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EMPLOYEE HANDBOOK

VINCI Construction LLC – 2331 Mill Road, Suite 501, Alexandria, VA 22314

TABLE OF CONTENT
1.0 REVISION LOG .................................................................................................................................................................... 7
2.0 WELCOME FROM THE CHAIRMAN .................................................................................................................................. 13
3.0 PURPOSE OF THIS HANDBOOK ........................................................................................................................................ 14
4.0 ABOUT VINCI AND VINCI CONSTRUCTION LLC ................................................................................................................ 15
5.0 EQUAL EMPLOYMENT OPPORTUNITY ............................................................................................................................. 17
6.0 EMPLOYMENT CATEGORIES ............................................................................................................................................ 18
7.0 EMPLOYMENT POLICIES .................................................................................................................................................. 20
7.1 At-Will Employment .......................................................................................................................................... 20
7.2 Employee Relationships and Disclosure ............................................................................................................ 20
7.3 Immigration Law Compliance ............................................................................................................................ 21
7.4 Business Ethics .................................................................................................................................................. 21
7.5 Outside Employment ......................................................................................................................................... 22
7.6 Non-Disclosure .................................................................................................................................................. 22
7.7 Reasonable Accomodations of Individuals with Disabilities ............................................................................. 23
7.8 Reasonable Accomodations of Indivduals' Religoius Beliefs and Practices ......................................................24
7.9 Reasonable Accomodation for Pregnancy, Childbirth, or Related Medical Conditions, Including Lactation ...24
7.10 Corporate Communication ................................................................................................................................ 25
7.10.a Solicitation, Distribution, and Use of Bulletin Boards .......................................................................... 26
7.10.b Social Media ......................................................................................................................................... 26
7.11 Customer Relations ........................................................................................................................................... 28
7.12 Employee Referral Program .............................................................................................................................. 29
8.0 PERSONNEL .................................................................................................................................................................... 31
8.1 Access to Personnel Files................................................................................................................................... 31
8.2 Security Clearances ........................................................................................................................................... 31
8.3 Employment Reference Checks ......................................................................................................................... 32
8.4 Employment Applications ................................................................................................................................. 32

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8.5 Personnel Records ............................................................................................................................................. 32


8.6 Annual Appraisals and Merit Increases ............................................................................................................. 33
8.7 Performance Improvement Plan (PIP) .............................................................................................................. 34
8.8 Promotion and Transfers................................................................................................................................... 34
8.9 Mentoring Program ........................................................................................................................................... 34
9.0 EMPLOYEE BENEFITS ...................................................................................................................................................... 35
9.1 Medical Insurance ............................................................................................................................................. 36
9.2 Dental Insurance ............................................................................................................................................... 36
9.3 Vision Program .................................................................................................................................................. 37
9.4 Benefits Continuation (COBRA) ......................................................................................................................... 37
9.5 Pre-tax Savings Benefits .................................................................................................................................... 37
9.6 Disability Insurance ........................................................................................................................................... 38
9.7 Basic Life and AD&D Insurance ......................................................................................................................... 38
9.8 Employee Assistance Program .......................................................................................................................... 38
9.9 401(k) Retirement Savings Plan......................................................................................................................... 38
9.10 Training Program ............................................................................................................................................... 39
9.11 Relocation Assistance ........................................................................................................................................ 39
9.12 Workers' Compensation .................................................................................................................................... 39
10.0 LEAVE .............................................................................................................................................................................. 41
10.1 Holidays ............................................................................................................................................................. 41
10.2 Vacation Leave .................................................................................................................................................. 42
10.3 Sick Leave .......................................................................................................................................................... 43
10.4 Inclement Weather ........................................................................................................................................... 44
10.5 Bereavement Leave ........................................................................................................................................... 44
10.6 Jury Duty ............................................................................................................................................................ 44
10.7 Voting ................................................................................................................................................................ 45
10.8 Court Appearance ............................................................................................................................................. 45

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10.9 Crime Victims .................................................................................................................................................... 45


10.10 Parental Leave ................................................................................................................................................... 46
10.11 Military Leave .................................................................................................................................................... 46
11.0 TIMEKEEPING AND PAYROLL .......................................................................................................................................... 47
11.1 Fundamentals of Time Reporting ...................................................................................................................... 47
11.2 Work Hours ....................................................................................................................................................... 47
11.3 Lunch Break ....................................................................................................................................................... 47
11.4 Paydays .............................................................................................................................................................. 48
11.5 Overtime............................................................................................................................................................ 48
11.6 Payroll Deductions............................................................................................................................................. 48
11.7 Direct Deposit of Payroll.................................................................................................................................... 50
12.0 BUSINESS TRAVEL AND GENERAL EXPENSES.................................................................................................................. 51
12.1 Expense Report Documentation Requirements................................................................................................ 51
12.2 Entertainment Expenses ................................................................................................................................... 52
12.3 Non-reimbursable Expenses ............................................................................................................................. 52
12.4 Responsibility .................................................................................................................................................... 52
13.0 EMPLOYEE CONDUCT ..................................................................................................................................................... 53
13.1 General Code of Conduct .................................................................................................................................. 53
13.2 New Hire Orientation ........................................................................................................................................ 54
13.3 Employee Introductory Period .......................................................................................................................... 54
13.4 Harassment Policy ............................................................................................................................................. 55
13.4.a Definitions of Harassment .................................................................................................................... 55
13.4.b Individuals and Conduct Covered......................................................................................................... 56
13.4.c Complaint Procedures .......................................................................................................................... 56
13.4.d The Investigation .................................................................................................................................. 57
13.4.e Responsive Action ................................................................................................................................ 57
13.5 Drug-Free Workplace Policy .............................................................................................................................. 57

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13.6 Drug Testing ...................................................................................................................................................... 59


13.7 Electronic Communication ................................................................................................................................ 60
13.8 Internet Usage ................................................................................................................................................... 61
13.9 Use of the Company or Client Computer System.............................................................................................. 62
13.10 Use of Cellular Phones....................................................................................................................................... 62
13.10.a Safety Issues for Cellular Phone Use .................................................................................................... 62
13.11 Violence Prevention in the Workplace .............................................................................................................. 62
13.12 Smoking Policy ................................................................................................................................................... 63
13.13 Attendance ........................................................................................................................................................ 64
13.14 Teleworking ....................................................................................................................................................... 65
13.15 Dress and Appearance....................................................................................................................................... 65
13.16 Employer Information and Property ................................................................................................................. 66
13.17 Workplace Etiquette ......................................................................................................................................... 67
13.18 Internal Complaint Procedures ......................................................................................................................... 67
13.19 Employment Termination ................................................................................................................................. 68
13.20 Death of an Employee ....................................................................................................................................... 69
13.21 Health and Safety Policy .................................................................................................................................... 69
13.22 Visitors in the Workplace .................................................................................................................................. 70
13.23 General Safety Rules ......................................................................................................................................... 70
13.24 Workplace Security ........................................................................................................................................... 71
13.25 On-the-Job Injuries ............................................................................................................................................ 71
APPENDIX A. ETHICS HOTLINE POLICY ........................................................................................................................................ 72
A.1 Purpose.............................................................................................................................................................. 72
A.2 Policy ................................................................................................................................................................. 72
A.3 Safeguards ......................................................................................................................................................... 72
A.3.a Harassment or Victimization ................................................................................................................ 72
A.3.b Confidentiality ...................................................................................................................................... 73

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A.3.c Anonymous Allegations ........................................................................................................................ 73


A.3.d Malicious Allegations ........................................................................................................................... 73
A.4 Procedures ........................................................................................................................................................ 73
A.4.a Reporting .............................................................................................................................................. 73
A.4.b Timing ................................................................................................................................................... 73
A.4.c Evidence ............................................................................................................................................... 73
A.5 How the Report Will Be Handled ...................................................................................................................... 73
A.5.a Initial Inquiries ...................................................................................................................................... 74
A.5.b Feedback to Reporter ........................................................................................................................... 74
A.5.c Further Information ............................................................................................................................. 74
A.5.d Outcome of an Investigation ................................................................................................................ 74
APPENDIX B. HUMAN RIGHTS POLICY ......................................................................................................................................... 75
EMPLOYEE HANDBOOK ACKNOWLEDGMENT............................................................................................................................. 76

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1.0 REVISION LOG


Page No. Policy Original Revision Date
15 4.0 About VINCI and VINCI Former Org Chart Updated Org Chart June 8, 2021
Construction LLC
17 5.0 Equal Employment The policies and principles of equal Removed paragraph August 16, 2021
Opportunity employment opportunity also apply to the
selection and treatment of independent
contractors, personnel working on our
premises who are employed by temporary
agencies, and any other persons or firms
doing business for or with VINCI
Construction LLC.
18 6.0. Employment Categories NON-EXEMPT employees are subject to NON-EXEMPT employees are August 23, 2021
the FSLA minimum wage and overtime subject to the FLSA minimum
provisions along with state mandated laws wage and overtime provisions
and may be paid on an hourly basis. Non- along with applicable state and
exempt employees are entitled to be paid local wage and hour laws and
one-and-one half times their regular rate may be paid on an hourly basis.
for every hour worked over 40 in a Non-exempt employees are
workweek. entitled to be paid one-and-one-
half times their regular rate for
every hour worked over 40 in a
workweek.
18 6.0 Employment Categories EXEMPT employees are exempt from the EXEMPT employees are exempt August 23, 2021
FSLA overtime provisions and therefore from the FLSA and applicable
are not entitled to overtime pay. Exempt state and local law overtime
employees are paid on a salary basis and provisions and therefore are not
the salary is intended to cover all hours entitled to overtime pay. Exempt
worked. employees are paid on a salary
basis and the salary is intended to
cover all hours worked.
18 6.0 Employment Categories Temporary employees retain that status Temporary employees retain that August 23, 2021
unless and until notified of change. All status unless and until notified of
legally mandated benefits (such as Social a change in writing. All legally
Security and workers’ compensation mandated benefits (such as Social
insurance) are provided to temporary Security and workers’
employees; however, temporary compensation insurance) are
employees are not entitled to additional provided to temporary
VINCI Construction LLC sponsored employees; however, temporary
benefits. employees are not entitled to
additional VINCI Construction LLC
sponsored benefits.

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22 7.5 Outside Employment The employee must obtain prior written The employee must obtain prior August 23, 2021
consent of his or her supervisor and written consent of his or her
department manager to work elsewhere supervisor and department
while employed at VINCI Construction LLC. manager to work elsewhere while
A written consent must include the employed at VINCI Construction
employee’s name, the name of the LLC. A written consent must
outside employer, and his or her primary include the employee’s name, the
job function. If it is determined that name of the outside employer,
outside work affects the employee’s his or her primary job function,
ability to perform his or her job with VINCI and the time and schedule
Construction LLC, the employee will be commitment of the outside work.
required to discontinue the outside work If it is determined that outside
as a condition of any continued work affects the employee’s
employment with VINCI Construction LLC. ability to perform his or her job
with VINCI Construction LLC, the
employee will be required to
discontinue the outside work as a
condition of any continued
employment with VINCI
Construction LLC.
24 7.9. Reasonable VINCI Construction LLC will provide VINCI Construction LLC will August 23, 2021
Accommodation for reasonable accommodations to provide reasonable
Pregnancy, Childbirth, or employees whose ability to perform job accommodations to employees
Related Medical Conditions, functions is limited by pregnancy, whose ability to perform job
Including Lactation childbirth, and related medical conditions, functions is limited by pregnancy,
including lactation. childbirth, and related medical
conditions, including lactation,
unless the accommodation would
pose an undue hardship on the
Company.
26 7.10b Social Media In addition, VINCI Construction LLC In addition, disclosure of VINCI August 16, 2021
financial disclosure is prohibited. Construction LLC’s financial
information is prohibited.
26 7.10b Social Media During an employee’s work hours and on During an employee’s work hours August 23, 2021
Company provided equipment, employees and/or on Company provided
should refrain from using social media, equipment, employees must
unless it is work-related and authorized by refrain from using social media,
their supervisor and the IT Department. unless it is work-related and
Employees are discouraged from using authorized by their supervisor
VINCI Construction LLC e-mail addresses and the IT Department.
to register on social networks, blogs, or Employees are prohibited from
other online tools used for personal use. using VINCI Construction LLC e-
mail addresses to register on
social networks, blogs, or other
online tools used for personal
use.
28 7.11 Customer Relations N/A Newly added policy June 8, 2021
29 7.12 Employee Referral N/A Newly added policy February 1, 2023
Program

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34 8.7 Performance The development of… At the discretion of the Company June 8, 2021
Improvement Plan (PIP)
34 8.7 Performance When an initial counseling session fails to When an initial counseling June 8, 2021
Improvement Plan (PIP) improve conduct, performance, or policy session fails to improve conduct,
violation, the manager, along with HR, performance, or policy violation,
may develop a PIP. The HR Department the manager, along with HR, may
and the manager would then meet with develop a PIP. The HR
the employee to discuss the plan. The Department and the manager
employee will be allowed the opportunity would then meet with the
to respond to the issues or concerns. The employee to discuss the plan and
steps in a PIP can be accelerated or give the employee the
skipped entirely if the employee is a opportunity to respond to the
chronic offender or the offense is issues or concerns. The steps in a
extreme. Failure to correct the issue PIP can be accelerated or skipped
stated could result in further disciplinary entirely and could result in
action, up to and including termination of further disciplinary action, up to
employment. and including termination of
employment.
34 8.7. Performance Added text Pursuant to the Company’s at-will June 8, 2021
Improvement Plan (PIP) employment policy, the Company
reserves the right to implement a
PIP, or not, in a particular
instance. Nothing in this
Handbook should be construed as
a promise of specific treatment in
a given situation.
34 8.8. Promotion and Transfers In addition, employees must have a good In addition, employees must have August 23, 2021
performance record. a good performance record to be
considered for a promotion or
transfer.
35 9.0 Employee Benefits Added text • Training Program August 23, 2021
• Relocation Assistance
• Workers’ Compensation
35 9.0 Employee Benefits Removed text • Holidays August 23, 2021
• Vacation and Sick Leave
35 9.0 Employee Benefits Added text • Benefits Continuation (COBRA) January 1, 2022
36 9.4 Benefits Continuation N/A Newly added policy January 1, 2022
(COBRA)
39 9.10 Training Program Added text In situations where an employee July 9, 2021
is approved for reimbursement
for a training or certification
beyond these options and they
terminate employment with the
Company within two years after
receiving reimbursement, the
Company will require repayment
of paid educational assistance.
39 9.11 Relocation Assistance Removed details after first paragraph Removed details after first August 23, 2021
paragraph

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41 10.1 Holidays VINCI Construction LLC observes eleven VINCI Construction LLC observes June 8, 2021
annual holidays. eleven paid annual holidays.
41 10.1 Holidays Removed text • Good Friday January 1, 2022
• Christmas Eve Day
• New Year’s Eve
41 10.1 Holidays Added text • Martin Luther King’s Birthday January 1, 2022
• President’s Day
• Juneteenth
42 10.2 Vacation Leave Added text Paid vacation time will not be August 23, 2021
counted as hours worked for the
purposes of determining
overtime in a particular work
week.
43 10.2 Vacation Leave Employees may only carry over a Employees may carry over the January 4, 2022
maximum of 5 days of accrued vacation balance of their accrued annual
leave from one fiscal year to the next. vacation from one calendar year
Employees may not carry more than 5 to the next within the aggregate
weeks of accrued leave at any time. Once limit of their annual vacation
an employee reaches the 5 weeks’ limit, allowance. The aggregate limit of
further accrual ceases until the their annual vacation allowance is
employee’s leave accrual dips below the defined as the maximum annual
cap of the 5 weeks of accrued leave. vacation allowance an employee
can earn (e.g., as stated in their
offer letter). An employee's
vacation balance will be capped
once the maximum annual
vacation allowance is reached.
43 10.3 Sick Leave Added text Paid sick leave will not be August 23, 2021
counted as hours worked for the
purposes of determining
overtime in a particular work
week.
43 10.3 Sick Leave Added text Upon separation of employment August 23, 2021
for any reason, employees will
not be paid for their accrued but
unused sick time.
44 10.6 Jury Duty Employees must show the jury duty Employees must show the jury June 8, 2021
Summons to their supervisor as soon as duty summonses to their
possible so supervisor and Human Resources
45 10.7 Voting the Company will allow you to take two the Company will allow you to June 8, 2021
(2) hours of paid time to vote. take up to two (2) hours of paid
time to vote.
48 11.3 Paydays Employees are paid semi-monthly. Employees are paid biweekly with January 1, 2023
Paydays are the 15th and the end of the one week in arrears. Paydays will
month. Should the 15th or end of the be every other Friday. If a
month fall on a weekend or a Monday regularly scheduled payday falls
holiday, payment will be made on the during a holiday, employees will
Friday prior. If a regularly scheduled be paid the day before.
payday falls during an employee’s

