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JCB NORTH AMERICA – HUMAN RESOURCES

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TABLE OF CONTENTS

INTRODUCTION............................................................................................................................................................................. 9

DISCLAIMER 11

ACKNOWLEDGEMENT & RECEIPT OF UNDERSTANDING 11

SECTION 1 - CODE OF CONDUCT & ETHICS 12

SECTION 2 - GENERAL EMPLOYMENT 12

2.1 Equal Employment Opportunity Statement 12

2.2 Americans with Disabilities Act (ADA) and the ADA Amendments Act (ADAAA) 13

2.3 Conflict of Interest 13

2.4 Relations with Competitors 13

2.5 Reporting Violations 14

2.6 Safety and Environmental Concerns 14

2.7 Copyrights, Trademarks and Patents 14

2.8 Accounting and Financial Reporting 14

2.9 Use of Company Property, Funds and Assets 14

2.10 Dealings with Government Officials 14

2.11 Eligibility for Employment - Immigration and Naturalization 14

2.12 Eligibility for Employment - Background 15

2.13 Employment Verification 15

2.14 Organizational Promotion and Transfer Policy 16

2.15 MVR/Driving Records 16

2.16 Employee Relations Philosophy 16

2.17 Open Door Policy 16

SECTION 3 - WORK SCHEDULE & ATTENDANCE 17

3.1 Work Schedule 17

3.2 Hours of Operation 17

3.3 Attendance Policy – JCB, Inc. 17

3.4 Inclement Weather/Emergency 18

3.5 Meal & Rest Periods 18

SECTION 4 - TIMEKEEPING 19

4.1 Maintaining Time Records 19

4.2 Editing Time Records 19

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4.3 Human Resources Information System (HRIS) - Dayforce 19

SECTION 5 - COMPENSATION 20

5.1 Pay Schedule 20

5.2 Payment of Wages 20

5.3 Employee Classification 20

5.4 Overtime 20

SECTION 6 - EMPLOYEE BENEFITS 21

6.1 Holidays 21

6.2 Paid Time Off 22

6.3 Bereavement Leave 23

6.4 Jury Duty/Witness Leave 24

6.5 Voting Leave 24

6.6. Election Leave 24

6.7 Employer Provided Insurance Benefits 24

6.8 Retirement Plan - 401k 24

6.9 Tuition Assistance 25

6.10 Employee Assistance Program 25

SECTION 7 - COMPANY PROPERTY AND SOCIAL MEDIA 26

7.1 Introduction 26

7.2 Electronic Communication and Internet Use 26

7.3 Social Media 26

7.4 Company Equipment & Property 27

7.5 Return of Company Issued Equipment and Property 27

SECTION 8 - GENERAL EMPLOYMENT POLICIES 27

8.1 Confidentiality of Company Information 27

8.2 Solicitations, Distributions and Posting of Materials 28

8.3 Office Appearance Policy 28

8.4 Outside Employment 28

8.5 Employment of Relatives and Personal Relationships 29

8.6 Relocation Costs & Agreement Terms 29

8.7 Employee Referrals 29

8.8 Introductory Review Period 29

8.9 Solicitation and Distribution of Literature 30


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8.10 Resignation 30

8.11 Employee Records 30

8.13 Rehire Status 30

SECTION 9 - EMPLOYEE CONDUCT AND POLICIES 31

9.1 Employee Conduct 31

9.2 Dress Code - Appropriate Attire, Grooming and Uniform Policy 31

9.3 Uniform Policy - Administrative & Office 32

9.4 Uniform Policy - Manufacturing 32

9.5 Safety & Uniforms 32

9.6 Smoke & Tobacco Free Workplace 33

9.7 Falsification of Information 33

9.8 Performance Guidelines 34

9.9 Corrective Action Program 34

SECTION 10 - ANTI-HARASSMENT POLICY 35

10.1 Introduction 35

SECTION 11 - TIME OFF & LEAVES OF ABSENCES 36

11.1 General Policy 36

11.2 Family and Medical Leave Act ("FMLA") - Eligibility 37

11.3 Qualifying Exigency Leave 38

11.4 Military Caregiver Leave 38

11.5 FMLA - Length of Time Available 39

11.6 FMLA - Intermittent Leave 39

11.7 FMLA - Procedure for Requesting FMLA Leave 39

11.8 Designation of FMLA Leave 39

11.9 FMLA - Returning from Leave 39

11.10 Military Leave - Eligibility and Purpose 40

11.11 Personal Leave of Absence 40

11.12 Paternity Leave 40

11.13 Parental Leave 41

SECTION 12 - SAFETY & SECURITY 41

12.1 Safety and Security in the Workplace 41

12.2 Visitors 41

12.3 Drug-Free Workplace 42


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12.4 Substance Abuse - Prohibited Conduct 45

12.5 Substance Abuse - For Cause and Reasonable Suspicion Screening 46

12.6 Substance Abuse - Pre-Employment Screening: Testing for Drugs and Alcohol 46

12.7 Substance Abuse - Current Employment: Testing for Drugs and Alcohol 46

SECTION 13- TRANSPORTATION SAFETY 47

13.1 General Legal Requirements & Transportation Safety for All Drivers 47

13.2 Recovering the Cost of Business Mileage 47

13.3 Motor Vehicle Record 47

13.4 Motor Vehicle Policy Statement, Expectations and Company Matrix 47

13.5 Accident Procedure 48

13.6 Driving & Parking Offenses 48

13.7 Working Hours & Rest Breaks 49

13.8 Best Practices for Fleet Safety 49

13.9 Driving Following Travel 49

13.10 Drinking, Drugs and Driving 50

13.11 Mobile Devices 50

13.12 Vehicle Allowance 50

13.13 Insurance 51

13.14 Pool Cars 51

13.15 Termination of Employment 51

13.16 Essential User Vehicle 51

13.17 Driving Proficiency 51

13.18 Vehicle Security 52

13.19 Change of Job or Recruitment 52

13.20 Authorized Drivers 52

13.21 Vehicle Safety 52

13.22 Insurance Certificates 52

13.23 Insurance of Personal Effects 53

13.24 Entitlement and Suitability to Drive 53

13.25 Mechanical Breakdown 53

13.26 Availability of Company Vehicles 53

13.27 Routine Maintenance Checks 53

13.28 Cleanliness of Vehicles 53


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13.29 Drivers with Disabilities 54

SECTION 14 - TRAVEL 54

14.1 Travel - Introduction 54

14.2 Travel - Company Statement 54

14.3 Travel - Working within the Law 55

14.4 Travel - Key Management Responsibilities 55

14.5 Travel - Assessing Risks 55

14.6 Travel - Rental Car 56

14.7 Travel - Personal Health 56

14.8 Travel - Risk Assessment and Personal Protective Equipment 56

14.9 Travel - Confidentiality 57

14.10 Travel - Booking 57

14.11 Travel Overseas - General Advice and Practical Guidelines 57

14.12 Travel Overseas - Theft 58

14.13 Travel Overseas - Cultural Awareness 58

14.14 Country Specific Requirements 58

14.15 Travel - Class 58

14.16 Travel Overseas - Security 59

14.17 Travel - Insurance Procedure 59

14.18 Travel - Preparations 59

14.19 Travel - Driving Overseas 60

14.20 Travel - What to do in the Event of an Emergency 60

14.21 Travel - Problems with the Journey 60

14.22 Travel - Emergency Support from the Occupational Health Department 61

14.23 Travel - Employee Conduct Inside & Outside of Business Hours 61

14.24 Travel - Return, Import and Export Restrictions 61

14.25 Travel - Health 61

14.26 Travel - Feedback 61

14.27 Travel - Returning to Work 61

SECTION 15 - EXPENSE POLICY 62

15.1 Completion of the Expense Form 62

15.2 Claimants Signature 62

15.3 Authorization 63
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15.4 Reimbursement 63

15.5 Entertaining Expenses 63

15.6 Non-allowable Expenses 63

15.7 Company Cars 63

15.8 Own Car Use – Mileage Allowance 64

15.9 Rental Car 64

15.10 Meals & Hotels 64

15.11 Air Travel 64

15.12 Telephone Costs 64

15.13 Emergency Travel and Medical 65

15.14 American Express Corporate Cards 65

15.15 Personal Credit Cards 65

15.16 Claims for Loss 65

15.17 Professional Fees 65

SECTION 16 – MOBILE DEVICE POLICY 66

16.1 Purpose 66

16.2 Responsibilities – Company 66

16.3 Employee 66

16.4 Security 67

16.5 Daily Usage 67

16.6 Internationational Travel/Calls 67

16.7 Mobile Device Bills 68

16.8 Monitoring Mobile Devices 68

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INTRODUCTION

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DISCLAIMER
ACKNOWLEDGEMENT & RECEIPT OF UNDERSTANDING
This JCB Employee Handbook is intended as a reference guide and summary of employment and personnel policies,
work standards and conduct, benefits and general information which should assist you during your employment. These
guidelines should not be construed as an exhaustive list. JCB reserves the right to make changes in content or application
as it deems appropriate and these changes may be implemented even if they have not been communicated, reprinted or
substituted in this Manual. The Manual disavows any representations to the contrary made by anyone other than
representations in writing by an authorized management representative. It should also be understood that employment is
terminable at the will of either the employee or JCB, at any time and for any reason, with or without cause or notice.
It is JCB’s policy to comply with all applicable laws. To the extent that any policies found in the handbook conflict with
applicable federal, state or other law, the applicable law shall govern.

My signature below acknowledges that I have been advised that the Employee Handbook and related attachments are
available on the JCB Resource Portal under the “Employee Policy Manual” button. Printed copies are also available from
the Human Resources department. I acknowledge that I am expected to read, understand and adhere to JCB’s policies
and I will familiarize myself with the contents of the Manual with attention given to these policies, which have been
updated in 2018:

• Anti-Harassment Policy
• Paid Time Off
• Social Media Policy
• Travel & Expense
• Tuition Reimbursement

I am expected to comply with the guidelines set forth in these policies and the entire policy Handbook. I understand that
failure to comply may be grounds for disciplinary action up to and including termination.

_________________________________

Name

____________________________________ ___________________________

Employee Signature Date

The original page remains in the Handbook for your reference. A copy of the signed signature page will be maintained in
your personnel file.

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SECTION 1 - CODE OF CONDUCT & ETHICS
A Company’s conduct and its reputation are among its most valuable assets. It sets the tone for the relationships that a
Company enjoys with its employees, customers, suppliers, shareholders, the communities in which it operates, the public
at large and its competitors. JCB, Inc. is committed to the practice of good ethics and conduct among its employees.

This commitment has many aspects, including:


• Avoiding conflicts of interest
• Maintaining confidentiality of information
• Ensuring compliance with laws
• Fostering a work atmosphere of mutual respect
• Properly using Company assets and observing accounting and control procedures

All Employees of JCB, Inc. should carefully read and adhere to the policies set forth below. Employees are required to
confirm that they have read this Code of Ethics and Conduct and accept responsibility for conducting their business affairs
in accordance with these policies and guidelines.

It is important to note that JCB, Inc. reserves the right to modify or revise this Code of Ethics and Conduct at any time,
with or without notice. Further, nothing set forth in this Code of Ethics and Conduct is intended to create contract of
employment or to otherwise alter JCB, Inc.’s employment-at-will policy.

SECTION 2 - GENERAL EMPLOYMENT


2.1 EQUAL EMPLOYMENT OPPORTUNITY STATEMENT
To further its goal of equal employment opportunity for all employees and prospective employees without regard to race,
color, religion, gender, sexual orientation, gender identity, national origin, age, disability, genetic information, marital status,
amnesty or status as a covered veteran in accordance with applicable federal, state and local laws. The Company states as
its policy the following:

It will be the policy of JCB Inc., in accordance with all applicable State and Federal laws, to recruit, hire, train, and promote
persons in all job titles without regard to race, color, religion, sex, age, disability, or national origin, or any other basis
prohibited by applicable law.

All employment decisions shall be consistent with the principle of equal employment opportunity and only valid
qualifications will be required.

All personnel actions, such as compensation, benefits, transfers, social and recreational programs, etc. will be administered
without regard to race, color, religion, gender, sexual orientation, gender identity, national origin, age, disability, genetic
information, marital status, amnesty or status as a covered veteran in accordance with applicable federal, state and local
laws.

JCB expressly prohibits any form of unlawful employee harassment based on race, color, religion, gender, sexual
orientation, national origin, age, genetic information, disability or veteran status. Improper interference with the ability of
JCB employees to perform their expected job duties is not tolerated.

To assure compliance with the plan, Tonya Poole, Vice President of Human Resources, has been designated to administer
and monitor the plan and make reports to Senior Management. The Plan is available for inspection in accordance with
applicable regulations.

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2.2 AMERICANS WITH DISABILITIES ACT (ADA) AND THE ADA AMENDMENTS ACT
(ADAAA)
The Americans with Disabilities Act (ADA) and the Americans with Disabilities Amendments Act, known as the ADAAA,
are federal laws that prohibit employers with 15 or more employees from discriminating against applicants and individuals
with disabilities and that when needed provide reasonable accommodations to applicants and employees who are qualified
for a job, with or without reasonable accommodations, so that they may perform the essential job duties of the position.

It is the policy of JCB to comply with all federal and state laws concerning the employment of persons with disabilities and
to act in accordance with regulations and guidance issued by the Equal Employment Opportunity Commission (EEOC).
Furthermore, it is our Company policy not to discriminate against qualified individuals with disabilities regarding application
procedures, hiring, advancement, discharge, compensation, training or other terms, conditions and privileges of
employment.

The Company will reasonably accommodate qualified individuals with a disability so that they can perform the essential
functions of a job unless doing so causes a direct threat to these individuals or others in the workplace and the threat
cannot be eliminated by reasonable accommodation and/or if the accommodation creates an undue hardship to JCB.
Contact the Human Resource department with any questions or requests for accommodation.

2.3 CONFLICT OF INTEREST


Employees and members of their immediate families may not offer or receive anything of value, either directly, to or from
any person or organization with which JCB, Inc. does business or is in competition with. Any transaction of such, where
the offer or acceptance might compromise JCB, Inc.’s interest, might interfere with an employee’s impartial discharge of
duties, is intended or appears to be intended to influence, acknowledge, or reward the award of any contract, or is in
violation of a law or statute.

Receipt of any gift, gratuity, favor, entertainment, fee, commission, or any form of compensation or benefit with a value
greater than $100 from persons or organizations with which JCB, Inc. does business, including prospective suppliers, is to
be reported in writing within a month of receipt to the Finance Controller.

No employee may engage in any outside business activity, pursuit, action, or investment that could by its nature or scope
(with or without personnel gain):
• Create an interest or benefit to the employee that may adversely affect the interests or reputation of JCB, Inc.
• Be objectively construed as impairing or potentially impairing an impartial discharge of duties.
• Interfere with the satisfactory performance of assigned duties with JCB, Inc.
• Reflect a compromise or misuse of JCB, Inc. information or assets.

Employees are expected to recognize and avoid activities or investments that involve a conflict of interest. While it is
impossible to list in this policy statement every circumstance which may suggest a possibility of a conflict of interest, the
standards for evaluating such activities or investments is the responsibility of the employee. If an employee is ever in doubt
of whether an activity might create a conflict of interest, the employee should feel free to contact the Human Resources
Department for advice.

2.4 RELATIONS WITH COMPETITORS


JCB, Inc. expects that its employees will comply with all applicable laws and regulations governing competition, including
antitrust laws. Your manager should approve in advance and/or be kept informed regarding actions of any kind in
conjunction with a competitor of JCB, Inc. Employees should exercise extreme caution in any situation where

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competitors are present to avoid any perception of illegal relationships, particularly at trade shows, trade associations
meetings and conventions.

2.5 REPORTING VIOLATIONS


The interest of JCB, Inc. and all its employees are best protected when there are not violations of this code and when any
violations that do occur are promptly identified and corrected. If you are aware of or have any reason to suspect a
violation has taken place, please promptly notify Human Resources. No employee will be subject to disciplinary action or
retaliation for making a report in good faith; however, any employee who makes a report that they know, or reasonably
believe, is untrue or misleading will be subject to appropriate disciplinary action, up to and including termination of
employment.

2.6 SAFETY AND ENVIRONMENTAL CONCERNS


All employees are required to obey all applicable national, local or other safety or environmental laws and regulations and
must observe the proper safety rules and environmental practices in work situations. JCB, Inc. does not expect or permit
the taking of unnecessary or unreasonable risks in the performance of duties by an employee. JCB, Inc. places importance
upon protection of the environment.

2.7 COPYRIGHTS, TRADEMARKS AND PATENTS


All patents, trademarks, copyrights, drawings, specifications, computer programs, designs, photograph processes, reports,
memoranda, models, notes and other intellectual property created by employees during their employment are the
property of JCB, Inc. not the employee.

2.8 ACCOUNTING AND FINANCIAL REPORTING


JCB, Inc.’s financial books and records should reflect the assets, liabilities, revenues, costs and expenses of the company in
accordance with Generally Accepted Accounting Principles (GAAP) JCB, Inc. policy and local laws and regulations.
Creating or attempting to create false or misleading records is absolutely forbidden. No employee may conceal
information from auditors or regulatory agencies. All books and records will be maintained in accordance with any JCB,
Inc. record retention policy established.

2.9 USE OF COMPANY PROPERTY, FUNDS AND ASSETS


JCB, Inc. funds and assets may only be used for proper corporate purposes. No company funds or assets may be used to
make any charitable or political contribution without the prior review and written approval of the JCB, Inc. President.

All JCB, Inc. e-mail and voicemail systems are the property of JCB, Inc. and should be used only for job related purposes.
All communications and information transmitted, received or stored through such systems are the property of JCB, Inc.
Incidental and occasional personal use of these systems is permitted, but employees should have no expectation of privacy
when using the company’s e-mail and voicemail systems, and the Company reserves the right to monitor and access an
employee’s e-mail and voicemail records.

2.10 DEALINGS WITH GOVERNMENT OFFICIALS


As a general matter, JCB, Inc. and its employees are legally prohibited from offering, promising or giving money, gifts,
rewards, entertainment or other favors to a government official or employee as a means of influencing official actions or
decisions. This includes all federal, state and local government agencies.

2.11 ELIGIBILITY FOR EMPLOYMENT - IMMIGRATION AND NATURALIZATION

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The U.S. Citizenship and Immigration Service (USCIS) requires that the Company and candidates for employment provide
specific information within three (3) days of commencing employment. Candidates for employment must complete
Section 1 of form 1-9 (the Employment Eligibility Verification form) and provide the Company with specific documents to
establish their identity and employment eligibility.

