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TABLE OF CONTENTS

WELCOME ..................................................................................................................................................... 4
SERVICE STANDARDS ..................................................................................................................................... 5
STATEMENT OF PALMS’ HOSPITALITY ........................................................................................................... 5
COMMITMENT TO COMMUNITY................................................................................................................... 5
THE GROUND RULES ..................................................................................................................................... 6
EQUAL EMPLOYMENT OPPORTUNITY ........................................................................................................... 6
CODE OF BUSINESS CONDUCT ...................................................................................................................... 6
Confidentiality ........................................................................................................................................... 7
WHISTLEBLOWER POLICY .............................................................................................................................. 8
NON-INTERFERENCE POLICY ......................................................................................................................... 9
DEVELOPMENT PERIOD ................................................................................................................................. 9
TRANSFERS .................................................................................................................................................. 10
WORKFORCE PLANNING.............................................................................................................................. 10
BALANCING YOUR WORK-LIFE..................................................................................................................... 10
Vacation .................................................................................................................................................. 10
Holidays................................................................................................................................................... 11
Religious Holidays ................................................................................................................................... 12
Jury Duty ................................................................................................................................................. 12
Voting ...................................................................................................................................................... 12
Subpoena/Witness Duty ......................................................................................................................... 13
BENEFITS ..................................................................................................................................................... 13
Health Plans ............................................................................................................................................ 13
401(k) Savings Plan ................................................................................................................................. 14
Employee Assistance Program (EAP) ...................................................................................................... 14
Tuition Assistance ................................................................................................................................... 15
Team Member Parking............................................................................................................................ 15
Team Member Meals and Refresh Periods............................................................................................. 15
Workers’ Compensation ......................................................................................................................... 16
COBRA (Consolidated Omnibus Budget Reconciliation Act)................................................................... 16
WORKPLACE SAFETY AND WORK-RELATED INJURIES .................................................................................. 16

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SECURITY EMERGENCY CONTACT ............................................................................................................... 17
TEAM MEMBER CLASSIFICATIONS............................................................................................................... 17
WORK CARDS AND LICENSES ....................................................................................................................... 18
TIPS, GIFTS AND GRATUITIES ....................................................................................................................... 18
TIP COMPLIANCE ......................................................................................................................................... 19
PAY STATUS ................................................................................................................................................. 19
PAYROLL DEDUCTIONS ................................................................................................................................ 20
PAY PERIODS AND DIRECT DEPOSITS........................................................................................................... 20
TIMEKEEPING .............................................................................................................................................. 20
OVERTIME ................................................................................................................................................... 21
ATTENDANCE AND PUNCTUALITY ............................................................................................................... 21
IMPORTANT MEETINGS ............................................................................................................................... 21
PERSONAL APPEARANCE ............................................................................................................................. 21
Uniforms.................................................................................................................................................. 22
Name Tags ............................................................................................................................................... 22
COMPANY PROPERTY .................................................................................................................................. 22
TECHNOLOGY .............................................................................................................................................. 22
COMPANY-PROVIDED CELL PHONES ........................................................................................................... 24
PERSONAL CALLS, MAIL AND VISITORS ....................................................................................................... 24
GUEST PRIVACY AND DECORUM ................................................................................................................. 25
PUBLICITY AND STATEMENTS TO THE MEDIA ............................................................................................. 26
SOCIAL MEDIA ............................................................................................................................................. 26
TEAM MEMBER MADE RECORDINGS .......................................................................................................... 26
YOUR PERSONAL PROPERTY ........................................................................................................................ 26
ENJOYING THE PROPERTY DURING OFF-DUTY HOURS ................................................................................ 27
TEAM MEMBER GAMBLING POLICY ............................................................................................................ 27
RESPONSIBLE GAMING ................................................................................................................................ 28
SALES AND SERVICE OF ALCOHOL ............................................................................................................... 28
LOST AND FOUND ....................................................................................................................................... 28
GIFTS ........................................................................................................................................................... 29
SOLICITATION/DISTRIBUTION ...................................................................................................................... 29
BULLETIN BOARDS AND ELECTRONIC MESSAGES ....................................................................................... 30
ANTI-HARASSMENT AND ANTI-BULLYING PREVENTION POLICY ................................................................. 30

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ARREST AND CONVICTIONS ......................................................................................................................... 32
EXPENSE REIMBURSEMENTS ....................................................................................................................... 33
PROGRESSIVE COUNSELING ........................................................................................................................ 33
FRATERNIZATION......................................................................................................................................... 34
HIRING OF RELATIVES .................................................................................................................................. 35
IF YOU DECIDE TO LEAVE US ....................................................................................................................... 36
REHIRE AND BRIDGE OF SERVICE ................................................................................................................ 36
AT-WILL EMPLOYMENT ............................................................................................................................... 36
YOUR EMPLOYMENT RECORDS ................................................................................................................... 37
OUTSIDE EMPLOYMENT .............................................................................................................................. 37
LEAVES OF ABSENSE .................................................................................................................................... 38
Military Leave.......................................................................................................................................... 38
Bereavement Leave ................................................................................................................................ 38
School Activities Leave ............................................................................................................................ 39
Occupational Injury Leave....................................................................................................................... 39
Family Medical Leave Act (FMLA) ........................................................................................................... 39
Unpaid Personal Leaves .......................................................................................................................... 44
AMERICANS WITH DISABILITY ACT .............................................................................................................. 44
NEVADA PREGNANT WORKERS’ FAIRNESS ACT ........................................................................................... 45
DRUG AND ALCOHOL-FREE WORKPLACE .................................................................................................... 46
CONDUCTING SEARCHES AND PROBABLE CAUSE TESTING ......................................................................... 47
NO REQUESTS FOR GENETIC INFORMATION............................................................................................... 48
THANK YOU! ................................................................................................................................................ 48

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WELCOME
On behalf of the San Manuel Gaming and Hospitality Authority and the Palms
Leadership Team, thank you for choosing Palms and welcome to the team! It
is with great pride and humbleness that I introduce myself as your General
Manager and officially welcome you.
This is an historic time as Palms becomes the first Native American owned and
operated casino resort in Las Vegas. This milestone is marked by the Tribe’s
rich history and culture and unmatched commitment to people and
community.
We have an exciting future ahead of us as we bring forward the strong values
of friendliness and hospitality into everything we do. From our Team Member
experience to our signature, friendly guest service, our goal is to create a
lively, fun and welcoming environment for everyone who enters our doors.
Our entire leadership team wishes you a warm welcome and we all look forward to meeting you. We
appreciate you embarking on this journey with us and can’t wait to see all that we’ll accomplish together
at our iconic Palms Casino Resort.
We’re thrilled you are here and excited to make history together!
Cynthia Kiser Murphey

Front Desk Palms Casino Resort

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SERVICE STANDARDS
Excellent guest service is everyone’s job. We want all our guests to feel welcome at Palms and have
experiences that surprise and delight. Each and every interaction should include:

• Sincere and Friendly Greeting – Welcoming body language and good posture, make eye contact,
smile, and acknowledge the guest.
• Make Our Guests Feel Special – Use the guest’s name, escort them to their destination, listen and
repeat so you get it right!
• Heartfelt Farewell – Thank the guest and invite them back.

STATEMENT OF PALMS HOSPITALITY


Friendliness First. Integrity Always. Community at Heart.
As we have the privilege to open Palms in April of 2022, we are honored to welcome guests to meet our
friendly and warm Team Members. We take our roles seriously and love to welcome guests from our
community and neighborhoods, our loyal Club Serrano and Yaamava’ guests, and from around the world.
We create fun, and bring San Manuel’s warm hospitality to the public.
Here is how we bring hospitality to life:
• We take ownership when action is needed and follow through on commitments.
• Be in the Know: be familiar with our property amenities, events and promote Palms venues.
• Take pride in your appearance and the look of our property.
• Be distinctive.
• Keep guest information confidential and secure.
• Demonstrate creativity and feel empowered to give suggestions for improvement.
• Be willing to assist others and work as a team.
• Set personal goals and consider your impact on the guest experience.
• Pay attention and exceed guest expectations by giving personalized and authentic service.
• Anticipate guest needs and seek out opportunities to enhance our guests’ experiences.
• Push past the status quo and make a difference – “our community and my workplace should be
better because I was here!”

COMMITMENT TO COMMUNITY
Palms’ culture is centered around community support, philanthropy and environmental sustainability,
following the rich culture of giving and stewardship created by the San Manuel Gaming and Hospitality
Authority. Team Members will all have an opportunity to participate in volunteerism, give back to the
community in a variety of ways, and support fellow Team Members in need. We’ll do all of this through our
Palms Cares program and in partnership with community organizations and nonprofits.

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THE GROUND RULES
This Handbook is designed to acquaint you with Palms (or the “Company”) and give you a reference to
answer questions regarding your employment. The contents of this handbook are a summary of the
benefits, policies, and employment regulations in effect at the time of publication. It is not intended to be
comprehensive or to address all the possible applications of, or exceptions to, the general policies and
procedures described. If you have any questions concerning eligibility for a particular benefit, or the
applicability of a policy or practice to you, address your specific questions with your Manager or contact
Human Resources.
If your position is covered by a Collective Bargaining Agreement (CBA), the CBA controls. Some of the
policies outlined in this handbook may not apply, so always consult your CBA first.
The procedures, practices, policies, and benefits described here may be modified or discontinued from
time to time, at the company’s discretion. Any changes made to this Handbook shall apply to existing, as
well as future Team Members. Should any provision in this handbook be found to be unenforceable and/or
invalid, such findings will not invalidate the entire handbook, but only the relevant provision.

EQUAL EMPLOYMENT OPPORTUNITY


Our Company has a work environment where differences among Team Members are valued and integrated
into every part of our work life. Through our culture, we foster a cooperative work environment where our
Team Members are treated with respect, trust and dignity, and are encouraged to reach their full potential.
Inherent in this respect for the individual is our commitment to diversity, equity, and inclusion, in all its
dimensions, as it relates to our guests, team members, vendors, business partners and community.
Palms is committed to equal employment opportunity. Palms does not discriminate against any applicant
or Team Member based on any legally-recognized basis, including, but not limited to: race, color, national
origin or ancestry, gender, gender identity, religion, age (40 and over), sex (including pregnancy, lactation,
childbirth or related medical conditions), physical or mental disability, genetic information (including
testing and characteristics), veteran status, uniformed servicemember status, sexual orientation, or any
other status protected by federal state or local law when it comes to all employment practices, including
but not limited to selecting, hiring, training, promoting, transferring, compensating, counseling, laying off,
recalling, and terminating Team Members.
We respect, appreciate and celebrate individual differences in our workforce and we are excited that we
have a team where many individuals come together to successfully accomplish our goals.

CODE OF BUSINESS CONDUCT


Actions speak louder than words – especially to our guests and fellow Team Members. It is important we
all act with honesty and integrity while doing our jobs. Palms is also committed to creating a fun and safe
work environment that brings out your full potential. As a condition of your employment, you must always
demonstrate professionalism when you are representing Palms, whether you are on property or
conducting business off-site. Refer to the Company's Code of Business Conduct for further details.

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Confidentiality
While employed, you may acquire knowledge of trade secrets, proprietary, confidential, or sensitive
information belonging to Palms, its Team Members and/or its customers, such as financial information
(other than information regarding wages, benefits and working conditions), agreements, sales figures,
business plans, and proprietary information.
All of this information, regardless of who it is about, is strictly confidential and shouldn’t be disclosed to
anyone, including San Manuel Tribal Citizens, vendors, customers or Team Members, during or after your
employment. The Company’s Code of Business Conduct must be acknowledged and agreed to as condition
of employment. The following are examples of confidential information:
• Information regarding business nature like bidding practices, financial information, reference
names, projects or proposals, products or services, costs, pricing, profits, markets, guest lists, all
data regarding customers and vendors, and plans for future expansion or business development.
• Non-public, technical information such as civil engineering plans and processes, customer lists,
Club Serrano information, pricing information, reports, computer programs, software and
supporting documentation, procedure manuals and related methods or technologies.
• Confidential performance evaluation data about Team Members. This policy does not preclude
Team Members from discussing wages, benefits and working conditions with others.
• Information about services, products, including results of, provided to Palms guests.
• Any information which if disclosed, could negatively impact Palms business, reputation and/or best
interests.
Additionally, you must not violate guest/Team Member privacy by discussing confidential or privileged
information. This privileged information includes but is not limited to a guest’s level of play, visitation
frequency, buy-in amounts, win/loss results or any other record of their play or personal information. This
information must not be shared with anyone other than the guest or a Team Member who clearly has a
business reason for needing to know. This prohibits disclosing information to the guest’s family members,
friends, or business associates.
No one is permitted to remove from the premises or make copies of any records, reports, or documents,
without prior written approval of management.
Disclosure of confidential information, proprietary, trade secrets or sensitive information, whether
deliberate or inadvertent, may result in progressive counseling, up to and including separation.
Furthermore, Palms can also file criminal charges.
Upon separation of your employment or at any time upon Palms request, you must return all copies of
confidential information, or other Palms property.
This policy is not intended and should not be construed as interfering, limiting, or preventing any Team
Member from exercising his/her rights under Section 7 of the National Labor Relations Act, to the extent
applicable.
If you have questions about confidentiality, contact your immediate manager. You may also refer to the
Company's Code of Business Conduct for further details, including permitted disclosures.