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vacation, direct deposit, if elected, will be


made as usual.
48 11.6 Payroll Deductions you should immediately contact the HR you should immediately June 8, 2021
department, the manager of payroll, or contact the Accounting
any other supervisor in the Company with department at the Corporate
whom you feel comfortable. If you are Office. If you are unsure of whom
unsure of whom to contact if you have not to contact if you have not
received a satisfactory response, please received a satisfactory response,
immediately contact VINCI Construction please immediately
LLC’s Chairman. contact the HR department.
53 13.1 General Code of Intentional damage or injury to VINCI Damage or injury to property or June 8, 2021
Conduct Construction LLC property or personnel. personnel.
53 13.1 General Code of Theft or misappropriation of VINCI Theft of property June 8, 2021
Conduct Construction LLC or personal property
53 13.1 General Code of Added text Misappropriation or misuse of August 23, 2021
Conduct the Company’s or any third
party’s property.
55 13.4 Harassment Policy (including pregnancy, childbirth or related (including pregnancy, childbirth August 30, 2021
conditions), sexual orientation, national or related conditions), sexual
origin, age, disability, genetic information, orientation, national origin, age,
gender identity or expression, veteran disability, marital status, genetic
status, or any other category protected by information, gender identity or
applicable federal, state or local law – see expression, veteran status, or any
section 4.0, Equal Employment other category protected by
Opportunity. applicable federal, state, or local
law— see section 5.0, Equal
Employment Opportunity.
55 13.4.a Definitions of Race, color, religion, national origin, age, race, color, religion, national August 30, 2021
Harassment disability, genetic information, gender origin, age, disability, marital
identity or expression, veteran status, or status, genetic information,
any other class of individual protected by gender identity or expression,
applicable law, or that of his/her relatives, veteran status, or any other class
friends, or associates, and that of individual protected by
applicable law, or that of his/her
relatives, friends, or associates,
and that
59 13.6 Drug Testing Drug and alcohol tests will be Drug and alcohol tests may be June 8, 2021
administered under the following administered at the discretion of
conditions: the Company under the following
conditions:
59 13.6 Drug Testing or occurrence that results in an injury under reasonable suspicion; June 8, 2021
on the job as defined by the Occupational
Safety and Health Administration;
59 13.6 Drug Testing After any vehicular accident when it Removed bullet point June 8, 2021
appears that the employee might
reasonably have avoided the accident or
minimized the consequences, but did not
do so;
61 13.8 Internet Usage Providing company information to Providing proprietary company August 30, 2021

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external parties without approval information to external parties


without approval
62 13.10 Use of Cellular Phones The company encourages a reasonable Removed text August 16, 2021
standard of limiting personal calls during
work time.
62 13.10 Use of Cellular Phones VINCI Construction LLC currently sponsors Removed text August 31, 2021
cellular/smart phones for some full time
VINCI Construction LLC employees.
64 13.13 Attendance If employees find it necessary to be absent If employees find it necessary to August 30, 2021
for any reason, be absent or tardy for any reason,
65 13.14 Teleworking Changes to this schedule must be Changes to this schedule must be August 30, 2021
reviewed and approved in advance by the reviewed and approved in writing
employee’s supervisor. in advance by the employee’s
supervisor.
66 13.16 Employer Information Added text Upon receiving company February 1, 2023
and Property equipment such as laptops or
smart phones, employees will be
provided with an Agreement to
Return and Care for Company
Equipment. In case of lost, stolen,
or misplaced equipment, you
must immediately report this to
your manager and the HR
department. In addition, the
Company will proceed, depending
on case-to-case basis, with the
following disciplinary actions:

1st offense – the employee will


receive a verbal warning
2nd offense – the employee will
receive a written disciplinary
warning
3rd offense – may result in
further disciplinary action, up to
and including termination
69 13.20 Death of an Employee N/A New policy added June 8, 2021
72 APPENDIX A. ETHICS “See NA-VCL-QHSE-NOT-00001-A – Ethics “See NA-VCL-QHSE-NOT-00004- June 8, 2021
HOTLINE POLICY & Compliance – 10-12-2019” B-Ethics & Compliance”
75 APPENDIX B. HUMAN VINCI Appendix to the Guide on Human VINCI Appendix to the Guide on June 8, 2021
RIGHTS POLICY Rights and VINCI’S Guide on Human Rights Human Rights and VINCI’S Guide
added on Human Rights added

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2.0 WELCOME FROM THE CHAIRMAN

Our Employee Handbook (“Handbook”) is a comprehensive guide for all employees at VINCI Construction LLC (the
“Company”) regarding our human resources policies, our benefits and employee rights and responsibilities. We
hope you will find this a useful source of data on the benefits offered, a guide to what is expected of you as a
member of the VINCI Construction LLC team and what you can expect from the Company.

VINCI Construction LLC’s diverse and highly talented workforce delivers services in the civil engineering industry
as well as many forms of construction. Such forms of construction are, but not limited to, heavy construction,
underground works, bridges, transportation infrastructure, airports, Combined Sewer Overflow (CSO), tunnels,
roadways and large infrastructure.

This Handbook is a living document and will be updated as necessary. If you have suggestions for additions and
improvements, contact the Human Resources (“HR”) Department.

Thank you in advance for taking the time to read it.

Christian TRICOIRE
Chairman, VINCI Construction LLC

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3.0 PURPOSE OF THIS HANDBOOK

A new and challenging experience awaits you as an employee of VINCI Construction LLC. This Handbook is designed
to acquaint you with VINCI Construction LLC and provide you with information on working conditions, employee
benefits, and other policies affecting your employment. You are required to read, understand, sign, and comply
with all provisions of this Handbook.

Policies set forth and referenced in this Handbook are neither intended to create a contract nor are they to be
construed to constitute either contractual obligations of any kind or a contract of employment, express or implied,
between VINCI Construction LLC and any of its employees or a promise of treatment in any particular manner in
any given situation. Nothing in this Handbook is intended to alter the at-will nature of the employment relationship
between VINCI Construction LLC and any of its employees. You are free to leave VINCI Construction LLC at any
time, with or without a reason and with or without notice. VINCI Construction LLC also has the right to end your
employment at any time, with or without a reason and with or without notice. Although the Company may choose
to end your employment for a cause, cause is not required. Further, VINCI Construction LLC has the right to manage
its work force and direct its employees. This includes the right to hire, transfer, promote, demote, reclassify, lay
off, terminate, or change any term or condition of employment at any time, with or without a reason and with or
without notice unless otherwise required by law. The at-will nature of employment may only be altered by a written
agreement signed by an employee and the Chairman of VINCI Construction LLC. No statement in this Handbook
entitles you to a particular condition, benefit, or procedure. The provisions of the Handbook have been developed
at the sole discretion of management and, except for its policy of employment-at-will, may be amended or cancelled
at any time at VINCI Construction LLC’s sole discretion.

No employee handbook can anticipate every circumstance or question about policy. As VINCI Construction LLC
continues to grow, the need may arise—and VINCI Construction LLC reserves its right—to revise, supplement, or
rescind any policies or portion of the Handbook from time to time as it deems appropriate, at its sole and absolute
discretion.

Any violation of the policies and/or procedures set forth in this Handbook may result in disciplinary action, up to
and including termination.

These provisions supersede all existing policies and practices and may not be amended or added to without the
express written approval of the Chairman of VINCI Construction LLC.

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4.0 ABOUT VINCI and VINCI CONSTRUCTION LLC

VINCI Construction LLC is a subsidiary of VINCI Construction Grands Projets. It was created on April 23, 2019, to
enhance the development of VINCI Construction Grands Projets in the United States of America.

VINCI Construction Grands Projets is a subsidiary of VINCI Construction, a division of VINCI Group, a global player
in concessions and construction, employing more than 211,000 people in some 100 countries. The mission of VINCI
is to design, finance, build and operate infrastructure and facilities that help improve daily life and mobility for all.

The history of the VINCI Group, heir to hundreds of companies gradually assembled in a convoluted process, goes
back to the 19th century. In 1899, two French civil engineers founded Société Générale d’Entreprises (SGE), which
became VINCI in 2000 following its merger with the GTM Group (Grands Travaux de Marseille) that was set up in
1890 to formerly build and operate the sewer system in the city of Marseille, France.

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VINCI Construction Grands Projets designs and builds major civil engineering structures and buildings:

• Transport infrastructures: bridges and viaducts, underground works, linear surface works, marine works
• Mining infrastructures: access tunnels, earthworks, underground and open-pit work, civil engineering
• Energy and oil & gas: LNG tanks, thermal and nuclear power plants
• Buildings: office and residential towers, car parks, airports, administrative and cultural facilities
• Hydraulic infrastructures: dams, pumping and wastewater treatment stations, water distribution and
evacuation
• Environment: drinking water supply and sanitation systems, technical landfill centers

As a complement to the Company’s high level of expertise, its consummate engineering skills, and expert project
management abilities, VINCI Construction Grands Projets practices a policy of involvement at the local level
wherever it operates, partnering with local firms and companies, enabling it to deploy wide-ranging yet modular
solutions.

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5.0 EQUAL EMPLOYMENT OPPORTUNITY

VINCI Construction LLC is an equal opportunity employer. It is our policy to prohibit discrimination and harassment
of any type and to afford equal employment opportunities to employees and applicants, without regard to race,
color, religion, sex (including pregnancy, childbirth, or related conditions), sexual orientation, national origin, age,
disability, marital status, genetic information, gender identity or expression, veteran status, or any other category
protected by applicable federal, state, or local law. VINCI Construction LLC will conform to the spirit as well as the
letter of all applicable laws and regulations. VINCI Construction LLC will take action to employ, advance in
employment, and treat qualified veterans and disabled veterans without discrimination in all employment
practices.

The policy of equal employment opportunity and anti-discrimination applies to all aspects of the relationship
between VINCI Construction LLC and its employees, including but not limited to recruitment, employment,
promotion, transfer, training, working conditions, wage and salary administration, employee benefits, application
of policies, and general treatment during employment.

Violations of this policy, regardless of whether an actual law has been violated, will not be tolerated. If an employee
believes someone has violated this policy or otherwise has questions regarding this policy, the employee may bring
the matter to the attention of the Senior Project Manager and the HR Department. VINCI Construction LLC will
promptly and thoroughly investigate every issue that is brought to its attention in this area and will take
appropriate disciplinary action, up to and including termination of employment.

No employee will be subject to, and VINCI Construction LLC prohibits, any form of discipline or retaliation for
reporting perceived violations of this policy, pursuing any such claim, or cooperating in any way in the investigation
of such claims.

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6.0 EMPLOYMENT CATEGORIES

VINCI Construction LLC employees are classified as non-exempt or exempt and as full-time or part-time for the
purposes of compensation administration.

VINCI Construction LLC will comply with all applicable federal and state laws governing the payment of overtime
compensation. The HR Department is responsible for classifying employees. Employees generally may be
categorized as follows:

• NON-EXEMPT employees are subject to the FLSA minimum wage and overtime provisions along with
applicable state and local wage and hour laws and may be paid on an hourly basis. Non-exempt employees
are entitled to be paid one-and-one-half times their regular rate for every hour worked over 40 in a
workweek.
• EXEMPT employees are exempt from the FLSA and applicable state and local law overtime provisions and
therefore are not entitled to overtime pay. Exempt employees are paid on a salary basis and the salary is
intended to cover all hours worked.

An exempt employee, charging hours to a specific contract that allows for compensation more than a forty (40)
hour workweek may be eligible for additional straight time compensation in addition to his or her salary.
Employees should seek further guidance from their Program Director or Manager or the Accounting Department
on contract specifics. Straight time is not classified as FLSA overtime pay. An employee’s EXEMPT or NONEXEMPT
classification may be changed only upon written notification by VINCI Construction LLC management.

In addition to the above categories, each employee will belong to one other employment category:

• REGULAR FULL-TIME employees are those who are not in a temporary status and who are regularly
scheduled to work VINCI Construction LLC’ full-time schedule of a minimum of 40 hours per week. They
are eligible for VINCI Construction LLC’s benefit package, subject to the terms, conditions, and limitations
of each benefit program.
• PART-TIME employees are those who are not in a temporary status and who are regularly scheduled to
work less than 40 hours per week. While they do receive all legally mandated benefits (such as Social
Security and workers’ compensation insurance), some other VINCI Construction LLC sponsored benefits
may also be available, subject to the terms, conditions, and limitations of each benefit program.
• TEMPORARY employees are those who are hired as interim replacements, to temporarily supplement the
work force, or to assist in the completion of a specific project. Employment assignments in this category
are generally of a limited duration. Employment beyond any initially stated period does not in any way

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imply a change in employment status. Temporary employees retain that status unless and until notified of
a change in writing. All legally mandated benefits (such as Social Security and workers’ compensation insurance) are
provided to temporary employees; however, temporary employees are not entitled to additional VINCI Construction
LLC sponsored benefits.

Employees will be informed of their initial employment categories upon commencing employment. An employee
may change classifications only upon written notification by the Company. There are no automatic conversions from
one classification to another. Employees should contact their supervisor or the HR Department if they are not sure
of their employment categories.

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7.0 EMPLOYMENT POLICIES

7.1 At-Will Employment

Employment with VINCI Construction LLC is at will. Employment is voluntarily entered into, and the employee is
free to resign at will at any time, with or without reason. Similarly, VINCI Construction LLC may terminate the
employment relationship at will at any time with or without notice, for any reason not prohibited by applicable
state, local, or federal law or for no reason.

7.2 Employee Relationships and Disclosure

VINCI Construction LLC is committed to a policy of employment and advancement based on qualifications and
merit. VINCI Construction LLC does not discriminate in favor of or in opposition to the employment of relatives.
However, the employment of relatives in the same area of an organization may cause serious conflicts and
problems with favoritism and employee morale. In addition to claims of partiality in treatment at work, personal
conflicts from outside the work environment can be carried over into day-to-day working relationships.

For the purposes of this policy, a relative is any person who is related by blood or marriage, or whose relationship
with the employee is like that of persons who are related by blood or marriage. This policy applies to all employees
without regard to the gender or sexual orientation of the individuals involved.

VINCI Construction LLC strongly discourages current employees from occupying a position that will be working
directly for or directly supervising their relative. VINCI Construction LLC also reserves the right to act if an actual
or potential conflict of interest arises involving relatives or individuals involved in a consensual relationship who
occupy positions at any level (higher or lower) in the same line of authority that may affect the review of
employment decisions.