Identity can be established by providing documentation such as a current state-issued driver's license, as state-issued
identification card, or similar document such as a school I.D. with photograph, voter's registration card, or military service
record. An employment eligibility document is a Social Security card, a birth certificate, or a certification of birth abroad
issued by the Department of State.

An employee may establish identity and employment eligibility with the same document by providing a United States
Passport, a Permanent Resident Card or Alien Registration Receipt Card, or an unexpired foreign passport with a
temporary 1-551stamp. Other acceptable documents are those listed on the Form I-9. An employee will not be allowed
to continue employment without providing proper acceptable documents as allowed for by Form I-9.

2.12 ELIGIBILITY FOR EMPLOYMENT - BACKGROUND


The Company reserves the right to check all applicants' and employees' personal and professional references, educational
history, employment history, and criminal background (to the extent such is permitted by applicable law). All background
checks will be conducted in accordance with applicable federal and state law, and the appropriate disclosures and
authorization shall be obtained from the employee prior to conducting a background.

2.13 EMPLOYMENT VERIFICATION


JCB North America uses The Work Number to provide automated employment and income verifications on employees.
The Work Number is a fast and secure way to provide proof of your employment or income. It is the simplest verification
process and accelerates credit decisions through an online system available to verifiers 24 hours a day, 7 days a week.

Give the authorized verifier the following information:

1.) The Work Number Access Methods

 www.theworknumber.com
 1-800-367-5690
 (1-800-424-0253 for TTY if hearing impaired)

2.) The JCB Inc. Employer Code: 26056

3.) Your Social Security Number

If asked to provide a salary key as your consent to the release income:

1.) Visit www.the worknumber.com/employees or call 1-800-367-2884 (1-800-424-0253 for TTY if hearing impaired).

 Enter the JCB Inc. Employer Code: 26056


 Enter your Social Security Number
 Enter your PIN# (Last 4 of SSN + MMDD of Birth)

2.) Follow the instructions to create a salary key.

3.) Provide the salary key to the person seeking your proof of income and direct them to www.worknumber.com to
complete the verification process.

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If the Work Number is not properly functioning; please provide a member of the Human Resources team a written
consent and supporting documentation from the requester.

2.14 ORGANIZATIONAL PROMOTION AND TRANSFER POLICY


This policy has been laid out to offer JCB, Inc. regular full time exempt and non-exempt employees at the Vice President
level and below the opportunity for development and career advancement through transfer and promotion from within
and to provide managers with qualified internal applicants.

Applicants must have acceptable performance, not be in an active corrective action program and must meet the minimum
requirements as outlined in the job description. Regular JCB, Inc. employees will be given first consideration for internally
posted positions. If regular employee applicants are deemed insufficient to meet Company objectives, then qualified
temporary workers and external candidates may also be considered. Meeting minimum requirements does not necessarily
guarantee an interview.

Newly hired JCB, Inc. employees will be eligible to take advantage of the posting process after completion of six (6)
months of service. Employees who have transferred to a new position or department will be eligible for the posting
process after twelve (12) months in the new department.

The Company reserves the right to grant exceptions based on business needs. Positions that open due to an employee
exiting do not require to be posted if there has been a previous posting of the same job or similar, within six (6) months
and there are qualified available applicants from the previous process.

Furthermore, the hiring manager and Human Resources representative may elect not to post certain positions on an
exception basis. JCB, Inc. reserves the right to change this policy at any time and for any reason.

Interested employees must fully complete the Transfer & Promotion Request form and submit to Human Resources with
a copy of their current resume.

2.15 MVR/DRIVING RECORDS


Employees expected to drive Company fleet or pool vehicles for Company business must provide the Company with
current and acceptable motor vehicle driving information upon receipt of vehicle. Assignment to a Company fleet or pool
vehicle will be conditional pending a satisfactory report.

2.16 EMPLOYEE RELATIONS PHILOSOPHY


The Company is committed to providing and maintaining a work environment that promotes teamwork and employee
participation. We believe it is management's responsibility to represent the best interests of our employees and to
continuously strive to ensure that employees are treated fairly and with respect.

We believe in open and direct communication that permits resolution of employee issues in an atmosphere of mutual
trust, responsive to individual circumstances. We endeavor to provide a positive N safe working environment, a
competitive compensation package, career development and employee satisfaction. The Company's management team is
committed to fostering a relationship that unites management and employees in a mutual respect and cooperation. We
urge every employee to help us build that relationship.

2.17 OPEN DOOR POLICY

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If an employee has a work-related concern, he or she should speak with his or her manager as soon as possible. The
manager will attempt to answer the question and/or resolve the issue. If the employee believes his or her manager did not
resolve the issue or if the issue directly involves the employee's manager, then the employee should take the issue to the
next level of management or to the Human Resources Department. For matters involving possible harassment or
discrimination, employees should follow the complaint procedures contained in the Harassment and Discrimination policy,
rather than the Open-Door Policy.

SECTION 3 - WORK SCHEDULE & ATTENDANCE


3.1 WORK SCHEDULE
To provide quality customer service and to operate the business effectively, it is important that all employees work their
scheduled hours, arrive to work at the time scheduled by their managers and notify their managers in advance of any days
on which they will be late, need to leave early or will be absent from work. The employee's manager and/or department
head is responsible for setting employees' work schedules.

The Company reserves the right to modify work schedules as needed to meet the business needs of the Company.
Employees may be asked to work additional hours, work fewer hours or change designated days off.

Employees will be paid for all hours worked in accordance with the Company's Compensation Policy and applicable
federal and state laws. Non-exempt employees may not work prior to their scheduled shift start time or past their
scheduled shift end time without obtaining authorization and approval from their manager in advance.

3.2 HOURS OF OPERATION


JCB observes the following work schedule:

JCB North America - Hours of Operation


Department M T W TR F Start Time End Time Lunch Total Hours
x x x x 8:00 a.m. 5:00 p.m. 30 minutes 34
Savannah Office Staff
x 8:00 a.m. 2:30 p.m. 30 minutes 6
40
*Manufacturing, Parts
Warehouse & Customer x x x x 7:00 a.m. 3:30 p.m. 30 minutes 33
Service x 7:00 a.m. 4:00 p.m. 30 minutes 7
40

*Indicates shifts that may vary, or change based off manufacturing needs. Employees must confirm hours with their
manager if assigned to one of these departments.

All sales, service and customer support will be on a bi-weekly rotation to ensure full coverage from 8:00 AM – 5:00 PM
each day for our customers.

It is important to understand that JCB hours of work must remain flexible and that at some point in the future, the
Company may decide to make changes to the work schedules that are listed above. When this occurs, JCB will provide
adequate notice to employees about the changes being made.

3.3 ATTENDANCE POLICY – JCB, INC.

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Employee attendance is important to a productive work operation. This policy is designed to provide guidelines and will
document employee expectations as they relate to attendance while assigned at JCB, Inc.

Notification Policy

• When possible, requests for time off should be requested at least 24 hours in advance of the absence from work.
• Employee’s must notify their JCB supervisor if he or she is expecting to be absent or tardy from work.
• An absence of three or more days without notice to JCB supervisor will be considered a voluntary resignation.

Attendance Policy - Definitions

• Absence is defined as an unapproved absence of one or more days, in which the employee has not properly
notified their JCB supervisor.

• Tardiness is defined as arriving late (1 minute after the shift is scheduled to begin) or leaving early (before the shift
is scheduled to end), in which the employee has properly notified their JCB supervisor.

Point System

• Each unexcused absence will = 1 Point


• Each No Call / No Show will = 2 Points
• Tardiness or Leaving Early, totaling less than ½ of the shift will = ½ Point
• 4 Points = Written warning (employee is ineligible for a transfer or promotion)
• 7 Points = Termination

Points "fall off" after 12-months, based on a rolling 12-month period.

3.4 INCLEMENT WEATHER/EMERGENCY


All updates are shared via e-mail or the Inclement Weather line at 912.665.6563. Severe Weather Conditions, when
authorized by the Company, are considered excused.

3.5 MEAL & REST PERIODS


JCB Café Hours:

Breakfast: 7:30 a.m. - 10:30 a.m. Monday - Friday


Lunch 11:30 a.m. - 1:30 p.m. Monday - Friday
Afternoon Snack 1:30 a.m. - 2:30 p.m. Monday - Thursday
JCB Café - early closure Friday ONLY

The scheduling of meal periods at JCB is set as follows:

11:30 a.m. - 12:00 p.m. Manufacturing


12:00 p.m. - 12:30 p.m. Manufacturing
12:30 p.m. - 1:00 p.m. Office Staff

Manufacturing Meal/Rest Period schedules vary based off the needs of the business. Please consult with your direct
supervisor for assigned meal/rest period time(s).

It is important to understand that JCB hours of work must remain flexible and that some point in the future, the Company
may decide to make changes in the work schedules that are listed above. When this occurs, JCB will provide adequate
notice to team members about the changes being made.

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Mandatory Meal Period

Employee meal periods are important to Company productivity and employee health; therefore, employees who work at
least six (6) consecutive hours will be provided a mandatory meal break, which should not exceed thirty (30) minutes. The
meal period will not be included in the total hours of work per day and is not compensable. Non-exempt team members
are to be completely relieved of all job duties while on meal breaks.

Rest Breaks

Exempt employees, as they are paid a weekly salary regardless of the hours they work, may choose to take breaks as
needed. Non-exempt team members are permitted a fifteen (15) minute rest break for each four (4) hours of work. Non-
exempt team members on rest breaks are not required to clock in and clock out because this time is considered “time
worked” and is compensable. Each day, the manufacturing and parts warehouse will stop for a fifteen (15) minute break
in the first half of the shift and for a fifteen (15) minute break in the second half of the shift.

Impermissible Use of Meal Period and/or Rest Breaks

Neither the lunch period nor the rest breaks may be used to account for an employee's late arrival, early departure or to
cover time off for another purpose. For example, rest breaks may not be accumulated to extend a meal period, and rest
breaks may not be combined to allow one (1) half-hour long break.

SECTION 4 - TIMEKEEPING
JCB North America must keep accurate records of employee’s working hours to (1) Meet requirements under federal
and state law (2) Ensure payroll records are accurate (3) Adjust employees’ accrued leave balances and other benefits
dependent on employees’ earnings or hours worked.

4.1 MAINTAINING TIME RECORDS


All JCB North America personnel, both exempt and non-exempt, housed in Savannah are required to clock in and out
daily.

All employees, both exempt and non-exempt, are required to use the time clock system to record their hours worked.
Non-exempt employees are required to clock in and out for payroll and attendance purposes. The time clock records will
also be used to track attendance for exempt employees.

Non-exempt employees should clock in no sooner than 7 minutes before and after the scheduled shift and clock out no
later than 7 minutes before and after the scheduled shift, unless overtime has been approved by a Manager.

4.2 EDITING TIME RECORDS


If an employee misses an entry in the timekeeping system, the employee will notify the supervisor as soon as possible;
written notification is the expectation to support the change. The supervisor will manually enter the employee’s work
hours via the manager time clock portal. Employees who consistently miss time clock entries will be subject to disciplinary
action.

As with any of our policies continued lack of compliance may result in termination. Any instance of falsifying time records
will result in immediate termination.

4.3 HUMAN RESOURCES INFORMATION SYSTEM (HRIS) - DAYFORCE

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Dayforce allows employees to access pay stubs, update personal information, request PTO and lots more.

Website: https://www.dayforcehcm.com/mydayforce/login.aspx

Company: JCB
Username: (first initial last name)
Password: Welcome (last 3 digits of SSN)

SECTION 5 - COMPENSATION
5.1 PAY SCHEDULE
For purposes of calculating overtime, each workweek begins on Monday and each workday begins at 12:00 a.m., unless
otherwise provided; the workweek ends on Sunday at 11:59 p.m. unless otherwise provided.

5.2 PAYMENT OF WAGES


All employees will be paid on a bi-weekly basis. Payroll checks, or direct deposit vouchers will be distributed for the
employees’ convenience on Thursday afternoon after 2:00 p.m. The actual pay day is every other Friday. If payday
happens to fall on a JCB observed holiday, checks and vouchers will be distributed on the day prior to the holiday.

As a practice, pay checks are not released to individuals other than the JCB employee.

As a service to all regular, full-time employees, JCB offers direct deposit of pay into individual checking or savings accounts.
To participate, an employee’s bank or financial institution must be a member of the National Automated Clearing House
and eligible to receive and process electronically transferred funds. It takes approximately four (4) weeks or two (2) pay
cycles to begin or discontinue direct deposit. To participate, employees must complete an authorization agreement and
furnish a voided check with their correct account number to the Human Resources Team. All employees are strongly
encouraged to participate in this program. If direct deposit is not an option JCB can aid employees in the establishment of
a debit card account.

5.3 EMPLOYEE CLASSIFICATION


Employees classified as salaried / exempt (staffs) are exempt from overtime pay and shall receive an annual salary that
compensates the employee pursuant to the employee's offer letter and record of employment. An employee’s annual
compensation will be established at the time of hire and all changes shall be documented in the employee’s personnel
record. While it may be subject to review and modification from time to time, the salary will be a pre-determined amount
that generally will not be subject to deductions for variations in the quantity or quality of the work you perform.

Employees classified as hourly / non-exempt (works) receive pay based on actual hours worked. Non-exempt employees
are paid a regular rate for all regular hours worked on behalf of the Company up to forty (40) hours in one work week
and are paid for any hours worked over forty (40) hours in one work week as overtime hours at a rate one and one-half
times their regular rate, or as federal or state law requires.

PTO, holiday and any other benefit hours do not count towards overtime. All overtime must be authorized and approved
in advance by the employee's manager.

5.4 OVERTIME

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Overtime is a result of the demand for our product and the result of JCB’s attempt to maintain a lean organization that is
flexible enough to respond to change.

JCB will make every effort to schedule production overtime throughout the normal workweek to limit scheduling of
weekend overtime. It is JCB’s goal to notify employees at the earliest opportunity of all overtime requirements.
Normally, production employees will be notified of daily scheduled overtime by the end of the second break period on
the day of the overtime requirement and notified of weekend overtime by the end of their regular shift on Thursday of
each week. Of course, major equipment breakdowns, emergency situations, etc. may mandate that less notice be
provided. Due to the nature of office and administrative positions, hourly non-exempt employees in these jobs may
receive short notice of daily, weekend, and/or holiday overtime, but every effort will be made to notify these employees at
the earliest moment.

Managers are responsible for scheduling all overtime hours; therefore, all employees are required to receive approval in
advance from their manager before working any overtime. The working of scheduled overtime hours is mandatory unless
an employee has received approval in advance from his/her manager not to work the overtime.

JCB calculates overtime as follows for non-exempt individuals working on a holiday:

If a non-exempt employee is required to work on a holiday, they will receive eight (8) hours of holiday pay at their regular
rate of pay. Any hours worked on the holiday will now be calculated at their regular rate of pay multiplied by two (double
time).

For example, if a non-exempt employee is compensated for $14.00 per hour and works the holiday they would be
compensated as follows:

Please feel free to contact a member of the Human Resources Department should you have any additional questions or
concerns.

SECTION 6 - EMPLOYEE BENEFITS


6.1 HOLIDAYS
To be eligible for holiday compensation the employee must work or be on an approved leave the regular workday prior
to and the workday after the observed holiday. If a holiday falls during approved scheduled PTO or leave, staff employees
will not be charged PTO for that day. Employees who, due to personal or family illness, death of a family member,
emergency or unforeseen circumstances, may be eligible for holiday compensation and may be asked to provide
satisfactory proof of the situation. Employees who are on an unapproved leave of absence, disability leave, or any other
leave except paid PTO at the time the holiday occurs are not eligible for holiday pay.

For purposes of this policy, immediate family is defined as: Brothers, Brother-in-law, Children, Daughters-in-law,
Domestic Partner, Fathers-In-law, Grandchildren, Grandparents, Mothers-in-law, Parents, Sisters, Sisters-in-law, Sons-in-
law, Spouses, Stepbrothers, Stepchildren, Stepfathers, Stepmothers and Stepsisters.

Part-time employees will be paid pro-rata holiday compensation only if normally scheduled to work on the weekday on
which the holiday falls. Full-time employees who work an alternative schedule will be granted a pre-scheduled day off
during the same week for those instances where a holiday occurs on their day off.

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6.2 PAID TIME OFF
JCB’s Paid Time Off (PTO) program is designed to provide greater flexibility and freedom with time off for employees
within the limits set by the policy and required staffing limits of the department.

PTO allows employees to draw from their PTO bank for purposes of shut down, vacation, sick leave, medical
appointments, family illness and personal reasons or to supplement partial pay or unpaid time during an approve leave.

JCB, Inc. has two shut downs through the year. Employees should schedule time off during the summer and winter shut
downs using PTO hours. If you do not have enough PTO time to qualify for shutdown you may choose to take one week
during the summer shut down rather than both weeks. To ensure there is adequate coverage required in critical business
areas, all PTO must be coordinated and approved with your manager.

JCB’s employees are a valued part of the team and each position is vital to JCB’s success. Good attendance is critical to
the organization’s overall performance. JCB believes it provides sufficient time for these purposes.

Eligibility

Full-time and part-time employees that are regularly scheduled to work a minimum of 30 hours per week are eligible for
JCB’s PTO program. Part-time employees who work less than 30 hours per week and temporary employees are not
eligible to participate.

The amount of PTO earned each year is based upon the employee’s years of service, in accordance with schedules
contained in this program. Part-time employees earn PTO on a pro-rated basis in direct proportion to the employee’s
work schedule.

Status changes during the year may result in an adjustment of PTO on the effective date of the status change. Part-time
employees, as well as those with a change in status, should consult with Human Resources to determine the change in
PTO days earned.

Accruals

PTO for employees accrues on a pay period basis; the accrual rate is based on full years of continuous service. If an
employee’s anniversary date falls between January 1 – June 30th, the employee will advance to the next earnings tier on
January 1st of the current year; if between July 1st and December 31st the employee will advance to the next PT0 earnings
tier on January 1 of the following year.

PTO balances for newly hired employees will be pro-rated based on the number of full months remaining in the calendar
year. Newly hired employees must complete three (3) consecutive months of continuous employment to be eligible for
PTO unless prior approval has been received from Human Resources.

PTO will not be earned on Short or Long-Term Disability or any paid or unpaid leave of absence. If an employee is on a
leave of absence, the annual PTO accrual will be adjusted based on the anticipated duration of the leave. Upon return to
work, appropriate adjustments will be made, including deductions from pay to recover any overpayments, unless
prohibited by state or local laws.

Accrual Rates

Employees Annual Equivalent


<1 pro-rated
1-2 13 days

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3 14 days
4 15 days
5 17 days
6 18 days
7 19 days
8 20 days
9 21 days
10 23 days
11 24 days
12+ 25 days

The accrual outlined above contains an additional day for each milestone achieved. For example, at year 5, 10, 15, 20 etc.
employees will earn one additional day of PTO.

