transcultural Clinical
Center, LLC by any promise or representation without express written approval.

6.14 Smoking

Victoria Transcultural Clinical Center, LLC provides a smoke-free environment for its employees, customers, and visitors. Smoking, including
the use of e-cigarettes and vaporizers, is prohibited throughout the workplace. We have adopted this policy because we have a sincere interest
in the health of our employees and in maintaining pleasant working conditions.

6.15 Cell Phones and Mobile Devices

Victoria Transcultural Clinical Center, LLC encourages employees to exercise sound business judgment when using cell phones and mobile
devices in the workplace. Personal cell phone use should not interfere with productivity or impact job performance.

Cell phones must be turned off or set to silent mode during meetings, in clients’ homes, or in locations where incoming calls may cause
disruption.

Unless otherwise authorized, Company-provided cell phones are for business purposes only. Employees may be required to reimburse Victoria
Transcultural Clinical Center, LLC for any personal use of a Company-provided cell phone or mobile device.

When driving, employees must adhere to all federal, state, or local rules on cell phone use. Employees who incur fines as a result of violating
these rules while operating vehicles owned by Victoria Transcultural Clinical Center, LLC, will be solely responsible for such fines. If you are
unsure whether the use of a cell phone while driving is prohibited in a particular area, please check with the Human Resources Department.

Violation of this policy may result in disciplinary action, up to and including termination of employment.

6.16 Training and Professional Development

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Victoria Transcultural Clinical Center, LLC is committed to the personal and developmental growth of all its employees. To this end, Victoria
Transcultural Clinical Center, LLC not only prepares its new hires to succeed with the Company Victoria Transcultural Clinical Center, LLC but
also continually teaches, develops, and improves current employees’ skills in order to constructively respond to today’s ongoing business
challenges.

Employee training and development are essential in responding to the rapid business changes that occur due to continual economic
fluctuations, global economy, enhanced technology, and cultural and demographic factors.  Victoria Transcultural Clinical Center, LLC strongly
encourages the training and development of employees to aid them in improving their ability to succeed in their current position and to prepare
them for career advancement.

Some training programs are required for all employees, such as anti-harassment training and anti-discrimination training, training on Victoria
Transcultural Clinical Center, LLC policies and procedures, as well as occupational safety training. Employees required to attend these training
sessions will be compensated pursuant to applicable federal and state laws.

In addition, Victoria Transcultural Clinical Center, LLC encourages employees interested in job-specific training and continuing education
opportunities to research such programs and consult the Human Resources Department.  Management approval must be obtained, in writing,
prior to registering for the seminars or courses. 

Victoria Transcultural Clinical Center, LLC firmly believes in developing employees by drawing on the knowledge and experience of its own
talented workforce.  To this end, Victoria Transcultural Clinical Center, LLC offers programs such as coaching and mentoring.  To obtain more
information on these types of programs, employees may consult with the Human Resources Department.

6.17 Company-Sponsored Events

Company-sponsored events are common throughout the year. While some events are intended to encourage awareness of Victoria
Transcultural Clinical Center, LLC, such as job fairs, other events are simply held for employee enjoyment.

All such events are optional and do not mandate attendance unless otherwise stated by Company management. Because attendance is
voluntary, no accidents, injuries, or illnesses as a result of employee participation in a Company-sponsored event may be considered to have
occurred while “at work.” Exceptions exist when non-exempt employees are being paid or when exempt employees are working during their
regular work hours, and their activities result in injury or illness.

Among some of our Company’s events are summer picnics and/or sports outings. Employees who would like to participate in outdoor
recreational activities may wish to consult a physician before participating to ensure good health and safety.

Finally, in the case of alcohol availability at Company-sponsored events, employees are to use caution and control their consumption. Although
these events may not be work-related, employees are still required to follow the Company’s policies on appropriate workplace conduct,
including anti-harassment harassment, personal appearance, and health and safety-related policies.

Questions regarding this policy should be directed to the Human Resources Department.

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7. Timekeeping & Payroll
7.1 Attendance & Punctuality

Absenteeism and tardiness place an undue burden on other employees and on the Company. Victoria Transcultural Clinical Center, LLC
expects regular attendance and punctuality from all employees. This means being in the workplace, ready to work at your scheduled start time
each day, and completing your entire shift. Employees are also expected to return from scheduled meal and break periods on time.