If a relative relationship is established after employment commences between employees who are in a reporting
situation described above, it is the responsibility of the employees involved in the relationship to disclose the
existence of the relationship to management and human resources. A conflict-of-interest agreement must be
signed by both employees if VINCI Construction LLC determines, in its sole discretion, that such agreement is
necessary. If the relationship has caused conflict that negatively impacts the business of VINCI Construction LLC,
or the Company believes the work relationship may cause a conflict (real, perceived, or apparent), the individuals
concerned will be given the opportunity to decide who is to be transferred to another available position, if one
exists. If that decision is not made within 30 calendar days or if there are no available positions in which an affected
employee can transfer, management will decide who is to be transferred or, if necessary, terminated from
employment.
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7.3 Immigration Law Compliance

VINCI Construction LLC participates in E-Verify. Upon completion of Form I-9, all employees are run through E-
Verify, the government’s web-based system that allows enrolled employers to confirm the eligibility of their
employees to work in the United States. The use of the E-Verify system is not to pre-screen job applicants or to re-
verify current employees.

Employees with questions or seeking more information on immigration law issues are encouraged to contact the
HR Department. Employees may raise questions or complaints about immigration law compliance without fear of
reprisal.

7.4 Business Ethics

VINCI Construction LLC is dedicated to developing and maintaining a reputation for uncompromising technical
excellence, professionalism beyond reproach, and the highest ethical standards for the conduct of business. The
pursuit of excellence is the responsibility of every employee within the Company as reflected in the following
articles.

• We will only perform work that we are qualified to perform.


• We will ensure that the conduct of business shall always be within the spirit of applicable laws and
regulations.
• We will never discriminate—see our Equal Employment Opportunity policy in section 5.0.
• We will never disclose sensitive information to third parties without specific prior approval.
• We are dedicated to VINCI Construction LLC, each other, and our clients.
• We will maintain a professional work environment.
• We will handle sensitive issues in a timely and professional manner.
• We will adhere to the highest ethical standards when dealing with our clients.
• We will work to the mutual benefit of VINCI Construction LLC, our employees, and our Board.

Anyone who witnesses what they believe to be a violation of ethical standards and/or the law, including but not
limited to fraud, waste, or abuse of authority, potential leaks of classified information, or potential acts of
terrorism, should reference section 9.14 Internal Complaint Procedures. Such reports should be made through the
chain of command, directly to a supervisor, to VINCI Construction LLC management, or to our Ethics Hotline (see
Appendix A).

A specific procedure for Ethics & Anti-corruption exists (NA-VCL-QHSE-NOT-00001-A), according to the VINCI Anti-

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corruption code of conduct and the VINCI Code of Ethics and Conduct and shall be applied by all VINCI Construction
LLC employees.

7.5 Outside Employment

An employee may work elsewhere, provided that written approval has been obtained from appropriate
management personnel, the employee can satisfactorily perform his/her job responsibilities with VINCI
Construction LLC, and the outside employment does not create a conflict of interest or present an appearance of
such a conflict of interest. The employee’s work for VINCI Construction LLC will be judged by the same performance
standards and will be subject to the same scheduling demands, regardless of the requirements of the other work.

The employee must obtain prior written consent of his or her supervisor and department manager to work
elsewhere while employed at VINCI Construction LLC. A written consent must include the employee’s name, the
name of the outside employer, his or her primary job function, and the time and schedule commitment of the
outside work. If it is determined that outside work affects the employee’s ability to perform his or her job with
VINCI Construction LLC, the employee will be required to discontinue the outside work as a condition of any
continued employment with VINCI Construction LLC.

If a conflict of interest is found, the employee will be notified quickly to take immediate action. Employees should
be aware that liability for breach of fiduciary duty may be imposed when employees or Officers misappropriate
trade secrets, misuse confidential information, and/or solicit VINCI Construction LLC’s clients or other employees
during employment. Whether specific conduct taken prior to resignation breaches a fiduciary duty requires a case-
by-case analysis.

For more information, see section 7.4, Business Ethics.

7.6 Non-Disclosure

The protection of confidential business information and trade secrets is vital to the interests and the success of
VINCI Construction LLC. Such confidential information includes, but is not limited to, the following examples of
information that is maintained confidentially by the Company and is not publicly known:

• Contract documents (i.e., Prime Contracts, Subcontracts, Non-disclosure Agreements (NDAs), Teaming
Agreements (TAs), Memoranda of Understanding (MOUs), Consultant Agreements, Vendor Agreements,
Partnership).
• Proposal materials (i.e., technical information, pricing data, proposal submissions, templates, forms,

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methodologies, past performance documentation, drawings, calculation note, interpretative


reports).
• Financial information (including forms and templates).
• Proprietary corporate information.
• Employee personal information.
• Business development sensitive information.
• Intellectual property.
• Any document labeled Company Proprietary and/or Confidential or containing such other language as to
reasonably place the reader on notice as to the proprietary or confidential nature of the material.

Employees who have access to business sensitive or Company proprietary information are required to sign a non-
disclosure agreement as a condition of employment or continued employment. Employees who knowingly and/
or improperly use or disclose trade secrets or confidential business information will be subject to disciplinary
action, up to and including termination of employment and legal action, even if they do not actually benefit from
the disclosed information.

7.7 Reasonable Accommodation of Individuals with Disabilities

VINCI Construction LLC is committed to complying with all applicable provisions of the Americans with Disabilities
Act, as amended (ADA), and applicable state law. It is VINCI Construction LLC’s policy not to discriminate against
any qualified employee or applicant about any terms or conditions of employment because of such individual’s
known physical or mental disability or perceived disability so long as the employee can perform the essential
functions of the job. VINCI Construction LLC will provide reasonable accommodations to a qualified individual with
a disability, as defined by applicable law, who has made VINCI Construction LLC aware of his or her disability,
provided that such accommodation does not constitute an undue hardship on VINCI Construction LLC or pose
direct threat of substantial harm to the employee or others. VINCI Construction LLC encourages individuals with
disabilities to come forward and request reasonable accommodation.

The procedure for requesting an accommodation is as follows:

• Employees with a disability who believe they need a reasonable accommodation to perform the
essential functions of their job should contact the HR Department.
• On receipt of an accommodation request, a member of the HR Department will meet with the employee
to discuss and identify the precise limitations resulting from the disability and the potential
accommodation that VINCI Construction LLC can provide to enable the employee to perform the essential
functions of the position. When appropriate, VINCI Construction LLC may request the employee’s

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permission to obtain additional information regarding the disability and resulting limitations from the treating
physician or other medical or rehabilitation professionals.
• VINCI Construction LLC will inform the employee of its decision with respect to the request for an
accommodation.

An employee or job applicant who has questions regarding this policy, wants to request an accommodation, or
believes that he or she has been discriminated against based on a disability should notify the HR Department. All
such inquiries or complaints will be treated confidentially, to the extent permissible by law and to the extent
possible while investigating of the allegations of discrimination.

7.8 Reasonable Accommodation of Individuals’ Religious Beliefs and Practices

VINCI Construction LLC recognizes and supports its obligation to endeavor to reasonably accommodate job
applicants and employees with sincere religious beliefs or practices who can perform the essential functions of the
position, with or without reasonable accommodation. The Company will endeavor to provide reasonable
accommodation to otherwise qualified job applicants and employees, unless doing so would impose an undue
hardship on the Company.

An applicant or employee who believes he or she needs a reasonable accommodation of a sincere religious belief or
practice should discuss the need for a possible accommodation with the HR Department.

7.9 Reasonable Accommodation for Pregnancy, Childbirth, or Related Medical Conditions, Including
Lactation

VINCI Construction LLC will provide reasonable accommodations to employees whose ability to perform job
functions is limited by pregnancy, childbirth, and related medical conditions, including lactation, unless the
accommodation would pose an undue hardship on the Company. A “reasonable accommodation” is an
accommodation that does not cause undue hardship in the operation of VINCI Construction LLC’s business.
Reasonable accommodations may include:
- more frequent or longer bathroom breaks,
- acquisition or modification of equipment or access to or modification of employee seating,
- a temporary transfer to a less strenuous or hazardous position,
- assistance with manual labor,
- job restructuring,
- a modified work schedule,
- light duty assignments, and/or

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- leave to recover from childbirth.

We will engage in good faith in a timely interactive process to determine reasonable accommodations for
employees who request or require them. We may request necessary medical certification.

The Company will provide a reasonable amount of break time to accommodate an employee desiring to express
breast milk for the employee’s infant child, to the extent required and in accordance with applicable law. The break
time, if possible, must run concurrently with rest and meal periods already provided to the employee. If the break
time cannot run concurrently with rest and meal periods already provided to the employee, the break time will be
unpaid, to the extent permitted by applicable law.

The Company will make reasonable efforts to provide employees with the use of a room or location other than a
toilet stall for the employee to express milk in private. This location may be the employee’s private office, if
applicable. The Company may not be able to provide additional break time if doing so would seriously disrupt the
Company’s operations. Please speak to the HR Department if you have questions regarding this policy.

7.10 Corporate Communication

Occasionally, VINCI Construction LLC will hold Company-wide staff meetings. During these meetings, employees
receive communications from management that are pertinent to VINCI Construction LLC. In addition, employees
are given the opportunity to discuss or bring attention to matters affecting their contracts and/or position. When
applicable, employees are recognized by their peers, clients, and management when they go “above and beyond”
the call of duty. We ask that all employees try their best to attend these meetings.

In addition, VINCI Construction LLC provides numerous employee communication portals such as VINCI’s Intranet,
where employees can find organizational announcements, news/events, and discussions about specific topics.
Employees are responsible for reading necessary information posted in the portal. Portal information is
confidential and proprietary, and access should not be provided to outside persons. Local communication will also
be available to employees based on their project organization.

VINCI Construction LLC encourages all employees to bring forward their constructive suggestions and good ideas
about making VINCI Construction LLC a better place to work and enhancing service to VINCI Construction LLC
clients and employees. Any employee who sees an opportunity for improvement is encouraged to talk it over with
their supervisor or management. Management can help bring ideas to the attention of the people in the
organization that will be responsible for possibly implementing them. All other suggestions should be sent to
vcllc.hr@vinci-construction.com.

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Successful working conditions and relationships depend upon successful communication. It is important that
employees stay aware of changes in procedures, policies, and general information. It is also important to
communicate ideas, suggestions, personal goals, or problems as they affect work at VINCI Construction LLC.

7.10.a Solicitation, Distribution, and Use of Bulletin Boards

Employees may not solicit any other employee while either person is on working time. Working time includes the
time during which any of the employees involved are scheduled to work, but does not include scheduled rest
periods, meal breaks and other specified times when employees are not expected to be working. Solicitation by
non-employees on Company premises is always prohibited. Employees may not distribute literature in work areas
at any time. Under no circumstances may an employee disturb the work of others to solicit or distribute literature
to them during their working time.

Persons not employed by VINCI Construction LLC may not solicit VINCI Construction LLC employees for any
purposes on Company premises. Distribution of literature by non-employees on Company premises is also always
prohibited.

Bulletin boards maintained by VINCI Construction LLC are to be used only for posting or distributing material of
the following nature:

• Notices containing matters directly concerning Company business; and


• Announcements of a business nature which are equally applicable and of interest to employees.

All posted material must have authorization from a manager and/or HR. Employees are expected to check these
bulletin boards periodically for new and/or updated information and to follow the rules set forth in all posted
notices. Employees should not remove material from the bulletin boards without prior approval.

7.10.b Social Media

At VINCI Construction LLC, we understand that social media can be a fun and rewarding way that employees share
their life and opinions with family, friends, and co-workers around the world. However, use of social media also
presents certain risks and carries with it certain responsibilities. To assist employees in making responsible
decisions about their use of social media, we have established the following guidelines for appropriate use.

Social media is a means of communicating or posting information or content of any sort on the Internet, including
to an employee’s own or someone else’s web log or blog, journal, or diary, personal web site, social networking or

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affinity website, web bulletin board or a chat room, whether associated or affiliated with VINCI Construction LLC, as
well as any other form of electronic communication. The Company respects the right of our employees to maintain
a blog or post a comment on social networking sites. However, the Company is also committed to ensuring that
the use of social media serves the needs of our business by maintaining the Company’s interests and ensuring
employees focus on their job duties.

Ultimately, employees are solely responsible for what they post online. Before creating online content, VINCI
Construction LLC requests that an employee consider some of the risks and rewards that are involved.

Employees are strongly encouraged to keep in mind that any conduct that adversely affects their job performance,
the performance of fellow associates, or otherwise adversely affects members, clients, suppliers, people who work
on behalf of VINCI Construction LLC, or VINCI Construction LLC’s legitimate business interests may result in
disciplinary action up to and including termination.

VINCI Construction LLC encourages employees to understand these guidelines, the Business Ethics, the General
Code of Conduct, Electronic Communications, Violence Prevention in the Workplace, and the Harassment policies
to ensure their postings are consistent with these policies. Inappropriate postings that may include discriminatory
remarks, harassment, and threats of violence or similar inappropriate or unlawful conduct will not be tolerated.
Any conduct which is impermissible under the law or our policies if expressed in any other form or forum is
impermissible if expressed through a social networking site.

VINCI Construction LLC reminds employees to be fair and courteous to fellow associates, clients, members,
suppliers, or people who work on behalf of the Company. Also, keep in mind that employees are more likely to
resolve work-related complaints by speaking directly with their co-worker(s) or by exercising an open-door policy
with VINCI Construction LLC management. Nevertheless, if an employee decides to post complaints or criticism,
such conduct might include offensive posts meant to intentionally harm someone’s reputation or posts that could
contribute to a hostile work environment in violation of our Equal Employment Opportunity policy (see section
5.0).

Employees must maintain the confidentiality of VINCI Construction LLC’s trade secrets and private or confidential
information. Trade secrets may include information regarding the development of systems, processes, products,
know-how, and technology. VINCI Construction LLC employees must not post internal reports, policies,
procedures, or other internal business-related confidential communications on social media. In addition,
disclosure of VINCI Construction LLC’s financial information is prohibited.

During an employee’s work hours and/or on Company provided equipment, employees must refrain from using

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social media unless it is work-related and authorized by their supervisor and the IT Department. Employees are
prohibited from using VINCI Construction LLC e-mail addresses to register on social networks, blogs, or other online
tools used for personal use.

VINCI Construction LLC prohibits taking negative action against any employee for reporting a possible deviation
from this policy or for cooperating in an investigation. Any employee who retaliates against another employee for
reporting a possible deviation from this policy or for cooperating in an investigation will be subject to disciplinary
action, up to and including termination.

For further guidance on this policy, please contact the HR Department.

7.11 Customer Relations

The success of the Company depends upon the quality of the relationships between the Company, our employees,
customers, suppliers, and the public. Our customers’ impression of the Company and their interest and willingness
to purchase from us is greatly formed by the people who serve them. In a sense, regardless of your position, you
are the Company’s ambassador. The more goodwill you promote, the more our customers’ will respect and
appreciate you, the Company and the Company’s products and services. Below are several things you can do to
help give customers a good impression of the Company. These are the building blocks for our continued success.

1. Act competently and deal with customers in a courteous and respectful manner.
2. Communicate pleasantly and respectfully with other employees, customers, and vendors at all times.
3. Follow up on requests and questions promptly, provide businesslike replies to inquiries and requests, and
perform all duties in an orderly manner.
4. Take great pride in your work and enjoy doing your very best.

These policies apply to all areas of employment, including recruitment, hiring, training and development,
promotion, transfer, termination, layoff, compensation, benefits, social and recreational programs and all other
conditions and privileges of employment in accordance with applicable federal, state, and local laws.

All employees are expected to treat customers with respect and act in a professional manner during all interactions
with customers.

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7.12 Employee Referral Program

VINCI Construction LLC’s Employee Referral Program is designed to encourage active employees (referrer) to
refer qualified candidates (referee) for open positions within the Company. At VINCI Construction LLC, we are
always looking for qualified people to join us. One of the best sources of finding qualified people are referrals
from our existing employees since they already know the culture of the company and firmly believe in their
referral’s abilities to do a good job.