Non-exempt employees may take PTO in fifteen-minute increments. Exempt employees take PTO in half day (4 hour)
increments.

If an employee does not have sufficient PTO to cover an absence, the time off (or the balance of the day) will be unpaid.
Partial pay for a day may be permitted under the Fair Labor Standards Act for exempt employees in accordance with state
laws.

PTO time will not be carried over from year to year.

In California, the policy limits the number of hours that may be accrued to a maximum of 350 hours. If an employee’s
accrued but unused PTO reaches the maximum, no additional PTO will be accrued until their balance drops below the
limit.

6.3 BEREAVEMENT LEAVE


Employees who experience a death in their family will be provided a period of paid time away from work to arrange and
attend the funeral. Bereavement leave benefits will be paid at the employee’s regular rate of pay as defined by their
regular work schedule.

Should you experience a death in your immediate family, you will be excused with pay for a maximum of three (3)
consecutive days, up to and including the day of the funeral. Should extended travel time be required to attend the
funeral, up to two (2) additional “travel” days, may be approved by Human Resources. Please note this is reserved for
travel over four (4) hours by vehicle. If additional bereavement time is required, you may be granted a personal leave of
absence without pay or utilize available PTO to cover this lost time.

For purposes of this policy, immediate family is defined as: Brothers, Brother-in-law, Children, Daughters-in-law,
Domestic Partner, Fathers-In-law, Grandchildren, Grandparents, Mothers-in-law, Parents, Sisters, Sisters-in-law, Sons-in-
law, Spouses, Stepbrothers, Stepchildren, Stepfathers, Stepmothers and Stepsisters.

If you experience a death of a relative, not in the immediate family, you may be excused with pay for up to two (2)
consecutive days in accordance with your regular work schedule to attend the funeral. Relatives not in the immediate
family include Aunts, Uncles, First Cousins, Nephews, Nieces and in-laws including Sisters, Brothers and Grandparents.

If you are on PTO when a member of your immediate family dies, your time lost will be considered as Bereavement
Leave and you will later be allowed to utilize the PTO missed because of the death.

An employee who wishes to take time off due to the death of an immediate family member should notify his or her
supervisor immediately. Documentation is required from all employees to support bereavement leave.

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Bereavement leave will be granted unless there are unusual business needs or staffing requirements.

6.4 JURY DUTY/WITNESS LEAVE


JCB regards serving as a witness or on a jury as a civic responsibility. Immediately upon receiving your summons to serve,
notify your manager and provide a copy of the official summons. Your manager will work with you to accommodate your
schedule. It is expected that you will devote as much time to your job as is practical and reasonable.

Upon submission of appropriate documentation to your manager, you will receive your regular rate of pay based on your
normal workweek schedule for all scheduled work hours that are lost because of the jury/witness service. Payment will be
limited to your regular rate of pay based on your normal work week schedule and will be in addition to any expense
reimbursement made to you by the court.

During the period you are serving on Jury/Witness Duty, all benefits will remain in effect. In addition, the hours spent
serving on Jury/Witness Duty during the normal work schedule will be considered as hours worked for overtime pay
calculation.

6.5 VOTING LEAVE


All employees should be able to vote either before or after regularly assigned work hours. When this is not possible, due
to work schedules, employees will receive up to three (3) hours during the work day to vote.

Time off for voting should be reported and coded appropriately on timekeeping records.

6.6. ELECTION LEAVE


Employees who are chosen to serve as election officials at polling sites will be permitted to take required time off to serve
in this capacity. It is incumbent on employees who are chosen to act as election officials to notify their manager a minimum
of seven (7) days in advance of their need for time off to accommodate the necessary rescheduling of work periods. Time
engaged as an election official should be reported and coded appropriately on timekeeping records.

6.7 EMPLOYER PROVIDED INSURANCE BENEFITS


Health and dental insurance is provided by Integra BMS. Your health insurance will go into effect thirty (30) days from
your hire date only if the proper documentation is completed and returned to Human Resources prior to your 25th day. If
you choose not to participate in either of the coverage plans, you must notify Human Resources in writing prior to your
30th day. Pre-existing conditions coverage is managed in accordance with HIPAA legislation.

For more information regarding benefits programs, please refer to the Company Summary Plan Descriptions, which are
provided upon hire, or contact the Human Resource department.

6.8 RETIREMENT PLAN - 401K


The Company offers a 401K-retirement plan with an employer contribution level of $.50 on the dollar for the first 6% that
you contribute. Under the JCB 401(k) plan you can contribute up to 100% of your salary on a pre-tax basis. Investment
options are offered through Principal. You will be automatically enrolled at a 6% contribution level, unless you notify the

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Human Resources team otherwise by submitting a signed 401(k) enrollment form. Your deferral and the Company
contribution will begin the first of the month following 90 days of employment.

6.9 TUITION ASSISTANCE


JCB’s tuition assistance program is designed to offset some of the costs of taking graduate admissions tests, gaining
professional certifications, or taking college courses in a field related to your current job, or jobs realistically in your career
path.

Employees may be reimbursed up to $1,000 per semester for eligible expenses associated with approved programs. The
Tuition Reimbursement program is not intended to cover the entire cost of continuing education.

JCB employees must be employed with the Company for twelve (12) months following the completion of any approved
programs. If you voluntarily terminate your employment with JCB North America, prior to completing the course, you
will refund the entire amount of the educational expenses provided to you.

If you voluntarily terminate employment with JCB North America after completion of the course, and prior to completing
twelve (12) consecutive months of active employment, you will refund the entire amount of the educational expenses
provided to you.

If you voluntarily terminate employment with JCB North America after completion of the course and after completing
twelve (12) months of active employment, but prior to completing 24 consecutive months of active employment, you will
refund 50% of the educational expenses provided to you.

This benefit is available to full-time JCB employees who are performing satisfactorily in their current role. The expenses
apply towards the following:
• College tuition - undergraduate or graduate courses
• Graduate school admissions tests and prep courses
• Professional certifications

6.10 EMPLOYEE ASSISTANCE PROGRAM


Through the Employee Assistance Program (EAP), JCB provides confidential access to professional counseling services.
The EAP, available to all employees and their immediate family members, offers problem assessment, short-term
counseling and referral to appropriate community and private services. This service is provided on behalf of JCB by
Unum.

The EAP is strictly confidential and is designed to safeguard an employee’s privacy and rights. Contacts to and information
given to the EAP counselor may be released to JCB only if requested by the employee in writing. There is no cost for an
employee to consult with an EAP counselor. If further counseling is necessary, the EAP counselor will outline community
and private services available. The counselor will also let employees know whether any costs associated with private
services may be covered by their health insurance plan. Costs that are not covered are the responsibility of the employee.

Unum
Toll-free, 24-hour access
1-800-854-1446 (English)
1-877-858-2147 (Spanish)
1-800-999-3004 (TTY/TDD)

Online Access
www.lifebalance.net

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user ID and Password: lifebalance

For more information or to get a brochure please see Human Resources.

SECTION 7 - COMPANY PROPERTY AND SOCIAL MEDIA


7.1 INTRODUCTION
This policy provides guidelines for the proper use of the Company’s property, Internet, email resources, instant message,
and social media. All employees are responsible for using these resources in a professional, ethical, and lawful manner. The
Company’s computers, telephones, wireless devices, cell phones, voicemail, email systems, Internet services, instant
message, facsimile machines, electronics and software are the property of the Company and are for business use only. Any
unlawful or unprofessional use is prohibited.

Employees should follow instructions and ask for help regarding how to use a machine or piece of equipment. Do not
attempt to use equipment or tools without proper training. Under no circumstances should an employee start or operate
equipment that may be unsafe, nor should an employee adjust or modify any equipment safeguards.

7.2 ELECTRONIC COMMUNICATION AND INTERNET USE


Electronic mail and the internet are to be used only for JCB business. All electronic mail originating from or delivered to
JCB is the property of JCB and is subject to regular review. Access to non-work-related websites is considered an
unauthorized use of Company resources. To ensure the security of JCB computer systems is protected, non-authorized
software or other material should not be downloaded, unless received from a known established business relationship.
To protect the JCB internet connection, very large electronic mail documents may be blocked or delayed for delivery
overnight.

7.3 SOCIAL MEDIA


JCB employees, dealers, partners and representatives should follow the guidelines below when using social media:

1. You may share your JCB employment status/affiliation in your social media profiles and posts.
2. You should disclose your JCB employment status/affiliation when posting about JCB products or services, or when
posting about JCB-sponsored public events. Doing so will provide context and enhance the online conversation.
3. You are encouraged to share JCB’s social media posts via your personal social media accounts.
4. You should clearly identify your online comments and opinions as your own, and not those of the company. If
necessary, include a statement such as: "Comments and opinions expressed here are my own and not necessarily
representative of JCB’s positions, preferences or policies".
5. Understand that online users may associate you with JCB, even if your online comments are clearly stated as your
own. Act accordingly. Do not post lewd, immoral, illegal, or untrue statements, and do not post racially or other
discriminatory or harassing content.
6. Be sure not to violate the company’s privacy, confidentiality, or legal obligations, or to share proprietary or
commercially sensitive information. If you are unsure whether something is appropriate to share, consult first with a
member of the Marketing team.
7. Do not post comments you know to be false or misleading about the Company or its products, events or services,
or its employees or representatives.
8. Do not post negative comments about the Company’s products or services. Be respectful of the Company’s
customers, vendors, and competitors.
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9. Do not post comments about emergency or crisis situations that might adversely impact the safety or welfare of
other JCB employees, dealers, partners and representatives.
10. Before posting copyright-protected written or visual content, be sure to obtain the copyright owner’s permission (an
email is usually sufficient) and give them credit in your post. In general, ensure your posts comply with all applicable
copyright and trademark laws.
11. If you reference JCB competitors in your online posts, avoid hyperbole and stick to facts. Include a link to the
reference/source, if appropriate.
12. If you state something incorrectly, apologize and correct your mistake.
13. If you encounter negative or false social media content about JCB’s products or services, bring it to the attention of
the Digital Marketing Specialist or a member of the Marketing team.
The JCB brand is best represented by its people. What you post online may reflect on the Company and your colleagues.
Use common sense and common courtesy, and when in doubt, consult with a member of the Marketing team. Failure to
comply with these guidelines may result in disciplinary action.

These guidelines are not intended to interfere with, restrain, or prevent employees’ lawful communications with one
another about the terms and conditions of their employment.

7.4 COMPANY EQUIPMENT & PROPERTY


The Company invests a substantial amount of money in state-of-the-art equipment and materials that enable employees to
perform their work more safely, efficiently and effectively. The default equipment configuration is a desktop computer,
monitor (or monitors) and related equipment. It is the responsibility of hiring managers to request IT equipment by
completing and submitting the below link for new employees:

http://jcbnewhire.com

The Company takes seriously the security, maintenance and safekeeping of Company-issued equipment. Employees
should carefully consider the physical security of computers, mobile devices and other Company-issued property and take
appropriate protective measures.

7.5 RETURN OF COMPANY ISSUED EQUIPMENT AND PROPERTY


All Company-issued items must be returned upon separation. Managers or an HR representative must collect security
badges, corporate credit cards, keys, IT equipment, fleet or pool vehicle(s). When an item is returned, if it is damaged
(other than normal wear and tear), the employee may be required to reimburse the Company for repair/replacement
costs, or these costs may be deducted from the final paycheck in accordance with state and federal requirement related to
payroll deductions.

SECTION 8 - GENERAL EMPLOYMENT POLICIES


8.1 CONFIDENTIALITY OF COMPANY INFORMATION
During employment, employees may be exposed to information about JCB, Inc. or other companies which is confidential
or otherwise not generally available to outsiders or even to other JCB, Inc. employees. It is expected that all employees
will use discretion with respect to discussions and other communications of confidential information. Confidential
information includes proposed business and product plans, cost structures, projected financial information, proposed
management and organizational changes, and supplier, sales, and client list and contacts.

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Employees should not disclose, modify, destroy, disseminate, or use this information, in any way, for their own or anyone
else’s personal benefit, profit or advantage, nor may they use such information, in any way, for their own or anyone else’s
personal benefit, profit or advantage, nor may they use such information to the detriment or damage of JCB, Inc.
Information in all forms relating to JCB, Inc. business, it's standard of care required to avoid unauthorized disclosure,
modification, and destruction or other improper use. In the case of information received from another firm, this standard
of care may include obligations required by the contract between JCB, Inc. and such firm.

Upon termination of employment with JCB, Inc. employees must return to the Company all confidential information in
their possession.

8.2 SOLICITATIONS, DISTRIBUTIONS AND POSTING OF MATERIALS


Solicitation of employees by other employees to join or contribute to any fund, organization, cause, activity or sale is
prohibited during times when either the employee being solicited or doing the soliciting is on working time. The
Company does participate in certain community charity efforts such as the United Way and Toys for Tots. These
important community projects will be supported by JCB and will not conflict with this policy. Distribution of literature,
including circulars or other printed materials, by employees is prohibited while an employee is on working time and is also
prohibited in any working area. Lastly, it should be noted that solicitation or distribution of literature on Company
property by any person who is not an employee is prohibited.

8.3 OFFICE APPEARANCE POLICY


JCB North America established this policy on office appearance in accord with its values of efficiency and professionalism.
As an expression of those values, all office areas, including employee work areas and shared areas, should be kept neat and
orderly.

Employees should keep their individual work areas as neat as possible during the regular workday. Before leaving the work
area at the end of the workday, JCB North America requires employees to have a clean desk and organize their areas to
secure work materials and to present an orderly and professional image.

Work areas do’s and don’ts


1. Posters, pictures, notes, etc., are not permitted on the outside of workstation panels.
2. Pictures and personal items are permitted on the inside of workstation panels if they are appropriate for
workplace display and are not offensive to other employees. JCB North America consistently enforces its policies
prohibiting workplace discrimination and harassment of any kind, including images, graphics or other visual
displays that may constitute offensive or inappropriate workplace conduct.
3. Hanging notes and miscellaneous documents are no longer permitted within work station panels.
4. Work-related materials are not permitted on the tops of workstation cabinets. This area should remain clear or
be tastefully decorated with plants or other appropriate workplace decorations.
5. Boxes and other storage items should remain out of sight within a workstation or placed in other appropriate
onsite or offsite storage areas.
6. Employees should leave public areas, such as conference rooms, restrooms and break areas in a clean and
orderly condition for guests and other employees.

Employees in violation of this policy will be subject to appropriate disciplinary procedures, up to and including termination
of employment, for repeated or egregious violations.

8.4 OUTSIDE EMPLOYMENT

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Employees are expected to devote their full working time and attention to their duties for JCB, Inc. Outside business
activities of employees are permitted provided they do not involve cooperating with or becoming a competitor, customer,
or vendor of JCB, Inc. or interfere with the satisfactory work performance of the employees.

8.5 EMPLOYMENT OF RELATIVES AND PERSONAL RELATIONSHIPS


It is JCB’s policy to hire the best qualified candidate for each job opening. Relatives of employees will not be given special
consideration but will be allowed to participate in pre-employment selection activity and, if they satisfactorily complete this
process, will be considered for employment. The following restrictions must be adhered to:

• No employee will be permitted to directly/indirectly supervise his/her relatives


• Organizational relationships will not be permitted where an employee handles cash items or transactions, and
where his/her relative is responsible for control over those items
• No organizational relationship involving relatives will be allowed to exist regardless of position if it has a negative
impact on JCB’s business.

JCB reserves the right to apply this policy to situations where there is a conflict or the potential for conflict because of the
relationship between employees, even if there is no direct-reporting relationship or authority involved.

8.6 RELOCATION COSTS & AGREEMENT TERMS


For eligible employees JCB offers a flat relocation benefit and this total sum is based off distance and outlined in the
employee offer letter. It is the expectation that those eligible complete two (2) years of satisfactory service from their date
of relocation. Failure to do so will result in the full relocation amount being paid back by the employee.

Mileage Benefit
100-499 $2000
500-999 $4000
1000-2999 $5000
3000+ $9000

For all General Manager, Vice Presidents, Regional Vice Presidents and International assignees in the process of repatriation
we continue to provide a full relocation service after obtaining three quotes from providers.

8.7 EMPLOYEE REFERRALS


The Company encourages current employees to refer the highest caliber candidates so that together the Company hires
the best talent. An employee may be eligible to receive a referral bonus if the employee refers a candidate who is hired
and remains employed and in good standing after ninety (90) days. The amount of the referral bonus varies based on
position filled and documentation of the referral is required. More information about the various referral bonus plans can
be found in the Human Resources Department.

8.8 INTRODUCTORY REVIEW PERIOD


The first 90 days of employment are an extension of the selection process during which supervisory personnel carefully
observe an individual. This probationary period will be utilized to evaluate the individual's ability to adapt to and meet
required standards of job progress, including attendance expectations. During this time, absenteeism/tardiness of any kind
could result in disciplinary action up to and including discharge.

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8.9 SOLICITATION AND DISTRIBUTION OF LITERATURE
Solicitation of employees by other employees to join or contribute to any fund, organization, cause, activity or sale is
prohibited during times when either the employee being solicited or doing the soliciting is on working time. The
Company does participate in certain community charity efforts such as the "United Way" and "Toys for Tots." These
important community projects will be supported by JCB and will not conflict with this policy. Distribution of literature,
including circulars or other printed materials, by employees is prohibited while an employee is on working time and is also
prohibited in any working area. Furthermore, solicitation or distribution of literature on Company property by any person
who is not an employee is prohibited. Violations of this policy should be reported to Human Resources.

It is not the intent of this policy to interfere with, or restrict, the distribution of work-related or training materials by Group
Leaders/Supervisors, Team Leaders, Managers, Human Resources and/or others approved by Management or HR.

8.10 RESIGNATION
The Company encourages employees who intend to resign their employment to provide at least a two (2) week,
advanced written notice to his or her manager; this is recommended unless the employee's signed offer letter requires that
additional notice be provided. Failure to provide appropriate notice may affect consideration for rehire. The Company
reserves the right to accept any employee resignations effective immediately. This policy does not change any employee's
at-will employment status.

Employees, who resign voluntarily with at least two weeks’ notice, will be paid for unused accrued PTO. Employees
discharged for cause, resign without two weeks’ notice or have not been employed for one (1) full year of service are not
eligible for a PTO payout unless prohibited by state or local laws.

If PTO hours have been advanced more than what has been accrued, the value of the PTO used beyond the accrual will
be deducted from the employee’s final paycheck unless prohibited by state or local laws.

PTO termination and reimbursement policy may vary by state due to state and local laws.