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WHISTLEBLOWER POLICY
Palms is committed to the highest possible standards of ethical, moral and legal business conduct. In
conjunction with this commitment and Palms’ commitment to open communication, this policy aims to
provide an additional avenue for Team Members to raise concerns and provides reassurance that they will
be protected from reprisals or victimization for whistleblowing in good faith. If however a Team Member
feels that their anonymity is not required, then they are encouraged to report any and all concerns to
management or Human Resources.
The whistleblower policy is intended to cover serious concerns that could have a significant impact on
Palms, including but not limited to, actions that may lead to incorrect financial reporting, are unlawful, are
not in line with company policy, or otherwise amount to serious improper conduct.
Palms adheres to applicable laws and regulations and expects Team Members’ support to maintain legal
compliance.
Examples of incidents that should be reported include:
• Ethical Violations
• Unsafe Working Conditions
• Quality of Service
• Discrimination or Harassment
• Alcohol and Substance Abuse
• Fraud
• Conflict of Interest
• Theft and Embezzlement
• Violations of Law
• Falsification of Contracts
• Wrongful Discharge
• Disregard of Internal Controls
• Vandalism and Sabotage
• Improper Conduct
• Conduct Violations
• Bribery and Kickbacks
• Misuse of Company Property
• Violations of Company Policy, including but not limited to the Anti-Harassment/Anti-Bullying Policy
• Violations of the Company’s Non-Interference Policy

If you are aware of any violations of the Palms’ Anti-Harassment/Anti-Bullying policy, the conduct should
be reported, in a manner that you are comfortable (either in writing or verbally) immediately to any of the
following options with which you feel comfortable:
● Your immediate supervisor, or
● Your Department Manager, or

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● Any Department Manager, or
● The General Manager, or
● The Company’s Human Resources Department, or
● Incident Reporting Hotline at
o English speaking: 833-950-4542
o Spanish speaking: 800-216-1288
o https://www.lighthouse-services.com/palms.

A Team Member making a complaint or report of harassment or discrimination will be asked to submit a
written statement that provides details about the situation. Promptly after receiving a complaint, the
Company will investigate and take all steps necessary to prevent harassment, discrimination, or retaliation.
The Company or its representative will promptly investigate all complaints and the Company will impose
appropriate corrective action where it determines that a violation of the Anti-Harassment/Anti-Bullying
policy is substantiated.
All complaints shall be kept confidential, to the fullest extent possible, to permit the Company to conduct
a thorough investigation. Witnesses to discrimination or harassment and victims of discrimination or
harassment shall not be retaliated against in any way for making a good faith complaint or for cooperating
in an investigation. Team Members who interfere with or obstruct any investigation will be subject to
progressive counseling, up to and including separation.

NON-INTERFERENCE POLICY
The Company has the honor and privilege of holding the first gaming license ever granted to a tribal owned
and operated casino in Nevada. As part of this historic and unique situation, extra steps have been taken
to ensure that the oversight and management of the Palms lies exclusively with the SMGHA Board and
Management Committee. This means that decisions about operations and management of Palms must be
made independently. The Company has created a Non-Interference Policy to set forth the minimum
standards and practices for ensuring the independent oversight and management of the Palms. By adhering
to this policy, you will protect yourself, your staff, SMGHA, and the integrity of operations at the Palms as
we make history as the first tribal owned and operated commercial casino in Nevada. Please refer to the
full Non-Interference Policy for further details.

DEVELOPMENT PERIOD
New Full-time Team Members are provided a ninety (90) calendar day Development Period and Part-time
and On-call Team Members are provided one-eighty (180) calendar day Development Period, starting with
their first day of employment. During this period, both you and Palms have time to decide if the
employment relationship is in the mutual interest of both parties. Palms may extend the duration of the
Development Period at its sole and absolute discretion. Successful completion of the Development Period
does not change the “at-will” status of Team Members. The employment relationship can be terminated
by the Team Member or Palms at any time during or after the Development Period, with or without cause,
with or without notice.

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TRANSFERS
We are committed to our Team Members’ growth and opportunity, and have created a transfer policy to
encourage Team Members to try new venues, positions or look for promotional opportunities. Team
Members are eligible to transfer after the successful completion of their development period. Team
Members with a Final Written Warning and Team Members currently on an action plan are not eligible for
transfer.

When a Team Member cannot satisfactorily perform the work of the job to which he/she transferred or if
they decide the new position is not suited for them, they may be transferred back within 30 days of the
transfer if their position or similar position is available and it is agreed upon by both managers and Human
Resources. If the Team Member transfers back to their prior position, their classification date will change
to reflect this new date of transfer. Seasonal and temporary Team Members are not eligible for this transfer
policy but are encouraged to look for available opportunities.

WORKFORCE PLANNING
Palms has created a centralized Workforce Planning department, so that managers can focus on coaching,
development and our guests, and so that Team Members have one centralized point of contact for
scheduling and attendance. If you are not available to work a scheduled shift, you should contact Workforce
Planning at 866-942-7770. Hours of operation will be 6am – 9pm, 7 days a week. Outside hours of
operations, please contact your Manager if you are late or need to be absent.

BALANCING YOUR WORK-LIFE


We encourage you to balance your work and personal life and take time away from work to rest, rejuvenate,
and enjoy those things most important to you, like spending time with family and friends.

Vacation
Full-time hourly Team Members are entitled to paid vacation according to the following schedule:
Years of Continuous Service upon Anniversary Date Vacation Allowance
1 year of service 1 week
2 - 5 years of service 2 weeks
6 + years of service 3 weeks
12 + years of service 4 weeks
Part-time Team Members who have twelve (12) months of continuous Company service are entitled to
paid vacations based on hours worked, at a rate of .01923 hours of vacation time per hour worked.
Team Members under a collective bargaining agreement (CBA) should refer to the agreement for
information regarding eligibility for this benefit or contact a union representative.
Vacation time must be pre-approved by Workforce Planning. The number of Team Members from each
department who will be scheduled for time off during any period will depend upon the business needs of
the department.

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Neither vacation nor floating holiday time may be carried over.
Vacation and/or floating holidays will not be paid to a Team Member in lieu of receiving an attendance
infraction under the Attendance and Punctuality Policy.
All earned and unused vacation hours will be paid upon separation of employment. Unused floating
holidays will not be paid upon separation of employment.
Vacation pay will be paid at a Team Member’s regular straight time hourly rate of pay or regular base salary
for the approved vacation period. Vacation days are not considered hours worked for purposes of
calculating overtime.
Team Members must use any earned vacation time and floating holiday time during all state and federal
family medical leaves to the extent permitted by law.
It may be necessary for some departments to block certain periods of time throughout the year, e.g.
holidays, when vacation or floating holidays cannot be taken to assure that we are able to provide sufficient
guest service at all times.
Palms is a 24-hour/365-day operation. Different departments recognize different black-out/required dates
in which time off requested is not approved. For questions about those dates, contact Workforce Planning.

Holidays
Regular full-time and part-time hourly (non-exempt) Team Members may be eligible for holiday pay and/or
time off. To be eligible for holiday pay, you must have completed ninety (90) days of continuous
employment with the Company and work your scheduled day before and scheduled day after the holiday.
The Company recognizes the following holidays:
• Memorial Day
• Independence Day
• Labor Day
• Thanksgiving Day
• Christmas Day
In addition, the Company offers three additional “floating” holidays for eligible full-time, non-exempt Team
Members.
To be eligible for holiday pay, you must have completed ninety (90) days of continuous employment with
the Company and work your scheduled day before and scheduled day after the holiday.
Eligible full-time non-exempt Team Members who are off on a designated holiday will receive 8 hours pay
at their regular hourly wage rate as holiday pay.
Eligible full-time non-exempt Team Members who work on a designated holiday will receive holiday pay,
as described above, plus pay at their regular rate for hours actually worked.
Eligible part-time non-exempt Team Members who work on a designated holiday will receive holiday pay
depending upon the hours worked on the holiday, at their regular hourly wage rate, plus pay at their regular
rate for hours actually worked.

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If a Team Member was scheduled at least one week in advance to work on a holiday and fails to report to
work on that holiday, he or she will not receive any holiday pay, except in unusual circumstances, and with
prior approval.
Unless otherwise required by law, Team Members on a leave of absence are not eligible for holiday pay.
If a paid observed holiday falls or is observed during your vacation time, you will be paid for the holiday and
will not be required to use vacation time for that day.

Religious Holidays
To reasonably accommodate the religious needs of Team Members, Palms makes every effort to
accommodate time off for religious observances that are not scheduled paid holidays.
Team Members must give reasonable advance notice to and obtain prior approval from Workforce Planning
when requesting time off. Reasonable notice is considered a minimum of ten (10) calendar days. At the
Team Member’s option, unused paid time off, if available, can be used for religious holiday observance. In
the absence of earned paid time off, these holidays can be observed as time off without pay.

Jury Duty
Palms supports the obligation of all U.S. citizens to serve on a jury when summoned to do so. All Team
Members are allowed time off to perform such civic service as required by law. Team Members must notify
Workforce Planning as soon as a jury duty notice is received.
If you are a full-time Team Member with at least one (1) year of employment and are summoned to jury
duty, the Company will pay the difference between your regular salary (not including tips) and the amount
you receive from the court (excluding any transportation allowance you may receive) for a maximum of
two (2) weeks per jury duty notice. If you do not qualify, all time off for jury duty will be unpaid.
If the required absence presents a serious conflict for management, Team Members may be asked to try
to postpone jury duty. Team Members must report to work for the major portion of the day if excused by
the court unless such a requirement is restricted by Nevada law. Team Members also must provide
verification of service.
Any pay provided for time spent on jury duty leave is not counted as hours worked for purposes of
calculating overtime.

You may keep any mileage allowance or other fees paid by the court for jury services.

Voting
If you are a registered voter and it is impracticable for you to vote before or after your hours of work, you
may take off sufficient time to vote. A sufficient time to vote shall be determined as follows:
• If the distance between the place of your employment and the polling place where you vote is 2
miles or less, 1 hour.
• If the distance is more than 2 miles but not more than 10 miles, 2 hours.
• If the distance is more than 10 miles, 3 hours.

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All time off will be paid. The time off shall be taken only at the beginning or end of your shift, unless your
Manager agrees otherwise. You must notify Workforce Planning and the Human Resources Department
prior to the day of the election, if time off will be needed.

Subpoena/Witness Duty
Team Members are paid their normal wage or salary if required by a subpoena to appear in court on behalf
of Palms. Team Members will not be paid for their time off if summoned to appear in court because of a
subpoena on matters not pertaining to Palms business or on matters in which they’re personally involved
in the legal action. You can request to use available accrued paid vacation or Personal Leave Time.
Team Members subpoenaed for witness duty must notify Workforce Planning as soon as possible.

BENEFITS
Our Benefits Plans are provided to support you and your family to help you build a healthy, rewarding and
a financially secure life.
Health Plans
Palms offers the following benefits to eligible Team Members
• Medical
• Dental
• Vision
• Medical Flexible Spending Account (FSA)
• Medical Health Saving Account (HSA)
• Life Insurance
• Accidental Death & Dismemberment
• Voluntary Benefits

Eligibility for certain benefits is based on a variety of factors including CBA coverage and Team Member
classification. You will be informed of the programs for which you are eligible. If you lose eligibility for
certain health and insurance benefits (i.e., reduced hours, employment status change, separation), you
have the right to continue some or all those benefits at the full premium rate. In this case, you will receive
formal notification of your coverage continuation rights when you first become eligible, and when you
experience a qualifying event that causes you to lose eligibility.
Some benefit programs require contributions from the Team Member. All benefits provided are pursuant
to and governed by the applicable plan document. Palms reserves the right to modify or discontinue any of
its Team Member benefits or plans on a prospective basis at any time.
• Initial Enrollment – This is the first day you become benefits eligible (i.e., hire date, status change
date). You have thirty (30) days from the date you become benefits eligible to enroll in health and
insurance benefits.
• Annual Open Enrollment – This is when you can make any changes to your health and/or insurance
enrollments. In general, changes made during this period are effective January 1.

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• Benefit Change – This is when you can make health and insurance enrollment changes as a result
of a life event (i.e., birth, marriage, loss or gain of coverage under another plan). When you
experience a life event, you have thirty (30) days from that event to make a change to your benefits.
If you have questions about benefits, visit the Palms Benefits Center at mypalmsbenefits.com or call 888-
732-4269, Monday through Friday, 8 a.m. to 5 p.m. Pacific Time.

401(k) Savings Plan


Palms provides eligible Team Members with a retirement savings opportunity through a 401(k) plan,
allowing for pre-tax or post-tax contributions. Eligible Team Members may begin making contributions as
early as 90 days of employment. The Plan has a selection of investment options. When you contribute to
the 401(k), Palms matches a percentage of your contributions. Palms also provides a discretionary 401(k)
contribution to eligible Team Members. 401(k) information will be sent to you upon eligibility. If you have
questions about the Palms 401(k) plan, contact Transamerica at 844-622-2133.