Therefore, if you know someone who you think would be a good fit for an open position at the Company, feel
free to refer them. If we end up hiring your referee, you will be eligible for a referral bonus. The following
specifications are applicable:

• The referral bonus for exempt positions is:


o $2,000.00 for managerial positions (Project Managers and above) and
o $1,000.00 for all other exempt positions.
• The referral bonus for non-exempt positions is $250.00 for hourly field positions.

This referral bonus does not apply to:


• HR employees and Company Officers
• Current employees transferring to a new position within the Company
• Current employees promoting to a new position within the Company
• Current employees of other VINCI entities or subsidiaries
• Rehired employees

To refer a candidate, the referrer must obtain an employee referral form from HR. Upon completion of the form,
referrer shall return it to HR with the referee’s resume. Forms must be received by HR prior to the referee’s
interview. The referee must continuously be employed with VINCI for at least six (6) months for the referred to
receive the referral bonus award. Keep in mind that bonuses are subject to taxation.

The Company will process referral bonuses payments within 30 days of the date the referee completes six (6)
months of employment. If two or more employees refer the same candidate, only the first referrer will receive
their referral bonus. A referring employee is limited to up to 3 referrals per calendar year.

VINCI Construction LLC may change this Referral Program if this policy proves ineffective or inefficient. The
Company will communicate any changes clearly and timely. Employees who referred candidates before this
policy is inactive will still receive the appropriate reward.

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We’d like to remind our employees that we are an equal opportunity employer and do not discriminate against
protected characteristics. We guarantee that all candidates will be given the same consideration and will
undergo our established employment policies and procedures.

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8.0 PERSONNEL

8.1 Access to Personnel Files

VINCI Construction LLC maintains a personnel file on each employee. The personnel file includes such information
as the employee’s job application, resume, records of training, documentation of performance appraisals and
salary increases, as well as disciplinary actions and other employment records.

Personnel files are the property of VINCI Construction LLC, and access to the information they contain is restricted.
Generally, only supervisors and management personnel of VINCI Construction LLC who have a legitimate reason
to review information in a file can do so. However, government investigators with signed authorization may be
provided with access to personnel files. Under court order, or as otherwise required by law, other access may be
granted.

Employees who wish to review their own file should contact the HR Department in writing. VINCI Construction LLC
will furnish a copy of all records or papers retained by the Company reflecting: the employee’s dates of
employment with the Company; the employee’s wages or salary during the employment; the employee’s job
description and job title during employment; and any injuries sustained by the employee during employment. The
Company will provide these records within 30 days of receipt of the employee’s written request. If the Company
determines it is unable to provide the requested records within 30 days, it will notify the employee in writing of the
reason for the delay and will produce the requested documents within 30 days of the notice of delay. The Company
may charge a reasonable fee per page for copying.

If an employee would like to see any additional records in his/her personnel file, with reasonable advance notice,
employees may review them in VINCI Construction LLC’s offices and in the presence of an individual appointed by
VINCI Construction LLC to maintain the files. Employees are not allowed to make a copy of any material in the
personnel file without express permission from the HR Department.

Any medical information received about any employee for any reason relating to employment will be kept
confidential in a separate medical file for that employee and will not be shared along with the general personnel
file, except where such information is deemed necessary to the review, or as otherwise required by applicable law.

8.2 Security Clearances

Positions within VINCI Construction LLC or with its clients do now or may in the future require a security clearance
and an additional security investigation. For these positions, a security clearance is an essential function of the job.

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The inability of an employee to obtain and maintain the required security clearance will result in the employee
being automatically disqualified from that position and may result in termination of employment.

8.3 Employment Reference Checks

All inquiries regarding a current or former VINCI Construction LLC employee must be referred to the HR
Department. Under no circumstances may any VINCI Construction LLC employee (other than designated
individuals in HR) release any employment information about any current or former VINCI Construction LLC
employee over the telephone, in writing, or in person.

Should an employee receive a request for a reference (either verbal or in writing), they should refer the request
to the HR Department.

A VINCI Construction LLC employee may provide a personal letter of reference for a current or former VINCI
Construction LLC employee that is not related to the employee’s employment. This letter should make clear that
the employee is making the reference in the employee’s personal capacity and not in their capacity as a VINCI
Construction LLC employee.

In response to an outside request for information regarding a current or former VINCI Construction LLC employee,
the HR Department will furnish or verify only an employee’s name, dates of employment, job title, and
department. No other data or information will be furnished unless the employee authorizes VINCI Construction
LLC to furnish this information in writing and will release VINCI Construction LLC from liability in connection with
furnishing the requested information.

8.4 Employment Applications

VINCI Construction LLC relies upon the accuracy of information contained in the employment application, as well
as the accuracy of other data presented throughout the hiring process and employment. Any misrepresentations,
falsifications, or material omissions in any of this information or data may result in the exclusion of the individual
from further consideration for employment or, if the person has been hired, termination of employment.

8.5 Personnel Records

To keep necessary Company records up to date, it is extremely important that employees notify the HR
Department of any changes in:

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• Name and/or marital status.


• Address and/or telephone number.
• Number of eligible dependents.
• W-4 deductions.
• Person to contact in case of emergency.

8.6 Annual Appraisals and Merit Increases

Annual Appraisals. It is the policy of VINCI Construction LLC to regularly assess the performance of each employee.
Managers and employees are strongly encouraged to discuss job performance and goals on an informal, day-to-
day basis. Additional formal performance appraisals, such as VINCI’s People Reviews, are conducted to provide
both Managers and employees the opportunity to discuss job tasks, identify and correct weaknesses, encourage,
and recognize strengths, and discuss positive, purposeful approaches for meeting goals.

Annual appraisals are generally scheduled annually. They must be conducted regardless of any other formal or
informal appraisals that an employee has received over the previous twelve (12) months. The process consists of
the Manager and employee conducting an interview then the final completion of an Annual Appraisal Form.

Regular annual appraisals should:

• Help employees clearly define and understand their responsibilities, provide criteria by which their
performance will be evaluated, and suggest ways in which they can improve performance.
• Identify professional development and training opportunities for the employee.
• Identify potential for employee advancement, promotion, transfer, or mobility within the Company.
• Help managers achieve departmental goals.
• Provide a fair basis for awarding compensation based on merit.

Employees must submit an updated resume with their completed Annual Appraisal Form.

Merit Increases. VINCI Construction LLC may, at its sole discretion, provide a merit increase to recognize an
employee for performance and achievement of objectives. The employee’s annual performance appraisal serves
as the basis for a merit increase. Appraisals and merit increase recommendations are then reviewed by Senior
Leadership and HR, and decisions are given to each manager. There is no guarantee of a merit increase after each
annual performance appraisal, or at any other time.

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8.7 Performance Improvement Plan (PIP)

At the discretion of the Company, it may decide to prepare a Performance Improvement Plan (PIP) to provide
employee the opportunity to undertake corrective action to improve low performance.

When an initial counseling session fails to improve conduct, performance, or policy violation, the manager, along
with HR, may develop a PIP. The HR Department and the manager would then meet with the employee to discuss
the plan and give the employee the opportunity to respond to the issues or concerns. The steps in a PIP can be
accelerated or skipped entirely and could result in further disciplinary action, up to and including termination of
employment.

Pursuant to the Company’s at-will employment policy, the Company reserves the right to implement a PIP, or not,
in a particular instance. Nothing in this Handbook should be construed as a promise of specific treatment in each
situation.

8.8 Promotion and Transfers

VINCI Construction LLC encourages employees to assume higher-level positions or lateral transfers for which they
qualify. (VINCI Construction Grands Projets has a job posting program that offers employees the opportunity to
apply for these positions within the Company.) Generally, an employee’s request for change in position will be
assessed on a case-by-case basis. In addition, employees must have a good performance record to be considered
for a promotion or transfer. Ideally, this promotion or transfer should be documented in the Annual Appraisal
process. Each employee applying for a position change will be considered along with all other applicants. Transfers
are judged on an individual basis, depending on the needs of the projects or departments involved and the
Company.

Employees who wish to apply for a position are encouraged to discuss it first with their Manager and the HR
Department so that it may be determined if their skills fit the requirements of the desired job.

8.9 Mentoring Program

VINCI Construction LLC will develop a voluntary mentoring program for all employees at every level of
employment. The primary purpose of this program is to advance highly qualified employees. VINCI Construction
LLC’s mentoring program provides employees the opportunity to develop skills and address personal and
professional growth. Mentoring helps employees work smarter, develop themselves, and become better at their
jobs. In turn this means more productivity and happier employees working at VINCI Construction LLC. Please speak
to the HR department if you have questions regarding this policy.
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9.0 EMPLOYEE BENEFITS

VINCI Construction LLC has developed a comprehensive benefits package for its employees. Some benefits are
provided to employees at no cost to the employees. Other benefits are available, if the employee chooses them,
at a shared cost. Each employee chooses the combination of benefits that best fits the needs of that employee
and the employee’s family. Several of the programs (such as Social Security, workers’ compensation, state
disability, and unemployment insurance) cover all employees in the manner prescribed by law.

This portion of the Handbook contains a very general description of the benefits to which VINCI Construction LLC
employees may be entitled. Please understand that this general explanation is not intended to, and does not,
provide employees with all the details of these benefits. Therefore, this Handbook does not change or otherwise
interpret the terms of the official plan documents. Employee eligibility and rights can be determined only by
referring to the full text of the official plan documents, which are available for examination from the HR
Department. In the event of any ambiguity or inconsistencies between this Handbook or any other oral or written
description of benefits and a formal plan document, the formal plan document will govern.

The following benefit programs are available to eligible employees:

• Medical insurance
• Dental insurance
• Vision insurance
• Benefits Continuation (COBRA)
• Pre-tax savings benefits
• Disability insurance (short and long term)
• Basic Life and Accidental Death and Dismemberment
• Employee assistance program
• 401(k) savings plan
• Training Program
• Relocation Assistance
• Workers’ Compensation

VINCI Construction LLC reserves the right, at its sole and absolute discretion, to amend, modify, or terminate, in
whole or in part, any or all the provisions of the benefit plans described herein, including any health benefits that
may be extended to retirees and their dependents. Further, VINCI Construction LLC reserves the exclusive right,
power, and authority, at its sole and absolute discretion, to administer, apply, and interpret the benefit plans
described herein, and to decide all matters arising in connection with the operation or administration of such plans.

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Please note that nothing contained in the benefit plans described herein shall be held or construed to create a
promise of employment or future benefits, or a binding contract between VINCI Construction LLC and its
employees, retirees, or their dependents for benefits or for any other purpose. All employees shall remain subject
to discharge or discipline to the same extent as if these plans had not been put in effect.

To be covered under any of the VINCI Construction LLC plans, the employee may be required to fill out certain
forms which can be obtained from HR. The filling out of these forms and other eligibility requirements are the
employee’s responsibility. Employees who do not wish to participate in any of these plans may be required to sign
a waiver to that effect. If an employee waives any of the voluntary benefits and later decides to join a plan, the
employee can join only during the open enrollment or if the employee experiences a “qualifying event.”

Additionally, please note that the eligibility requirements for the Company’s insurance plans, and the extent of
coverage, are governed solely by the terms of whatever insurance plans are in effect at any given time. All of VINCI
Construction LLC’s insurance plans are subject to the limitations and requirements of the insurance carrier. Any
questions regarding insurance should be directed to HR.

For more complete information regarding any of our benefit programs, please refer to the Summary Plan
Descriptions, which are provided to employees separately or contact the HR Department. Employees who have
lost or misplaced those descriptions can contact the HR Department for another copy.

9.1 Medical Insurance

Regular full-time employees are eligible to participate in the medical insurance plan. The specific benefit plans that
apply to you may vary. Therefore, please refer to the separate benefits booklets given to you at the time of your
enrollment in any benefit plans for further information.

Insurance is effective the 1st of the month following the completion of 30 days of full-time employment. The
employee premium contribution rates may be found in the Summary of Benefits. Premiums are paid through
payroll deductions on a pre-tax basis.

9.2 Dental Insurance

Regular full-time employees are eligible to participate in the dental insurance plan. The specific benefit plans that
apply to you may vary. Therefore, please refer to the separate benefits booklets given to you at the time of your
enrollment in any benefit plans for further information.

Insurance is effective the 1st of the month following the completion of 30 days of full-time employment. The
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employee premium contribution rates for each level of coverage may be found in the Summary of Benefits.
Premiums are paid through payroll deductions on a pre-tax basis.

9.3 Vision Program

Regular full-time employees are eligible to participate in the vision plan. The specific benefit plans that apply to
you may vary. Therefore, please refer to the separate benefits booklets given to you at the time of your enrollment
in any benefit plans for further information.

Insurance is effective the 1st of the month following the completion of 30 days of full-time employment. Unless
bundled with the health insurance plan, the employee premium contribution rates for each level of coverage may
be found in the Summary of Benefits. Premiums are paid through payroll deductions on a pre-tax basis.

9.4 Benefits Continuation (COBRA)

The Federal Consolidated Omnibus Budget Reconciliation Act (COBRA) of 1985 gives employees and their
qualified beneficiaries the opportunity to continue health insurance coverage under the Company’s health plan
when a “qualifying event” would normally result in the loss of eligibility. Some common qualifying events are
termination of employment, death of an employee, a reduction in an employee’s hours or a leave of absence,
divorce or legal separation, or a dependent no longer meeting eligibility requirements.

Under COBRA, the employee or beneficiary pays the full cost of coverage at the Company’s group rates plus an
administration fee. Your payments after the first payment for continued coverage must be made within 30 days
of the due date or, if the insurer provides a grace period of longer than 30 days, within that longer period. The
Company (or its designee) provides each eligible employee with a written notice describing rights granted under
COBRA within a certain period of time after a qualifying event occurs that would render the employee eligible for
continuation coverage under the Company’s health insurance plan. The notice contains important information
about the employee’s rights and obligations.

9.5 Pre-tax Savings Benefits

Employees are eligible to participate in these benefits the 1st of the month following the completion of 30 days of
full-time employment. Participation in this benefit allows employees to save money by taking advantage of tax
savings through payroll deductions.

By participating in a pre-tax benefit, employees use before-tax income to pay for expenses usually paid for with
after-tax income. Making use of these plans will mean lower taxes and higher take-home pay for the employee as
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premiums are deducted before federal and state income taxes and Medicare tax (where applicable) are taken out
of the employee’s pay.

9.6 Disability Insurance

VINCI Construction LLC’s disability plans work together to help employees pay their household expenses if they
become disabled and cannot work. Employees who become temporarily disabled for a non-work-related reason
may be eligible for short-term disability (STD) benefits and long-term disability (LTD) benefits.

Disability insurance is an income-protection plan that provides partial paycheck reimbursement for times of serious
illness or injury which leads to total disability. Total disability is defined as the inability to perform any job function
because of the injury or illness. Full-time employees qualify for this coverage. Employees are responsible for
notifying a supervisor of their inability to work due to a disability. Employees must also notify HR of their disability
and expected date of return, so that a claim can be processed in a timely manner.

VINCI Construction LLC may request that an independent medical provider perform an examination. In addition,
the Company may require a medical release form prior to the employee’s returning to work. Any payments
received from worker’s compensation or state disability will result in an equal decrease in disability benefits.
Disability benefits are subject to employment withholding provisions.

9.7 Basic Life and AD&D Insurance

VINCI Construction LLC offers each full-time employee Basic Life/Accidental Death and Dismemberment insurance.
Please contact the HR Department for further details about the plan.