8.11 EMPLOYEE RECORDS


The Company maintains personnel records on each employee including a job application, wages and salary information,
promotions, transfers, training records, and all other information reflecting an employee's status. Employee files are the
property of the Company and will be treated the same as any other confidential Company information. Managers are
required to forward all personnel information on each employee to Human Resources as soon as practicable. This
includes, but is not limited to, written corrective action forms and all employee status changes.

Employees are responsible for making any personal information changes via the self-service portal in Dayforce or may
contact Human Resources for support. These changes include name, home address and telephone number. Accurate
contact information is critical for applicable benefit plan information, distributions of W-2's, and to help the Company
contact the employee in the event of an emergency.

All requests from outside sources or from former employees for employment records must be directed to the Human
Resources Department.

8.13 REHIRE STATUS


Employees who voluntarily terminate their employment are eligible to be rehired depending upon their qualifications for
the position and their former work performance. Employees whose employment was involuntarily terminated may be

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eligible for rehire at the sole discretion of the Company. Former employees who are seeking to be rehired should submit
an employment application for processing. Hiring managers and recruiters must contact the Human Resources
Department for a determination of a former employee’s eligibility for rehire.

SECTION 9 - EMPLOYEE CONDUCT AND POLICIES


9.1 EMPLOYEE CONDUCT
The Company expects all employees to abide by certain work rules of general conduct and performance at all time. The
regulations governing employee conduct and responsibilities have been established in the best interest of the Company, its
employees, and its customers. Accordingly, a violation of these regulations constitutes misconduct on the part of the
employee and appropriate disciplinary action will be initiated. These rules are guidelines only and are not all inclusive.
Disciplinary action may include, but is not limited to, informal warning, written warning, and or suspension from work with
or without pay, final warning, and immediate termination of employment. Management reserves the right to terminate or
discipline any employee as the Company, in its discretion, considers necessary in individual circumstances. Employment
with the Company remains “at-will” always. Examples of the actions, practices and behaviors that will not be tolerated and
may result in corrective action up to and including termination, at management’s sole discretion, are as follows:

 Unsatisfactory job performance


 Unexcused absenteeism or tardiness
 Disrespectful conduct and inappropriate behavior
 Refusal or failure to perform responsibilities or assigned tasks
 Unethical conduct or behavior
 Insubordination
 Sleeping while on the job
 Fighting or threatening violence, obscene language or gestures
 Falsifying time records, personnel records, financial reports or other Company records
 Sexual harassment or other forms of harassment and/or discrimination and/or retaliation
 Theft, misappropriation or concealment of individual property from fellow employees, or any unapproved
removal or possession of Company property
 Violation of any Company procedure or police detailed in this Handbook.

The above list is not all-inclusive, and other actions and behaviors may also result in corrective action up to and including
termination.

9.2 DRESS CODE - APPROPRIATE ATTIRE, GROOMING AND UNIFORM POLICY


It is important for all employees to project a professional image while at work by being appropriately attired. JCB
employees are expected to wear an approved JCB branded uniform while on the job. Clothing must be consistent with
the standards for a business environment and must be appropriate to the type of work being performed.

The purpose of the Uniform Policy shall be to maximize safe working conditions and reflect professional appearance.
Wearing a Company uniform is a positive, visual statement by employees of their dedication and commitment to the
success of the team and the Company. Individuals who do not adhere to the above guidelines will be asked to go home
and change.

Employees are reminded to be sensitive of the image they project when wearing the JCB uniform after working hours,
since it represents the Company.

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9.3 UNIFORM POLICY - ADMINISTRATIVE & OFFICE
 Approved JCB logo apparel can be purchased through either the Lands' End JCB store site or through the JCB
Company Store. Only approved JCB logo apparel can be worn as part of the daily uniform policy.

 Each year, the company will provide full-time JCB employees with the opportunity to refresh their uniforms. A
Lands' End certificate code will be provided to each full-time administrative and office staff employees to assist
with this yearly refresh.

 Your JCB shirt should be ironed and fully buttoned. If the shirt style is to be tucked in, please do so. Your slacks
should be “dress slacks” that are also ironed with creases. Jeggings, jeans (black or otherwise) and leggings are
not permissible under any circumstances. Khaki, Dickey or other work pants are not acceptable unless you are
working in the field or the demo site. Slacks should be either black, charcoal grey, or navy. Slacks should be of
an appropriate length. Capris pants are not considered professional dress.

 Skirts should be either black, charcoal grey, or navy; and no more than 3" above the top of the knee.

 Dresses should be limited to those available on the Lands' End JCB Store site.

 Sweaters or vests must be black or grey with or without the JCB logo. If your sweater or vest is without the
JCB logo it should not bear any other logo or design.

 Blazers and sweaters should be black and charcoal grey. Pullover sweater vests or cardigans are acceptable. If
you are expecting customers, you may choose to wear a blazer with your uniform or a black suit with your
company approved JCB shirt/blouse. This applies to ladies and gentlemen.

 Employees should wear well maintained black or brown dress shoes. Sneakers, sandals, or boots over the knee
are not acceptable.

9.4 UNIFORM POLICY - MANUFACTURING


All employees are required to report to work and perform their work in approved uniforms. Replacement uniforms are to
be supplied to employees on an “as needed” basis. To receive a replacement uniform, the employee must return the old
uniform. Each employee is responsible for maintenance and cleaning of their own uniforms. All employees are expected to
arrive at work daily exhibiting a neat, clean, and professional appearance. JCB employees found to be insubordinate, with
respect to this uniform policy, will be subject to disciplinary action or removal from employment in accordance with JCB’s
Policies and Procedures. If an employee is working in Fabrication and chooses to wear a t-shirt while working, the shirt
should be either solid navy blue or black and should be free from any tears or holes. T-shirts should not have any logos
(except for JCB) or images of any kind. Shirts must have a sleeve and be full length.

Manufacturing Operations employees will receive: Five (5) pants, Five (5) shirts, One (1) belt, One (1) jacket

Manufacturing Production employees will receive: Ten (10) pants, Ten (10) shifts, One (1) belt, One (1) jacket

Upon separation from JCB Inc. employees are required to surrender the uniforms they have received. Failure to
surrender the uniforms will result in reimbursement to JCB Inc. for the cost of the uniforms.

9.5 SAFETY & UNIFORMS


Safety Shoe Program (up to $50.00 reimbursement)

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All protective clothing and accessories necessary to ensure the safety and well-being of employees are considered part of
the uniform and must be worn always. This includes but is not limited to high visibility vests, hearing protection and safety
shoes. Any employee who reports to work and fails to wear approved safety shoes or attire, not meeting the criteria
outlined above, will not be allowed to work.

For ladies, only closed toe shoes and short heels may be worn on the manufacturing floor.

9.6 SMOKE & TOBACCO FREE WORKPLACE


JCB is committed to ensuring that a mutually comfortable environment is maintained for all team members. This can only
be achieved through the thoughtfulness and cooperation of both smoking and non-smoking team members.

The Company provides all team members with a safe, healthy and comfortable work environment.

The following guidelines will apply to smoking and the use of smokeless tobacco products (i.e. vape) at JCB:

Plant and Office Areas


· Smoking will not be permitted on company property. This includes: inside the building at any time, in work
areas, while traveling (i.e., walking, riding) between different work areas or in company vehicles.
· The Tobacco/Smoking Area is located to the north side of the building near the wash bays and outside of the
fence. There is a gate about 80 yards from the front to the north side of the building that provides access.
· Effective immediately, there will be no tobacco/smoking in the Employee Parking Lot or anywhere else on JCB
property.

Housekeeping
It is important that team members understand that even when smoking in the designated area, they have a responsibility to
fellow team members to maintain acceptable standards of housekeeping.

These standards include:


· Always using the appropriate receptacles for discarding waste.
· Not throwing cigarette butts on the grounds.
· Not allowing ashes to fall on the grass.

Smokeless Tobacco
The guideline restrictions outlined above for smoking are also applied to the use of smokeless tobacco. Team members
using these products, however, must provide for their own housekeeping/disposal methods. Team members are asked
not to spit in receptacles.

It is JCB’s goal to develop a policy that can accommodate the needs of smokers and non-smokers. To be successful,
however, team members must be considerate of each other’s feelings and work together to provide everyone a good
place to work.

Compliance with this policy is expected with immediate effect and non-compliance will lead to disciplinary action up to and
including termination of employment.

9.7 FALSIFICATION OF INFORMATION


Falsification of any information is prohibited. This includes but is not limited to verbal communication provided to a
member of management, falsifying information on employment applications, qualifications, time records, production
records, sales tickets, expense reports, client records, employee records, sickness records, injury claims, complaints against

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employees, or any other information whether written or documentary that is necessary for the normal operations of
business.

9.8 PERFORMANCE GUIDELINES


JCB has confidence in the good judgment of its employees and sincerely believes that each employee will perform in a
manner consistent with these expectations. Listed below are examples of some of the types of behaviors JCB expects
from employees:

o Support the performance of the team and work to help other employees.
o Help the team to meet its goals and participate in team activities.
o Support and abide by JCB policies, guidelines, and philosophies.
o Promote kaizen, by continually looking for opportunities to make JCB more efficient and the job easier
to perform.
o Achieve quality goals and improve quality standards—immediately correct all improper workmanship
you discover.
o Assist JCB in achieving production goals and schedules.
o Treat every JCB employee with dignity and respect.
o Be honest in dealings with JCB and fellow employees.
o Promote good housekeeping and maintain a safe work environment.
o Come to work each day—absence creates a burden on fellow employees and has a negative effect on
the quality/quantity of JCB’s products.
o Strive to make JCB a showplace—this is our future, and our visitors’ impressions will control our
destiny.
o Perform all responsibilities sincerely.

These performance guidelines can be grouped into six (6) areas. JCB wants employees to:

o Be good “JCB citizens”—refrain from any actions that have a disruptive or negative effect on other
employees or on the efficient operation of the organization.
o Maintain a good attendance and punctuality record.
o Follow all safety rules –always work in a safe manner.
o Perform excellent work—maintain acceptable standards of quality and production.
o Support and abide by JCB policies.
o Provide quality customer service.

9.9 CORRECTIVE ACTION PROGRAM


JCB believes that disciplinary actions that are punitive in nature are not conducive to a positive, productive work
environment. The Corrective Action Program has been designed to address employee performance in a positive manner
by:

 Emphasizing the correction or improvement of the employee's performance.


 Allowing the employee to retain his/her self-respect and dignity during the process.
 Having a series of progressive steps. The Company provides the employee with sufficient notice of the problem
and ample time to implement whatever corrective action is needed to avoid the next level of the program.
 Providing fair and consistent treatment. All decisions are based on the same criterion, which allows us to
consider factors such as am employee's work record; length of service, seriousness of the action, intent, and
actions taken by JCB with other employee's in similar situations. By making decisions on a case-by-case basis,
respect for each employee as an individual rather than a number is ensured.

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Corrective Action

The level of Corrective Action will be determined based upon consideration of the following:

 seriousness of the action;


 contributing circumstances;
 prior work record;
 actions taken with other employees in similar situations;
 intent
 effect on fellow employees and/or JCB business; and
 other relevant factors.

The following is a description of each of the progressive levels of the Corrective Action Program which apply to employees
who have completed their six-month evaluation period:

Oral Reminder – This is a simple conversation between the Employee and Manager. It is used when a team member has
a minor problem that can be corrected by simply bringing it to the attention of the employee. Oral reminders are placed
in the employee's personnel file and will not be considered after a six (6) month period if the employee is able to correct
the performance/behavior problem.

Written Reminder – If an employee fails to correct a problem previously discussed in an Oral Reminder or if the
employee’s behavior is serious enough to skip the Oral Reminder, the employee will be given a Written Reminder. This
corrective action involves a conversation like that in an Oral Reminder along with written documentation of the
conversation and JCB’s future expectations for the employee. The Written Reminder will be placed in the employee's
personnel file and will remain active for a period of 12 months.

Corrective Action Conference – The next level in the corrective action program is the Corrective Action Conference.
This level will be taken if an employee fails to correct a problem or if the behavior is serious enough to bypass the written
reminder level.

The Corrective Action Conference is a formal meeting in which the unacceptable aspects of the employee's
behavior/performance are discussed. The employee is asked to come up with alternative ways to more acceptably handle
similar situations in the future. The employee is given very clear expectations of how to behave/perform in the future and
possible consequences of future unacceptable behavior. A Corrective Action Conference is documented and will be
placed in the employee’s personnel file and remain active for a period of twenty-four (24) months.

Termination/Separation - This is the final level in the Corrective Action Program. At JCB, each employee represents a
tremendous investment of the Company’s time and resources. The Company’s hope is that it is never placed in a position
where an employee's employment must be terminated.

There are certain situations when terminating an employee's employment is necessary. If an employee refuses to respond
to the progressive steps outlined above or if the employee’s behavior is sufficiently serious, their employment at JCB will
be terminated.

The progressive corrective actions that have been detailed above are in place to change behavior/performance, not
punish. It is JCB’s sincere wish that it is never placed in a position where an employee's employment must be terminated
because of his/her behavior/performance.

SECTION 10 - ANTI-HARASSMENT POLICY


10.1 INTRODUCTION

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JCB is committed to providing a positive work environment in which each team member is respected as an individual and
can realize his or her full potential, with equal opportunity for advancement and personal growth.

Consistent with this commitment, JCB strictly prohibits all forms of harassment in the workplace, to include sexual
harassment. Such conduct will not be tolerated at any level at JCB, and any person who is found to have engaged in
harassment will be subject to immediate corrective action, up to and including immediate termination of employment.

Sexual harassment consists of unwelcome sexual advances, requests for sexual favors or other verbal or physical conduct
of a sexual nature where (1) submission to such conduct is made a condition or term of employment; (2) an employment
decision (such as promotion or job assignment) is based on acceptance or rejection of such conduct; or (3) such conduct
interferes with a team member’s work performance or creates an intimidating, hostile or offensive work environment.

Sexual harassment takes a variety of forms and may involve personnel in any position and at any level of responsibility.
Although it would be impossible to list all forms of sexual harassment, we have set out below some types of conduct
which violate JCB’s sexual harassment policy:

Intentional physical conduct of a sexual nature, such as touching, fondling, pinching, patting or grabbing another team
member;

• Making unwelcome or persistent sexual advances toward another employee;


• Making sexual comments, jokes, noises or gestures to, or in the presence of another employee;
• Using explicit or derogatory sexual terms about, or in the presence of, another employee;
• Displaying sexually explicit or sexually oriented materials in the workplace including, but not limited to, magazines,
posters, calendars, photographs, sketches or cartoons;
• Granting or promising preferential treatment to an employee in exchange for submitting to or participating in sexual
conduct; Threatening an employee directly (or implicitly) with termination, demotion, poor evaluation, or other
detrimental or retaliatory conduct to obtain sexual favors;
• Retaliating in any way against an employee who has complained of or reported sexual harassment, or who has
participated in the investigation of such conduct.

If any employee believes that he/she has been subjected to harassment at JCB, or has witnessed or has knowledge of such
behavior, we urge him/her to report such conduct immediately. To fully protect employees, we must be notified of
harassment at the first opportunity. By reporting such conduct, an employee is not only protecting himself/herself, but also
others who may be subject to similar conduct in the future.

Incidents of harassment may be reported to an employee’s immediate supervisor or the Human Resources Manager.
Every complaint of harassment will be promptly and thoroughly investigated. Such complaints will be handled
confidentially, to the extent consistent with a complete investigation. Where an investigation confirms the existence of
harassment (sexual or otherwise), prompt Corrective Action imposed will vary according to the nature and severity of the
employee’s conduct, but may involve any level of Corrective Action, up to and including immediate termination of
employment. Of course, no employee will be subject to any form of retaliation for making a good faith report or
participating in an investigation of sexual or other forms of harassment.

Harassment is illegal, counterproductive and demeaning to the victim. Every employee is entitled to dignity and respect in
the workplace. JCB will make every reasonable effort to ensure that employees are afforded this basic privilege of
employment; however, this is a responsibility shared by all. The cooperation of every employee is essential to create a
positive working environment at JCB.

SECTION 11 - TIME OFF & LEAVES OF ABSENCES


11.1 GENERAL POLICY

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The Company offers certain types of unpaid leaves of absence to eligible employees such as:

• Family Medical Leave Act (FMLA)


• Qualifying Exigency Leave
• Military Caregiver Leave
• Military Leave
• Personal Leave
• Other State Mandated Leaves

In addition, the Company offers certain paid leave of absences such as paid time off ("PTO"), bereavement/funeral leave,
jury duty or witness leave, paternity leave and parental leave. Eligibility requirements and the amount of time available for
each type of leave may vary. Employees must contact Human Resources and his or her manager for approval of a leave of
absence.

11.2 FAMILY AND MEDICAL LEAVE ACT ("FMLA") - ELIGIBILITY


Upon hire, JCB provides all new employees with notices required by the U.S. Department of Labor (DOL) on Employee
Rights and Responsibilities under the Family and Medical Act (FMLA).

The function of this policy is to provide employees with a general description of their FMLA rights. In the event of any
conflict between this policy and the applicable law, employees will be afforded all rights required by law.

Eligible Employees
Only eligible employees are entitled to take FMLA leave. An eligible employee is one who:

 Works for a covered employer;


 Has worked for the employer for at least 12 months;
 Has at least 1,250 hours of service for the employer during the 12-month period immediately preceding the
leave; and
 Works at a location where the employer has at least 50 employees within 75 miles.

Leave Entitlement
Eligible employees may take up to 12 workweeks of leave in a 12-month period for one or more of the following reasons:

 The birth of a son or daughter or placement of a son or daughter with the employee for adoption or foster care;
 To care for a spouse, son, daughter, or parent who has a serious health condition;
 For a serious health condition that makes the employee unable to perform the essential functions of his or her
job; or
 For any qualifying exigency arising out of the fact that a spouse, son, daughter, or parent is a military member on
covered active duty or call to covered active duty status.

A serious health condition is defined as a condition that requires inpatient care at a hospital, hospice or residential medical
care facility, including any period of incapacity or any subsequent treatment in connection with such inpatient care or as a
condition that requires continuing care by a licensed health care provider.

This policy covers illnesses of a serious and long-term nature, resulting in recurring or lengthy absences. Generally, a
chronic or long-term health condition that would result in a period of three consecutive days of incapacity with the first visit
to the health care provider within seven days of the onset of the incapacity and a second visit within 30 days of the
incapacity would be considered a serious health condition. For chronic conditions requiring periodic health care visits for
treatment, such visits must take place at least twice a year.

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Employees with questions about what illnesses are covered under this FMLA policy or under the company's sick leave
policy are encouraged to consult with the Human Resource manager.