Employee Assistance Program (EAP)


Palms provides Team Members with a comprehensive Employee Assistance Program (EAP) through
Harmony Healthcare. Our EAP provides rapid responses to you, your dependents and anyone who lives in
your household with work-life needs. EAP telephonic counseling is available 24 hours a day, seven days a
week. You may also receive up to five (5) visits free of charge.
EAP offers confidential counseling when dealing with personal issues, including depression and anxiety,
marital issues, alcohol or drug abuse, marital conflicts, adolescent behavioral problems, financial problems
or legal problems.
Other services available through the EAP include:
• Referral services for childcare, elder care, after school program, and summer camps
• Health and wellness programs
• Self-improvement programs
• Cleaning service
• Discount programs
• Relocation assistance
• Colleges/universities and private schools, financial aid and scholarships
• Adoption assistance
• Legal Services, tax assistance, immigration, consumer issues, personal/family law, real estate,
financial and retirement planning
Contact Harmony Healthcare at (702) 251-8000 or (800) 363-4874. You may also access their website for
online tools, articles, resources and more at www.harmonyhc.com.

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Tuition Assistance
Palms reimburses the cost of tuition and books associated with a full-time Team Member’s enrollment and
expenses related to required training for your position, certification, graduate, or undergraduate courses.
The maximum reimbursement available to a Team Member during a calendar year is $500. Benefits are
provided upon your successful completion of eligible classes. Reimbursement will not be made for the cost
of application fees, examination fees, travel or lodging costs, or any miscellaneous fees or expenses.
Successful completion means you passed an undergraduate course with a grade of “C” or better, or its
equivalent, or passed a postgraduate course with a grade of “B” or better, or its equivalent.
Team Members must obtain pre-approval by Human Resources prior to enrollment to be eligible. You must
be actively employed to receive this benefit and be active and eligible when you take the course. You are
required to pre-pay tuition and books subject to reimbursement. Upon successful completion of course
work, you will receive reimbursement. Claims for reimbursement must be submitted within thirty (30)
calendar days of receiving your grade(s). Team Members are eligible for education tuition assistance after
the completion of the Development Period.

Team Member Parking


Team Members may only park in designated parking areas. Team Members visiting Palms or Palms Place
off duty must use public parking areas.
It is very important to drive safely while on any Company property. If you damage another car, immediately
report the incident to Security, along with the license plate numbers of both vehicles and any other
information. Palms does not assume any liability for any loss or damages you may sustain in using Team
Member parking areas.

Team Member Meals and Refresh Periods


Palms is committed to offering fresh and healthy meal options in our Team Member Dining Room. For the
convenience of the Company, eligible Team Members are provided with meals and are paid for their meal
break time. If you work more than four (4) consecutive hours, you are entitled to a meal period of at least
thirty (30) minutes. Your manager schedules a meal period taken within four (4) hours after the beginning
of a shift. The Company provides one (1) free meal per shift and unlimited beverages. Team Members are
not permitted to leave property during their paid lunch break or use the Team Member Dining Room (TDR)
during off-duty time, unless authorized by management.
Departments may have specific refresh and meal periods scheduled. Make sure you understand your
department practices regarding coordination of breaks. Team Members must take all meal rest period away
from their workstations in authorized break areas at their respective locations unless otherwise authorized.

Palms recognizes your need to take time to refresh throughout the workday. Departments schedule paid
refresh periods around operational needs. Generally, refresh periods are no more than ten (10) minutes
for each four (4) hours worked or major fraction thereof when employed for at least 3 ½ hours and occur
as closely as possible to the middle of each four (4) hour segment. If you require specific refresh periods,
please discuss with your manager.

Updated 4/13/22 Page 15


Workers’ Compensation
The Company pays the entire amount of the Workers’ Compensation insurance premium, which provides
benefits to Team Members who experience injury or illness connected with their employment. To be
eligible for Workers’ Compensation benefits, the injury must be a direct result of the job. Benefit
entitlements are governed by law, but it is essential that you report all work-related accidents, injuries, and
illnesses regardless of how minor to your Manager immediately and within the same day of the accident,
injury or illness. Filing a false or fraudulent claim will also result in progressive counseling, up to and
including immediate separation.
COBRA (Consolidated Omnibus Budget Reconciliation Act)
If you are covered by the Company’s group health plan, you have the right to choose continuation coverage
if you lose your group health coverage for various reasons, including due to a reduction in your hours of
employment or the separation of your employment (for reasons other than gross misconduct on your part).
Your eligible dependents may also have the right to elect and pay for continuation coverage for a temporary
period in certain circumstances where their coverage under the plan would otherwise end. If you have any
questions concerning your rights under COBRA, please contact the Human Resources Department.

WORKPLACE SAFETY AND WORK-RELATED INJURIES


Safety is the top priority at Palms. Applicable law requires that Palms keep records of occupational illnesses
and injuries that happen while working. If you experience a work-related injury or illness, you may qualify
for certain benefits. Immediately (within 24 hours) notify your manager, regardless of how small the
incident. You should notify your manager and/or the Security or Safety department as soon as the incident
occurs, as it may impact your eligibility for workers’ compensation benefits.
An approved leave for a “work-related disability” generally is extended for the duration of the disability
until a Team Member is released for either full or partial duty, is determined to be permanently disabled
and unable to return to work, or informs Palms they do not intend to return to work for Palms. Before
returning to work, you must provide Human Resources with a medical release from a Concentra physician.
Note: You should be aware that the law prohibits filing a knowingly false or fraudulent claim for workers’
compensation benefits, or to submit knowingly false or fraudulent information in connection with any
workers’ compensation claim. Filing a false or fraudulent workers’ compensation claim is also a violation of
Palms policy, and results in progressive counseling, up to and including immediate separation. Palms policy
is to investigate all questionable workers’ compensation claims and to refer them to the appropriate
agencies and/or avail itself of all right and remedies under the law if they appear to be fraudulent.
Applicable law also provides for your right to know about any health hazards present on the job. For
questions or concerns, contact the Safety Manager at safety@palms.com or your Manager for more
information.
It is everyone’s responsibility to report unsafe conditions at work. In addition to reporting all injuries (no
matter how small) to your manager immediately, report anything needing repair or that presents a safety
hazard.
Below are examples of the type of general, common sense safety rules you must follow. Your department
may post other safety procedures for your work area.
• Avoid overloading electrical outlets with too many appliances or machines.

Updated 4/13/22 Page 16


• Do not plug extension cords together.
• Do not use temporary space heaters.
• Use flammable items, such as cleaning fluids, with caution.
• No candles or open flames.
• Only use space heaters that have been provided by the Company.
• If you See Something, Say Something, report all specious activity to Security.
• Walk — do not run.
• Use stairs one at a time and use handrails.
• Report to your manager if you or another Team Member is ill or is injured.
• Ask for help when lifting heavy objects or moving heavy furniture.
• Smoke and/or vape in designated smoking areas only.
• Keep cabinet doors and file and desk drawers closed when not in use.
• Sit firmly and squarely in chairs that roll or tilt.
• Wear or use appropriate safety equipment as required in your work.
• Avoid “horseplay” or practical jokes.
• Start work on any machine only after safety procedures and requirements are explained (and you
understand them).
• Only operate powered industrial or aerial lift equipment if training and certifications are current.
• Only use ladders if you have completed ladders safety training and inspect the ladder prior to use.
• Wear appropriate personal protective equipment, like shoes, hats, gloves, goggles, etc., in
designated areas or when working on an operation requiring their use.
• Keep your work area clean and orderly and aisles clear.
• Stack materials only to safe heights.
• Watch out for the safety of fellow Team Members.
• Use the right tool for the job and use it correctly.
• Never walk past a spill or object that could cause a slip, trip, or fall for another employee or guest.
• Follow all pandemic-related safety measures (i.e., wearing a face covering, social distancing, etc.)
when directed by Human Resources.

SECURITY EMERGENCY CONTACT


For any on-property emergency, Security may be contacted by dialing extension 6889. For a medical
emergency, dial 911.

TEAM MEMBER CLASSIFICATIONS


• Regular Full-Time: Team Members who regularly work thirty (30) hours or more per week.
• Regular Part-Time: Team Members who are scheduled to work less than thirty (30) hours per week.
• Temporary or Seasonal: Team Members hired for a specific period of time or specific project.
• On-Call: Team Members who have no set/bidded schedule and are scheduled as needed, typically
below 30 hours per week.

Updated 4/13/22 Page 17


• Interns: Team Members hired or transferred for a specific period through a qualified school
internship program.

WORK CARDS AND LICENSES


I.D. Cards are issued to all new hires and all on duty Team Members must keep any required cards on their
person. Failure to do so will result in progressive counseling.
All work cards, gaming registrations, licenses and/or certifications/cards must be current and valid during
your employment with the Company. It is your responsibility to renew your work cards prior to their
expiration date. Failing to renew a required work card prior to its expiration will result in you being unable
to work and your removal from your department’s schedule. If you then return to work with valid work
cards within three (3) business days, you will be returned to the schedule but will receive progressive
corrective action under job performance. If you do not return within three (3) business days with valid
work cards, you may be separated.
When you renew any of these cards, you must take them to the Human Resources Department to update
your personnel file:
• Gaming Registration is required of Team Members who work with gaming funds, systems and/or
gaming documents and records.
• A Driver’s License is required of all Team Members who drive vehicles belonging to the Company
and/or Guests. Team Members who drive their personal vehicle for work must maintain current
automobile insurance in addition to a current driver’s license.
• Work Permits must be obtained by all Team Members who are 17 years of age and under, from
the appropriate juvenile authorities.
• Alcohol Awareness Certification is required of Team Members who work around or serve alcoholic
beverages. You must carry the card with you at all times while on duty.
• Non-Gaming Cards issued by the local police department are required as a condition of
employment for many Team Members. You must carry the card with you at all times while on duty
if it is a requirement of your position at your property.
• Health Cards, where applicable, must also be obtained by certain Team Members. Check with your
Department Manager. You must carry the card with you at all times while on duty.
Other Work Cards & Licenses may be required for certain positions. Please check with Human Resources
to determine what you are required to maintain.

TIPS, GIFTS AND GRATUITIES


To avoid conflicts of interest and the appearance of conflicts of interest, Palms has established the following
guidelines for tips, gifts, meals, accommodations, and gratuities.

Palms recognizes that guests will regularly provide tips and gratuities for exceptional guest service. Team
Members may not solicit or pressure any guest to leave a tip or gratuity. Members of management are not
allowed to accept tips or gratuities from guests.

Updated 4/13/22 Page 18


Palms prohibits receiving anything of value that may influence or appear to influence the actions or
judgment of others. You, any member of your family or anyone acting as an agent on your behalf shall not
solicit or accept for personal benefit directly or indirectly any gift, favor, meal, entertainment, loan,
discount or any item of substantial monetary value, beyond the limits provided below.

If you are presented with a situation or circumstances where you are unsure as to whether it is acceptable,
a customary business practice, and/or exceeds the monetary limits listed below, please contact your
manager or Human Resources.

Gifts and entertainment given to or received from persons who have a business relationship with the
Company are generally acceptable, if the gift or entertainment is modest in value, appropriate to the
business relationship, and does not create an appearance of impropriety. However, even nominal gifts
should not be accepted if the potential for a conflict of interest or personal obligation exists. Additionally,
Team Members should avoid a pattern of accepting frequent gifts from the same source. No cash or cash
equivalent payments should be given or received. In addition, gifts must not be given to or received from
public officials. Team Members who do not comply with these requirements may be required to reimburse
the Company for the value of any gifts or benefits they make or receive on behalf of the Company. Giving
or receiving any payment or gift in the nature of a bribe or kickback is absolutely prohibited. Refer to the
Company's Anti-Bribery Policy for further details.

Meals and accommodations may only be accepted if they are reasonable in cost and consistent with
customary business practices. As a recommended practice, you should always inform your manager when
presented with these opportunities.

TIP COMPLIANCE
The Company participates in the IRS’s Gaming Industry Tip Compliance Program (GITCA). Your position may
or may not earn tip income; however, if it does, you are required by law to report tips as your earnings.
Under GITCA, the IRS establishes an average tip rate for each tipped position. Participating employees are
relieved of the burden of manually counting their tips and reporting that income on their tax returns. Tip
rates and copies of the Tip Compliance Agreement may be requested by contacting the Human Resources.
If you opt-out of tip compliance, you are required to report your tip earnings to the Company on a bi-weekly
basis.

PAY STATUS
Exempt Team Members are paid a salary and typically serve in an executive, professional, or administrative
capacity. Their specific duties and responsibilities permit them to be “exempt” from overtime pay
provisions as provided by applicable state and federal law. If you are an exempt Team Member, you will be
advised of this classification at the time you are hired or transferred.
Non-exempt Team Members are paid hourly and are generally eligible for overtime pay if they work in
excess of forty (40) hours per workweek pursuant to applicable law. You should direct any questions
regarding overtime eligibility and pay to your manager or Human Resources.