9.8 Employee Assistance Program

All full-time, VINCI Construction LLC employees are eligible to participate in the Employee Assistance Program
(EAP). An EAP is a third-party professional counseling and referral service designed to help employees with
personal, job, or family matters. Professionals will confidentially help employees deal with a wide range of personal
problems such as marital or family problems, alcoholism, and drug abuse, and they can provide legal, financial,
and psychological counseling. It is a free, voluntary, and strictly confidential employee benefit. Employee
accessibility of this program terminates as of the last date of employment with VINCI Construction LLC.

9.9 401(k) Retirement Savings Plan

The VINCI Construction LLC 401(k) Retirement Savings Plan is an excellent way for employees to save for their
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retirement. Employees must meet the eligibility requirements to participate. Eligible employees who do desire to
participate choose a whole percentage of their gross pay to be deducted from their semi-monthly paycheck and
put into a designated 401(k) account. VINCI Construction LLC offers both traditional pre-tax and after-tax (Roth)
salary deferrals to employees. VINCI Construction LLC also provides a matching contribution on employee’s
contributions; these contributions follow the vesting schedule. Details regarding eligibility and vesting are
explained in the Summary Plan Description. Contact HR for detailed information regarding eligibility, employee
contributions, vesting period, employer contributions, and other information.

9.10 Training Program

VINCI Construction LLC offers full-time employees access to an array of courses, training, and certifications. This
program is designed to promote employees’ professional development throughout their tenure with the Company.
Trainings are subject to approval by the HR Department and VINCI Construction LLC management. In general, VINCI
Construction LLC pays for approved trainings. Employees are encouraged to follow the VINCI Academy e-learning.
In situations where an employee is approved for reimbursement for a training or certification beyond these options
and they terminate employment with the Company within 1 year after receiving reimbursement, the Company will
require repayment of paid educational assistance. For specific details on the program, please contact the HR
Department.

9.11 Relocation Assistance

This policy provides a standard procedure for the financial assistance of new hires and transferring employees for
relocation to locations elsewhere in the United States. Under the general provisions of this policy and with prior
approval, a written relocation and repayment agreement will be entered with the new hire or employee. The
provisions of this policy will apply only to assignments and relocations that are planned to exceed twelve (12)
months in duration and where the new hire or employee resides outside the primary location assignment, or more
than fifty (50) miles from the new hire or employee’s current place of residence and assigned work location.

9.12 Workers’ Compensation Insurance

VINCI Construction LLC provides a comprehensive workers’ compensation insurance program at no cost to
employees. This program generally covers injuries and accidents arising out of or sustained in the course of
employment.

Subject to applicable legal requirements, workers’ compensation insurance generally provides benefits after a
short waiting period or, if the employee is hospitalized, immediately. Employees who sustain work-related injuries
or illnesses should inform their supervisor immediately. No matter how minor an on-the-job injury or illness may
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appear; it is important that it be reported immediately. This will enable an eligible employee to qualify for coverage
as quickly as possible. An incident report of injury or illness must be completed and forwarded to HR within 24
hours of an on-the-job injury or illness. An employee’s report should contain as much detail as possible, including
the date, time, and description of the illness or injury, and the names of any witnesses.

Workers’ compensation is solely a monetary benefit and not a leave of absence. Neither VINCI Construction LLC
nor the insurance carrier will be liable for the payment of workers’ compensation benefits for injuries that occur
during an employee’s voluntary participation in any off-duty recreational, social, or athletic activity sponsored by
VINCI Construction LLC.

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10.0 LEAVE

10.1 Holidays

Generally, VINCI Construction LLC observes eleven, paid, annual holidays.

• New Year’s Day.


• Martin Luther King’ Birthday.
• President’s Day.
• Memorial Day.
• Juneteenth.
• Independence Day.
• Labor Day.
• Veterans Day.
• Thanksgiving Day.
• Post-Thanksgiving Day.
• Christmas Day.

The above list is subject to change per business and project requirements. The annual holiday schedule will be
provided by HR department to employees at the end of each year.

Generally, holidays are to be charged in 8-hour increments. In situations where employees need to work during a
holiday due to contract requirements, deliverables, or deadlines, employees may with the prior written approval
of their supervisor float that holiday; however, the holiday must be used by the end of the pay period following the
one in which the holiday fell.

If a designated holiday falls during an eligible employee’s paid absence, holiday pay will be provided instead of the
vacation or sick leave benefit that would otherwise have applied. If eligible non-exempt employees work on a
designated holiday, they will receive holiday pay plus wages at their hourly rate for the hours worked on the
holiday.

To be eligible for any holiday pay, eligible non-exempt employees must work their regularly scheduled workday
before and after the holiday and work the holiday if required (unless the holiday ends or precedes your scheduled
vacation or unless otherwise required by applicable law). Employees on leaves of absence are not eligible for
holiday pay. Paid time off for holidays will not be counted as hours worked for the purposes of determining
overtime in a particular work week.

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10.2 Vacation Leave

Only regular full-time employees are eligible to earn and use paid vacation days as described in this policy.

Vacation time off with pay is available to eligible employees to provide opportunities for rest, relaxation, and
personal pursuits. The amount of paid vacation full-time employees receives each year will increase with the length
of your employment as shown in the following vacation earning schedule:

Tenure Vacation Allowance Accrual Rate (Per


Month)
Up to the 4th year 2 weeks per year 0.83
days
5th – 9th year 3 weeks per year 1.25
days
10th year onward 4 weeks per year 1.67
days

Vacation accrual generally is calculated per fiscal year. The fiscal year is defined as the twelve-month period that
begins January 1st and ends December 31st. Vacation time off begins accruing each month following the
employee’s hire date. Once employees enter an eligible employment classification, they begin to earn paid
vacation time according to the schedule.

Paid vacation can be used in minimum increments of 1 day, unless otherwise authorized in writing. For vacation
requests, written notice should be submitted to your manager for approval no later than two weeks in advance.
Requests will be reviewed based on several factors, including business needs, and staffing requirements. If any
conflicts arise in vacation requests, management will consider department and Company needs to resolve which
employee shall be given time off.

VINCI Construction LLC can require employees to use their paid vacation days in the Company’s discretion (i.e.,
during furloughs, in between project, leave of absence, shutdown, etc.).

Vacation time off is paid at the employee’s base rate at the time of the vacation. Paid vacation does not include
overtime or any special forms of compensation such as incentives, commissions, bonuses, or shift differentials.
Normally, only accrued leave may be taken. Requests for advance vacation pay (for vacation time taken more than
your vacation accrual balance) will be evaluated on a case-by-case basis.

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Employees may carry over the balance of their accrued annual vacation from one calendar year to the next
within the aggregate limit of their annual vacation allowance. The aggregate limit of their annual vacation
allowance is defined as the maximum annual vacation allowance an employee can earn (e.g., as stated in their
offer letter). An employee's vacation balance will be capped once the maximum annual vacation allowance is
reached. Upon separation of employment for any reason, an employee will be paid his accrued but unused
vacation time up to the maximum of his annual vacation allowance.

If a Company-recognized holiday falls within a scheduled vacation, the holiday time off will not be charged against
the employee’s accrued vacation time. Paid vacation time will not be counted as hours worked for the purposes
of determining overtime in a particular work week.

10.3 Sick Leave

Separate from vacation leave, VINCI Construction LLC offers full-time employees 10 full days of paid sick leave at
the beginning of the calendar year in the event of employee sickness, illness, or disability. Employees who are
unable to report to work due to illness or injury should notify their direct supervisor before the scheduled start of
their workday, if possible. The direct supervisor should also be contacted on each additional day of absence or be
provided in advance with the estimated amount of time to be taken. In instances when your direct supervisor is
out of the office you should notify the HR Department.

The Company may, in its sole and absolute discretion, require a doctor’s certificate verifying the necessity for
absence(s) and the specific illness, injury or other disability to which the absence is attributed. Sick leave benefits
will be calculated based on your base pay rate at the time of your absence and will not include any special forms
of compensation, such as incentives, commissions, bonuses, or shift differentials. As an additional condition of
eligibility for sick leave benefits, an employee on an extended absence must apply for any other available
compensation and benefits, such as worker’s compensation or disability insurance. Sick leave benefits will be used
to supplement any payments that you are eligible to receive from state disability insurance, worker’s
compensation, or the Company – provided disability insurance programs. The combination of any such disability
payments and sick leave benefits cannot exceed your normal weekly earnings.

Sick leave benefits are intended solely to provide income protection in the event of illness or injury and may not
be used for any other absence. Once employees have exhausted their sick leave, they may use any remaining
vacation days for further illness. Unused sick leave will not carry over from year to year. Paid sick leave will not be
counted as hours worked for the purposes of determining overtime in a particular work week.

Upon separation of employment for any reason, employees will not be paid for their accrued but unused sick time.

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10.4 Inclement Weather

During any inclement weather situation, the safety of our employees and their families is of the highest priority.
VINCI Construction LLC highly encourages employees to use their best judgement to prioritize safety and well-
being ahead of work responsibilities. However, VINCI Construction LLC will make every effort to maintain normal
working hours during inclement weather conditions. The Company will follow their project’s operating status for
offices at the assignment location.

When an employee is unable to work during any inclement weather situation (e.g., safety concerns, loss of power,
contract does not permit telework, etc.), then employees are encouraged to coordinate with their project
director/manager to agree upon a plan to make up lost hours as contract provisions allow.

10.5 Bereavement Leave

Employees who wish to take time off due to the death of an immediate family member should notify their
supervisor immediately. VINCI Construction LLC defines “immediate family” as the employee’s spouse, parent,
child, or sibling, and the employee’s parents’ in-law. Special consideration will also be given to any other person
whose association with the employee was like any of the above relationships.

Bereavement pay is calculated based on the base pay rate at the time of absence and will not include any special
forms of compensation, such as incentives, commissions, bonuses, or shift differentials. Employees will be required
to provide proof of death in the form of a death certificate or funeral services pamphlet. An employee may receive
up to 3 consecutive, paid days for services due to bereavement.

Bereavement leave will normally be granted unless there are unusual business needs or staffing requirements.
Employees may, with their supervisors’ approval, use any available vacation leave for additional paid time off as
necessary.

10.6 Jury Duty

VINCI Construction LLC understands that occasionally employees are called to serve on a jury, and we encourage
employees to fulfill their civic responsibilities by serving jury duty when required. A jury duty leave of absence will
be granted to a full-time employee who has been notified to serve.

VINCI Construction LLC will provide an employee 3 days of paid leave for jury duty per calendar year. If an employee
goes beyond the 3 days provided by VINCI Construction LLC, the remainder of the jury duty will be unpaid. If
employees are required to serve jury duty beyond the period of paid jury duty leave, they may use any available
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vacation time off or may request an unpaid jury duty leave of absence.

Employees must show the jury duty summons to their supervisor and Human Resources as soon as possible so
that the supervisor may decide to accommodate their absence. Of course, employees are expected to report for
work whenever the court schedule permits.

10.7 Voting

The Company encourages you to exercise your voting privileges in local, state, and national elections. However,
since the polls are open for long periods, you are encouraged to vote before or after regular working hours. If you
are unable to vote in an election during non-working hours, the Company will allow you to take up to two (2) hours
of paid time to vote. You should request time off to vote from your supervisor at least two working days prior to
the election date. Advance notice is required so that the necessary time off can be scheduled at the beginning or
end of the work shift, whichever provides the least disruption to the normal work schedule.

10.8 Court Appearance

If an employee chooses, he or she may use accrued paid vacation leave to receive compensation for a court
appearance-related absence. If employees choose not to use their paid leave, any court attendance time will be
unpaid for nonexempt employees. For exempt employees, leave will be unpaid if permissible under federal and
state laws.

10.9 Crime Victims

When an employee has been identified by local law enforcement authorities as a “victim” of a crime, the Company
will grant a leave of absence from work to permit the employee to attend criminal proceedings relating to the
crime, unless the leave will create an undue hardship on the Company’s operations.

For purposes of this policy, a “crime” means a felony or assault, stalking, sexual battery, maiming, or DUI. A “victim”
may include not only the specific individual who has suffered harm as the result of a crime, but also that person’s
spouse or child, parent, or legal guardian (where the victim is a minor), and spouse, parent, sibling or legal guardian,
where the victim is incapacitated or deceased.

“Criminal proceeding” applies not only to a criminal trial, but to other judicial proceedings, such as the initial
appearance of the suspect, any proceeding in which a negotiated plea is presented to the court, any sentencing
proceeding, and all proceedings relating to probation.

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An employee taking leave under this policy must provide the Company with a copy of a form which the victim
receives from police after being identified as the victim of a crime, and a copy of notices the employee receives of
each scheduled criminal proceeding.

Leave under this policy is unpaid for non-exempt employees. For exempt employees, leave will be unpaid as
permissible under federal and state laws.

10.10 Parental Leave

VINCI Construction LLC will provide employees with ten (10) working days of paid leave during the first year a child
is with the parent. Parental leave will be authorized for childbirth or adoption and may be taken at any agreed-
upon time(s) during the first year following the birth or adoption of the child. A birth certificate may be required
as proof of the event. Employees should notify HR as soon as they can that they will be requesting Parental Leave.

Any Parental Leave not used during the first year following the birth or adoption of the child will not be carried
over into another year and will not be paid out. Unused Parental Leave will not be paid out upon separation.

10.11 Military Leave

If you are called to active military duty or enlist in the uniformed services, you are eligible for unpaid military leave
of absence in accordance with state and federal law. Present your supervisor with a copy of your service papers as
soon as you receive them. To be eligible for military leave, you must provide management with advance notice of
your service obligations unless you are prevented from providing such notice by military necessity or it is otherwise
impossible or unreasonable for you to provide such notice.

During your absence, your length of service accumulates, and your benefits will continue as required by applicable
law. Provided your absence does not exceed applicable statutory limitations, you will retain reemployment rights
and accrue seniority and benefits in accordance with applicable federal and state laws.

If you are required to attend yearly Reserves or National Guard duty, you may apply for an unpaid temporary military
leave of absence not to exceed the number of days allowed by law (including travel). However, if you prefer, you may
use your accrued vacation time for this purpose. You should give your supervisor as much advance notice as possible
so we can ensure proper coverage while you are away.

Please ask management for further information about your eligibility for Military Leave.

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11.0 TIMEKEEPING and PAYROLL

FALSIFICATION OF A TIME RECORD BY AN EMPLOYEE OR FOR ANOTHER EMPLOYEE IS A BREACH OF COMPANY


POLICY AND IS GROUNDS FOR DISCIPLINARY ACTION, UP TO AND INCLUDING TERMINATION OF EMPLOYMENT.

11.1 Fundamentals of Time Reporting

It is the policy of VINCI Construction LLC to comply with applicable laws that require records to be maintained of
the hours worked by our employees. Before starting a new assignment, obtain from the appropriate supervisor
the correct project number (charge code) and the maximum amount of time that may be worked on the
assignment without additional supervisory approval. Any work more than eight (8) hours per day performed by a
non-exempt employee must be approved in advance by the employee’s supervisor. Non-exempt employees must
record all hours worked; they cannot work off the clock.

For salaried employees, monthly timesheets should be prepared for submission to their supervisor mid-month.
For hourly employees, weekly timesheets must be prepared for submission to their supervisor every week.
Managers need to review the timesheets for approval then submit to the Accounting Department in a timely
fashion.

Travel/expense charges and timecard charges should follow the same project. For example, if the purpose of the
travel and/or expense is contract specific, labor hours reported on the timecard during the trip and the expense
report should be coded to the specific project.

11.2 Work Hours

The VINCI Construction LLC office will maintain normal working hours of 8:00 a.m. to 5:00 p.m., Monday through
Friday, with an hour for lunch. Hours may vary depending on work location, job responsibilities, and contract
requirements. Daily and weekly work schedules may be changed from time to time at the discretion of VINCI
Construction LLC to meet the varying conditions of our business. Changes in work schedules will be announced as
far in advance as possible.

For payroll purposes, the workweek begins at 12:01 a.m. Sunday and ends at 12:00 a.m. Saturday.