If an employee takes paid time off for a condition that progresses into a serious health condition and the employee
requests unpaid leave as provided under this policy, the company may designate all or some portion of related leave taken
as leave under this policy, to the extent that the earlier leave meets the necessary qualifications.

11.3 QUALIFYING EXIGENCY LEAVE


Qualifying exigency leave for families of members of the National Guard or Reserves or of a regular component of the
Armed Forces when the covered military member is on covered active duty or called to covered active duty.

An employee whose spouse, son, daughter or parent has been notified of an impending call or order to covered active
military duty or who is already on covered active duty may take up to 12 weeks of leave for reasons related to or affected
by the family member’s call-up or service. The qualifying exigency must be one of the following: a) short-notice
deployment, b) military events and activities, c) child care and school activities, d) financial and legal arrangements, e)
counseling, f) rest and recuperation, g) post-deployment activities, and h) additional activities that arise out of active duty,
provided that the employer and employee agree, including agreement on timing and duration of the leave.

Covered active duty means:

• In the case of a member of a regular component of the Armed Forces, duty during the deployment of the
member with the Armed Forces to a foreign country.
• In the case of a member of a reserve component of the Armed Forces, duty during the deployment of the
member with the Armed Forces to a foreign country under a call or order to active duty under a provision of law
referred to in Title 10 U.S.C. §101(a)(13)(B).

The leave may commence as soon as the individual receives the call-up notice. (Son or daughter for this type of FMLA
leave is defined the same as for child for other types of FMLA leave except that the person does not have to be a minor.)
This type of leave would be counted toward the employee’s 12-week maximum of FMLA leave in a 12-month period.

11.4 MILITARY CAREGIVER LEAVE


Military Caregiver Leave, also known as covered service member leave, to care for an injured or ill service member or
veteran.

An employee whose son, daughter, parent or next of kin is a covered service member may take up to 26 weeks in a
single 12-month period to take care of leave to care for that service member.

Next of kin is defined as the closest blood relative of the injured or recovering service member.

The term covered service member means:


• A member of the Armed Forces (including a member of the National Guard or Reserves) who is undergoing
medical treatment, recuperation or therapy or is otherwise in outpatient status, or is otherwise on the temporary
disability retired list, for a serious injury or illness.

• A veteran who is undergoing medical treatment, recuperation or therapy for a serious injury or illness and who
was a member of the Armed Forces (including a member of the National Guard or Reserves) at any time during
the period of five years preceding the date on which the veteran undergoes that medical treatment, recuperation
or therapy.

The term serious injury or illness means:

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• In the case of a member of the Armed Forces (including a member of the National Guard or Reserves), an injury
or illness that was incurred by the member in line of duty on active duty in the Armed Forces (or that existed
before the beginning of the member’s active duty and was aggravated by service in line of duty on active duty in
the Armed Forces) and that may render the member medically unfit to perform the duties of the member’s
office, grade, rank or rating.

• In the case of a veteran who was a member of the Armed Forces (including a member of the National Guard or
Reserves) at any time during a period when the person was a covered service member, a qualifying (as defined
by the Secretary of Labor) injury or illness that was incurred by the member in line of duty on an active duty in
the Armed Forces (or that existed before the beginning of the member’s active duty and was aggravated by
service in line of duty on active duty in the Armed Forces) and that manifested itself before or after the member
became a veteran.

11.5 FMLA - LENGTH OF TIME AVAILABLE


An FMLA leave of absence cannot exceed a total of twelve (12) workweeks or twenty-six (26) for the care of an injured or
ill service member in a rolling twelve (12) month period. The service member leave of absence, of up to 26 workweeks,
is only available during a single twelve month period. FMLA leave of absence for the birth and care of a newborn child, or
the adoption or placement of a child in foster care must be taken within 12 months of the birth, adoption or placement of
the child.

11.6 FMLA - INTERMITTENT LEAVE


The employee may take FMLA leave in 12 consecutive weeks, may use the leave intermittently (take a day periodically
when needed over the year) or, under certain circumstances, may use the leave to reduce the workweek or workday,
resulting in a reduced-hour schedule. In all cases, the leave may not exceed a total of 12 workweeks (or 26 workweeks to
care for an injured or ill service member over a 12-month period).

11.7 FMLA - PROCEDURE FOR REQUESTING FMLA LEAVE


All employees requesting FMLA leave must provide a member of Human Resources with a verbal or written notice of the
need for the leave. Within five business days after the employee has provided this notice, the appropriate Human
Resources representative will provide the employee with the DOL Notice of Eligibility and Rights.

• When the need for the leave is foreseeable, the employee must provide the employer with at least 30 days'
notice.
• When an employee becomes aware of a need for FMLA leave, less than 30 days in advance, the employee must
provide notice of the need for the leave either the same day or the next business day.
• When the need for FMLA leave is not foreseeable, the employee must comply with the Company’s usual and
customary notice and procedural requirements for requesting leave.

11.8 DESIGNATION OF FMLA LEAVE


Within five business days after the employee has submitted the appropriate certification form, the HR manager will provide
the employee with a written response to the employee's request for FMLA leave.

11.9 FMLA - RETURNING FROM LEAVE


The Company may require an employee on FMLA leave to report periodically on the employee’s status and intent to
return to work. Furthermore, an employee who takes leave under this policy may be asked to provide a fitness for duty
(FFD) clearance from the health care provider

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In cases where state law would provide the employee with greater rights than the federal law, state law will be followed.

11.10 MILITARY LEAVE - ELIGIBILITY AND PURPOSE


JCB is committed to protecting the job rights of employees absent on military leave. In accordance with federal and state
law, it is the company’s policy that no employee or prospective employee be subjected to any form of discrimination
based on their membership in or obligation to perform service for any of the Uniformed Services of the United States.
Specifically, no person will be denied employment, reemployment, promotion or other benefit of employment based on
such membership. Furthermore, no person will be subjected to retaliation or adverse employment action because such
person has exercised his or her rights under applicable law or Company policy. If any employee believes that he or she
has been subjected to discrimination in violation of Company policy, he or she should immediately contact Human
Resources.

JCB supports and accommodates employees who are members of the U. S. Armed Services or National Guard and who
are called to serve a period of short-term military duty. A leave of absence to cover the time that is missed from work will
be granted. You will be provided the opportunity to return to the same position you held prior to the leave. To receive
approval for the leave, you must complete a “Request for Military Leave of Absence” form and hand this in to your
manager and Human Resources, along with your military orders.

Employees who are out on approved military leave will be compensated the difference between their JCB base pay and
their total military pay; this differential pay benefit is only provided to employees who have been with the Company for
twelve (12) months. In the event the employee’s military pay exceeds their JCB base pay, no payment will be made.

11.11 PERSONAL LEAVE OF ABSENCE


JCB understands that personal situations can develop which result in an employee needing time away from work.
Personal leaves of absence will only be granted when it is determined that a serious situation exists for an employee that
cannot be effectively addressed in any other matter.

Regular JCB employees who plan to be absent for more than five (5) consecutive workdays due to non-medical reasons,
must request, in advance, a Personal Leave of Absence by completing a “Personal Leave of Absence Request” form. All
requests must be submitted through your manager and to Human Resources for approval. Requests will be addressed on
a “case by case” basis taking into consideration the reason for the request and the current operating requirements for JCB.

Personal leaves of absence will initially be granted for a maximum period of thirty (30) days. If the employee requires
additional time, extensions will be evaluated and considered by JCB. Personal leaves will not be granted for vacation
purposes or to attend to routine personal business that could be addressed during non-working hours.

Employees on an approved Personal Leave of Absence will not receive pay for time lost. Benefits may remain in effect
during the leave of absence only if the employee plans to continue payment of insurance premiums. Should an employee
fail to return from Personal Leave of Absence on the first scheduled work day, JCB will assume that he/she has voluntarily
terminated his/her employment effective on the first scheduled work day that is missed following expiration of leave.

All regular employees employed for a minimum of 90 days are eligible to apply for an unpaid personal leave of absence.
Job performance, absenteeism and departmental requirements will all be taken into consideration before a request is
approved.

Please contact Human Resources for more information on request procedures.

11.12 PATERNITY LEAVE


• Three (3) consecutive days of paid Paternity Leave for fathers for the birth of their child.

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11.13 PARENTAL LEAVE
• Eligible team members get additional PTO for activities related to the care and well-being of their newborn or
adopted child
• One (1) additional week of PTO for each year following the birth or the coming of the child into custody, care
and control of the parent for the first time, up to a total of three years.

SECTION 12 - SAFETY & SECURITY


12.1 SAFETY AND SECURITY IN THE WORKPLACE
JCB is committed to providing the safest possible workplace through the security system. For this to work correctly, each
employee must recognize and accept their individual responsibility as users of this system. Remember, we are responsible
for our own safety and security at JCB.

Employees are reminded of the purpose for the security access cards:

 Preparation for foreign trade zone agreements.


 Control access to the property.
 Provide accountability in event of an emergency evacuation from the building.

Each employee is issued a security access card. These cards allow only the issued user access to the building. They are
not to be used by family members or guests you invite to JCB.

Employees should challenge anyone who enters their work area without a visitor badge or who is doing anything that
looks suspicious in nature. If you do not recognize the individual, you should report their presence to your manager or
security promptly.

After normal business hours employees are encouraged to call security to advise of their departure. Using cameras,
security can observe an employee exit the building and safely reach his/her vehicle.

After 8:30 PM, and on weekends, employees will use their employee badges to gain access to the building. While the
security officer will know that a specific employee is in the building via this procedure, the system does not “flag” entrance.
To ensure the security officer is aware of the employee’s presence, the employee should call the security officer and
advise their arrival, exit, location and anticipated length of stay. As the security officer makes physical rounds, once every
two hours, and will check on the employee. When departing, the employee should call and advise the security officer. If
the employee has not called the security officer by the anticipated departure time, the security officer will call for an
updated anticipated departure. If the employee does not respond to the security officer’s call, she/he will physically check
on the employee. If the employee cannot be located, the security officer will notify management and/or the Human
Resources Manager. Management will determine appropriate next steps.

Working together to ensure these procedures are followed will guarantee the safety and security of all JCB employees and
visitors.

12.2 VISITORS
If you are expecting a guest or family member, please notify security before they arrive at the front gate. Guest and family
members arriving on foot or vehicle must check in at the front gate before they are allowed access on the property.

Employees must not allow other employees to use their cards. This also means not allowing visitors, temporaries, and
especially any unknown or unauthorized person to use your access card when entering or exiting the building.

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Visitors, guests, family members, and customers are to enter and leave through the building front entrance and sign in/sign
out at the front desk. Visitors are to be escorted always. Dealer and customer groups will always be escorted through the
plant, as well as enter and leave through the front entrance.

12.3 DRUG-FREE WORKPLACE


Employees who abuse, use, possess or are under the influence of drugs and/or alcohol at work or on the Company’s
property present a hazard to themselves, other team members, customers and in some instances, the public. In addition
to the potential criminal consequences of their conduct, these employees are a safety risk, reduce productivity, damage
morale and contribute to increased medical costs.

It shall, therefore, be the policy of JCB to prohibit the illegal use, sale, manufacture, distribution, transfer or possession of
illegal drugs while on the job, operating Company vehicles, or on Company property. Prohibit the use or possession of
alcohol on Company property, except at Company sponsored social events (i.e. Christmas Party), and during business
related meetings or involving entertainment of customers. Prohibit employees from working under the influence of illegal
drugs and/or unauthorized controlled substances such as alcohol. JCB employees are required to comply with this policy
as a condition of employment. A violation of this policy constitutes grounds for corrective action, up to and including
termination of employment. Any illegal drug found on Company property will be turned over to the appropriate
authorities. In addition, failure to comply with a drug or alcohol testing request will be considered a positive result. A test
initiated in accordance with this policy by the Company that results in a confirmed positive result, will be grounds for
terminating the employee’s employment. An employee who comes forward on a voluntary basis, prior to an initiated test,
and who tests positive, will be allowed to be a candidate for rehabilitation through the Employee Assistance
Program/Medical Provider. Any employee who fails to rehabilitate will be terminated.

Definitions

 Drug: any substance capable of altering an individual’s mood, perception, pain level or judgment to include
alcohol.
 Prescription drug: any substance prescribed for individual consumption by a licensed medical practitioner.
 Illegal drug: a controlled substance, the general sale or consumption of which is prohibited by law.
 Substance abuse: the use of any substance (including alcohol, legally obtained over-the-counter medications,
prescription drugs, or illegal drugs) such that the user experiences physical, emotional, or social complications
which threaten or impair their well-being or the well-being of others.
 Company property: includes all facilities, land, Company vehicles, parking lots and building structures.

Prescription Drugs
No prescription drug shall be brought on or consumed on Company property by any employee other than the one for
whom it is prescribed. Such drugs will be used only in the manner, combination and quantity prescribed, and if its use will
not impair performance or impact safety.

Those employees who use prescribed drugs which may cause drowsiness or in some manner affect work
performance/behavior must be cleared by their physician and the safety specialist prior to reporting to work.

Handling Substance Abuse Situations


Handling substance abuse is a very sensitive issue. Managers who observe employees who appear to be impaired, or
who suspect that there may be a substance abuse problem should notify their direct supervisor and Human Resources.

Together the Human Resources representative and manager will assess the situation, determine the next step and, if
necessary, refer the employee for appropriate substance abuse screening.

Illegal Substance Searches

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Based on reliable information, it may become necessary to conduct searches of the property or, in some cases, individual
property, such as items contained in lockers or vehicles, parked on Company property, for illegal substances. Such
searches must meet a “reasonableness standard”, which means there must be reasonable suspicion that there is an illegal
substance on the property or in possession of an individual. This search may be initiated by the Company or by law
enforcement authorities based on the reliable information meeting the “reasonableness standard.” Any illegal substance(s)
found during the search process will be turned over to law authorities and be subject to the full enforcement of the law.

Post Incident: Drug Testing


Testing for drugs and alcohol will occur immediately after an on-the-job incident which results in:

• Damage to Company property.


• Anyone receiving work-related medical treatment or responsible for causing a work-related incident.
• An operational error that results in the release of a non-permitted, hazardous or toxic substance.

Random Drug Testing:


Under the direction of Human Resources, a random selection will be used to identify employees to be tested each month.
Ten percent of the number of employees will be tested each year, this percentage is at management’s discretion. Each
month, 1/12th of this percentage will be selected and tested.

Since the selection is random, the same employee may be selected more than once or not at all. Should the selected
employee not be available due to Company travel, vacation, illness, etc., they will be notified and tested immediately upon
return to work.

All JCB employees and applicants for positions with the Company will be required to complete and sign a consent form,
or one provided by the designated medical provider before the actual testing takes place.

Refusal to sign a consent form will be considered and treated as a positive result.

Drug Testing
All aspects of the testing procedure will be carried out in a confidential and private manner. After notification by JCB, the
employee or applicant will report to the on-site location or designated collection site and will:
• Be notified by the service provider of the testing protocol.
• Assist in completing a Drug Testing Chain of Custody and Control form.
• Provide a specimen i.e. urine or a swab.
• Be expected to observe the complete collection, processing and chain of custody of the specimen.
• Be instructed to read (or have read to them), as well as sign and date the chain of custody statement certifying
the specimen is that of the individual’s and has not been changed or altered at the time of the collection.
• Note the temperature reading on the collection bottle and verify the temperature reading was recorded on the
form.

The Company’s on-site representative or designated medical provider reserves the right to observe the specimen
collection process and / or request that a new one be provided where there is reasonable cause to believe that the
specimen has been altered or substituted.

All Confirmation testing of the specimen will be done by a National Institute of Drug Abuse or College of American
Pathologists approved laboratory.

Alcohol Testing
The screening profile for both reasonable cause testing and post-incident testing includes alcohol. The policy for identifying
the presence of alcohol may use either the individual’s blood or breath as a source.

The Employee consent form applies to either blood or breath specimens of alcohol and a urine specimen for drugs. The
Employee must sign the consent form before testing proceeds.
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The following two methods will be used to test for alcohol. The method selected will be determined by the administering
official. The designated service provider will follow established, legal protocol.

Blood Alcohol Testing


A licensed physician, registered nurse, or certified medical technologist is required to obtain the blood sample.

Breath Alcohol Testing


A certified breath alcohol technician (BAT) using an evidential breath testing (EBT) device is required for breath testing (in
accordance with Department of Transportation regulations).

Reasonable Cause Test Results


Employees may be required to submit to immediate Reasonable Cause Testing. Employees will continue to be paid
pending receipt of test results.

If test results are negative the employee will return to work. If test results are positive, the employee is subject to
corrective action, including termination of employment in cases involving the use, possession, or distribution of illegal drugs
or alcohol during working hours while on the job (including Company travel) or on Company property.

Post Incident Test Results


If appropriate (as determined by the Safety Specialist, Human Resources and Manager), the tested employee will be
allowed to return to work if the substance abuse test is negative. If the test results are positive, the employee’s
employment will be terminated as soon as positive test results can be confirmed with testing facility.

Voluntary Testing with Positive Results


Employees who voluntarily submit to Drug / Alcohol testing will be subject to the following procedures:

• The employee will be notified of positive results.


• The Company’s medical provider will be available to discuss the results with the individual.
• Medical justification, i.e. medically prescribed drugs taken in prescribed quantities, will allow the Company’s
medical provider to verify the results as negative.
• There will be immediate and unpaid suspension of the employee after a confirmed positive test result (except as
described for any confirmed post-incident positive test). The employee will be notified by Human Resources
and their manager.
• A meeting will be arranged between the employee and a representative of the Employee Assistance Program /
Medical Provider. Counseling will be required, and a plan of treatment or rehabilitation will be developed.
• The Employee must agree in writing to comply with the health provider’s recommended treatment or
rehabilitation plan.
• The Employee must sign a release form authorizing the health provider to inform JCB regarding participation in
the treatment program.
• The Employee may return to work following successful completion of the rehabilitation or treatment program
with the recommendation of the health provider’s rehabilitation counselor, or treatment professional and
completion of a negative drug screen. If the Employee has not returned to work within sixty (60) days of the
initial date, the Employee will be terminated from employment.
• The Employee must agree to unannounced, periodic testing for two years following the return to work. This will
include a minimum of six (6) random tests over a 24-month period of time.
• Employee’s employment will be immediately terminated if he/she tests positive during the 24-month period.

Employee Assistance Program


JCB offers Employees and family member’s professional help in assessing substance abuse problems through the
Company’s EAP / Medical Provider Program. Rehabilitation, if appropriate, may be obtained through the Company’s
medical coverage. Employees are responsible for non-covered costs.