Updated 4/13/22 Page 19


PAYROLL DEDUCTIONS
Applicable federal and state laws require Palms to withhold mandatory taxes and disability insurance
contributions from Team Members’ wages. These deductions are itemized on your paycheck stub. If you
wish to change the number of your exemptions or your marital status for federal and/or state income tax
withholding purposes, complete the appropriate form available in Workday.
Palms encourages all Team Members to enroll in direct deposit, where your paycheck is deposited directly
into your savings or checking account at a participating bank, as the most efficient way to receive your
paycheck. You can authorize Palms to make additional voluntary deductions from your paycheck, for
insurance premiums, 401(k) contributions and payroll savings plans. Visit Workday for details and to
complete the necessary authorization.
Palms can be required to honor legally required deductions from your wages, such as wage garnishments,
tax liens, or child support deductions. You will be notified of any garnishments or other deductions required
by Palms. It is your responsibility to contact the requesting agency if there’s a dispute regarding a wage
garnishment or lien.
All deductions, whether they’re legally required or voluntary, are itemized on each Team Member’s
paycheck stub.

PAY PERIODS AND DIRECT DEPOSITS


Palms payroll workweek begins on Monday at 12:00 a.m. and ends on Sunday at 11:59 p.m. The pay period
is every other Friday. When the payday falls on a Palms holiday, you are paid on the preceding day, unless
notified otherwise. Each paycheck covers work performed for the pay period ending the previous Sunday
at 11:59 p.m.
All Team Members are encouraged to enroll in direct deposit, to go paperless and receive electronic copies
pay stubs and year-end tax forms. If a Team Member would like to enroll in these options, he or she must
visit Workday. This website is available from any computer to access pay data. In addition, a Team Member
can update his or her Federal and State tax forms and subscribe to receive his or her year-end tax
statements electronically instead of in paper format.
If you believe there is an error on your paycheck, contact your manager or Workforce Planning immediately.
Any errors on time reporting will be adjusted on the following pay period. Palms does not cash payroll
checks or permit any wage or salary advances to Team Members.

TIMEKEEPING
All non-exempt Team Members are subject to timekeeping requirements and should clock-in and clock-out
at designated time clocks.
The following rules apply:
• You are strictly forbidden to clock-in for another Team Member.
• If you fail to clock-in or clock-out incorrectly or you record time incorrectly, you must see your
manager immediately to correct the error. Corrections to time records must be made and
approved by management.

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Remember, you are entitled to be compensated for all time worked. If you feel you have not been
compensated correctly, contact your manager or Human Resources immediately.

OVERTIME
You may be asked to work beyond your normally scheduled hours. When overtime is required, your
manager will attempt to provide as much notice as possible.
Non-exempt Team Members who work overtime will receive overtime pay in accordance with applicable
law and Palms compensation policies. All overtime must be approved in advance by your manager. While
you will be paid for all overtime hours worked, working overtime without your Manager’s approval may
result in progressive counseling, up to and including separation.
Team Members who qualify for exemption under applicable law, do not receive overtime pay and are not
subject to this policy.

ATTENDANCE AND PUNCTUALITY


As a Company that embraces a community atmosphere, it is very important that we support each other. If
our Team Members are excessively late or absent, it creates a tremendous burden to our guests and fellow
Team Members. Being there for each other is critical to our success.

IMPORTANT MEETINGS
From time to time, Palms or your manager may schedule important meetings which you are required to
attend. To keep you informed of business objectives and results, Palms holds regular meetings. You are
expected to attend these meetings as they’re designed to accommodate various schedules. If a meeting is
scheduled outside of your regular work hours and you are a non-exempt Team Member (i.e., entitled to
overtime pay), you are paid for the time spent at the meeting, including any resulting overtime, if
applicable.

PERSONAL APPEARANCE
Maintaining a professional, clean, and well-groomed appearance is important to our brand and the guest
experience at Palms. You must always dress professionally and practice good grooming and personal
hygiene.
Departments may have specific guidelines that address appearance, safety, health and security
considerations. You are responsible to understand the guidelines for your position and must always adhere
to them. Team Members dressed inappropriately will be sent home and instructed to return to work
properly dressed and groomed. If you are sent home, you will not be paid for the time away from work.
Palms respects the religious beliefs and practices of all Team Members and will not tolerate or condone
discrimination, harassment or retaliation based on religious beliefs and practice, whether engaged in by
Team Members or non-Team Members who conduct business with Palms. Palms encourages reporting of
all incidents of religious discrimination, harassment, or retaliation, and will promptly investigate complaints
and take appropriate corrective action where warranted.

Updated 4/13/22 Page 21


Upon request, we endeavor to make accommodations for known religious beliefs or practices, including
religious dress and grooming requirements. A Team Member whose religious beliefs or practices conflicts
with his/her job, work schedule, or Palms policy or practice on dress and appearance, or with other aspects
of employment and who seeks a religious accommodation must submit a written request for the
accommodation, to your manager and Human Resources.
Uniforms
Palms provides uniforms for certain Team Members to wear while at work. The Uniforms Department
makes repairs to uniforms upon request. Team Members issued a uniform are responsible for
replacements, which may be required if the uniform is lost or damaged (other than from normal wear and
tear).
Upon separation of employment, you must return issued uniforms.
Name Tags
Name Tags are issued to all Team Members at the time of hire. Name tags must always be worn while on
duty. Any Team Member who reports to work without his or her name tag may be sent home, off-duty, to
retrieve it. Team Members will be responsible for paying for the actual replacement cost for any lost or
damaged name tag, which at this time is $4. The replacement cost is subject to change without notice.

COMPANY PROPERTY
All Palms equipment and property, including computers, tablets, mobile devices, telephones, radios, credit
cards, copiers, postage meter, etc., should be used for business purposes only. You should not have any
expectation of privacy in the use of Palms equipment and property.
When using Palms property, you are expected to act responsibly, exercise care, immediately notify the
proper contact person if maintenance is required, and follow all operating instructions, safety standards,
and guidelines. If equipment appears to be damaged, defective, or in need of repair, notify the proper
contact person as soon as possible. Prompt reporting can prevent deterioration of equipment and possible
injury to you or to others.
We take internal theft very seriously and do not tolerate property theft of any type. Losses from theft,
regardless of how big or small, affect the profitability of Palms operations and can ultimately affect you.
You are required to report any instances of theft of any Palms property, cash, merchandise, discount or
free play cards, vouchers, gifts, food, etc., to your manager immediately.

TECHNOLOGY
Team Members may not duplicate any licenses, software or related documentation for use either on Palms’
premises or elsewhere unless Palms is expressly authorized to do so by agreement with the licenser.
Unauthorized duplication of software may subject users and/or Palms to both civil and criminal penalties
under the United States Copyright Act. Team Members may not give software to any outsiders including
contractors, customers or others. Team Members may use software on local area networks or on multiple
machines only in accordance with applicable license agreements. Team Members may not download
software from the internet and install it on their computers.

Updated 4/13/22 Page 22


Palms does not condone the unlawful copying and distribution of copyrighted material. You are required
to use software in accordance with the software publisher’s license agreement. Palms reserves the right to
audit any company computer to determine what software is installed on the local drive(s).
If you know, or have reason to think, a Team Member is making, distributing, receiving, obtaining access
to, and/or using unauthorized software, tell your manager or any other member of management
immediately.
Palms electronic information systems are the property of Palms intended for business purposes. You should
not expect your email, voicemail, or other communications to be private, including any personal
information created with, received by, deleted from, or stored on these systems. Palms provides individual
access codes for computers, email, and voicemail to you in order to prevent unauthorized access. Use of
Palms electronic communications and information systems establishes your agreement to this policy.
No Team Member may access, or attempt to obtain access to, another Team Member’s communication or
computer systems without appropriate authorization. All system pass codes must be made available to
Palms on request, and you cannot use pass codes that are unknown to Palms. Backup copies of email and
voicemail are maintained and can be referenced for business and legal reasons.

Any personal use of Palms’ communication and computer systems must not interfere with performance or
operations and must not violate any Palms policy or applicable law. In addition, Palms encourages all Team
Members to keep email and voice messages businesslike and refrain from gossip and personal messages.
Palms’ policies including, but not limited to, those prohibiting harassment, in their entirety, apply to the
use of Palms’ communication and computer systems. Additionally, Team Members may not use Palms’
communication and computer systems in violation of any law including, but not limited to, those related to
copyrights and software piracy. Some examples of prohibited use include but are not limited to:
• Storing discriminatory, sexual or offensive messages, comments, indignities, obscenities, jokes, or
graphics.
• Offensive images relating to race, religion, color, sex, national origin, citizenship status, age,
handicap, disability, sexual orientation, or any other status protected under federal laws.
• Making threatening or harassing statements to another Team Member, or to a vendor, customer,
or other outside party.
• Sending or receiving confidential or copyrighted materials without prior authorization.
• Soliciting personal business opportunities, or personal advertising.
• Gambling, monitoring sports scores, or playing electronic games.
If you receive an email containing any material mentioned above, report it to your manager.
To safeguard and protect the proprietary, confidential and business-sensitive information of Palms and to
ensure the use of all information, including, but not limited to, all software and equipment, is consistent
with Palms legitimate business interests, authorized representatives of Palms may monitor the use of such
systems, messages, files on the systems, list servers and equipment. Also, if Palms is required to produce
documentation or other material in response to a subpoena or other legal request, Palms reserves the right
to access and retrieve such information.
Palms provides access to internet exclusively for business purposes. The same obligations, limitations and
requirements that apply to the use of email and other computer-based capabilities apply to the use of the

Updated 4/13/22 Page 23


Internet. You are prohibited from sending, viewing, or receiving obscene, offensive or discriminatory
materials, including pornography. Additionally, you must recognize any message sent over the Internet is
subject to interception. You should be aware that your use of the Internet may be logged for work
performance purposes.
In addition, please be aware that copyright laws may protect materials available on the Internet. Although
many providers of information permit the downloading of material for personal use, make sure you check
if there are limitations even on this use. In general, use of materials from the Internet for other than
personal use, e.g., commercial use, or mass distribution to others should only be done in accordance with
applicable copyright laws.

COMPANY-PROVIDED CELL PHONES


Palms-provided portable communication devices, including cell phones, are to be used for business
purposes only. You have no reasonable expectation of privacy regarding the use of such devices, and all
use, including personal communications, can be monitored.
All conversations, text messages and emails must be professional. When sending a text message or using a
company-provided cell phone for business purposes, you must follow these guidelines, including Palms’
policies on sexual harassment, discrimination, conduct, confidentiality, equipment use and operation of
vehicles.
Using a Palms-issued devise to send or receive personal text messages is never allowed and personal use
during working hours should be limited to emergency situations.
This policy is not intended and should not be construed as interfering, limiting, or preventing a Team
Member from exercising his/her right under the National Labor Relations Act

Cell Phone Usage While Driving

Team Members who drive on business must follow all applicable state or local laws prohibiting or limiting
cell phone use while driving. Further, even if usage is needed, you should still refrain from using any cell
phone while driving. “Use” includes, but is not limited to, talking or listening to another person or sending
an email or text message.

Regardless of the circumstances, including slow or stopped traffic, if any use is needed while driving,
proceed to a safe location off the road and safely stop the vehicle before placing or accepting a call. If
answering a call is absolutely necessary while driving, and permitted by law, use a hands-free option and
tell the caller you cannot talk right now and will return the call as soon as you can. Under no circumstances
should you feel you need to place yourself at risk to fulfill business needs.

Palms does not require any Team Member to use a cell phone while driving. Team Members charged with
traffic violations because of cell phone while driving are solely responsible for all liabilities that result from
such actions. Texting and emailing while driving is prohibited in all circumstances.

PERSONAL CALLS, MAIL AND VISITORS


We realize that you may need to make personal calls during the day. We have created guidelines for using
Palms equipment and your personal cell phones while on Palms property and while on duty.

Updated 4/13/22 Page 24


You are encouraged to limit your calls to emergencies only. You can ask to use a Palms phone if it is an
emergency. All other calls should be made outside of working hours. However, you are permitted to use
your personal cell phones during refresh and meal periods in designated areas.
Palms telephones can only be used for business purposes. You can be asked to reimburse Palms for any
unauthorized charges resulting from personal use of Palms telephones.
Palms may monitor certain telephone lines to ensure compliance with this policy, to ensure calls are
handled professionally, and for other business reasons. You should not expect conversations on company
lines to be private.
You may not use personal cell phones or other personal electronic devices while on duty or in work areas.
You may not have personal mail or packages delivered to yourself at Palms, nor can Palms postage be used
for any personal correspondence.
Restricting access to Palms premises helps maintain safety standards, protect against theft, ensure security
of equipment, protect confidential information, safeguard Team Member welfare, and avoid potential
distractions and disturbances. For this reason, only authorized visitors are allowed in the workplace and all
authorized visitors, including friends, family and former associates, must register with Security. All visitors
must be escorted at all times by a Palms Team Member.
Team Members being visited are responsible for the actions of their guest(s). Should a guest of a Team
Member act in such a manner that disrupts the normal working conditions of Palms or threatens the
security of Palms and/or its Team Members, the Team Member accompanying the guest may be held
responsible for the guest's actions and subject to progressive counseling up to and including termination
of employment.
Palms reserves the right to verify the contents of packages and briefcases brought onto company premises
by visitors.
If a Team Member suspects or becomes aware of any unusual situation, they should immediately notify
Security and/or Human Resources.