11.3 Lunch Break

Lunch scheduling and duration are generally left up to the individual departments or locations. Normal break hours

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for lunch are within 11:30 a.m. and 1:30 p.m. Employees are not restricted to the building and may eat elsewhere
provided the normal lunch period permits sufficient time. Every employee is allowed to take up to an hour lunch
break. Lunch breaks, where no work is performed, are not part of the employee’s working time and, therefore
should not be recorded on the timecard.

11.4 Paydays

Employees are paid biweekly with one week in arrears. Paydays will be every other Friday. If a regularly scheduled
payday falls during a holiday, employees will be paid the day before. Employees should review their pay statements
for errors. If they find a mistake, they should report it to the Accounting Department immediately.

11.5 Overtime

In accordance with the Fair Labor Standards Act (FLSA) and applicable state law, non-exempt employees are paid
at the rate of one-and-one-half times an employee’s regular rate for hours worked more than forty (40) hours per
work week, not to include any leave. All overtime must be approved in advance by the employee’s supervisor.

Holiday, vacation, sick, and other paid leave does not count towards the 40 hours worked for overtime purposes.

11.6 Payroll Deductions

As required by federal and state mandatory law, deductions from an employee’s gross earnings will be made for
the following:

• Federal income tax.


• Social Security.
• Medicare tax.
• State income tax (where applicable).
• City tax (where applicable).
• Any court ordered garnishment or levy.
• 401(k) deferral and loan(s).

Any other deduction from pay will not be taken without the written and voluntary authorization of an employee,
where necessary, and in accordance with the applicable state law. Any questions an employee may have about

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his/her paycheck or the deductions made should be addressed to the Accounting Department. Employees will be
required to sign a wage deduction authorization form.

Deductions for Exempt Employees

It is the policy and practice of VINCI Construction LLC to accurately compensate employees and to do so in
compliance with all applicable state and federal laws. To ensure you are paid properly and no improper deductions
are made, you must review your pay stubs promptly to identify and to report all errors.

If you believe a mistake has occurred or if you have any questions, please use the reporting procedure outlined
below.

As an exempt salaried employee, you receive a salary which is intended to compensate you for all hours you work
for the Company. This salary will be established at the time of hire or when you become classified as an exempt
employee. While it may be subject to review and modification from time-to-time, such as during salary review times,
the salary will be a predetermined amount that will not be subject to deductions for variations in the quantity or
quality of the work you perform.

Under federal and state law, your salary is subject to certain deductions. For example, absent contrary state law
requirements, your salary can be reduced for the following reasons:

• Full-day absences for personal reasons.


• Full-day absences for sickness or disability if you have exhausted the paid sick leave available to
you.
• Intermittent absences, including partial-day absences, covered by the federal Family and Medical
Leave Act (if applicable), if you have exhausted other paid leave available to you.
• Full day disciplinary suspensions for infractions of VINCI Construction LLC’s written policies and
procedures.
• To offset amounts received as payment for jury and witness fees or military pay.
• During the first or last week of employment in the event you work less than a full week.
• Any workweek in which you perform no work for the Company.

Your salary also may be reduced for certain types of deductions, such as your portion of health, dental or life
insurance premiums; state, federal or local taxes, social security; or voluntary contributions to a 401(k) or pension
plan.

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In any workweek in which you performed any work, your salary will not be reduced for any of the following
reasons:

• Absences for personal reasons, sickness, or disability.


• Your absence on a holiday when the facility is closed, or because the facility is otherwise closed on
a scheduled workday.
• Absences for jury duty, attendance as a witness, or military leave in any week in which you have
performed any work.
• Any other deductions prohibited by state or federal law.

If you believe you have been subject to any improper deductions, you should immediately report the matter to your
supervisor. If the supervisor is unavailable or if you believe it would be inappropriate to contact that person (or if you
have not received a prompt and fully acceptable reply), you should immediately contact the accounting department
at the Corporate Office. If you are unsure of whom to contact if you have not received a satisfactory response, please
immediately contact the HR department.

Every report will be fully investigated, and corrective action will be taken where appropriate, up to and including
termination for any employee(s) who violates this policy. In addition, the Company will not allow any form of
retaliation against individuals who report alleged violations of this policy or who cooperate in VINCI Construction
LLC’s investigation of such reports. Retaliation is unacceptable, and any form of retaliation in violation of this policy
will result in disciplinary action, up to and including termination.

11.7 Direct Deposit of Payroll

Direct deposit allows each employee to designate one (1) bank account in which to have their paycheck directly
deposited. If an employee elects direct deposit, a direct deposit authorization form must be completed in advance
by the employee. Employees will receive a direct deposit statement, which will contain all the current and year-
to-date information that is normally contained on the paychecks. Employees may make changes to their bank
account at any time during the year if they do so sufficiently in advance of the next regularly scheduled payday.

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12.0 BUSINESS TRAVEL AND GENERAL EXPENSES

The Company will reimburse employees for all reasonable and necessary expenses while traveling on authorized
Company business or entertaining business clients with whom we are in or hope to be in a business relationship.
Employees seeking reimbursement should incur the lowest reasonable expenses. Authorization and approval
methods are described below. Employees must file expense reports per their Project specifications.

12.1 Expense Report Documentation Requirements

Employees must provide the following information with their expense report to be reimbursed for any business-
related meals or entertainment expenditures:

 Receipts for all expenditures. An explanation of the business expense and the names, titles, and
company affiliations of the individuals entertained (in the case of meal/entertainment receipts)
must be documented next to the original receipt. If you affix the receipt(s) to a piece of paper, you
can write the explanation on that.

The following receipts are acceptable:

o Original receipt completed by the vendor, for example—

– Air/Rail – original passenger receipt


– Hotel – receipt from the hotel with itemized expenses
– Car rental – rental agency invoice
– Mileage for use of personal car for specific business trip – Government (e.g. IRS) mileage
rate
– Entertainment – register receipt for all expenses; and
– Meals – itemized register receipts.

Receipts must include the name of the vendor, location, date, and dollar amount. Actual invoice/receipts must be
submitted. Expense reports containing entries that cannot easily be supported by receipts will be rejected. All
expenses must be reported, regardless of how they were paid. Expense reports that are incorrect or incomplete:

 Will be rejected.
 May result in delay or non-reimbursement of specific items.

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Employees can resubmit rejected expense reports when they have all the required documentation. Disregard for
Company policy or altering of receipts can result in disciplinary action up to and including termination.

12.2 Entertainment Expenses

When entertaining business client, employees must keep in mind the Ethics and Anti-Corruption Code of VINCI:

• Invitations (Meals, events - matches, concerts, travel, etc.) given or received are completely prohibited if
the Company is about to enter a contract with the entity that the beneficiary belongs to.
• All entertainment expenses necessitate prior written approval from management.

12.3 Non-reimbursable Expenses

As an example, the following items [non-exhaustive list] will not be reimbursed by VINCI Construction LLC:

 Airline club memberships.


 Airline upgrades.
 Business class for domestic flights or first class for all flights.
 Childcare, babysitting, house-sitting, or pet-sitting/kennel charges.
 Commuting between home and the primary work location.
 Costs incurred by traveler’s failure to cancel travel or hotel reservations in a timely fashion.
 Evening or formal wear expenses.
 Haircuts and personal grooming.
 Passports, vaccinations, and visas when not directly related to business travel.
 Personal entertainment expenses, including in-flight movies, headsets, health club facilities,
hotel pay-per-view movies, in-theater movies, social activities, and related incidental costs.
 Other expenses not directly related to the business travel.

12.4 Responsibility

Employees are responsible for complying with all the requirements for reimbursement of business travel and
general expenses. The manager who approves and signs expense reports is responsible for accurately reviewing
expense reports for compliance. VINCI Construction LLC assumes no obligation to reimburse employees for
expenses that are not in compliance with this policy. The Company’s Chairman must approve in advance any
deviation from this policy.

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13.0 EMPLOYEE CONDUCT

13.1 General Code of Conduct

VINCI Construction LLC does not intend to control the personal lives of its employees. But, because we are in a
business that is based upon client acceptance and trust, each of us, as we represent VINCI Construction LLC in the
workplace, should consistently demonstrate the qualities that will create confidence in us as individuals and the
Company overall. Conduct on the job which could be detrimental to VINCI Construction LLC may, in accordance
with applicable law, be considered sufficient reason for termination of employment.

Employees of VINCI Construction LLC are expected to take their job responsibilities seriously, to recognize and
respect the rights of their employees, and to conduct themselves so as not to endanger others or their property.

Type of behaviors, such as, but not limited to, the ones listed below are sufficient grounds for immediate dismissal.

• Falsification of VINCI Construction LLC records.


• Excessive absenteeism or tardiness.
• Failure to notify your supervisor in the event of absenteeism or tardiness.
• Failure to comply with the duties, responsibilities, and performance standards of the job.
• Timecard violations.
• Refusal to perform lawful work assignment or job duties.
• Possessing, selling, consuming, or being under the influence of alcohol or drugs, narcotics, or controlled
substances on the job.
• Damage or injury to property or personnel.
• Abusive or foul language used against a supervisor, employees, or clients.
• Indecent conduct on the job.
• Theft of property.
• Misappropriation or misuse of the Company’s or any third party’s property.
• Possessing dangerous weapons on VINCI Construction LLC or client premises, either on the employee’s
person or in a vehicle.
• Unauthorized disclosure of confidential or proprietary information obtained by an employee in the
ordinary course of business.
• Fighting, gambling, or horseplay at work.
• Breach of trust or dishonesty.
• Conviction of a felony.
• Violation of an established rule or policy.
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• Conduct violating the Company’s harassment or equal employment opportunity policies.


• Gross negligence.
• Insubordination.

The Company will address violations of this Code of Conduct and any other violations of Company policy on an
individual basis. Pursuant to the Company’s at-will employment policy, the Company reserves the right to impose
whatever form of discipline it chooses, or none, in a particular instance. Disciplinary action may include, but is not
limited to, oral or written warnings, suspension, demotion, or involuntary termination. Nothing in this Handbook
should be construed as a promise of specific treatment in each situation.

For more information, see section 7.4, Business Ethics.

13.2 New Hire Orientation

VINCI Construction LLC prides itself with onboarding new employees to the culture of the organization to facilitate
organizational learning and employee productivity. Each new employee will be notified by HR of the date, time, and
location for the orientation to be conducted. Orientations may be conducted individually or in group settings.
Employees will be expected to complete their new-hire administrative forms which they receive either with their
offer letter or upon their start date. Employees will receive information about the Company and its benefits. Time
spent in orientation is considered paid time, and therefore each employee’s timecard should reflect the time
engaged in the orientation program as paid hours and be coded appropriately.

13.3 Employee Introductory Period

VINCI Construction LLC has a ninety-day (90-day) introductory period for new employees and employees
transitioning to a new role. During this period, employees are expected to learn and understand VINCI Construction
LLC policies, procedures as well as their new position.

The introductory period is just that—an introduction. Completion of the introductory period signifies VINCI
Construction LLC’s hope you will be capable of functioning fully in your position. Completion of the introductory
period is not in any way unqualified acceptance by VINCI Construction LLC of your performance or an assurance of
continued employment. As such, completion of the introductory period does not alter the at-will nature of
employment.

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13.4 Harassment Policy

It is the policy of VINCI Construction LLC to ensure equal employment opportunity without discrimination or
harassment based on an individual’s race, color, religion, sex (including pregnancy, childbirth or related
conditions), sexual orientation, national origin, age, disability, marital status, genetic information, gender identity
or expression, veteran status, or any other category protected by applicable federal, state, or local law— see
section 5.0, Equal Employment Opportunity. VINCI Construction LLC expressly prohibits and will not tolerate any
such discrimination or harassment toward any employee or by any employee of VINCI Construction LLC.
Harassment is considered a form of employee misconduct. Violation of this policy will subject an employee to
disciplinary action up to and including immediate termination of employment.

13.4.a Definitions of Harassment

Sexual harassment constitutes discrimination and is illegal under federal, state, and local laws. For the purposes
of this policy, sexual harassment is defined as unwelcome sexual advances, requests for sexual favors, and other
verbal or physical conduct of a sexual nature when, for example:

(i) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s
employment
(ii) submission to or rejection of such conduct by an individual is used as the basis for employment
decisions affecting such individual; or
(iii) such conduct has the purpose or effect of unreasonably interfering with an individual’s work
performance or creating an intimidating, hostile, or offensive working environment.

Sexual harassment may include a range of subtle and not so subtle behaviors and may involve individuals of the
same or different gender. Depending on the circumstances, these behaviors may include, but are not limited to:
unwanted sexual advances or requests for sexual favors; sexual jokes and innuendo; verbal abuse of a sexual
nature; commentary about an individual’s body, sexual prowess, or sexual deficiencies, leering, catcalls, or
touching; insulting or obscene comments or gestures; display or circulation in the workplace of sexually suggestive
objects or pictures (including through e-mail); and other physical, verbal, or visual conduct of a sexual nature. Sex-
based harassment (i.e., harassment not involving sexual activity or language) may also constitute discrimination if
it is severe or pervasive and directed at employees because of their sex.

Harassment based on any other protected characteristic is also strictly prohibited. Under this policy, harassment
is verbal, visual, or physical conduct that denigrates or shows hostility or aversion toward an individual because of
his/her race, color, religion, national origin, age, disability, marital status, genetic information, gender identity
or expression, veteran status, or any other class of individual protected by applicable law, or that of his/her
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relatives, friends, or associates, and that:

(i) has the purpose or effect of creating an intimidating, hostile, or offensive work environment
(ii) has the purpose or effect of unreasonably interfering with an individual’s work performance; or
(iii) otherwise adversely affects an individual’s employment opportunities.

Harassing conduct includes, but is not limited to epithets, slurs, or negative stereo typing; threatening,
intimidating, or hostile acts; denigrating jokes and display or circulation in the workplace of written or graphic
material that denigrates or shows hostility or aversion toward an individual or group (including through e-mail,
voicemail, chat rooms, Internet use or history, text messages, pictures, images, writings, words, or gestures).

13.4.b Individuals and Conduct Covered

These policies apply to all applicants, employees, vendors, subcontractors, consultants, and any third-party doing
business with VINCI Construction LLC and prohibit harassment, discrimination, and retaliation whether engaged in
by fellow employees, by a supervisor or manager, or by someone not directly connected to VINCI Construction LLC
such as vendors, clients, or others who do business with VINCI Construction LLC.

Conduct prohibited by these policies is unacceptable in the workplace and in any work-related setting outside the
workplace, such as during business trips, business meetings, and business-related social events.

13.4.c Complaint Procedures

VINCI Construction LLC strongly urges the reporting of all incidents of discrimination, harassment, or retaliation,
regardless of the offender’s identity or position. Individuals who believe they have experienced or witnessed
conduct that they believe is contrary to VINCI Construction LLC’s policy or who have concerns about such matters
should file their complaints with their immediate supervisor or any member of the HR Department as soon as
possible. Individuals should not feel obligated to file their complaints with their immediate supervisor first before
bringing the matter to the attention of the HR Department. If the employee makes a complaint under this policy
and has not received a satisfactory response or he or she does not feel comfortable filing the complaint with the
contacts listed in this policy, he or she should contact the Senior Project Manager immediately.

Harassment training, early reporting, and intervention have proven to be the most effective method of resolving
actual or perceived incidents of harassment. Therefore, while no fixed reporting period has been established, VINCI
Construction LLC strongly urges the prompt reporting of complaints or concerns so that rapid and constructive

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action can be taken. VINCI Construction LLC will make every effort to stop alleged harassment but can do so only
with the cooperation of its employees.

The availability of this complaint procedure does not preclude individuals who believe they are being subjected to
harassing conduct from promptly advising the offender that his or her behavior is unwelcome and requesting that
it be discontinued.