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Employees are strongly encouraged to voluntarily take advantage of the Employee Assistance Program / Medical Provider’s
services for confidential counseling and treatment or rehabilitation assistance before becoming subject to corrective action
under the Performance Guidelines Policy.

Record Keeping
 All drug and alcohol testing information specifically relating to individual Employees and applicants will be treated
as confidential and protected in accordance with Occupational Safety and Health (OSHA) regulations.

 Employees will be identified with an assigned number other than their social security number. On a regular basis,
a compilation of statistical data, including test results, may be submitted to Human Resources by the Medical
Provider.

 Any Employee who is subject to substance abuse testing, will upon written request, have access to and may
obtain a copy of their results.

 All test results will be maintained in the Employee’s medical file, separate and apart from the Employee’s
personnel file.

JCB Commitments
Contractors / Vendors will be required to demonstrate that they have an established drug and alcohol testing policy as a
requirement to contract work with JCB.

Contractor / vendor personnel who violate their Company substance abuse policy or JCB’s policy while on JCB property
or business will be barred from Company jobs and its property.

No Employees will be required to undergo drug / alcohol testing on their scheduled days off.

No Employee will be randomly selected for testing more than three (3) times in a twelve (12) month period.

Employee Education Program


Twice a year, Human Resources will provide a training program on substance abuse and its effects on the workplace.

The training program will be conducted over a one-hour time and will include a review of JCB’s Substance Abuse Policy,
outline the Employee Assistance Program / Medical Provider benefits available to Employees through the Company’s
health provider.

12.4 SUBSTANCE ABUSE - PROHIBITED CONDUCT


• The use, sale or possession of alcohol on Company property or during work hours.
• The use, sale, manufacturing, distribution, purchase or possession of illegal narcotics, drugs or controlled
substances while on the job or on Company property, and the use any lawful drugs other than as prescribed for
that Employee.
• The use of controlled substances prescribed by a licensed physician in not prohibited. However, employees
taking controlled substances that may impair their job performance are required to make such use know to
Human Resources.

The term "on the job" includes all work hours and any rest or meal periods that occur during the business day. The term
"Company property" includes the store premises including parking and shared areas, vehicles owned or leased by the
Company, and personal vehicles while use on Company business. Violation will result in disciplinary action up to and
including termination.

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12.5 SUBSTANCE ABUSE - FOR CAUSE AND REASONABLE SUSPICION SCREENING

To ensure that illegal drugs or alcohol do not enter or affect the workplace, the Company may take any or all of the
following steps while employees are on Company property or on the job:

• Observing the employee's actions;


• Counseling the employee;
• Performing or ordering chemical screening (i.e. urinalyses, blood tests, etc.) as permitted by state law; and/or
• Performing searches in accordance with the Company's Search & Seizure policy.

12.6 SUBSTANCE ABUSE - PRE-EMPLOYMENT SCREENING: TESTING FOR DRUGS


AND ALCOHOL
JCB shall require candidates for jobs with the Company, as a condition of employment, to submit to substance abuse
screening. Candidates who refuse to submit to the required tests are not eligible for employment.

Candidates who test positive for:


• Illegal drugs
• Drugs not prescribed to the candidate
• Drugs prescribed but present in non-prescribed quantities
• Drugs prescribed to the candidate but not disclosed on the informed consent and release of liability form shall not
be eligible for hire.

Positive alcohol tests will also result in applicant not being eligible for hire.

12.7 SUBSTANCE ABUSE - CURRENT EMPLOYMENT: TESTING FOR DRUGS AND


ALCOHOL

Employees will be required, as a condition of employment, to submit to substance abuse screening when there is
reasonable suspicion to believe that a Employee is under the influence of an illegal drug and / or alcohol. The following
circumstances could cause reasonable suspicion:
• Observed drug or alcohol use.
• Apparent physical state of impairment.
• Incoherent mental state.
• Marked change in personal behavior that is otherwise unexplainable.
• Deteriorating work performance that is not attributable to other factors.
• Any circumstance which causes a reasonable suspicion that a Employee is under the influence of illegal drugs or
alcohol.

If a leader suspects an employee at work is under the influence of alcohol or a controlled substance they can be tested on-
site or transported to a designated medical provider. The leader is responsible for arranging transportation if the
employee is taken to a medical provider.

Before transporting to the medical provider, the most senior leader on-site or a Human Resources representative must
complete an “Authorization for Treatment Form”, at the time the test is to be administered

Employees operating company vehicles that require a commercial driver’s license must have an annual drug test in
accordance with the Department of Transportation requirements.

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Furthermore, employees operating Company assigned fleet vehicles must have annual drug test conducted on site.

SECTION 13- TRANSPORTATION SAFETY


13.1 GENERAL LEGAL REQUIREMENTS & TRANSPORTATION SAFETY FOR ALL
DRIVERS
It is the responsibility of the driver to ensure that legal requirements such as the use of seat belts, installation and use of
child car seats, etc. are met. All JCB North America employees who are required to operate a motor vehicle, as part of
their role, should have current and sufficient auto insurance. For those operating Company fleet or pool vehicles they will
be provided as a benefit that accompanies the assigned vehicle.

If an employee, who is required to drive a pool or fleet vehicle for his or her position, loses the right to operate a vehicle,
he or she is required to notify his or her direct supervisor immediately. Failure to report any changes may invalidate
Company insurance coverage, thus placing the Company and employee at risk. JCB reserves the right to withdraw a
Company vehicle from a dedicated user without notice depending on the seriousness of the situation, as well as address
with disciplinary action, up to and including termination.

The Company reserves the right to review current employees motor vehicle record and driving histories on an annual
basis to determine ongoing edibility and insurability.

13.2 RECOVERING THE COST OF BUSINESS MILEAGE


Fuel consumed for business use should be claimed back through the normal expense procedure.
Toll and parking charges will be reimbursed where reasonable.

13.3 MOTOR VEHICLE RECORD


The Company will implement a motor vehicle matrix as part of the standard new hire background screening process. As
such, the company will continue to utilize a third-party background screening provider, which captures employee motor
vehicle record status and history as part of the traditional background screening procedure. Motor vehicle reports will be
reviewed initially at the start of an employee’s hire process and then annually to evaluate individual driver performance.
This procedure includes grading that ranges from acceptable, conditional, and unacceptable violations. Failure to meet
Company expectation will result in disciplinary action up to and including termination, as well as eligibility to drive
Company vehicle(s).

All employees who are asked to drive on Company business, whether in their own vehicle, fleet, rental, or pool cars must
produce their license for review by the Human Resources Representative responsible for fleet and pool cars prior to
driving. In the case of rental cars, upon request by the rental car company.

13.4 MOTOR VEHICLE POLICY STATEMENT, EXPECTATIONS AND COMPANY MATRIX


The Company’s goal is to ensure that vehicle risk is continually reviewed to minimalize, as vehicle operations create a
substantial risk for the company. By initially and annually evaluating a driver’s motor vehicle record, the Company will
reduce vehicle risk by placing only safe drivers in Company vehicles, as well as those conducting Company business in
personal vehicles.

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The provisions of the Motor Vehicle Policy and matrix JCB North America observes are classified as major, minor, and
non-moving. Non-moving are typically not included in the evaluation process. Accidents are often classified as preventable
or non-preventable.

By observing the matrix, it is the expectation that employees have exhibited safe driving practices during the past three (3)
years. Employees who fail to meet safe driving qualifications will not be considered for employment. Violations of current
employees, that are identified during annual motor vehicle screenings, will be addressed with progressive disciplinary
action up to and including separation from the Company.

13.5 ACCIDENT PROCEDURE


Accidents do not just happen - there is always a cause and a subsequent effect. When an accident does occur, it is vital
that no admission of fault is accepted by the Company driver, or any person driving as an agent of the Company, whatever
the apparent circumstances.

Call 911 immediately if an accident happens, stay calm, move away from other vehicles involved, collect and exchange
information in accordance with the policy.

The driver should provide insurance details to all drivers involved; obtain insurance details, names and addresses and
registration number(s) of other vehicles involved; photographs should, where possible, be taken of damage to vehicles
involved; witness names and addresses; details of any police officer in attendance and any other information relevant to the
incident.

If any other party involved admits responsibility at the scene of the incident, a written statement should be obtained. The
other party and/or parties must not be placed under any duress. Any communication received from any party after the
incident must be sent to the insurance Company immediately, without acknowledgement. It is not the responsibility of the
driver to become involved except at the request of the Company.

All drivers, specifically those driving Company vehicles, should be familiar with the Company’s Accident Reporting
Procedure. In the trauma of an accident, it is easy to forget information required at the scene. If you do have an accident,
the form is used to report it.

It is a legal requirement that in the case of an accident involving personal injury to any party involved, or damage to road
fixtures or fittings or to other third-party property, the incident must be reported to the police as soon as possible and in
any case, within 24 hours. Should the police decline to take note of your report, in the driver's and in the Company's
interest, details of the time, date and place of the report, whether written or verbal, along with the name of the officer
concerned, should be noted.

Accidents involving personal injury to employees should also be reported immediately to the Human Resources
Department.

All drivers must report accidents and damages immediately to our insurance company. If, after investigation, the accident is
proved to be the employee's fault by inappropriate driving or conduct, disciplinary action will be considered.

13.6 DRIVING & PARKING OFFENSES


Drivers are personally responsible for fines or charges which may arise from their use of the vehicle. This includes such
offenses as parking and speeding but does not exclude other relevant offences. The driver must pay any fine or charge if
guilt is accepted. If guilt is not accepted, it is the driver's responsibility to take such steps as necessary to establish a
defense.

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The driver is responsible for the timely payment of fines or charges levied by the appropriate authority. If the leasing
company or the Company is forced to make such payment, the cost plus an appropriate administration charge, will be
passed on to the driver to whom the vehicle has been allocated, even if such person has authorized another person to
drive as an agent of the company.

13.7 WORKING HOURS & REST BREAKS


It is important that drivers are aware of the risks of becoming fatigued whilst on the road and plan their journeys to enable
them to take sufficient rest breaks. Rest breaks are required for professional drivers (i.e. commercial vehicles or vehicles
fitted with a tachograph) to comply with current legislation and, as such, it is the expectation of the Company that this be
adhered to.

For non-professional drivers, a 15-minute break after every 2 hours driving is recommended, or a compulsory 30-minute
break after every 4.5 hours driving.

A working day must consist of no more than 13 working hours, giving a minimum 11-hour daily rest period in any 24
hours

13.8 BEST PRACTICES FOR FLEET SAFETY


Where an employee is required to drive as part of their role, the following driving approaches apply and should be
considered while operating a motor vehicle issued by the Company. Please note these are best practices for all JCB, Inc.
employees operating Company issues, but should be observed by all Company drivers:

When approaching hills, expect the unexpected, be aware, and drive slowly. When descending downhills be sure to
reduce speed, downshift to an appropriate gear and do your best to maintain a safe speed limit to reduce skidding. If you
identify a need to brake or stop, check your surroundings through your mirror to communicate your actions to others
sharing the road.

Approach intersections with confidence, at a safe speed, and be prepared to yield the right of way even if it legally belongs
to you. Never assume the other driver will stop. Be aware of other vehicles approaching and/or passing through
intersections. Ultimately have your vehicle under control always. Keep in mind that rear end collisions are often
preventable and can be reduced by simply being aware of your surroundings. Ensure that vehicle mirrors and windows are
adjusted, as well as clean, to ensure visibility of others on or around the exterior of the vehicle.

Protect yourself and the Company by making a habit of buckling up. Seatbelts keep you secure and alleviate any bouncing
around in the event of an accident. If buckled up properly, drivers can avoid injuries, unconsciousness, and being thrown
from the vehicle in the event of crash. Move slowing when backing out or in reverse. Be sure you can see clearly and are
seen by other drivers around you. It is recommended that the driver conduct a review of vehicle surroundings prior to
entering their vehicle. Upon backing up it is best practice to keep control by ensuring your foot is on the break. Double
check blind spots as you back up and don’t rely solely on mirrors.

To avoid overhead damage for larger fleet vehicles, employees should utilize GPS whenever possible. This will aid in the
calculation of safe routes. In the even that overhead clearance has placed the driver and vehicle in a potentially hazardous
situation it is the responsibility of the fleet vehicle driver to contact the authorities for proper guidance.

13.9 DRIVING FOLLOWING TRAVEL


An employee’s working day (including travel time to work, working time and travel time to destination) should not exceed
13 hours. Where possible, travel time in terms of flying and driving should be limited following a full or partial days’ work.

For example, if an employee travels overseas in the afternoon/evening of a working day, and at the end of the flight their
working day exceeds 13 hours, they should either travel by taxi, or, obtain reasonably priced overnight accommodation

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close to the airport, the cost of which will be reimbursed by the Company. This will need to be planned and employees
should consider this safety precaution when planning their journey. If an employee feels comfortable to drive following air
travel, as there will be an opportunity for sustained rest during the flight, then they should do so with care, taking regular
breaks.

Employees who feel uncomfortable to drive alone in overseas locations should discuss this with their manager and should
not be asked to do this alone where it is not reasonable. Once again, this should be considered in advance of the journey.

13.10 DRINKING, DRUGS AND DRIVING


JCB Inc. is a Drug Free Workforce Employer and will not tolerate the use of intoxicants before or while driving. It is the
responsibility of the driver to ensure that legal requirements are met and that ability to drive is not impaired. Please be
aware that the risk of accidents increases well before the legal limit is reached and the Company advises drivers not to
drink alcohol at lunchtime, during meals out when entertaining, or at night if driving is planned for the next morning. This
extends to the use of properly prescribed drugs where the driver must ensure that driving is undertaken only with the
advice of a properly qualified medical practitioner. The Company will accept no responsibility for consequences of a
prosecution.

13.11 MOBILE DEVICES


Don’t be a distracted driver, as it can significantly impair your reaction time, speed, position on the road, judgement of
traffic gaps, and overall general awareness of others you’re sharing the road with. Be attentive and practice keeping both
hands on the wheel and be aware of your surroundings and potential hazards in your environment.

Use of a cell phone while driving is not recommended in any situation and employees are expected to refrain from using
their phone while driving. Employees are strongly encouraged to pull off to the side of the road and safely stop the vehicle
before placing or accepting a call. If acceptance of a call is unavoidable and pulling over is not an option, employees are
expected to keep the call short. The Employee Handbook strictly prohibits employees from using a cell phone without a
hands-free device while driving.

Should an employee driving on Company business receive an incoming call or text message, they should pull over in a
safe, legal and timely manner before answering the call or checking for any voice or text messages. If calls are made to a
mobile phone, the driver must inform the caller if they are driving and ask them to call back later / when it is safe to do so.

Under no circumstances can a hand-held mobile be used by the driver of a moving vehicle. If the driver stops the vehicle
to use a mobile phone, they must ensure that the vehicle is stopped in a safe place.

13.12 VEHICLE ALLOWANCE


People who qualify for a car allowance as part of their compensation package will be offered a taxable allowance payable
with salary. This option may be exercised by new employees or by existing employees where it is appropriate and at full
Company discretion.

The vehicle allowance will be reviewed annually and adjusted if market conditions deem it necessary.

The employee must undertake to make available a vehicle for their own use, when required by the Company, which is
suitable for business purposes. Business mileage will be reimbursed at 45¢ per mile.

The car allowance is to be utilized by employees to acquire a vehicle that is fit for business use, is maintained to a high
standard and is road legal. The allowance may be withdrawn if the employee does not comply with these conditions.

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The Company reserves the right to withdraw the allowance if employees fail to utilize the allowance to acquire a suitable
vehicle for business use.

All vehicles acquired through the allowance should be professional and reflective of individuals who are leaders of the
company. Ideally vehicles should have a hard-top and have the capacity to hold up to three (3) passengers.

13.13 INSURANCE
Employees who use their own vehicle for business trips must ensure that their personal vehicles are insured for business
use and confirm that their vehicle is in good roadworthy condition when asked to drive on Company business.

All employees, either driving their own vehicles or driving a Company vehicle must comply with the policy on driving
licenses as stated above.

It is vital that all employees are insured to drive any vehicle that they are required to make use of during their off-site visit,
including Company vehicles, personal vehicles and rental cars.

Do not leave keys on or in the vehicle at any time as insurance will not cover costs and you would be personally liable.

13.14 POOL CARS


Where possible, own car use should be no more than 50 miles per day. Any journey that is more than this should be
traveled using a pool or rental car.

Pool cars and rental cars should be requested via the Human Resources Manager.

13.15 TERMINATION OF EMPLOYMENT


Employees who receive a vehicle allowance will be paid this for the duration of their notice period. Upon termination,
employees should voluntarily notify Human Resources of their fleet, pool, or rental car location to coordinate secure
delivery.

13.16 ESSENTIAL USER VEHICLE


All Company vehicle users will be required to sign and acknowledge receipt of this Company Travel Policy and awareness
of how it affects them and to keep a copy of this policy in the Company vehicle.

Employees with Company cars will be reimbursed for all normal expenditure, but expenses for car cleaning, consumables
and car accessories are not to be reclaimed from the Company. Valid receipts for re-fueling should be submitting to the
Accounting Department on a regular basis.

13.17 DRIVING PROFICIENCY


The Company may require the driver to undertake what it deems to be an appropriate driving course if the driver's
record, in the company's opinion, indicates that this would be beneficial.

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Accidents occurring while on Company business are recorded and should an employee’s accident record or driving
capability be of concern, the Company will review the entitlement of the employee to retain or drive a vehicle on behalf of
the Company.

13.18 VEHICLE SECURITY


It is the responsibility of the driver to ensure that all reasonable security arrangements are made including locking-up the
vehicle under cover overnight wherever possible, ensuring that the doors, sun roof and boot are locked, laptops are
removed from the vehicle, removable radio covers are taken from the vehicle and alarm systems have been activated.
The theft of Company property from private or Company vehicles should be reported to the Human Resources
Department.

13.19 CHANGE OF JOB OR RECRUITMENT


A change of job within the Company does not entitle an employee to a change of vehicle or an allowance prior to the date
of replacement of the current vehicle. Recruits entitled to a vehicle are not automatically entitled to a new vehicle but may
be asked to take over a vehicle from within the Company, should it be available. This is at the discretion of the Human
Resources department.

13.20 AUTHORIZED DRIVERS


Drivers are expected to ensure that due care is taken always when using the vehicle, whether driving or parked. The
Company restricts the use of the vehicle to the employees and their partner and, where necessary, other appropriate
employees of JCB with a full driving license for the class of vehicle. Company vehicles may not be driven by learner
drivers.

It is the responsibility of the employee to whom the vehicle has been allocated to ensure that any other driver of the
vehicle is properly licensed and fit to drive. The use of an allocated vehicle by anyone other than a Company employee
for business is specifically prohibited unless prior permission is obtained from the Human Resources Department.