GUEST PRIVACY AND DECORUM


From time to time, you might encounter celebrities, Tribal Citizens and public figures at Palms. We know
this is exciting, but it is also important you always maintain the highest level of professionalism and
discretion. It is essential for you to respect their rights of privacy and non-intrusion. This includes not
photographing or recording them, mentioning them on social media or placing any images or recordings of
these celebrities on social media. From time to time, you may be asked or encouraged to post Palms
activities on social media, at which time guidelines will be provided to you. You should also avoid placing
yourself in a position compromising your safety, security, and integrity.
Finally, we rely on you to not only treat guests with the highest level of respect and professionalism, but to
inform Palms management if you experience and or witness anyone engaging in inappropriate or harassing
behavior which violates this or any other Palms policy.

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PUBLICITY AND STATEMENTS TO THE MEDIA
All media inquiries regarding Palms and its operations must be referred to our Marketing and/or Public
Relations department. Only authorized personnel may make or approve public statements pertaining to
Palms or its operations. No Team Member, unless specifically designated, is authorized to make statements
on behalf of Palms. If you wish to write and/or publish an article, paper, or other publication on behalf of
Palms, you must first obtain written approval.

SOCIAL MEDIA
Palms understands that social media can be a fun and rewarding way to share your life and opinions with
family, friends, and Team Members. However, social media also presents certain risks and carries with it
certain responsibilities. To help you make responsible decisions regarding social media use, follow the
guidelines below:
• All rules regarding confidential and proprietary business information apply to your participation in
social media programs. The use of the Company’s or a customer’s trade secret information or
proprietary information in any form while participating in social media activities is strictly
prohibited.
• Do not post internal reports, policies, procedures, or any other internal business-related
documents.
• Do not post a photograph of a supervisor, manager, co-worker, vendor, supplier, or customer
without their express permission.
• Express your personal opinions. Never represent yourself as a spokesperson for the Company.
• If you post information related to the work you do or subjects associated with this Company, you
should indicate that your views are your own and do not reflect the views of the Company.
• Team members are prohibited from using Company trademarks or logos in a manner that would
mislead or confuse the public or guests regarding product quality, intentionally damage the
Company’s goodwill associated with such trademarks or logos, or unlawfully interfere with the
Company’s ability to effectively use trademarks or logos in its business operations.

Social media tools are a powerful form of communication that can have a significant impact on
organizational, professional, and individual reputations. To review the complete social media policy, please
visit Workday or HR.

TEAM MEMBER MADE RECORDINGS


Team Members are prohibited from recording communications, including in-person and telephonic
communications with other Team Members without prior knowledge and consent of all those involved in
the communications. Team Members are prohibited from taping anywhere on Palms property without the
prior written authorization of Human Resources.

YOUR PERSONAL PROPERTY


Please limit the personal property you bring with you to work, to only those items you need. Palms is not
responsible for any damage, lost, or stolen personal property. You should keep all personal property with
you or safely secured, at all times. If you choose to bring personal property to work (i.e., purse, backpack,

Updated 4/13/22 Page 26


bag, etc.) or any other personal items, it is subject to search before entering, while on Palms property, and
when exiting Palms property.

ENJOYING THE PROPERTY DURING OFF-DUTY HOURS


We encourage you, your family and friends to enjoy Palms when you are off-duty. You must be aware that
your behavior while visiting the property during off-duty hours can directly reflect on the image and
reputation of Palms. We expect you, whether on or off-duty, to behave professionally and treat everyone
with courtesy, dignity and respect.
To ensure that your visit is a positive, enjoyable experience, please make sure you follow the guidelines
listed below:
• You and your guests must be at least 21 years of age to patronize the Casino;
• You should follow the guidelines on Team Member gambling;
• You may enjoy alcohol beverages but know you will be held accountable for your personal conduct;
• You should not wear your uniform when patronizing the property;
• You may park in the parking structure and enter and exit the property through patron entrances.
You should not use assigned Team Member parking when visiting the resort;
• Team Members are not permitted in the guest rooms area of the hotel, or any restricted area, at
any time unless required by their essential duties of their job or authorization from management,
including visiting friends or family members staying in the hotel.

TEAM MEMBER GAMBLING POLICY


Palms has established a policy outlining the circumstances under which Team Members may gamble at
Palms. Team members of a legal age may gamble at Palms if it does not violate state gaming regulations,
create the potential for conflict of interest and/or a guest relations concern or interfere with the
performance of the Team Member’s normal duties. While not an exhaustive list, the Company’s Team
Member Gaming Policy prohibits Team Members from:
• Gambling while on duty.
• Gambling while in uniform or when wearing any item that may identify you as a Palms Team
Member, including Palms-issued apparel such as name tags, vests, aprons, etc.
• Gambling at Palms at any time if you are a Surveillance, Information Technology or Compliance
Team Member.
• Gambling 30 minutes or less prior to the start or end of the Team Member’s scheduled shift.
• Gambling at Palms if you hold a position of Director or above. This may create an appearance of
impropriety.
• Holding a player’s card or gambling at Palms if you have the ability to adjust or input information
into Palms’ casino management systems.
• Playing slots at Palms if you are a Slot Technician.

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• Playing any slot machines with progressive jackpots, including wide-area progressives such as
Megabucks.
Team Members permitted to gamble at Palms may belong to the Company’s player’s clubs, but may not
participate in any market drawings, contests, sweepstakes, slot or table games tournaments or promotions,
including free or promotional events or promotions, and may not accept any promotional items or services
at Palms. If you have any questions, pleases contact your manager or Human Resources regarding the rules
for your position.

RESPONSIBLE GAMING
Palms recognizes that problem gambling can have a detrimental effect on the lives of our Guests, Team
Members and ultimately our community. We are a responsible corporate citizen that provides tools and
resources to our Team Members and Guests to prevent and treat problem gambling. If you need assistance
or help, you may contact our EAP, Harmony Healthcare at (702) 251-8000, (800) 363-4874 or visit their
website for online tools, articles, resources and more at www.harmonyhc.com.
If you have additional questions or concerns about Responsible Gaming, please talk to your manager or
visit Human Resources.

SALES AND SERVICE OF ALCOHOL


Each Team Member has a responsibility to co-workers and the public to deliver services in a legal, safe and
conscientious manner. Only those in positions in which selling or serving alcohol is part of their job
description, may do so to legal guests. An Alcohol Awareness Certification is required of Team Members
who work around or serve alcoholic beverages. You must carry the card with you at all times while on duty.
The Company prohibits: (1) the service of alcoholic beverages to guests who are or appear intoxicated; (2)
sale, service, possession, purchase and/or consumption of alcoholic beverages by persons under the legal
age; and (3) loitering in areas of bars and lounges by persons under the legal age.

Team Members will be trained as necessary based on position responsibilities regarding acceptable forms
of identification, possession and/or service of alcoholic beverages, loitering/presence in a bar or cocktail
lounge, alcoholic beverage ordered through room service, appropriate course of action once a minor is
identified, and appropriate course of action should a guest refuse to cooperate.

Team Members who sell or serve alcohol to a minor(s) in violation of Company policies or procedures will
be subject to progressive counseling, up to and including termination, potential loss of gaming and/or liquor
license and/or work permit, and potential civil and criminal penalties. Any Team Member who serves
alcohol to a visibly intoxicated person in violation of Company policies will be subject to progressive
counseling, up to and including termination; and potential loss of gaming and/or liquor license and/or work
permit.

LOST AND FOUND


You are expected to act responsibly when you find lost items in the hotel or casino. You are required to
turn in these items to Security for appropriate handling. Please see the full Lost and Found policy for further
information.

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GIFTS
To avoid conflicts of interest and the appearance of conflicts of interest, Palms has established the following
guidelines for gifts, meals, accommodations, tips, and gratuities.
Palms prohibits receiving anything of value that may influence or appear to influence the actions or
judgment of others. You, any member of your family or anyone acting as an agent on your behalf shall not
solicit or accept for personal benefit directly or indirectly any gift, favor, meal, entertainment, loan,
discount or any item of substantial monetary value, beyond the limits provided below.
If you are presented with a situation or circumstances where you are unsure as to whether it is acceptable,
a customary business practice, and/or exceeds the monetary limits listed below, please contact your
manager or Human Resources.
Gifts and entertainment given to or received from persons who have a business relationship with the
Company are generally acceptable, if the gift or entertainment is modest in value, appropriate to the
business relationship, and does not create an appearance of impropriety. However, even nominal gifts
should not be accepted if the potential for a conflict of interest or personal obligation exists. Additionally,
Team Members should avoid a pattern of accepting frequent gifts from the same source. No cash or cash
equivalent payments should be given or received. In addition, gifts must not be given to or received from
public officials. Team Members who do not comply with these requirements may be required to reimburse
the Company for the value of any gifts or benefits they make or receive on behalf of the Company. Giving
or receiving any payment or gift in the nature of a bribe or kickback is absolutely prohibited. Refer to the
Company's Anti-Bribery Policy for further details.

Meals and accommodations may only be accepted if they are reasonable in cost and consistent with
customary business practices. As a recommended practice, you should always inform your manager when
presented with these opportunities.

SOLICITATION/DISTRIBUTION
To avoid distractions, solicitation by a Team Member of another Team Member is prohibited while either
the person doing the soliciting, or the person being solicited is on working time.

Distribution of advertising material, handbills, printed or written literature of any kind during working time
or in working areas of the Company is prohibited. Working areas include gaming areas, dining areas, and
adjacent aisles and corridor frequented by customers, but do not include the Team Member dining room,
Team member break areas, Team Member restrooms and Team Member parking areas.

Working time includes the time during which any of the Team Members involved are actually scheduled to
work, but does not include scheduled rest periods, meal breaks and other specified times when Team
Members are not expected to be working.

Team Members are also prohibited from engaging in solicitation and distribution to customers or working
Team Members at any time in customer service or sales areas during the time when customers are provided
services or sales are occurring.

Updated 4/13/22 Page 29


These guidelines also apply to solicitation by electronic means. This policy is not intended and should not
be construed as interfering, limiting, or preventing a Team Member from exercising his/her right under the
NRLA to the extent it is applicable to Palms.

BULLETIN BOARDS AND ELECTRONIC MESSAGES


Palms various departments have bulletin boards to communicate with Team Members. In addition, Palms
may also use email to convey business information to Team Members. These bulletin boards and electronic
messages display important information, and Team Members should consult them frequently for
affirmative action statements, internal memoranda, job openings, announcements, payday notices,
workers’ compensation insurance information, and State disability insurance/unemployment insurance
information. Please read the bulletin board(s) regularly so that you are familiar with the information posted
on it.
The posting of written solicitations on bulletin boards (whether located in the offices or on the Intranet) is
restricted. Only authorized personnel are permitted to post, remove, or alter any notice on the bulletin
board(s).

ANTI-HARASSMENT AND ANTI-BULLYING PREVENTION POLICY


We pride ourselves in our work environment being free of intimidation, hostility, bullying or harassment by
or toward any Team Member, vendor, independent contractor, or customer. If such harassment occurs in
the workplace by someone not employed by Palms, the procedures in this policy should be followed. The
workplace includes: actual worksites, any setting in which work-related business is being conducted
(whether during or after normal business hours), company-sponsored events, including cyberbullying or
harassment, or company owned/controlled property. Palms strictly prohibits any verbal, physical or visual
harassment on the basis of another’s race, color, national origin, gender, gender identity, religion, age, sex,
pregnancy (including lactation, childbirth or other related medical conditions) physical or mental disability,
genetic information (including testing and characteristics) sexual orientation, veteran status, uniformed
servicemember status or other characteristics protected by federal, state, or local law.
Harassment includes, but is not limited to, unwelcome slurs or gestures, epithets, jokes, pranks, threats,
derogatory or offensive remarks or comments, written materials, jokes, cartoons, pictures, email messages
or other computer transmissions, teasing, and other similar verbal, graphic or physical conduct that
demeans, ridicules or torments an individual because of race, color, national origin, gender, gender identity,
religion, age, sex, physical or mental disability, sexual orientation, or other characteristics protected by
federal law.
Sexual harassment is defined as unwanted sexual advances, requests for sexual favors or visual, verbal or
physical conduct of a sexual nature when:
• Submission to such conduct is made a term or condition of employment; or

• Submission to, or rejection of, such conduct is used as a basis for employment decisions affecting
the individual; or

• Such conduct has the purpose or effect of unreasonably interfering with a Team Member’s work
performance or creating an intimidating, hostile or offensive working environment.