13.4.d The Investigation

Any reported allegations of harassment, discrimination, or retaliation will be investigated promptly, thoroughly,
and impartially. The investigation may include individual interviews with the parties involved and, where
necessary, with individuals who may have observed the alleged conduct or may have another relevant knowledge.

Confidentiality will be maintained throughout the investigatory process to the extent consistent with an adequate
investigation and appropriate corrective action; however, confidentially cannot be guaranteed. The employee
making a complaint of harassment under this policy will be informed of the general findings of the investigation.

13.4.e Responsive Action

Misconduct constituting harassment, discrimination, or retaliation will be dealt with promptly and appropriately.
Responsive action may include, for example, training, referral to counseling, monitoring of the offender, and/or
disciplinary action such as warning, reprimand, withholding of a promotion or withholding of pay increase,
reduction of wages, demotion, reassignment, temporary suspension without pay, or termination, as VINCI
Construction LLC it is sole discretion believes appropriate under the circumstances. VINCI Construction LLC
reserves the right to other forms of discipline at its sole discretion.

Individuals who have questions or concerns about these policies should talk with the HR Department.

VINCI Construction LLC’ Business Ethics policy contains additional information regarding avoidance and handling
of harassment in the workplace.

13.5 Drug-Free Workplace Policy

VINCI Construction LLC has a strong commitment to its employees to provide a safe and productive work
environment and to establish programs that promote high standards of employee health. This policy applies to all
full-time and part-time employees and temporary workers of VINCI Construction LLC as well as to all consultants,

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vendors, and other individuals providing services to the Company at any time on the premises, while engaged in
business for the Company, or while driving a Company vehicle or driving a personal vehicle for Company business.

VINCI Construction LLC prohibits the use, purchase, sale, possession, manufacture, distribution, concealment, or
transportation on its premises, facilities, or workplace or while on business travel of any of the following:

• Alcoholic beverages or alcoholic beverage containers.


• Intoxicants or narcotics.
• Illegal or unauthorized drugs or other controlled substances.
• Contraband, including firearms, ammunition, explosives, and weapons.
• Illicit drug equipment or paraphernalia.

VINCI Construction LLC employees must not report for duty under the influence of any drug, alcoholic beverage,
intoxicant, narcotic, or other substance (including legally prescribed drugs and medicines) that will in any way
adversely affect the safety of themselves or others on the job.

The following conditions must be met to possess and use prescription drugs or over-the-counter medications that
have the potential to impair safety or performance:

• Prescription drugs must be prescribed by a licensed physician for the person in possession of the drugs.
• The prescription must be filled by a licensed pharmacist for the person possessing the drugs.
• The individual must notify his supervisor if he or she will be using impairment- causing prescription drugs
or over-the-counter medications or such drugs or medication that may pose safety concerns, and
appropriate steps must be taken to discuss an accommodation, including but not limited to, removal from
work for the period of possible impairment.

Entry into or presence on company premises, facility, or workplace by any person is conditioned upon the
company’s right to search that person and his or her property for any substances named in this policy. The
employee’s property may include, but is not limited to, the following: wallets, purses, lockers, baggage, offices,
desks, toolboxes, clothing, and vehicles. An employee’s refusal to consent to a search or inspection when
requested by the company constitutes a violation of this policy and – as with other violations of this policy – is
grounds for adverse employment action, up to and including termination of employment.

Manufacture, distribution, dispensation, possession, or use of any intoxicant, narcotic, illegal or unlawful drug,
alcohol, or controlled substance while on company premises is strictly prohibited. These activities constitute
serious violations of company rules, jeopardize the company, and can create situations that are unsafe or that

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substantially interfere with job performance. Employees in violation of the policy are subject to appropriate
disciplinary action, up to and including termination of employment. Additionally, VINCI Construction LLC reserves
the right to require an employee to undergo a medical evaluation under appropriate circumstances, in accordance
with applicable law.

The company strongly encourages employees who believe that they have a problem with alcohol or drugs – legal
or illegal – to seek assistance before a violation of this policy is found. For those employees who self-identify a
substance-abuse problem to the company, sources of help may be provided. The employee would be referred for
a medical assessment, possible counseling and rehabilitation, and possible re-testing during and after
rehabilitation, and would − at the company’s sole discretion − be subject to continued employment.

The company maintains a policy of non-discrimination and will endeavor to make reasonable accommodations to
assist individuals recovering from substance and alcohol dependencies, and those who have a medical history
which reflects treatment for substance abuse conditions. However, employees may not request an
accommodation to avoid discipline for a policy violation.

Consistent with the requirements of the Drug-Free Workplace Act of 1988, the company’s employees working on
federal government contracts must notify the HR Department of any criminal drug statute conviction for a violation
occurring in the workplace no later than five days after such conviction.

13.6 Drug Testing

Employees of VINCI Construction LLC may be required to undergo a drug and/or alcohol test as a condition of
continued employment as directed by the company, at its sole discretion, consistent with applicable law. An
employee's refusal to submit to testing; failure to fully cooperate in the testing process; attempt to tamper with,
substitute for, adulterate, dilute, or otherwise falsify a test sample; and/or any other conduct which would
intentionally prevent or compromise a valid test result will be considered insubordination and will result in
termination of employment.

Drug and alcohol tests may be administered at the discretion of the Company under the following conditions:

• A requirement of the contract under which the employee is working


• On a for-case basis, such as if an employee shows signs of impairment on the job
• On a universal, neutral, random-selection basis
• Reasonable suspicion
• After any accident under reasonable suspicion, during and post-rehabilitation, including return-to-duty
testing; and as otherwise deemed necessary and appropriate by the Company.
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Any employee whose drug test is positive will be in violation of this policy and will have his or her employment
terminated. An employee whose alcohol test is positive will be in violation of this policy, and will be subject to
adverse employment action, up to and including termination of employment.

13.7 Electronic Communication

VINCI Construction LLC provides a variety of electronic communications systems for use in carrying out its business.
In keeping with federal, state, and local laws governing the use of such systems, all software, documentation, or
electronically transmitted data used by or developed with the aid of the VINCI Construction LLC computing
resources are the property of VINCI Construction LLC and can only be used in connection with performing business
functions.

The e-mail, voice mail, and computer systems provided for employee use are the exclusive property of VINCI
Construction LLC and/or its affiliated entities. Anything generated using these systems is the property of VINCI
Construction LLC, even when created using a personal password. Users should understand that electronic
communications may be saved through the backup system and may continue to exist even though the user deletes
it from the user’s own computer. Employees have no right or expectation of privacy with respect to any matter
stored in, created by, received by, or sent over VINCI Construction LLC’s e-mail, voice mail, or computer systems
including personal e-mail and documents viewed, created, or received on a VINCI Construction LLC computer or
other device owned by the company.

The company’s policy prohibiting all types of harassment applies to the use of the company’s electronic
communications systems, including Internet access. No one may use electronic communications in a manner that
may be construed by others as harassment based on race, national origin, sex, sexual orientation, age, disability,
religious beliefs, or any other characteristic protected by applicable federal, state or local law.

Information stored on electronic media, portable devices, and computers is solely the property of VINCI
Construction LLC and protected in accordance with the Information Security Policy. Employees should immediately
report theft, loss, or unauthorized disclosure of confidential information. Employees are only allowed to access
the information that has been authorized for their specific job role. VINCI Construction LLC management can
change access authorization as required.

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It is understood that VINCI Construction LLC may monitor activity on any hardware or software asset or network
system and that any violations of VINCI Construction LLC’s policies will result in disciplinary action up to and
including termination of employment or other legal action.

13.8 Internet Usage

Access to the Internet has been provided to employees for use in performing their jobs and for the benefit of VINCI
Construction LLC and its clients. Use of the Internet, however, must be tempered with common sense and good
judgment.

Acceptable Uses of the Internet. Employees accessing the Internet during work hours are representing VINCI
Construction LLC. Employees are responsible for ensuring that the Internet is used in an effective, ethical, and
lawful manner in the course of their employment.

Unacceptable Use of the Internet. Each employee is responsible for the content of all text, audio, or images that
they place, send, view, or receive over the Internet. The following activities are not permitted using company
resources or on company time:

• Using the internet for personal gain or advancement of individual views.


• Violating the rights of any person or company protected by copyright, trade secret, patent, or other
intellectual property, similar laws, or regulations.
• Using unauthorized peer-to-peer networking or file sharing.
• Downloading and/or installing unauthorized software, games, or entertainment software.
• Exporting software, technical information, encryption, or software technology in violation of
international or regional export control laws.
• Using the Internet or computer system in any way that violates VINCI Construction LLC’s Harassment
Policy (located within this Handbook). Violations of policy may result in disciplinary action up to and
including termination.
• Using or accessing copyrighted material, classified information, or distributing controlled or classified
information without approval.
• Intentionally introducing malicious software or hardware.
• Disrupting or intercepting network communication without approval.
• Providing proprietary company information to external parties without approval.

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13.9 Use of the Company or Client Computer System

It is the policy of VINCI Construction LLC that the use of computers and software belonging to VINCI Construction
LLC, or our clients are limited solely to appropriate business use. Upon termination of employment, or when
requested by management, employees must return all company property, equipment, work products, and
documents in their possession or control.

13.10 Use of Cellular Phones

While at work, employees are to exercise the same discretion in using personal cellular/smart phones as they do
for company phones. Excessive personal calls, texts, and e-mails during the workday, regardless of the phone used,
can interfere with employee productivity and be distracting to others. Flexibility will be provided in circumstances
demanding immediate attention.

13.10.a Safety Issues for Cellular Phone Use

Employees whose job responsibilities include regular or occasional driving and who use their cell phone for
business are expected not to use their phone while driving, in accordance with applicable law. Safety must come
before all other concerns. Regardless of the circumstances, including slow or stopped traffic, employees are
strongly encouraged to pull off to the side of the road and safely stop the vehicle before placing or accepting a call.
Special care should be taken in situations where there is traffic, inclement weather, or the employee is driving in
an unfamiliar area.

Texting or email while driving is always prohibited. Employees whose job responsibilities do not specifically include
driving as an essential function but who are issued a cell phone for business use are also expected to abide by these
provisions. Under no circumstances are employees allowed to place themselves at risk to fulfill business needs.
Employees who are charged with traffic violations resulting from the use of their phone while driving will be solely
responsible for all liabilities that result from such actions.

In many instances, personal cellular phones/cellular picture phones will not be allowed on client sites. The
company will not be liable for the loss of personal cellular phones brought into the workplace.

Violations of this policy will be subject to disciplinary action up to and including termination of employment.

13.11 Violence Prevention in the Workplace

VINCI Construction LLC is committed to preventing workplace violence and to maintaining a safe work
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environment. Therefore, the Company has adopted the following guidelines to deal with intimidation, harassment,
or other threats of (or actual) violence that may occur during business hours or on its premises.

All employees, including temporary employees, should be always treated with courtesy and respect. Employees
are expected to refrain from fighting, horseplay, or other conduct that may be dangerous to others.

Conduct that threatens, intimidates, coerces, or harasses another employee, a client, a member of the public, or
anyone else affiliated with or doing business with VINCI Construction LLC at any time, when performing VINCI
Construction LLC duties or on VINCI Construction LLC premises, will not be tolerated. This prohibition includes all
acts of harassment, including harassment that is in violation of our Equal Employment Opportunity policy (see
section 5.0). For purposes of this policy, a threat includes any verbal or physical harassment or abuse, attempts to
intimidate or to instill fear in others, menacing gestures, bringing weapons to the workplace, stalking, or any other
hostile, aggressive, injurious and/or destructive actions undertaken for the purpose of domination or intimidation.

Employees should report all threats of (or actual) violence, both direct and indirect, as soon as possible to their
immediate supervisor or any other member of management. This includes threats by employees as well as threats
by clients, vendors, solicitors, or other members of the public. When reporting a threat of violence, the employee
should be as specific and detailed as possible.

All suspicious individuals or activities should also be reported as soon as possible to a supervisor. Employees should
not place themselves in peril. VINCI Construction LLC promptly and thoroughly investigate all reports of threats of
(or actual) violence and of suspicious individuals or activities. To maintain workplace safety and the integrity of its
investigation, VINCI Construction LLC may suspend employees, either with or without pay, pending investigation.

Anyone determined to be responsible for threats of (or actual) violence or other conduct that is in violation of
these guidelines will be subject to prompt disciplinary action up to and including termination of employment.

VINCI Construction LLC encourages employees to bring their disputes or differences with other employees to the
attention of their supervisors or the HR Department before the situation escalates into potential violence. VINCI
Construction LLC is willing to assist in the resolution of employee disputes and will not discipline employees for
raising legitimate safety concerns.

13.12 Smoking Policy

It is our intent to provide a safe, healthful, and non-distracting work environment. To provide this environment as
well as comply with government regulations, VINCI Construction LLC has prohibited smoking

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throughout its workplace. This includes tobacco/clove cigarettes, cigars, pipes, chewing tobacco, and electronic
cigarettes. However, the patch, lozenges, and nicotine gums when used appropriately are considered acceptable
items to be used during standard work hours. Employees who wish to partake in tobacco or nicotine-based
products must leave the building during their scheduled break times and use only designated areas outside which
have appropriate disposal receptacles.

Any questions regarding the smoking policy should be directed to the HR Department.

13.13 Attendance

We expect regular attendance from our employees. Employees are expected to be at work on time each day, fully
able and ready to work. If employees find it necessary to be absent or tardy for any reason, it is the employees’
responsibility to notify their supervisor prior to the beginning of their workday. If employees are absent more than
one (1) day, they must notify their supervisor each day of their absence. Failure to comply with this Policy warrants
disciplinary action, up to and including termination of employment. If employees are absent three (3) or more
consecutive workdays due to the illness of the employee or a family member, or have a pattern of absence, they
may be required to provide their supervisor with a doctor’s statement. Failure to notify their supervisor of their
absence for the three (3) consecutive workdays is considered job abandonment, and such employees are deemed
to have voluntarily resigned their employment. On the fourth day, notice of termination will be sent to the
employee’s last known address on record.

Employees may not leave work before the end of the work shift without prior permission of their supervisor.
If employees find it necessary to be absent or tardy for any reason, it is the employees’ responsibility to notify
their supervisor prior to the beginning of their workday
The company is committed to complying with all federal, state, and local laws providing you with the right to be
away from work. All aspects of this attendance policy will be interpreted and applied to ensure compliance with
these laws. Any unscheduled absence, tardiness or other occurrence that is protected by federal, state, or local
law will not count against an employee under these attendance guidelines or otherwise.

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13.14 Teleworking

Teleworking is the practice of working at home or at a site near the home instead of physically traveling to a central
workplace. It is a work alternative that VINCI Construction LLC may permit to some employees at its sole discretion
when it would benefit both the company and the employee. The decision to approve a telecommuting
arrangement will be based on factors such as position and job duties, performance history, related work skills, and
the impact on the organization.

The employee’s compensation, benefits, work status, work responsibilities, and the amount of time the employee
is expected to work per day or per pay period will not change due to participation in the teleworking program
(unless otherwise agreed upon in writing). The employee’s at-home work hours will conform to a schedule agreed
upon by the employee and his or her supervisor. If such a schedule has not been agreed upon, the employee’s
work hours will be assumed to be the same as they were before the employee began teleworking. Changes to this
schedule must be reviewed and approved in writing in advance by the employee’s supervisor.

All employee requests to telework must be reviewed by their immediate supervisor and approved by project
management and/ or approved by VINCI Construction LLC management. Teleworking is an alternative method of
meeting the needs of the organization and is not a universal employee benefit. As such, VINCI Construction LLC has
the right to refuse to make teleworking available to an employee and to terminate a teleworking arrangement at
any time. Teleworking in no way changes the at-will nature of an employee’s employment or the other terms and
conditions of employment with the company.