13.21 VEHICLE SAFETY


The Company regards company vehicles as part of the workplace and therefore the same standards and policies that are
applied in a factory, warehouse or office will be applied to the vehicle. This is regarding any activity performed at work and
it is a management responsibility to ensure that risk assessments have been performed surrounding the use of a vehicle(s)
and associated tasks.

Drivers should familiarize themselves with hazard information contained within the vehicle handbook, such as the hazards
associated with fluids and vehicle checks, etc. and must exercise caution if the vehicle becomes immobile through some
mechanical or electrical breakdown.

The Company therefore insists that it’s drivers exercise care and attention on the road always and have respect for other
road users.

13.22 INSURANCE CERTIFICATES


Insurance certificates and registration should be in the vehicle always. Human Resources will provide annual updated
documents, and these should remain in all fleet or pool vehicles.

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13.23 INSURANCE OF PERSONAL EFFECTS
Property lost or stolen from the vehicle is the responsibility of the driver. The driver has a responsibility to place
removable items out of sight, whether owned by the Company or personally, and to make them as secure as possible.
Normally, the driver’s home contents insurance will cover personal property in the vehicle, however it is the driver’s
responsibility to check this.

13.24 ENTITLEMENT AND SUITABILITY TO DRIVE


The Company has the right to withdraw the vehicle allocated if, in the opinion of the Company following thorough
investigation, the driver has abused the privilege of the allocation of a Company vehicle or has failed to maintain the vehicle
to proper standards.

The Company also reserves the right to withdraw the company vehicle or vehicle allowance from an employee in any of
the following situations:

• Non-authorized use of vehicle


• Non-adherence to the Company Vehicle Policy

13.25 MECHANICAL BREAKDOWN


In the event of mechanical breakdown, other than that occasioned by accident, reference should be made to the
instructions as laid out in the section on maintenance and repairs within this policy. Where necessary a basic relief vehicle
will be provided if the regular vehicle is immobilized.

Where a rental vehicle or fleet car has been used, the driver is responsible for returning the vehicle in the condition in
which it was received, including fuel replenished to the level at which it was received. This is the personal responsibility of
the driver. Should fuel not be replenished, the driver will be required to reimburse the Company for any fuel charges
made by the rental Company.

13.26 AVAILABILITY OF COMPANY VEHICLES


Although vehicles are normally allocated to individual employees, the Company retains the right to authorize the use of the
vehicle by another employee at any time. Allocation of a vehicle does not imply the right to exclusive use.

13.27 ROUTINE MAINTENANCE CHECKS


Routine checks such as water/oil levels, tire pressure, and road worthiness are the clear responsibility of the driver. The
driver is responsible for carrying out routine maintenance in accordance with the manufacturer's instructions and company
vehicle procedures for ensuring that the vehicle is in a legal and roadworthy condition always.

13.28 CLEANLINESS OF VEHICLES


It is the responsibility of employees to ensure that all vehicles are kept and maintained in a clean and tidy condition always
to ensure a positive image. Attention should be made to the cleanliness of the vehicles lights and registration plates. All
fleet vehicles should be returned to JCB Inc. in a clean and tidy condition.

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13.29 DRIVERS WITH DISABILITIES
Where any modifications are required to be carried out on a vehicle to ensure its suitability for use by a permanently
disabled driver (as defined from time to time by law), such modifications will be carried out at cost to the Company and
will not affect the personal entitlement of the user. If you believe adjustments need to be made, please contact the
Human Resources Department.

Any other modification to a company vehicle must be requested and authorized by the Human Resources Department.

SECTION 14 - TRAVEL
14.1 TRAVEL - INTRODUCTION
The Company values the health and safety of its employees, whether they are working from their home base or traveling
on behalf of the Company. The goal of the Travel Policy is to provide information on Company standards, to provide links
to other appropriate documentation or resources and to ensure that any JCB Inc. employee traveling on Company
business is fully aware of the support available, the processes in place, and the responsibility of the Company and
themselves.

To comply with Health and Safety Regulations and obligations, this policy will help to protect and maintain, so far as is
practicable, the personal health and safety of all employees and contractors (where relevant) while traveling in the U.S. or
overseas on company business. This policy aims to standardize health and safety processes and procedures used in all
aspects of off-site working in the U.S. and overseas (i.e. preparation, travel, emergency procedures, etc.). It will outline
and clarify the roles and responsibilities of the Company and its managers, and all those who travel on Company business
in terms of required processes and procedures, behaviors and conduct, and emergency procedures.

The policy also outlines the Company expectations regarding the required behaviors and conduct of employees and
contractors working off-site, in order that the reputation of the Company and confidentiality of company information are
maintained.

The Travel Policy and Expenses Policy are closely linked and therefore should be read together.
This policy will be reviewed for its ongoing appropriateness and legal compliance on a regular basis by the Human
Resources department and amended where necessary. Company travelers will be advised of changes as appropriate.

This policy does not form part of any employee's contract of employment and it may be amended at any time.
The company is covered under statutory state workers' compensation laws. Employees who sustain work-related injuries
must immediately notify their department supervisor.

14.2 TRAVEL - COMPANY STATEMENT


JCB is a strong advocate of environmental leadership and recognizes that travel has a significant impact upon its carbon and
environmental footprint.

As part of its objectives of working towards a sustainable future, JCB is asking its employees to consider if the business
travel they are planning is essential. Is the journey necessary? Could the same outcome be achieved by conference call?
Do you really need to fly?

When planning your travel, think about how you are going to get there, if the journey is necessary and if you can schedule
your meetings to reduce miles travelled. Business travel is an essential part of maintaining a profitable future for our
company, but so is managing the world’s resources.

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We all have a responsibility and duty of care towards other drivers and to the local community. Poor driving standards of
JCB employees reflect badly on the company and project a negative image. We expect employees to behave courteously
and legally while driving. Failure to do so may result in complaints by other drivers which will be taken seriously, with
appropriate action taken.

14.3 TRAVEL - WORKING WITHIN THE LAW


Individual countries have different laws surrounding the various activities that employees may undertake when travelling on
company business (i.e. driving, import and export restrictions). It is the employee’s responsibility to ensure that they
remain within these legal restrictions when travelling off-site / overseas on company business.

14.4 TRAVEL - KEY MANAGEMENT RESPONSIBILITIES


It is the responsibility of all managers to ensure that any employee who may be required to work/travel off-site on
Company business has read and understands this policy. Managers should pay attention to their responsibilities
surrounding risk assessment, driving following travel, personal protective equipment and contact details/itinerary of
employees travelling off-site.

Equally, managers signing to authorize U.S. and overseas travel should have read and understood this policy. Managers
should also be able to advise on its content and act in accordance with it. Where a manager is not able to fulfil these
requirements, then travel should not be authorized. The manager should contact the VP of Human Resources for advice,
prior to authorizing travel.

Employees should hold meetings with supplier representatives on JCB Company premises. Where this is not suitable,
prior authorization from their President & CEO must be obtained.

Wherever possible, employees should communicate with other JCB companies world-wide by use of the video
conferencing facilities available on most sites. This will avoid wasted travel time and excessive travel cost. Vice Presidents
must be satisfied that there is a pressing need for face-to-face contact before authorizing air travel for non-
customer/dealer-facing business.

The guidelines should be followed by all employees before any offsite travel in the UK or overseas is undertaken.

14.5 TRAVEL - ASSESSING RISKS


Risk assessments for any work-related travel should follow the same principles as any other similarly situated work activity.
Employees should keep in mind that failure to properly manage work-related safety is more likely to endanger other
people in the workplace.

 A risk assessment is nothing more than a careful examination of what at work activities can cause harm to people.
 It helps to weigh upon whether you, as an employee, have done enough to ensure safe working practices or
should do more to prevent harm.
 Your risk assessment should be related to the circumstances and functions of JCB and does not have to be over
complex or technical.
 It should be carried out by a competent person with a practical knowledge of the work activities being assessed.
 For most of JCB’s activities, the hazards will be easy to identify.

The intention of ongoing risk assessment(s) is to minimize injury and fatality and ultimately ensure that these
outcomes are as low as possible. Furthermore, employees should understand and be able to identify the
difference between a hazard and a risk.

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o Hazard means anything that can cause harm

o Risk is the chance, high or low, that someone will be harmed by the hazard

It is the responsibility of the employee or contractor’s immediate manager to ensure that either the host location provides
all necessary equipment including Personal Protective Equipment (PPE) or that the employee or contractor takes it with
them. If the employee or contractor feels that the nature of the work may cause serious or imminent danger, they should
stop work and seek advice from their manager immediately.

Safety is an important consideration for employees staying in overnight accommodation offsite. Employees should take
time to orientate themselves with exit routes and emergency exits.
Employees should use the safest method of travel to their accommodation always.

14.6 TRAVEL - RENTAL CAR


DO NOT leave keys on or in the vehicle, as if the car is stolen you will be personally liable.

BEFORE DRIVING YOUR VEHICLE please check for damage, paying particular attention to scratches and alloy wheels.
We have 24 hours from the time of rental to report any damage, therefore if you do find any damage not listed on the
documentation, please contact the car hire company immediately and note the time, date and name of the person you
reported it to. If possible, take photographic evidence (preferably with a date stamp, which includes visibility of the car
registration).

The rental car specification should be reasonable given the driver(s) and the distance to be driven/equipment to be
transported.

14.7 TRAVEL - PERSONAL HEALTH


It is the employee’s responsibility to ensure that they are fit to travel, including fitness to fly. Where individuals have any
concerns, they should contact their medical provider.

Where necessary, it is the employee’s responsibility to ensure that they have adequate supplies of prescription medication
for the duration of the trip. If the employee is unable to obtain adequate supplies of prescription medication before they
travel, then travel must not go ahead.

If the employee is required to carry prescription medication through customs with them, then they should pack this at the
top of their hand luggage in a suitably labelled container. They should carry a signed copy of their prescription or a letter
from their physician to avoid any complications at customs according to airline regulations at the time of travel. Please
check these regulations prior to departure.

Employees traveling to areas of the world where vaccinations are required should consult with their medical provider at
the earliest possible opportunity prior to the trip to ascertain which are required.
Note that in some countries it may be necessary to carry a first aid kit at all times, and in others this is advisable.

14.8 TRAVEL - RISK ASSESSMENT AND PERSONAL PROTECTIVE EQUIPMENT


A risk assessment should be undertaken or obtained for all work that employees and/or contractors are requested to do
off-site.

While working off-site the employee and/or contractor is responsible for ensuring that all relevant safety instructions and
equipment are used at the appropriate time. Details of the necessary safety instructions and equipment should be available
in the off-site location.

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It is the responsibility of the employee’s and/or contractor’s immediate manager to ensure that either the host location
provides all necessary equipment including PPE or the employee and/or contractor takes it with them.

If there is any doubt that the work can be undertaken safely or if PPE is not available, employees and/or contractors should
not be sent to work off-site. If an individual believes that they are being placed at risk while working off-site, then they
should use their own judgment and decline to carry out work until they have consulted with their manager and ensured
that the necessary safety and control measures are in place.

14.9 TRAVEL - CONFIDENTIALITY


Many off-site visits will require the use of public transport and will result in employees spending time in public areas. In
public places all employees must ensure that they maintain confidentiality of company information, particularly during any
discussion that might take place between groups of employees and during any telephone conversations of a business
nature.

This obligation to maintain confidentiality of company information also applies to contractors.


Likewise, employees and contractors should always adhere to their obligation to maintain confidentiality during any social
or ‘sight-seeing’ activities outside of working hours. Failure to maintain confidentiality of company information may result in
disciplinary action being taken.

14.10 TRAVEL - BOOKING


Please book hotel accommodation via the Concur Travel Request System. It is expected that employees will book a
recommended hotel from the re-populated options in Concur. Any hotel booking outside of the recommendations must
be pre-authorized by the Vice President of Finance per the Expenses Policy statement relating to expenses that fall outside
of normal procedure.

Flights and vehicles should be booked using the Concur Travel System. The method of travel used should be the most
reasonable and sensible considering safety and reasonable business cost. First Class or Business Class travel tickets will not
be issued without the express permission of the President & CEO.

Overseas car rental bookings should be included in the flight request using the Concur Travel Request System. Please
contact the Human Resources Travel Coordinator with any questions regarding this process.

14.11 TRAVEL OVERSEAS - GENERAL ADVICE AND PRACTICAL GUIDELINES


The following advice and guidelines should be followed by employees and contractors whilst working overseas:

 Be security conscious and take sensible precautions.


 Be alert to unattended baggage in public places.
 Avoid political and other demonstrations or gatherings.
 Avoid unlit streets at night.
 Carry only the minimum amount of cash that you need for the day.
 Leave your valuables and spare cash in the hotel safe or other secure place.
 Do not ‘flaunt’ your (relative) wealth.
 Never resist violent theft.
 Should you lose your hotel room key card, bear in mind that information stored on it may include your name,
home address, hotel room number, check in and check out dates, credit card number and expiry date.
 Keep abreast of the local and regional political scene in the media.

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 Adhere to the laws and procedures which apply to the country you are in.
 Do not carry all of your cards with you – leave at least one in the hotel safe. If you lose or have your card stolen,
cancel it immediately by phoning the relevant 24-hour emergency number.
 Change money in banks or legal foreign exchange dealers. It is often illegal to exchange with unauthorized
persons, and you run the risk of receiving fake currency and arrest.
 Keep all exchange receipts, as you may have to prove you obtained your local currency legally.

14.12 TRAVEL OVERSEAS - THEFT


If your money, passport or anything else is stolen report it at once to the local police. Obtain a police statement and/or a
reference number as you will need this to make your insurance claim.
In the event of the theft of traveler's checks – contact the issuing agent.
Theft of tickets – contact your ticket provider to arrange replacement.

14.13 TRAVEL OVERSEAS - CULTURAL AWARENESS


 Respect local and religious customs and dress codes, and if possible do some research
 into the local culture before going on the trip. Refer to the Lotus Notes HR Resource Centre or visit
http://www.worldbusinessculture.com.
 Be discreet about your views on cultural differences and behaviors.
 Always ask an individual’s permission before you take a photograph and respect their reply.
 An employee may be eligible for intercultural training when travelling to certain locations in the world. Please
contact the Human Resources Director if you feel this would benefit you.

14.14 COUNTRY SPECIFIC REQUIREMENTS


Please make sure that before you travel you have the correct equipment (i.e. suitable clothes for the climate of the country
you are visiting, snow tires, etc.)

14.15 TRAVEL - CLASS


It is the policy of the Company to use the lowest fare whenever possible. We require additional approval for any flight
requests less than seven days in advance. Flights within the USA and Canada will be economy class and maximum use
must be made of discounted fares.

Vice Presidents and employees accompanying a Vice President may travel in premium economy/business class for
intercontinental travel. Requests from any other employee to travel Business Class must be specifically authorized by the
President & CEO.

All requests for air or rental car must be made via the Concur Travel System.

All intercontinental flights must be authorized by the President and CEO and where reasonable should commence on a
Saturday or Sunday, depending upon the distance involved, enabling the employee to start work first thing on Monday
morning at their destination.

Please see the JCB Expenses Policy for details of food and drinks allowances. The cost of food and drinks outside of these
allowances are not recoverable from the Company unless specifically authorized by a director.
The cost of the use of airport lounges / airport facilities is not recoverable from the Company.

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14.16 TRAVEL OVERSEAS - SECURITY
Please note that there is a general risk of terrorism when travelling to locations across much of the world, both from local
political tensions and broader campaigns against ‘Westerners’. While this general risk cannot be avoided, the employee
should be vigilant, take sensible precautions, be aware of local sensibilities and monitor the media where relevant. It
would be considered sensible not to unnecessarily exhibit your connection with the Company or the fact that you are a
business traveler in certain countries.
Where an employee is traveling to a country with markedly different cultural norms to North America or where the
employee will be spending a significant amount of time overseas, they may wish to visit www.cdc.gov/travel for further
information. Please photocopy your passport, leaving one copy in North America and taking one copy with you.

14.17 TRAVEL - INSURANCE PROCEDURE


When traveling off-site all employees must have in their possession details of the Company travel insurance document to
ensure that they have access to medical insurance coverage provided by the Company to its employees. This can be
obtained from the Human Resources Department prior to any travel and carried with you at all times. The telephone
number and policy number should be kept in your mobile phone.
The insurance will provide the employee with 24-hour emergency medical assistance. Note that the insurance provider
will not be liable for any claim where the employee is traveling on business against the advice of a Medical Practitioner or a
claim has arisen because of alcohol or substance abuse.

14.18 TRAVEL - PREPARATIONS


Passports/Visas - If an employee is required to travel overseas they must hold a full ten year passport, even for a day trip.
An employee’s passport should be valid for a minimum of 6 months from the date of their return. It is the travelers
responsibility to check the validity of the passport and any visa required.

Contact Details – It is the manager’s responsibility to ensure that they have an up to date copy of the employee’s off-site
contact details and their itinerary prior to departure. It is the employee’s responsibility to leave contact details of their next
of kin with their manager and inform them or an appropriate colleague should their contact details or itinerary change for
any reason. Employees should also leave a copy of their itinerary and contact details with a relative or reliable friend prior
to departure, again informing them of any changes as necessary, to ensure full contact access if required.

Identification- it is advisable to carry identification with you at all times, for example your driving license.

Emergency numbers – when travelling abroad please ensure you have details of emergency contact numbers (i.e. the
emergency services) for the country you are visiting.

Mobile Phones - It is essential that employees are contactable by mobile phone while working away on business. For
overseas travel, mobile phones will need to have ‘international roaming’ capability. To enable this capability, employees
with a Company mobile should contact the Information Services Department and employees with personal mobile
phones should contact their mobile network provider. It is advisable to do this well in advance of departure date, as it can
take up to 14 days, and it cannot be activated from overseas.

Employees should check that their existing handset will work in the country they are travelling to as this may not be the
case.

Employees should ensure that they know the driving laws and regulations, license requirements and driving conditions
specific to the country that they are visiting. Note that in many countries there are on-the-spot fines for traffic offenses.
Exceptions are not made for foreign nationals, and fines or penalty charges of any nature will not be reimbursed by the
Company. The Company will pay parking/tolls if they are part of a business trip. Employees should refer to the Expenses
Policy for further information on how to claim.
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The Company absolutely prohibits the use of hand-held mobile phones while driving on company business, regardless of
whether this is legal in the country that the employee is travelling in, unless a hands-free kit is available.

14.19 TRAVEL - DRIVING OVERSEAS


If employees are required to undertake driving during any part of their off-site visit, then they must ensure that their driving
license is current and valid. THIS MUST BE CARRIED WITH YOU AT ALL TIMES. Employees will need to take both
parts of their license (card and paper). Some countries require drivers to hold an International Driving Permit (IDP) with a
license. The employee is responsible for ensuring the safe condition of the vehicle being used for the duration of any
travel.