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Palms does not tolerate any harassing behavior that affects tangible job benefits, interferes with your job
performance, or creates an intimidating, hostile, or offensive working environment for Team Members,
visitors or anyone conducting business with Palms.
Sexual harassment includes, but is not limited to:
• Unwanted sexual advances, or visual, verbal, or physical conduct of a sexual nature.
• Offering employment benefits (such as a raise or promotion) in exchange for sexual favors.
• Making or threatening reprisals (such as separation or progressive counseling) after a negative
response to sexual advances.
• Visual conduct: leering or staring, making or using sexual or obscene gestures or language, and/or
displaying sexually suggestive objects, pictures, cartoons, graffiti, calendars, email messages,
computer transmissions, or posters.
• Verbal conduct: making or using derogatory comments, epithets, slurs, and/or jokes about gender
specific traits.
• Verbal and/or written abuse of a sexual nature, graphic verbal commentaries about an individual’s
body, sexually degrading words used to describe an individual, and/or suggestive or obscene
letters, notes or invitations; sexually oriented “kidding,” “teasing,” or “practical jokes.”
• Physical conduct, contact or touching of a sexual or personal nature (brushing, patting, hugging,
pinching, or shoulder rubs), assault, and/or impeding or blocking movements.
• Retaliation for making reports or threatening to report sexual harassment.
Palms also does not tolerate bullying behavior. Individuals who engage in workplace bullying may be
counseled, up to and including termination of employment.
Palms considers the following as examples of bullying:
• Verbal Bullying: slandering, ridiculing or maligning a person or family; constant name calling that is
hurtful, insulting, humiliating; using a person as a subject of jokes; abusive and offensive remarks.
• Physical Bullying: pushing, shoving, kicking, poking, tripping, assault or threat of physical assault,
damage to a person’s work area or property.
• Gesture Bullying: nonverbal threatening gestures; glances conveying threatening messages.
• Exclusion: socially or physically excluding or disregarding a person in work-related activities.
• Verbal or physical conduct a reasonable person would find threatening, intimidating, or
humiliating.
• Using verbal or obscene gestures.
• Personal insults and use of offensive nicknames.
• Deliberately interfering with mail and other communications.
• Spreading rumors and gossip regarding individuals.
• Inflicting menial tasks not in keeping with the normal responsibilities of the job.
• The gratuitous sabotage or undermining of a person’s work performance.

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• Unwanted physical contact, physical abuse or threats of abuse to an individual or an individual’s
property (defacing or marking up property).
Cyberbullying refers to bullying, as defined above that occurs through the use of a computer, cell phone,
smartphone, tablet, pager or other device that transmits electronic information, regardless of whether the
device is owned by or located at the Company or connected to the Company network. Cyberbullying is also
prohibited.
This policy in no way prohibits Team Members from engaging in activities that are protected under
applicable state and federal laws, including but not limited to any activity that is protected under Section 7
of the National Labor Relations Act, which includes the right of Team Members to speak with others, engage
in workplace debates and protest about their terms and conditions of employment.
Team Members are encouraged, but not required, to communicate to the offending person that the
person’s conduct is offensive and unwelcome. Anyone in management who receives a complaint of
harassment, bullying, or retaliation must immediately report the allegation to Human Resources.

If you are aware of conduct that violates this policy, Palms expects you to report the incident immediately
— without fear of retaliation — to your manager, Human Resources, or to the Incident Reporting Hotline.
Refer to the Whistleblower Policy in this handbook for further details. Be prepared to provide details
including names, witnesses, and the incident date, time and location. Reporting the incident right away
allows us to investigate and resolve the issue as quickly as possible. Palms will not retaliate against you for
reporting, in good faith, about conduct that violates this policy.
All complaints are investigated in a thorough and objective manner. Confidentiality will be maintained to
the extent practical and permitted by law. Investigations will be conducted as confidentially as possible
and related information will only be shared with others on a need-to-know basis. The investigation will be
completed, and a determination made and communicated to the Team Member as soon as practical. The
Company expects all Team Members to fully cooperate with any investigation conducted by the Company
into a complaint of proscribed harassment, discrimination or retaliation, or regarding the alleged violation
of any other Company policies, and during the investigation, to keep matters related to the investigation
confidential. If an investigation confirms a violation of this policy or the Palms’ Equal Employment
Opportunity policy has taken place, Palms will take immediate, appropriate corrective action, up to and
including immediate separation. If a complaint cannot be substantiated, Palms may take appropriate action
to reinforce its commitment to providing a work environment free from harassment.

The Equal Employment Opportunity Commission ("EEOC") and equivalent state agencies may accept and
investigate charges of unlawful discrimination and harassment at no charge to the complaining party. The
nearest office of the EEOC and equivalent state agencies can be found in your local telephone directory or
online at www.eeoc.gov.

ARREST AND CONVICTIONS


If you are arrested or convicted of a crime, your employment at Palms may be impacted. You must notify
your manager, Workforce Planning and Human Resources within three (3) calendar days of the incident.
Driving under the influence (DUI) charges must be reported within 24 hours of the incident. Failure to

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report an arrest and/or conviction as required by this policy may result in progressive counseling, up to and
including discharge.
Your continued employment is based upon:
• The alleged offense.
• The outcome.
• Any circumstances that adversely affect Palms’ reputation, gaming and liquor license, or other legal
obligations; and your attendance or ability to perform essential job functions, maintain/hold
licenses, certificates and/or affiliations, and/or violates our Code of Business Conduct policy.

EXPENSE REIMBURSEMENTS
Business expense reimbursement, including travel, must be approved in advance by your manager. If you
have questions about what expenses are reimbursed, you must ask your manager before making the
purchase.
Examples of such expenses include:
• Meals
• Lodging and transportation costs associated with business trips
• Automobile expenses
• Incidental purchases of supplies, tools and equipment undertaken at Palms request
If you are asked to do company business using your personal vehicle, you are reimbursed at the current
federal mileage rate. Contact Accounting Shared Services for the current rate.
You must submit completed expense reports to your manager within thirty (30) days of incurring the
expense, together with a per diem report and the receipts for any expenses that are not per diem expenses.
Exempt Team Members will be paid their regular salary for any weeks in which they travel. Nonexempt
Team Members will be paid for travel time in accordance with Palms policy and with federal and state wage
and hour laws.
Abuse of this business travel expense policy, including falsifying expense reports to reflect costs not
incurred by the Team Member, may result in progressive counseling, up to and including termination of
employment.
Contact your manager for more information.

PROGRESSIVE COUNSELING
We operate with positive behavior and a sense of unity of purpose; with our team working together to
achieve our goals. We also understand that, while we are an at-will employer, there are times when issues
at the workplace are most effectively addressed and improved by issuing corrective counseling to modify
behavior. Where appropriate we utilize progressive counseling to ensure that Team Members are treated
fairly, to encourage communication, to make sure expectations are clear, and in an effort to resolve
problems as early as possible.

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Progressive counseling is intended to help address concerns when Team Members fail to follow Company
policies and procedures, violate codes of conduct, fail to adhere to standards of service, or display problems
related to job performance, behavior, attitude or attendance. Department managers and Human Resources
will determine the appropriate counseling measure for the situation at hand based on the specific facts and
circumstances of the situation. To correct behavior in a way that provides ample time to improve, for hourly
Team Members, a three-step process is used. Each step of corrective action need not to be taken prior to
separation.

The three-step process includes the following:

• Verbal Counseling and Coaching – Verbal counseling and coaching are appropriate for offenses that
are considered minor. Verbal warnings need not be issued in writing to the Team Member, but the
conversation should be documented.
• Written Notice – Written counseling notices are issued to Team Members for moderate violations
or for repeat or continued violations of Company and department standards and/or policies and
procedures.
• Final Written Notice – Final written counseling notices are issued for serious violations or for repeat
or continued violations of Company and department standards and/or policies and procedures.
• Decision Days/Suspension Pending Investigation – During the progressive counseling process, a
Team Member may be suspended pending the outcome of an investigation of the alleged offense.
Upon the conclusion of the investigation, decision days/suspension pending investigation may be
resolved without counseling, be converted into a suspension or lesser level of counseling, or it may
result in a termination from employment.

Nothing in this Progressive Counseling Policy changes or limits the at-will relationship. This means that
either you or the Company may terminate your employment at any time, for any reason, with or without
cause or notice.

FRATERNIZATION
Palms strongly believes in a work environment where Team Members maintain clear boundaries between
personal and business interactions. This promotes a more effective way of conducting business and
enhancing productivity. Palms also desires to avoid misunderstandings, actual or potential conflicts of
interest, complaints of favoritism, possible complaints of sexual harassment and the Team Member morale
problems that can potentially result from romantic or intimate relationships involving managerial and
supervisory team members in the Company or certain other Team Members in the Company.
You are expected to conduct yourself in a professional and appropriate manner without interfering with
others, including guests, or with overall productivity. Do not engage in any inappropriate contact with
guests or other Team Members while on Palms property.
It is strictly prohibited for anyone in a management role to be in a romantic or intimate relationship with a
Team Member who is a subordinate. If you are in this situation or become aware of a situation, immediately
contact Human Resources. Failure to cooperate with Palms to resolve potential conflicts caused by a
romantic or intimate relationship may impact your overall work performance and/or your employment.

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HIRING OF RELATIVES
We encourage the hiring of family and friends. We do so in a manner to create a workplace that is free of
conflict. Palms is committed to employing and advancing candidates and Team Members based on
qualifications and merit. Palms is concerned about the potential conflicts which can be carried into the daily
working relationship, such as favoritism, influence and/or personal conflicts from outside the work
environment. Palms shall be the sole judge as to whether or not a conflict exists.
Candidates and current Team Members related to existing Team Members by blood or marriage or through
co-habitation are considered for employment provided they will not work directly with, for, and/or
supervise a relative or significant other. Department management reserves the discretion to ensure against
potential conflicts of interest in this area. You are responsible for immediately reporting any potential
conflicts to your manager.
Relatives are defined as relationships by blood or marriage, including but not limited to:
• Spouse or registered domestic partner
• Parent, including stepparent
• Child, including stepchild
• Grandparent
• Grandchild
• Sibling, including half, step and adopted
• In-laws, including parent-in-law, brother-in-law, and sister-in-law
• Uncle and aunt
• Nephew and niece
• Cousins
• Biological parents of the same child
Best efforts shall be made to locate and secure a position in another department as soon as possible. If a
change in the organizational structure cannot be made, Palms reserves the right to separate one or both
Team Members based on business needs.
Due to the sensitivity of the department and information shared, Team Members in sensitive areas cannot
be related by blood or marriage to another Team Member working in sensitive areas regardless of the
reporting structure unless it has been approved by the General Manager. Sensitive departments include:
• Surveillance
• Information Technology
• Cage
• Accounting
• Count Room
• Security

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• Casino
Sensitive departments may restrict the employment of people related by blood or marriage from working
in any department within Palms. If you have any questions, please direct them to your manager or Human
Resources.

IF YOU DECIDE TO LEAVE US


It is preferred you provide a letter of resignation to your manager at least two (2) weeks in advance of your
ending your employment.
You may be asked to participate in an exit interview where you receive benefits information. All Palms
property, including, identification badges, electronic devices, uniforms, and/or any other company issued
property must be returned on your last day of employment.
Your health care coverage ends on the last day of the month your employment ended. Contact Palms
Benefits Center for questions about your benefits. Final wages will be paid in accordance with applicable
law. When you leave, you are paid for actual time worked through your last day worked. A final check will
be direct deposited or mailed to the address on file and will include any accrued vacation time due.
Notify Palms if your address changes during the calendar year in which separation occurs so that tax
information is sent to the proper address.

REHIRE AND BRIDGE OF SERVICE


You may be eligible for rehire if you leave Palms in good standing. If rehired, you are subject to Palms usual
pre-employment standards.
Palms returns you to your vacation accrual rate at the time of your departure, provided the break in service
does not exceed 90 days. If you are rehired beyond 90 days, it triggers a new service date.

AT-WILL EMPLOYMENT
Unless your position is covered by a CBA providing otherwise, your employment with the Company is “at-
will,” meaning, that neither you or the Company are obligated to continue your employment relationship
and it is not set for a specific amount of time. You can quit or be transferred, reassigned, suspended,
demoted, or terminated at any time, with or without reason, cause or notice. This “at-will” relationship
stays in effect for the duration of your employment. Nothing in this Handbook or any oral statement shall
limit the right to terminate at-will. This at-will employment policy is the sole and entire agreement between
the Team Member and Palms regarding the fact that employment with Palms is at-will. No manager has
any authority to enter into a contract of employment express or implied that changes the fact that
employment with Palms is at-will. Only the General Manager of Palms or a member of the Board of the
Company or that person’s authorized representative has the authority to enter into an employment
agreement that alters the fact that employment with Palms is at-will, and any such agreement must be in
writing signed by the General Manager of Palms or a member of the Company or an authorized
representative.