All time off must be requested in writing, in advance, as outlined in the Company’s Paid Time Off (PTO) policy. If an employee is unexpectedly
unable to report for work for any reason, he or she must directly notify their supervisor, scheduler, and Director of Outreach as early as
possible, and preferably prior to their scheduled starting time. It is not acceptable to leave just a text message with the scheduler, except in
extreme emergencies. In cases that warrant leaving a text message or when an employee’s direct supervisor is unavailable, a follow-up must
be made later that day.

If an illness or emergency occurs during work hours, employees should notify their supervisor and scheduler as soon as possible.

Employees who are going to be absent for more than one day should contact their supervisor and scheduler on each day of their absence.
Victoria Transcultural Clinical Center, LLC reserves the right to ask for a physician's statement for all call-outs or multiple illnesses or injuries.

If an employee fails to notify their supervisor and scheduler after three consecutive days of absence, Victoria Transcultural Clinical Center, LLC
may presume that the employee has voluntarily resigned. Victoria Transcultural Clinical Center, LLC will review any extenuating circumstances
that may have prevented him or her from calling in before the employee is removed from the payroll.

Should undue or recurrent absence and tardiness become apparent, the employee will be subject to disciplinary action, up to and including
termination of employment. If an employee calls out on (5) occasions within a 90-day span, with less than 24 hours' notice to the scheduler, he
or she will be released from employment.

This policy is not intended to restrict an employee’s right to discuss or act together to improve wages, benefits, and working conditions with co-
workers or in any way restrict employees’ rights under the National Labor Relations Act.

7.2 Timekeeping

It is the Company's policy to comply with applicable laws that require records to be maintained of the hours worked by our employees. Every
employee is responsible for accurately recording time worked.

In addition to recording arrival and departure time, non-exempt employees are required to accurately record the start and end of each meal
period as well as any departure for non-work-related reasons. Any errors in time records must be immediately reported to your supervisor.

Absent prior authorization, non-exempt employees are not permitted to start work until their scheduled starting time or work past their
scheduled ending time.

Victoria Transcultural Clinical Center, LLC strictly prohibits non-exempt employees from working off the clock for any reason. All time spent
working must be logged and accounted for; this includes time spent using electronic devices for work-related purposes. 

Vacation days, sick days, holidays, and absences for jury duty, funeral leave, or military training must be specifically recorded by all employees.

It is the responsibility of all employees to validate their time records daily and again at the end of each week.

Altering, falsifying, tampering with time records, or recording time on another employee's time record may result in disciplinary action up to and
including termination of employment.

7.3 Paydays

Victoria Transcultural Clinical Center, LLC employees, are paid on a bi-weekly basis. If a regularly scheduled payday falls on a holiday,
employees will be paid on the day preceding the holiday unless otherwise required by state law.

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Paychecks will not, under any circumstances, be given to any person other than the employee without written authorization. Paychecks may
also be mailed to the employee's listed address or, upon advance written approval, deposited directly into an employee's bank account.
Employees who elect payment through direct deposit will receive an itemized statement of wages when the Company makes direct deposits.

In the event of employee termination, the employee will receive their accrued pay per applicable federal, state, and local laws.

7.4 Payroll Deductions

Victoria Transcultural Clinical Center, LLC makes deductions from employee pay only in the circumstances permitted by applicable law. This
includes but is not limited to mandatory deductions for income tax withholding, Social Security and Medicare contributions, and voluntary
deductions for health insurance premiums and other related contributions.

If you believe an improper deduction has been made from your pay, raise the issue immediately with the Human Resources Department.
Victoria Transcultural Clinical Center, LLC will promptly investigate. If the investigation reveals that you were subjected to an improper
deduction from pay, you will be reimbursed promptly.

7.5 Direct Deposit

All Victoria Transcultural Clinical Center, LLC employees may elect to have their pay directly deposited into their bank accounts. Direct deposit
saves employees the hassle of going to the bank on paydays to cash or deposit their paychecks.

Employees choosing this benefit must complete a Direct Deposit Authorization Form. To obtain this form, contact the office or the Human
Resources Department.
If you elect direct deposit, your paychecks will be directly deposited into your bank account, and you will receive an itemized statement of
wages.