13.15 Dress and Appearance

Discretion in style of dress and behavior is essential to the efficient operation of VINCI Construction LLC. Employees
are, therefore, required to dress in appropriate business attire and to have a professional, businesslike manner.
Employees should use good judgment in their choice of work clothes and remember to conduct themselves at all
times in a way that best represents themselves and the company. Employees should avoid extremes in dress.

VINCI Construction LLC dress and appearance standards are based on comfort, productivity, health, safety, and
applicable to the professional services industry. Specific articles of clothing, dress styles, or grooming fashions may
be prohibited if it contributes to an unsafe work environment.

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Shirts and blouses, unless designed to be worn out, should be tucked in and buttoned at all times. Clothing will be
clean and free from unsightly stains and tears. Facial hair, beards, and mustaches must be neat and well groomed.
Be aware that people may be sensitive to scents, so use perfumes and colognes in moderation.

VINCI Construction LLC is confident employees will use their best judgment in following this policy, particularly
those employees working off-site or with the client routinely. This is not an all-inclusive list; thus, management
reserves the right to determine appropriateness. A rule of thumb: if in doubt, don’t wear it.

When an employee violates the dress and appearance policy, counseling and corrective action may occur, up to
and including termination.

13.16 Employer Information and Property

The protection of VINCI Construction LLC’s business information, property, and all other company assets are vital
to the interests and success of VINCI Construction LLC. No VINCI Construction LLC related information or property,
including without limitation documents, files, records, computer files, equipment, office supplies, or similar
materials, may be removed from the company’s premises, except as required in the ordinary course of performing
company business. In addition, when an employee leaves VINCI Construction LLC or upon the request of
management, the employee must return to the company all VINCI Construction LLC related or client/customer
related information and property that the employee has in his or her possession, including without limitation
documents, files, records, manuals, information stored on a personal computer or on a computer disc, supplies,
and equipment or office supplies.

Upon receiving company equipment such as laptops or smart phones, employees will be provided with an
Agreement to Return and Care for Company Equipment. In case of lost, stolen, or misplaced equipment, you must
immediately report this to your manager and the HR department. In addition, the Company will proceed,
depending on case-to-case basis, with the following disciplinary actions:

1st offense – the employee will receive a verbal warning


2nd offense – the employee will receive a written disciplinary warning
3rd offense – may result in further disciplinary action, up to and including termination

Violation of this policy is a serious offense and will result in appropriate disciplinary action, up to and including
termination of employment and may also be subject to civil and or criminal penalties. For additional details please
review the Information Security Policy.

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13.17 Workplace Etiquette

VINCI Construction LLC strives to maintain a positive work environment where employees treat each other with
respect and courtesy. Sometimes issues arise when employees are unaware that their behavior in the workplace
may be disruptive or annoying to others. Many of these day-to-day issues can be addressed by politely talking with
a co-worker to bring the perceived problem to their attention. In most cases, common sense will dictate an
appropriate resolution.

VINCI Construction LLC encourages all employees to keep an open mind and graciously accept constructive
feedback or a request to change behavior that may be affecting another employee’s ability to concentrate and be
productive.

The following workplace etiquette guidelines are not necessarily intended to be hard and fast work rules with
disciplinary consequences. They are simply suggestions for appropriate workplace behavior to help everyone be
more conscientious and considerate of co-workers and the work environment. Employees should contact their
supervisor or HR if they have comments, concerns, or suggestions regarding these workplace etiquette guidelines.

• Avoid public accusations or criticisms of other employees. Employees should address such issues
privately with those involved or their supervisor.
• Be conscious of how voices travel and try to speak softly when talking on the phone or to others in open
areas.
• Keep socializing to a minimum and try to conduct conversations in areas where the noise will not be
distracting to others.
• Minimize talking between workspaces or over cubicle walls. Instead, conduct conversations with others
in their workspace.
• Refrain from using inappropriate language (i.e., swearing).
• Avoid discussions of personal life and issues in conversations that can be overheard.
• Monitor the volume when listening to music, voice mail, or a speakerphone that others can hear.
• Employees should clean up after themselves.

13.18 Internal Complaint Procedures

To foster sound employee-employer relations through communications and reconciliation of work-related


problems, VINCI Construction LLC provides employees with the following procedures for expressing employment
related concerns. In situations where employees feel a complaint is in order, the following steps should be taken:

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• Employees who believe that they have a legitimate work-related complaint are encouraged to first
attempt to resolve the issue(s) through discussions with their immediate supervisor.
• If the situation is not promptly resolved by talking with the immediate supervisor, or the employee does
not feel comfortable discussing it with the immediate supervisor, it should be brought to the attention of
the next level supervisor or the HR Department in writing. The company will attempt to resolve the
complaint within a reasonable period while preserving the confidentiality and privacy of those involved
to the extent feasible.

This policy does not apply to termination decisions or claims involving perceived violations of the company’s equal

employment opportunity and harassment policies or any other policies in which the company has established
separate reporting procedures. Such claims should be reported immediately and, in the manner, set forth in the
applicable company policy, and will be addressed in accordance with the provisions of the applicable policy.

13.19 Employment Termination

Separation of employment from VINCI Construction LLC may result because of a resignation, retirement, release,
furlough, layoff or reduction in force, or an employee’s death.

Since employment with VINCI Construction LLC is based on mutual consent, both the employee and VINCI
Construction LLC have the right to terminate employment at will, with or without notice, for any reason not
prohibited by state, local, or federal law, or for no reason at all. However, the company prefers that the employee
provide at least two (2) weeks’ notices in writing to their immediate supervisor and HR.

Any employee who voluntarily chooses not to return to work for a period of three (3) consecutive scheduled
workdays without approval and appropriate notification may be considered to have abandoned his or her
employment and may be considered a voluntary resignation. Employees who are voluntarily separating from their
employment from VINCI Construction LLC may not extend their final working day by using paid vacation, sick or a
holiday. Their final working day must be a worked day.

HR will generally schedule exit interviews at the time of employment. The exit interview will afford an opportunity
to discuss such issues as employee benefits, repayment of outstanding debts to VINCI Construction LLC, or return
of Company-owned property. Suggestions, complaints, and questions can also be voiced.

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13.20 Death of an Employee

Because the death of an employee is a tragic occurrence, the Company will make a concerted effort to help the
bereaved parties and minimize the suffering and loss. Therefore, upon being notified of the death of an employee,
the supervisor will immediately inform the CEO who will coordinate payment of insurance and other benefits with
the Human Resources Manager. In order to provide monetary continuity to your beneficiary (as named under the
life insurance policy), the Company will continue to pay the deceased employee’s salary for a period of three (3)
months to their named beneficiary, subject to all withholdings required by law.

13.21 Health and Safety Policy

VINCI Construction LLC is committed to providing a safe and healthful working environment. The company makes
every effort to comply with relevant federal and state occupational health and safety laws and to develop the best
feasible operations, procedures, technologies, and programs conducive to such an environment.

VINCI Construction LLC’s policy is aimed at minimizing the exposure of our employees, clients, and other visitors
to our facilities to health or safety risks. To accomplish this objective, all VINCI Construction LLC employees are
expected to work diligently to maintain safe and healthful working conditions and adhere to proper operating
practices and procedures designed to prevent injuries and illnesses.

The responsibility of all employees of VINCI Construction LLC does in this regard include:

• Exercising maximum care and good judgment at all times to prevent accidents and injuries.
• Reporting all injuries (no matter how slight) to supervisors.
• Seeking first aid for all injuries regardless of how minor.
• Reporting unsafe conditions, equipment, or practices to supervisory personnel.
• Using safety equipment provided by the company at all times.
• Observing conscientiously all safety rules and regulations at all times.
• Notifying their supervisors before beginning of the workday of any medication they are taking that may
cause drowsiness or other side effects that could cause any safety concerns, including but not limited to,
leading to injury to them and their co-workers.

Employees are responsible for acceptance of all safety rules and regulations and for continuously practicing
safety while performing their duties.

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13.22 Visitors in the Workplace

For safety, insurance, and other business considerations, only authorized visitors are allowed in the workplace.
When deciding for visitors, employees should request that visitors enter through the main reception area and sign
in and sign out at the front desk. Employees should be aware that visitors must follow their work site location’s
privacy and safety guidelines.

13.23 General Safety Rules

Employees should follow these general rules:

• Never move furniture, boxes, or equipment unless their supervisor has told them to do so and given
them appropriate lifting instructions.
• Get help when moving items that are either too heavy or too large to move themselves.

• Arrange electrical and phone cords so that they are not in a traffic path.
• Arrange file drawers so that the most weight is in the lower portion of the cabinet.
• Open one drawer at a time on file cabinets so that cabinets will remain balanced and will not fall over.
• Never operate equipment that they have not been trained on or that they are not authorized to use.
• Make certain that all safety guards are in place prior to operating any equipment.
• Use all safety equipment that has been provided for their job.
• Keep all aisles, halls, and stairways clear of boxes, file cabinets, or any other materials that would reduce
the traffic path.
• Stack materials neatly so that the stacks are stable.
• Know how to handle any hazardous materials with which they may work.
• If a fire alarm sounds, leave the building immediately. Once outside, stay with a supervisor or the
person in charge of their area until notified to do otherwise.
• Do not participate in horseplay. Do not run-on company premises—always walk.
• Clean up spilled liquids immediately.
• Use good common sense. Employees who are unsure of what to do in a situation should ask their
supervisor.

Your supervisor will inform you of any additional safety rules that apply to your particular job or work location.

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13.24 Workplace Security

VINCI Construction LLC maintains and receives confidential information on a regular basis. It is important to take
precautions to protect that information and the staff. Employees must be alert and aware of any potential dangers
to themselves or their coworkers and take every precaution to ensure that their surroundings are safe and secure.

Guard personal belongings and company property. Report any suspicious activity to a supervisor immediately.

13.25 On-the-Job Injuries

Maintaining a safe work environment requires the continuous cooperation of all employees. The company strongly
encourages employees to communicate with fellow employees and their supervisor regarding safety issues.

All employees will be provided care, first-aid, and emergency assistance, as required, for injuries or illness while
on VINCI Construction LLC premises. Employees should contact their supervisor, the nearest supervisor, and/or
911 in the event of an accident or emergency. When a fire alarm or other emergency alert system goes off, proceed
quickly and calmly to the nearest exit. Once the building has been evacuated, only authorized emergency
personnel or the police may authorize employees to reenter.

If an employee is injured on the job, VINCI Construction LLC provides coverage and protection in accordance with
the applicable state Workers’ Compensation law. When an injury is sustained while at work (no matter how slight),
it must be reported immediately to the employee’s supervisor, who in turn will notify HR of the incident.

Failure to report accidents is a serious matter as it may delay or preclude an employee’s coverage under Workers’
Compensation. See additional information in the Workers’ Compensation policy, section 9.11.

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APPENDIX A. ETHICS HOTLINE POLICY

This policy applies to all VINCI employees, including part time, temporary, and contract employees. NA-VCL-
QHSE-NOT-00004-B-Ethics & Compliance.

A.1 Purpose

VINCI is committed to the highest possible standards of ethical, moral, and legal business conduct. In conjunction
with this commitment and VINCI’s commitment to open communication, the company provides an avenue for
employees to raise concerns with a reassurance that they will be protected from reprisals or victimization for
whistleblowing in good faith. However, if employees feel that their anonymity is not required then they should
follow our existing grievance procedure.

A.2 Policy

The company provides employees the option to anonymously report, through an ethics hotline, serious concerns
that could have a large impact on VINCI, such as actions that

• May lead to incorrect financial reporting


• Are unlawful
• Are not in line with company policy, including the Code of Business Conduct; or
• Otherwise amount to serious improper conduct.

Regular business matters that do not require anonymity should be directed to the employee’s supervisor and are
not addressed by this policy.

See NA-VCL-QHSE-NOT-00004-B-Ethics & Compliance.

A.3 Safeguards

A.3.a Harassment or Victimization

Harassment or victimization of individuals submitting hotline reports will not be tolerated.

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A.3.b Confidentiality

Every effort will be made to protect the reporter’s identity by our hotline vendor. Please note that the information
provided in a hotline report may be the basis of an internal and/or external investigation by our company into the
issue being reported. It is possible that as a result of the information provided in a report the reporter’s identity
may become known to us during the course of our investigation.

A.3.c Anonymous Allegations

The policy allows employees to remain anonymous at their option. Concerns expressed anonymously will be
investigated, to the extent possible based on the information provided.

A.3.d Malicious Allegations

Malicious allegations may result in disciplinary action.

A.4 Procedures

A.4.a Reporting

See NA-VCL-QHSE-NOT-00004-B-Ethics & Compliance.

A.4.b Timing

The earlier a concern is expressed, the easier it is for us to take action.

A.4.c Evidence

Although you are not expected to prove the truth of an allegation, employees submitting a report need to
demonstrate in their hotline report that there are sufficient grounds for concern.

A.5 How the Report Will Be Handled

See NA-VCL-QHSE-NOT-00004-B-Ethics & Compliance.

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A.5.a Initial Inquiries

Initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should
take. Some concerns may be resolved by agreed upon action and not need an investigation.

A.5.b Feedback to Reporter

Whether reported directly to VINCI personnel or through the hotline, the individual submitting a report will be
given the opportunity to receive follow-up on their concern:

 Acknowledging that the concern was received


 Indicating how the matter will be dealt with
 Giving an estimate of the time that it will take for a final response
 Telling them whether initial inquiries have been made
 Telling them whether further investigations will follow, and if not, why not.

A.5.c Further Information

The amount of contact between the individual submitting a report and the body investigating the concern will
depend on the nature of the issue, the clarity of information provided, and whether the employee remains
accessible for follow-up. Further information may be sought from the reporter.

A.5.d Outcome of an Investigation

At the discretion of the company and subject to legal and other constraints the reporter may be entitled to receive
general information about the outcome of an investigation.

VINCI reserves the right to modify or amend this policy at any time as it may deem necessary.

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APPENDIX B. HUMAN RIGHTS POLICY

Here at VINCI, we believe “we have a duty everywhere to respect human rights”. Human rights are rights inherent
to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. Human
rights include the right to life and liberty, freedom from slavery and torture, freedom of opinion and expression
and the right to work and education. Labor migration, recruitment practices, working conditions, living conditions,
human rights practices in the value chain and local communities are also considered human rights. The attached
Human Rights Guide and Appendix provide further detail of these areas and more.

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EMPLOYEE HANDBOOK ACKNOWLEDGMENT

A copy of this page must be on file for every VINCI Construction LLC employee. This form can be signed
electronically or by hand. Forms signed electronically should be completed using an electronic source or e-mailed
directly to vcllc.hr@vinci-construction.com. Forms completed by hand should be mailed to:

VINCI Construction LLC


Attn: Human Resources Department
2331 Mill Road, Suite 501
Alexandria, VA 22314

I have received a copy of the VINCI Construction LLC Employee Handbook, including the incorporated Appendix
(“Handbook”), and I acknowledge that the information, policies, and benefits described in the Handbook are
subject to change and that revisions to the Handbook may occur. I understand and accept that my employment
with the company is at-will. I have the right to resign at any time with or without reason, just as VINCI Construction
LLC may terminate my employment at any time with or without cause or notice, subject to applicable laws. I
understand that such revisions may supersede, modify, or eliminate existing policies and that only the President
or the President’s designee has the authority to revise the Handbook or any policy it references, including the
parties right to terminate employment at will, which may only be modified by an express written agreement signed
by the President of the company. I further understand that such revision must be in writing to be effective. I
understand that it is my responsibility to read and comply with the policies contained in this Handbook and any
revisions to it.

Edwin Perez
EMPLOYEE’S NAME (TYPED OR PRINTED)

EMPLOYEE’S SIGNATURE

DATE

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