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YOUR EMPLOYMENT RECORDS
Human Resources maintains employment records and related personnel administration information. You
should contact Human Resources for questions regarding your employment file. Palms keeps an
employment file on each Team Member. Your employment file begins with your job application and
expands with your experience at Palms.
It is your responsibility to update your personal information as it may change. Changes in name, home
address, telephone numbers, marital status, number of dependents or changes in next of kin and/or
beneficiaries can be updated in Workday. If you operate a Company vehicle, contact management
regarding changes to your driving record or status of driver’s license.
Your employment file is kept confidential and viewed by authorized individuals only. Health or medical
information is maintained in a separate file. Palms safeguards all its records from disclosure and may divulge
such information only as permitted by applicable law, or in the following cases:
• In response to a subpoena, court order, or order of an administrative agency.
• To a governmental agency as part of an investigation by that agency of the Company’s compliance
with applicable law.
• In a lawsuit, administrative proceeding, grievance, or arbitration in which you and/or the Company
are parties.
• In a workers’ compensation proceeding.
• To administer Team Member benefit plans.
• To a health care provider.
• To first aid or safety personnel, when necessary.
• Dates of employment and positions held upon your written approval.

OUTSIDE EMPLOYMENT
Palms discourages you from accepting outside employment preventing you from devoting full attention to
your job with Palms. However, you are permitted to work a second job if it does not interfere with your job
performance or pose a conflict of interest at Palms.
If you have a second job, you are expected to work your assigned schedules at Palms. A second job will not
be considered an excuse for poor job performance, absenteeism, tardiness, leaving early, refusal to travel,
or refusal to work overtime or different hours. Palms is under no obligation to schedule around your
secondary employment. If outside work activity causes or contributes to job-related problems, it must be
discontinued.
While employed by Palms, never work for a competitor of Palms or work on your own if it competes in any
way with the products or services or entertainment we provide to our customers. You may not use Palms
facilities, staff, computer, telephones or equipment or resources in performing work for another employer.
Inform Human Resources of all outside business or work activities you participate in. Palms workers’
compensation insurance will not pay for illness or injury arising from any outside employment or outside
business activity.

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LEAVES OF ABSENSE
Military Leave
Palms fully supports Team Members who enter the Uniformed Services of the United States and their
families. This includes the National Guard and the Commissioned Corps of the Public Health Service, or the
state military forces, or the reserve components of the same. Military Leave is available for Team Members
to participate in active or inactive duty or training. Time off is also permitted for an examination to
determine one’s fitness for duty in any of the federal military forces. Such leave will be granted in
accordance with the applicable state and federal laws, provided all legal requirements are satisfied and the
Team Member returns to work or applies for reemployment within the time prescribed by law. The Team
Member must provide advance notice of the need for leave whenever possible. The Team Member should
give his or her Manager as much advance notice as possible to allow the Company to make arrangements
to cover his or her position.
Team Members on federal military leave may be entitled to continue health insurance benefits, at the Team
Member’s expense, for up to 24 months.
To obtain further information about military leaves, please contact the Human Resources Department.
Bereavement Leave
After 90 days of employment, full-time and part-time Team Members are eligible for paid bereavement
leave for the death of an immediate family member. For purposes of this policy, immediate family members
can include a:
• Parent
• Legal guardian
• Stepparent
• Spouse
• Child
• Child-in-law
• Stepchild
• Sibling
• Spouse of sibling
• Grandparent
• Grandchild
• Spouse’s parent
• Spouse’s sibling
• Spouse’s sibling’s spouse
The Company will provide up to 3 regularly scheduled days off with pay to attend to matters related to the
death of an immediate family member. Some circumstances may warrant additional time off. Additional
time off requires the approval of your Manager. The additional time off may be taken as vacation days or,
if you do not have vacation time or are ineligible for vacation time, without pay. Appropriate documentation
is required.

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School Activities Leave
Team Members who are a parent, guardian, or custodian of a child in a public school are eligible for up to
four (4) hours of unpaid leave each school year per child so that he or she may attend or participate in
certain school-related activities. These activities include:
• Attending parent-teacher conferences.
• Attending school-related activities during regular school hours.
• Volunteering or otherwise being involved at the child’s school during regular school hours; and
• Attending school-sponsored events.
Team Members must use parental leave in increments of at least one (1) hour.
Team Members requesting leave must submit a written request for leave to their Manager at least five (5)
school days before the leave is taken, when practicable. Team Members may use accrued Personal Leave
Time or vacation for this purpose.
Team Members who take leave must also provide documentation that during the time of the leave, the
Team Member attended or was otherwise involved at the school or school-related activity.

Occupational Injury Leave


Any request for a leave of absence for a work-related injury (see Workplace Injuries section of this
handbook) requires a statement of disability from a licensed physician. An unpaid leave of absence will be
granted for the period that the physician states the Team Member is unable to perform their regular duties.
For more information, contact our Safety Manager.
Benefits for work-related injuries and/or occupational diseases are provided in accordance with state law.
If you are injured or become ill on the job, you must immediately report such injury or illness to your
Manager or Human Resources, so that you are not at risk of losing your Worker’s Compensation benefits.

Family Medical Leave Act (FMLA)


This policy summarizes the federal Family and Medical Leave Act (FMLA) policy. Eligible Team Members
may request a leave of absence under the FMLA for the purposes, and subject to the terms and conditions,
described below.
Eligibility

Eligible Team Members are those who have been employed by the Company for at least 12 months (not
necessarily consecutive), have worked at least 1,250 hours during the 12 months immediately prior to the
requested leave of absence and are employed at a worksite where there are 50 or more Team Members
of the Company within 75 miles.
Team Member Request for and Notice of Leave

Team Members must provide sufficient information so the Company can determine whether the request
for time off qualifies as family and medical leave, as well as the timing and duration of the leave. When the
need for family and medical leave is foreseeable, such as due to a planned medical procedure, a Team

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Member must notify the Company of the need for the leave at least 30 days before the leave begins. If 30
days advance notice is not practicable because the Team Member just learned of the need for leave or
there is a change in circumstances or a medical emergency, then the Team Member must request the leave
as soon as practicable (generally the same day or the day following the day the Team Member became
aware of the need for leave). The Team Member must follow the Company’s standard call in procedures
for unscheduled absences. The Team Member must inform the Company when taking time off for a reason
for which family and medical leave was previously taken or certified. Failure to comply with the request
and notice procedures may delay the start of a leave.
Purposes

A family and medical leave may be taken by an eligible Team Member for the following reasons:

The birth of a Team Member’s son or daughter or the placement of a son or daughter with the Team
Member for foster care or adoption, so long as the leave is completed within 12 months of the birth or
placement of the son or daughter.

To care for the Team Member’s spouse, son, daughter or parent with a “serious health condition.”

Due to the “serious health condition” of the Team Member that renders the Team Member unable to work
or in need of medical treatment.

Because of any qualifying exigency arising out of the fact that the Team Member’s spouse, son, daughter
or parent is on covered active duty or has been notified of an impending call or order to covered active
duty in the Armed Forces of the United States.

To care for a covered service member (who is the Team Member’s spouse, son, daughter, parent or next
of kin) with a serious illness or injury (“military caregiver leave”).

Definitions

A “serious health condition” includes 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 Team Member from performing the functions of the Team
Member’s job or prevents qualified family members 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 3 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 chronic
condition. Other conditions may meet the definition of continuing treatment.

A “covered service member” means (A) a current member of the Armed Forces (including National Guard
or Reserves) of the United States who is the Team Member’s spouse, son, daughter, parent or next of kin,
and is undergoing medical treatment, recuperation or therapy, is otherwise in outpatient status, or is
otherwise on the temporary disability retired list, for a serious injury or illness, or (B) a Veteran who is
undergoing. medical treatment, recuperation or therapy, for a serious injury or illness and who was a
member of the Armed Forces (including a member of the National Guard or Reserves) of the United States
at any time during the period of 5 years preceding the date on which the Veteran undergoes that medical
treatment, recuperation or therapy.

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“Covered active duty” means (A) in the case of a member of the regular component of the Armed Forces
of the United States, duty during the deployment of the member to a foreign country; and (B) in the case
of a member of the reserve component of the Armed Forces of the United States, duty during the
deployment of the member to a foreign country under a call or order to active duty, as provided by law.

A “serious injury or illness” means in the case of a member of the Armed Forces (including a member of
the National Guard or Reserves) of the United States, an injury or illness incurred by the member in the line
of duty while on active duty in the United States Armed Forces (or that existed before the beginning of the
service member’s active duty and was aggravated by service in the line of duty on active duty in the Armed
Forces) and that may render the service member medically unfit to perform the duties of the service
member’s office, grade, rank or rating. In the case of a veteran who was a member of the Armed Forces
(including a member of the National Guard or Reserves) of the United States at any time during the 5 year
period preceding the date on which the veteran undergoes medical treatment, recuperation or therapy, a
serious injury or illness means a qualifying (as defined by the Secretary of Labor) injury or illness that was
incurred by the service member in the line of duty on active duty in the Armed Forces (or that existed
before the beginning of the service member’s active duty and was aggravated by service in line of duty on
active duty in the Armed Forces) and that manifested itself before or after the service member became a
veteran.

A “qualifying exigency” is provided to an eligible Team Member when the Team Member’s spouse, parent,
son or daughter is on covered active duty or on call to covered active duty status, resulting in the need for
the Team Member to take time off work to address issues related to short notice deployment, make
arrangements for child care, attend certain school activities, handle certain financial or legal arrangements,
attend certain counseling sessions, attend military ceremonies or informational briefings, to spend short
periods of time for rest and recuperation leave during the period of deployment or participate in certain
post-deployment activities.

The “designated 12-month period” is the rolling 12-month period measured backward from the date a
Team Member uses any family and medical leave. It is the period during which the 12 workweeks of family
and medical leave may be used.

The “single 12-month period” is the 12-month period that begins on the first date the Team Member uses
any military caregiver leave. It is the period during which the 26 workweeks of military caregiver leave may
be used.

“Veteran” means a person who served in the active military, naval or air service, and who was discharged
or released from such service under conditions other than dishonorable.

Duration

Family and medical leave may be taken for up to 12 workweeks during the designated 12-month period for
the purposes described above. Leave for the purpose described in military caregiver leave, may be taken
for up to twenty-six (26) workweeks in a single 12-month period. During the single 12-month period, an
eligible Team Member shall be entitled to a combined total of 26 workweeks of leave for the reasons
specified above. In other words, any family and medical leave taken during the single 12-month period for
reasons specified above (up to 12 weeks), will be counted towards the total 26-week entitlement permitted
for leave to care for a covered service member with a serious illness or injury during that single 12-month

Updated 4/13/22 Page 41


period. All time off that qualifies as family and medical leave will be counted against the Team Member’s
federal family and medical leave entitlement to the fullest extent permitted by law.

Use of Leave

Team Members need not use family and medical leave in one block. Intermittent or reduced schedule leave
is available, if medically necessary. Team Members must make a reasonable effort to schedule planned
medical treatments so as not to unduly disrupt business operations. For planned absences that are
intermittent or on a reduced schedule, the Company may require the Team Member to temporarily
transfer to an alternative position for which the Team Member is qualified, with equivalent pay and
benefits, that better accommodates the recurring periods of leave than the Team Member’s regular
position. Leave due to qualifying exigencies may also be taken on an intermittent basis.

Medical Certification

When leave is requested for the Team Member’s or a family member’s (see paragraphs above) medical
reasons, the Team Member must submit a medical certification from the health care provider of the patient
that establishes the Team Member is eligible for family and medical leave. The Human Resources
Department will provide the appropriate certification form. A complete and sufficient certification must be
provided as soon as is reasonably practical, and not later than the date leave begins or within 15 days of
the Company’s request, whichever is later.

When the leave is requested because of the Team Member’s own serious health condition, the certification
must include: (1) the date the serious health condition commenced, (2) the probable duration of the serious
health condition, (3) information sufficient to establish that the Team Member has a serious health
condition, and (4) information sufficient to establish the Team Member cannot perform the essential
functions of the Team Member’s job as well as the nature of any other work restrictions and the likely
duration of such inability. The Team Member must provide the required medical certification to the
Company in a timely manner to avoid a delay or denial of leave. Obtain appropriate forms from the Human
Resources Department.

If the Company has reason to doubt the validity of a medical certification, it may require at its expense that
the Team Member get a second opinion from a healthcare provider chosen or approved by the Company,
as long as that healthcare provider does not work for the Company. If the opinions of the healthcare
providers for the first and second certifications differ, the Company may require the Team Member to
obtain a certification from a third healthcare provider (approved jointly by the Company and the Team
Member) at the Company’s expense. The third certification shall be final and binding.

When leave is requested to care for a family member (either because the family member has a serious
health condition or needs military caregiver leave), the certification must include: (1) information sufficient
to establish that the family member has a serious health condition or serious injury or illness, and the date
the condition began, (2) the probable duration of the condition, (3) information sufficient to establish the
family member is in need of physical and/or psychological care, and (4) an estimate of the frequency and
duration of the leave required to care for the family member.

The Company will notify the Team Member if the certification is incomplete or insufficient and provide the
Team Member seven (7) calendar days to correct the deficiency. The Company reserves the right to contact

Updated 4/13/22 Page 42


the health care provider to seek authentication or clarification of information in the certification, as
needed, and may require recertification, as appropriate.

Before returning to work at the conclusion of a leave due to the Team Member’s own serious health
condition, the Team Member is required to provide a certification from his or her health care provider
regarding the Team Member’s fitness for duty.