Final paychecks will not be direct deposits. Employees must stop by the office to pick up a live check.

7.6 Pay Corrections

Victoria Transcultural Clinical Center, LLC takes all reasonable steps to ensure that employees receive the correct pay in each paycheck and
are paid promptly on the scheduled payday.

In the unlikely event that there is an error in the amount of pay, the employee should promptly bring the discrepancy to the attention of your
supervisor so that corrections can be made as quickly as possible.

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8. Organizational Development
8.1 Required Training

Our goal is to provide high-quality services to our customers. We must ensure that all company employees are trained and educated to a level
that supports high-quality service delivery. Service delivery not only consists of clinical service delivery but also includes areas such as
customer service and accuracy in communications. As a member of the VTCC team, you must complete organizational, state, and national
level training requirements. When training events are provided by or through the company, you must make the appropriate accommodations to
attend these required training. Required training topics include but are not limited to: ABA services, safety care, basic life saving, and equal
employment opportunity. VTCC required and augmentative company-hosted training events will be paid training events.

8.2 Augmentative Training

Augmentative training is training that is specific to the company's goals. These augmentative training are required by the company and may be
specific to the individual based on their department, credentialing level, and position within the company. Augmentative training topics may
include but are not limited to record keeping, billing, safety, stress management, and ABA service delivery. Employees will be paid at the
training rate established in separate correspondence. Required training events attended outside of the organization may be reimbursable
events; however, prior approval must be obtained. Employees will contact the front office to be directed to the appropriate approval authority
based on their training event.

8.3 Quarterly Evaluations

All employees will receive quarterly evaluations. Supervisors and Directors are required to complete a copy of the most updated version of the
evaluations form (VTCC HR-1). The Talent Management Director is responsible for the execution of all counseling sessions. During the
counseling session, a member of the Talent Management (TM) section, or a person designated by the TM Director, will review the completed
VTCC HR-1 form with the employee. The TM director will liaise with supervisors to provide pre and post-counseling out-briefs.

8.4 Corrective Counseling

VTCC Supervisors and Directors will provide corrective counseling when they deem it necessary to mature the organization. Corrective
counseling is designed to notify employees of a discrepancy and provide them with actionable steps to remedy the discrepancy. Corrective
counseling for concerns such as timeliness, task completions, customer satisfaction, and communications deficits can be initiated. This list is
not all-inclusive, as the supervisor or appropriate VTCC leadership determines the counseling need. Employees who receive (3) corrective
counseling forms within a six-month period will be released from employment.

8.5 Bonuses

Employees who receive a quarterly rating between 43 and 45 points will be provided a Step promotion commensurate with their previously held
Grade and Step. Any individual who receives a score of (0) in the areas of “Discipline” or “Development” on the VTCC HR-1 Evaluation Form
will be automatically disqualified from any promotions or pay raises associated with the evaluation observation period. If an employee receives
an award from a Supervisor or Director within the counseling period, he/she will receive a Step change. If an employee receives an award from
the Chief of Operations, Chief of Staff, or Clinical Director within the counseling period, he/she will receive a Grade change.

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 Employee Acknowledgment of Handbook
I acknowledge receiving and reviewing Victoria Transcultural Clinical Center, LLC’s Employee Handbook. I understand and recognize that
there may be changes to the information, policies, and benefits in the Handbook. I understand that Victoria Transcultural Clinical Center,
LLC may add new policies to the Handbook and replace, change, or cancel existing policies. I understand that I will be told about any
Handbook changes, and I understand that Handbook changes can only be authorized by Victoria Transcultural Clinical Center,
LLC management.

I understand and acknowledge that there is no specified length to my employment and that my employment is at will. I understand and
acknowledge that "at will" means that I may terminate my employment at any time, with or without cause or advance notice. I also understand
and acknowledge that "at will" means that the Company may terminate my employment at any time, with or without cause or advance notice,
as long as they do not violate federal or state laws.

I understand that I must read and comply with all policies in the employee Handbook. I further understand that I should consult my supervisor
regarding any questions.

Employee signature: ___________________________________________________________________________

Printed Name: ________________________________________________________________________________

Date: ________________________________________________________________________________________

Company Representative: _______________________________________________________________________

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