Certification of Qualifying Exigency

When leave is due to a qualifying exigency, the Team Member must submit a completed Certification of
Qualifying Exigency for Military Family Leave to establish the Team Member’s eligibility for this leave. The
Human Resources Department will provide the appropriate certification form. A complete and sufficient
certification must be provided as soon as is reasonably practical, and within 15 days of the Company’s
request.

Pay and Benefits

Family and medical leave is unpaid. However, an eligible Team Member must use any earned vacation and
floating holiday time during family and medical leave. Use of vacation and floating holiday time is subject
to the terms and conditions of the Paid Vacation and Paid Holidays policies.

During a family and medical leave, group health benefits will be maintained for up to 12 workweeks (up to
26 workweeks for military caregiver leave) as if the Team Member were continuously employed, however,
the Team Member must continue to pay the Team Member’s share of premiums for the Team Member
and any covered dependents, if any, during the leave. If the Team Member fails to return to work at the
conclusion of the approved leave, the Company may recover its share of the premiums paid during the
leave, unless the inability to return is due to circumstances beyond the Team Member’s control or
otherwise excused. A Team Member on an approved family and medical leave will not lose any benefits
accrued before the leave began.

Reinstatement

Team Members who return to work immediately after the end of an approved family and medical leave
will normally be reinstated to the same or an equivalent position and will receive pay and benefits
equivalent to those the Team Member received prior to the leave, as required by law. If the Team Member
does not return to work on the first workday following the expiration of an approved family and medical
leave, the Team Member will be deemed to have resigned from employment. In certain circumstances,
“key” Team Members may not be eligible for reinstatement following a family and medical leave. The
Company will provide written notice to any “key” Team Member who is not eligible for reinstatement.

Employer Responsibilities

The Company will inform Team Members requesting leave whether they are eligible under FMLA and as
applicable, state law. If they are, the Notice of Eligibility will specify any additional information required, as
well as the Team Member’s rights and responsibilities. If a Team Member is not eligible, the Company shall
provide a reason for the ineligibility.

Updated 4/13/22 Page 43


The Company shall also inform eligible Team Members if leave will be designated as FMLA-protected and
the amount of leave that will be counted against the Team Member’s leave entitlement. If the Company
determines the leave is not FMLA-protected, the Company shall notify the Team Member.

The company will not interfere with, restrain, or deny the exercise of any right provided under FMLA;
discharge or discriminate against any person for opposing any practice made unlawful by FMLA or for
involvement in any proceeding under or relating to FMLA.

FMLA does not affect any federal or state law prohibiting discrimination or supersede any State or local law
or collective bargaining agreement which provides greater family or medical leave rights. For additional
information you may call (866) 487-9243 or TTY at (877) 889-5627 www.wagehour.gov.

If you have any questions concerning or would like to submit a request for a family and medical leave of
absence, please contact the Human Resources Department.

Unpaid Personal Leaves


An unpaid personal leave is available, at the Company’s discretion, to all full-time and part-time Team
Members who have completed 180 days of continuous service. Personal leave is available for unforeseen,
emergent personal reasons. The Company will consider operating requirements when determining
whether or not to grant an unpaid personal leave.
Up to three (3), thirty (30) day periods of leave may be granted in a 12-month period. Each 30-day period
may not be split. Team Members must take all earned, unused floating holidays and earned vacation in
conjunction with a personal leave.
Upon completion of an approved personal leave, there is no guarantee that Team Members will be
reinstated to their former position or any position.
Requests for a personal leave of absence must be submitted in writing to your Manager. Your request must
be pre-approved by your Manager and reviewed by the Human Resources Department to confirm eligibility.
Your benefits continue during personal leave and you will be responsible for paying your share of the cost
in advance of your leave. If you do not make payment prior to your leave, premiums will be withheld from
your paycheck upon return from work.
If you do not return to work on the first workday following the expiration of an approved personal leave of
absence, you will be deemed to have resigned from employment.

AMERICANS WITH DISABILITY ACT


The Company is committed to complying with the Americans with Disabilities Act (ADA) and its equivalent
state and local laws. We do not discriminate against any qualified Team Member or applicant with regard
to any terms or conditions of employment because of an individual’s disability or perceived disability, so
long as the Team Member can perform the essential functions of the job, with or without reasonable
accommodation. In line with our policy of nondiscrimination, we will reasonably accommodate qualified
individuals with a disability, as defined by the ADA or applicable state or local law, who have made us aware
of their disability, provided that such accommodations do not constitute an undue hardship on the
Company.

Updated 4/13/22 Page 44


Team Members with a disability who believe they need a reasonable accommodation to perform the
essential functions of their job should contact Human Resources. Human Resources will communicate with
the Team Member and engage in an interactive process to determine the nature of the issue and what, if
any, reasonable accommodation(s) may be appropriate. In some cases, this interactive process may be
triggered without a request from the Team Member, such as when the Company receives notice from its
own observation or another source that a medical impairment may be impacting the Team Member’s
ability to perform essential job functions.
The Company encourages individuals with disabilities to come forward and request reasonable
accommodations. Team Members who believe they need an accommodation must specify, preferably in
writing, what barriers or limitations prompted the request. The Company will evaluate information
obtained from the Team Member, and possibly the Team Member’s health care provider or another
appropriate health care provider, regarding any reported or apparent barriers or limitations, and will then
work with the Team Member to identify possible accommodations, if any, that will help to eliminate or
otherwise address the barrier(s) or limitation(s). If an identified accommodation is reasonable and will not
impose an undue hardship on the Company and/or a direct threat to the health and/or safety of the
individual or others, Palms will generally make the accommodation, or it may propose another reasonable
accommodation which may also be effective. Team Members are required to cooperate with this process
by providing all necessary documentation supporting the need for accommodation and being willing to
consider alternative accommodations when applicable.
Palms will also consider requests for reasonable accommodations for medical conditions related to
pregnancy, childbirth and lactation where supported by medical documentation and/or as required by
applicable federal, state or local law.
Team Members who wish to request unpaid time away from work to accommodate a disability should
speak to Human Resources.

NEVADA PREGNANT WORKERS’ FAIRNESS ACT


Team Members in Nevada have the right to be free from discriminatory or unlawful employment practices
based on pregnancy, childbirth, or a related medical condition. The Act requires Palms to provide Team
Members with this information.
We will not:
• Deny a reasonable accommodation to female Team Members and applicants, upon request, for a
condition related to pregnancy, childbirth, or a related medical condition, unless an
accommodation would impose an undue hardship on the business of the employer.
• Take adverse employment actions against a female Team Member because the Team Member
requests or uses a reasonable accommodation.
• Deny an employment opportunity to a qualified female Team Member or applicant based on a
need for a reasonable accommodation.
• Require a female Team Member or applicant to accept an accommodation that the Team Member
or applicant did not request or chooses not to accept or to take leave from employment if an
accommodation is available.

Updated 4/13/22 Page 45


We may:
• Require a female Team Member to submit written medical certification from the Team Member’s
physician substantiating the need for an accommodation because of pregnancy, childbirth, or
related medical conditions, and the specific accommodation recommended by the physician.
In addition, Palms and the Team Member will engage in a timely, good faith interactive process to
determine an effective, reasonable accommodation, subject to the terms of the policy and law stated
above. Examples of potential reasonable accommodations include, but are not limited to:
• Modifying equipment or providing different seating
• Revising break schedules (e.g., frequency and duration of breaks)
• Providing space reasonable space for expressing breast milk
• Providing assistance with manual labor that is NOT part of the primary work duties
• Light duty work assignment
• Transfer temporarily to a less strenuous or hazardous position
• Restructuring a position (but NOT creating a new position that would not be created for other
Team Members with medical limitations)
• Modifying a work schedule.

If you have questions regarding your rights or have need for an accommodation for a condition relating to
pregnancy, childbirth, or related medical condition, please contact Human Resources. For further
information regarding the Act, Team Members may contact the Nevada Equal Rights Commission.

Equal Rights Commission Equal Rights Commission


Las Vegas Northern Nevada
1820 East Sahara Avenue, Suite 314 1325 Corporate Blvd., Room 115
Las Vegas, NV 89104 Reno, NV 89502
Phone (702) 486-7161 Phone (775) 823-6690

DRUG AND ALCOHOL-FREE WORKPLACE


To help ensure a safe, healthy, and productive work environment for our Team Members and others,
protect Palms property, and ensure efficient operations, Palms has adopted a policy of maintaining a
workplace free of drugs and alcohol.

The unlawful or unauthorized use, abuse, solicitation, theft, possession, transfer, purchase, sale, or
distribution of controlled substances, drug paraphernalia, or alcohol by an individual anywhere on
Company premises, while on Company business (whether or not on Company premises), while driving a
Company vehicle or driving a personal vehicle for Company business, or while representing the Company,
is strictly prohibited. Team Members also are prohibited from reporting to work or working while they are
using or under the influence of alcohol, any drugs as well as any controlled substances which may impact a
Team Member’s ability to perform the Team Member’s job or otherwise pose safety concerns, except when
the use is pursuant to a licensed medical practitioner’s instructions and the licensed medical practitioner
authorized the Team Member to report to work. However, to the extent permitted by and in accordance
with applicable law, this exception does not extend any right to report to work or perform work under the
influence of medical marijuana or to treat the lawful use of medical marijuana as a defense to a policy
violation or a positive drug test, to the extent you are subject to any drug testing requirement.

Updated 4/13/22 Page 46


A blood alcohol level at or in excess of the limit prescribed by Nevada law, or under the influence of a
substance not prescribed to you, constitutes an absolute presumption that the individual is under the
influence and may result in separation of the Team Member.

Violation of this policy may result in progressive counseling, up to and including discharge.

The Company maintains a policy of non-discrimination and will endeavor to make reasonable
accommodations to assist Team Members recovering from substance and alcohol dependencies, and those
who have a medical history that reflects treatment for substance abuse conditions. Team Members may
not request an accommodation to avoid counseling for a policy violation. If you need help, contact our EAP
Harmony Healthcare at (702) 251-8000, (800) 363-4874, or access their website for online tools,
articles, resources and more at www.harmonyhc.com.

It is everyone’s responsibility to ensure our work environment is free of alcohol and drugs. If you have
knowledge of a violation and do not report it, you are also subject to corrective action, up to and including
separation. If you have questions or concerns about this policy, please contact Human Resources.

CONDUCTING SEARCHES AND PROBABLE CAUSE TESTING


Palms maintains a work environment that is free of illegal drugs, alcohol, firearms, explosives or other
improper materials. To this end, Palms prohibits the control, possession, transfer, sale or use of such
materials on its premises to the extent permitted by applicable law. We require the cooperation of all Team
Members in administering this policy.
Desks, lockers and other storage devices are provided for the convenience of Team Members but remain
the sole property of Palms. Accordingly, they, as well as any articles found within them, can be inspected
by any agent or representative of Palms at any time, either with or without prior notice.
In addition, to ensure the safety and security of Team Members and customers, and to protect our
legitimate business interests, we reserve the right to question and inspect or search any Team Member or
other individual entering or leaving company premises or job sites. The inspection or search may include
any packages or items that the individual may be carrying, including briefcases, handbags, knapsacks,
shopping bags, et cetera. If a non-exempt Team Member is present during any search or inspection, the
Team Member must report the time spent during the search or inspection as working time.
In addition, Palms can require drug and/or alcohol testing when:
• There is reasonable suspicion you are under the influence of legal or illegal drugs or alcohol, based
on objective symptoms, including, but not limited to factors related to your appearance, behavior,
speech, and/or other objective factors.
• You were directly or indirectly involved in a work-related accident, regardless of whether an injury
resulted from such accident or violation, if the accident involved a violation of a Palms safety
standard or workplace rule and there is reasonable suspicion that legal or illegal drugs or alcohol
may have been involved in the incident.
• There is reasonable suspicion you have, or may have been involved in the use, possession, transfer,
distribution, manufacture, and/or sale of legal or illegal drugs or alcohol in Palms-controlled areas,

Updated 4/13/22 Page 47


Palms property, while on duty, or while operating a vehicle or potentially dangerous equipment
owned or leased by Palms.
If you refuse to submit to a screening, your actions will be considered insubordination and you will be
subject to immediate separation.

NO REQUESTS FOR GENETIC INFORMATION


The Company complies with the Genetic Information Nondiscrimination Act of 2008 (GINA) and asks that
Team Members not provide any genetic information when responding to a request for medical information
for purposes of leaves of absence or otherwise. “Genetic Information" includes an individual's family and
medical history, the results of an individual's or family member's genetic tests, the fact that an individual
or an individual's family member sought or received genetic services, and genetic information of a fetus
carried by an individual or an individual's family member or an embryo lawfully held by an individual or
family member receiving assistive reproductive services. If you have any questions about the information
to be provided, please contact the Human Resources Department. In the event that the Company
inadvertently acquires a Team Member’s genetic information, it will not be used in any way when making
employment decisions.

THANK YOU!
As we reopen Palms and welcome back guests to our iconic property, we are highly committed to each of
you, our valued Team Members. Thank you for choosing Palms and we look forward to working with you
for many years to come, to create memorable experiences for you, our community and our guests.

Updated 4/13/22 Page 48

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