It is the obligation of the individual to ensure that they are adequately insured in the vehicle they are traveling in for the
purposes of their journey. If, for whatever reason, you find yourself in a position where you need to personally arrange
car hire/travel arrangements for Company business you must ENSURE THAT YOU TAKE OUT THE FULL INSURANCE
PACKAGE. The Company will not be held responsible for any loss, damage or injury incurred to or by any employee
because of their failure to ensure adequate insurance coverage is in place.

Employees MUST NOT hire vehicles in China, India, Brazil and other Latin American Countries. Prior to visiting the
country, you must arrange with the local JCB business unit to be collected from the airport and taken to the hotel. You
must also arrange with the local JCB business unit for a driver or taxi driver to be available when traveling from the hotel
to particular sites.

YOU MUST ensure the local JCB business unit in the country you are visiting receives an itinerary from yourself which
includes details of the company insurance policy and telephone number in the event of an emergency or accident.

14.20 TRAVEL - WHAT TO DO IN THE EVENT OF AN EMERGENCY


Emergency situations will vary in severity, location and context. The employee must therefore assess each situation
individually and take the most appropriate action to the individual situation.

Please contact the Human Resources department at 912.447.2000 during office hours or if after hours contact the Human
Resources Vice President directly.

14.21 TRAVEL - PROBLEMS WITH THE JOURNEY


If for example the flight is delayed, the employee should inform their manager and notify the contact in the receiving
country. Reasonable business expenses may be incurred where necessary.
In the event of an emergency such as a natural disaster, serious illness or terrorist activity, the employee should follow the
guidelines below, noting that use of mobile phones may not be possible in these circumstances (due to network
failures/restrictions).

• Contact the country’s specific emergency number, if necessary (i.e. 999, 911).
• Contact your family and your manager.
• Inform them of the situation, your location, and your options.
• If you are only able to make one call - contact one of the above and ask them to contact the other party. Note
that the Company will not contact your family and/or next of kin unless you specifically request us to do so.
• Even if you are not personally affected by the emergency please adhere to the above – remember that those
outside of the emergency will not know exactly where you are but they will worry if they think you are in
potential danger.

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• If you change your plans then re-contact your family, as well as manager, to inform them of any new travel or
contingency plans.
• Ensure your EA and or colleague has your itinerary and if you fail to keep to the agreed schedule that person will
be able to take action.

14.22 TRAVEL - EMERGENCY SUPPORT FROM THE OCCUPATIONAL HEALTH


DEPARTMENT
In the event of a tragedy such as death of a colleague or family member, or serious illness, occurring whilst the employee
is overseas, a member of the Human Resources Department is available for support and guidance.

14.23 TRAVEL - EMPLOYEE CONDUCT INSIDE & OUTSIDE OF BUSINESS HOURS


All employees and contractors traveling on Company business are acting as ambassadors for the Company, and in this
respect, should conduct themselves appropriately and professionally both inside and outside of working hours. Employees
and contractors should take care if they choose to consume alcohol outside of working hours, as consumption of alcohol
can lead to impaired judgement. Any impaired judgement can impact upon behavior and conduct, as well as increasing the
risk of accidents and becoming a victim of crime. Please refer to the JCB Substance Abuse Policy for further information.

If employees and contractors wish to socialize or explore outside of working hours it is advisable not to do so alone, and if
possible, to be accompanied by a local and trusted person, especially after dark. Where possible, employees and
contractors should take advice from local colleagues on safe places to visit and stay within busy and well-lit areas.

14.24 TRAVEL - RETURN, IMPORT AND EXPORT RESTRICTIONS


Most countries have different import and export restrictions. It is the employee’s responsibility to ensure that the goods
that they purchase and travel with are within the legal limits. The Company will not be responsible for any fines or losses
incurred as a result of importing and exporting goods outside of the legal restrictions.

14.25 TRAVEL - HEALTH


It is important for employees to bear in mind that there is a possibility that illnesses occurring following recent travel may
be related to travel. Employees who have traveled recently and fall ill should consult with their physician informing them of
the location and duration of any recent travel.

14.26 TRAVEL - FEEDBACK


In addition to reporting any accidents, injuries or illnesses to the company, it is important that employees communicate
feedback (positive or negative), to the Human Resources department (as appropriate) that might be essential or useful to
subsequent travelers or current employees.

14.27 TRAVEL - RETURNING TO WORK


Return into work date/time following an overseas trip should be agreed locally with line management before travel.

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SECTION 15 - EXPENSE POLICY
The policy provides an easy reference guide for expenses relating to travel, accommodation and entertaining expenses. It
is the responsibility of the Financial Controller in each business unit to ensure that compliance is maintained on a day to day
basis.

It is the policy of the Company that individuals are not out of pocket following trips on Company business. Claims for
items not specifically covered by this expenses policy should be discussed and approved by your Manager prior to the
claim being made.

It is the responsibility of the claimant to ensure that all expenses are reasonable and incurred wholly and exclusively during
Company business. It is also the responsibility of the authorizer to ensure that expenses claimed are covered in the policy
or have the express authorization from a manager if they fall outside the guidelines.

Disciplinary action may be taken against any employee who is found to have violated the procedures within the policy or
authorizer who is found to have been negligent in authorizing expenses for payment.

15.1 COMPLETION OF THE EXPENSE FORM


All claims for reimbursement of expenses incurred wholly and exclusively during Company business must be made either
through the Concur System or the Electronic Reimbursement Form. Any claims made on other documentation will not
be paid. Claims should be submitted at least monthly and the claimant must complete the expenses form in full. All
portions of the expenses form where applicable are to be completed, along with a full explanation, must be given for all
items included on the form. All relevant general ledger codes must be entered and original receipts, numbered and in the
same order as on the claim form, and documentation must be attached to the expense form.

A separate total is required for each column heading on the expenses form. It is not acceptable to group different
expenses together to show only one aggregated amount. Any claims submitted on an aggregated basis will not be
processed and will be returned to the originator.

For subsistence and entertaining meals all persons included in the meal should be clearly noted on the expenses form.

The “Miscellaneous Expenses Code” must be completed with sufficient detail to identify the type of expense incurred by
the claimant prior to presenting the form for checking. The originator must specify the correct account code before
submitting the form otherwise it will not be processed.

Expense forms must be accompanied by all valid receipts and bills for hotel charges, meals, etc., and where travel is
involved, the reason must be stated.

The senior person present at an event must incur the expense to ensure that the expense can be appropriately
authorized.

It is not acceptable for a subordinate to incur the expense and then present an expense form for authorization to a person
who had some benefit from the expense being authorized. This would constitute self-authorization of the expenses
incurred.

15.2 CLAIMANTS SIGNATURE


The claimant submits the expense via Concur or signs the expense form to ‘Certify that all of the expenses on this form
were incurred on company business and in accordance with the company’s policy. If the form is submitted or signed and
this statement is untrue, the claimant may be subject to disciplinary action up to and including dismissal. The regulations
referred to are those detailed in this policy and any additional guidance, which may be issued separately. By signing the
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expenses form, the claimant is acknowledging they understand that all claims are subject to audit and anyone making an
improper claim may be subject to disciplinary action.

15.3 AUTHORIZATION
The claimant is responsible for the validity and accuracy of the claim. By authorizing the expense reimbursement, the
authorizer is acknowledging that they are responsible for ensuring the validity of the claim and understand that anyone
negligently authorizing an improper claim may be liable to disciplinary action. All expense forms must be authorized by the
Line Manager who agreed the expenditure and a Vice President or Controller. All expenses incurred by a Vice President
must be authorized by the President & CEO.

15.4 REIMBURSEMENT
Reimbursement will be by electronic debit directly to the employee’s bank account used for salary payments. Claims up to
$200.00 can be paid in cash with the submission of a petty cash reimbursement form. Reimbursement of foreign currency
expenditure will be at the prevailing exchange rate when the expenses are processed. Valid receipts must be attached to
expense claims. Expenses incurred in foreign currency on personal credit cards for company business, including any
associated charges incurred from the credit card company, are repaid either at the actual amount charged to the personal
credit card per the credit card statement, providing this is supplied or at the prevailing exchange rate when the expenses
are processed with a 2% uplift to cover charges levied by the credit card company.

15.5 ENTERTAINING EXPENSES


All expenses relating to meal entertainment, whether incurred on company premises or at other locations, must be
supported by valid receipts. In addition, the names of all persons attending - both third parties and JCB employees. The
third-party organizations represented by the attendees. The purpose of the entertainment. The venue of the
entertainment. Any event or activity above $2000.00 must also be approved by the VP-Finance.

Meal and Entertainment expenses should remain within IRS Guidelines always. If you require clarification or have specific
questions related to the guidelines, please contact the Human Resources Department.

15.6 NON-ALLOWABLE EXPENSES


No payment will be made for (1) Newspapers and Magazines (2) Confectionery, Tobacco, Toiletries (3) Luggage,
briefcases, office equipment (4) Alcoholic beverages, except for one drink per person per evening meal (5) In-room
movies or other in room entertainment (6) Purchase/hire of formal wear not wholly, necessarily and exclusively for
business use (7) Sundry services, such as visits to the health club, gym or beauty salon (8) Laundry and dry cleaning or
ironing services for trips of less than 5 nights unless the employee is working in a hot/humid climate which requires regular
laundering (9) Cost of the use of airport lounges / airport facilities (10) Any other item not considered to be necessary
expenditure incurred in the normal course of business (11) Gratuities over 18%.

15.7 COMPANY CARS


Employees with Company cars will be provided with a fuel card. Expenses for car cleaning, consumables, and car
accessories are not to be reclaimed from the company. When making a claim for mileage allowance the expense
reimbursement policy should be completed. The location visited and reason for the visit must be provided in all cases.

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15.8 OWN CAR USE – MILEAGE ALLOWANCE
For those employees without a car allowance, their own cars should only be used when pool cars are not available,
except where it would be impracticable to do so. Mileage from home to an employee’s usual place of work or vice versa
is not claimable. Where the shortest route to a destination is not taken, the reason why should be noted on the expense
form. Where a journey includes an intermediate point, such as to collect an item or to pick up a colleague, this must be
noted on the expense form (including the colleague’s name). When employees share a single car for a journey, the
mileage claim can only be made by the car driver, and not by each employee. The distances for mileage claims will be
subject to audit. When making a claim for mileage allowance the expense reimbursement form should be completed. The
location visited and reason for the visit must be provided in all cases. When an employee’s own car is used on company
business, the rate for business mileage claims for all vehicles will follow the IRS Guidelines for the given year. When
traveling to the airport, please utilize a taxi if you will be parked multiple days.

15.9 RENTAL CAR


All rental cars should be paid for on the JCB issued American Express or the BTA card. If a rental car is used it MUST be
refueled prior to return. Refueling by the rental company costs JCB considerably more than average fuel prices. This is an
unnecessary cost and must be avoided.

15.10 MEALS & HOTELS


All requests for hotel accommodation must be made via the Concur System for the company to take advantage of specially
negotiated rates and track our utilization. When field personnel are in Savannah the recommended hotels in Savannah
should be utilized to ensure we are taking full advantage of the corporate rates we have available. Where an employee is
visiting an overseas JCB Group company, the hotel booking may be completed either by the Company being visited on
behalf of the employee or via Concur. Reimbursement for individual meals is as follows:

Breakfast (per head) $15


Lunch (per head) $15
Dinner (per head) $25

• Employees are only permitted to travel with fellow employees on company business. Only in exceptional
circumstances and, with prior approval from the President & CEO, will a spouse or family member be allowed to
accompany employees.
• Dinner is limited to one (1) alcoholic beverage.

15.11 AIR TRAVEL


All flight requests must be considered carefully to ensure the most cost-effective method of travel and booking is used.
Travel should be booked at least seven days in advance unless there are extenuating circumstances. All air travel requests
must be booked through the Concur System. Justification will be required if the most economical route is not selected.

Any changes to authorized and ticketed flights can incur a cost from the airline and so will need to be entered as a further
authorization request on the Concur expense system referring in the additional information section to the original flight
request number and reason for the amendment.

15.12 TELEPHONE COSTS


• While an employee is away on Company business reasonable private telephone costs are claimable. If a
company phone is held with the appropriate call roaming, please use this to make the calls rather than the hotel
phone.
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• Private telephone accounts must not be submitted to the company for payment, unless the employee does not
possess a company cellular phone. Claims for reimbursement of costs incurred on private telephone accounts
should be made using the expense form and should include documentary evidence of all call costs claimed.
• JCB will meet the cost of mobile telephones provided for business use, including a modest degree of personal
use, however it will not permit use of its phones/devices for premium call numbers.
• The company will expect the employee to voluntarily cover the cost of personal calls if the use could be deemed
excessive.

15.13 EMERGENCY TRAVEL AND MEDICAL


• The company maintains an insurance policy to cover any expenses incurred by employees arising from sickness
or accident, i.e. doctor or hospital charges, when travelling abroad on company business.
• All employees must submit a separate expense claim for any medical expense incurred.

15.14 AMERICAN EXPRESS CORPORATE CARDS


• All field-based positions and roles that travel frequently should possess a JCB Corporate American Express Card.
This card should be utilized for all hotel expenses as well as meals and entertainment.
• JCB expenses charged to JCB issued American Express cards should only include business related expenses.
• Credit card balances are expected to be paid on a timely basis; any deviations from these credit card policies will
result in possible disciplinary action.
• Annual service charges for American Express green card will be reimbursed by JCB. If a different card is chosen,
the individual will be responsible for the difference between the green card and the level they select.
• Service charges arising from past due payments because of delayed submission of expenses for authorization will
not be paid by the Company and will be recharged to the employee.

15.15 PERSONAL CREDIT CARDS


• The Company will not reimburse interest charges incurred on personal credit cards unless it can be proved that
this was attributable to the Company.
• The Company will not reimburse the annual subscription charge for personal credit cards.

15.16 CLAIMS FOR LOSS


• Prior to submitting a claim for loss or damage of personal possessions while on company business, the claimant
must contact the Vice President of Finance for advice on the procedure.
• Any Vice President authorizing a subsequent claim must separately approve claims for loss or damage of personal
possessions while on company business.

15.17 PROFESSIONAL FEES


The reimbursement of professional fees is an illustration of JCB’s commitment to the development of its staff. JCB will
reimburse the professional fees of its employees, where this is essential to carry out their role or where their performance
in the job would be enhanced by the membership. JCB will reimburse subscriptions up to $500.00 annually with pre-
approval from a Vice President.

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SECTION 16 MOBILE DEVICE POLICY
16.1 PURPOSE
The Company recognizes that mobile devices are increasingly becoming part of everyday life, but that they can cause
issues when used inappropriately.

This policy sets out the Company rules on the use of mobile devices for employees issued with such equipment to carry
out their roles and responsibilities. For the purposes of this policy, the term ‘mobile device’ refers to any handheld
electronic device with the ability to receive and/or transmit voice, text, email or data usage, without a cable connection.
The Company issues mobile devices to those employees who travel extensively on Company business or for whom it is
deemed beneficial to the role. In issuing these mobile devices, employees will use such equipment to assist them in
performing their roles and, as such, the Company has certain expectations regarding usage. The aim of this policy is to
clearly outline the protocols and responsibilities expected of employees.
This is a JCB Inc. Policy relating to users of Company-issued mobile devices.

16.2 RESPONSIBILITIES - COMPANY


Mobile devices are provided by the Company and must not be purchased independently and claimed through the
expenses system.

HR must be notified if a mobile device is no longer required, for example, if a user leaves their employment with the
company. The device will be returned to IT for cancellation, through the employee’s line Manager.

Group IT Service Desk is responsible for providing system support for Company-owned mobile devices.

Group HR is responsible for the development, implementation and review of this mobile device policy.

It is for line Managers to take responsibility for whether an employee fulfils the relevant criteria to be issued with a mobile
device. Only certain roles are eligible for such equipment to be issued, and it remains at the discretion of the Company as
to which roles are applicable on a case-by-case basis.

Any Company-issued mobile device and its associated number remains the property of the Company at all times and, as
such, the Company reserves the right to recall the item when necessary.

16.3 EMPLOYEE
It is the responsibility of the employee allocated a Company-owned mobile device to read, understand and adhere to this
Policy and any subsequent revisions always. Employees found in violation of this Policy may be subject to suspension of
mobile computing privileges and/or disciplinary action up to and including termination of employment, where appropriate.
Company issued mobile device costs are paid by the Company, including any reasonable personal usage. Such personal
use should be reasonable as these devices are primarily intended for business use.
It should be noted that desk phone usage should be the preferred choice wherever possible, as call rates are always
cheaper than mobile device costs. When using a desk phone to make an overseas call to a JCB site, the ‘Short Dial’
telephone system should be used.

When in a JCB office, the appropriate Wi-fi connection should be used for mobile devices, rather than relying on the
roaming facility, which will incur additional costs.

Employees must not under any circumstances, access offensive or inappropriate websites or circulate or receive such
material through email or the Internet, when using company mobile devices, whether it is during or outside of working
hours.

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When issued with a Company mobile device, it is the employee’s responsibility to ensure that the equipment is looked
after appropriately. Unattended Company-issued devices must be physically secured away. Should the device get lost,
damaged or stolen, the user should immediately notify the IT Service Desk.

The responsible Business Unit/Department and/or Employee will be liable for the cost of a replacement mobile device in
the case of regular occurrences of loss or damage for an individual device.

The Company reserves the right to act, in case of proven misuse of the mobile device, including recharge to the employee
and/or appropriate disciplinary action up to and including termination of employment.

16.4 SECURITY
All Company-issued mobile devices must have a PIN code (a minimum 4-digit security code that controls access to the
device) set. This PIN code should not be shared with any other employee other than if requested by the Group IT Service
Desk in relation to resolving a technical issue.

Employees must not use cameras or video recording functions on mobile devices whilst on-site at any JCB premises
unless written permission is obtained from a Director. Such devices should not be used to access personal social media
services.

All mobile devices must use approved and pre-installed virus, spyware and personal firewall protection software.
To protect the Company’s interest, all data may be deleted by the Group IT Service Desk from a Company-issued mobile
device, if the device appears to be lost or stolen, or if the employee leaves the Company. Therefore, it is important that
no personal data or applications are stored on the mobile device as they would also be deleted as part of this process.

Using a Company-issued mobile device to make audio recordings of meetings is forbidden in all situations, unless an
audible or written approval from each participant is clearly stated at the beginning of the recording.

For security reasons, sensitive Company data stored on mobile devices, should not be transmitted over public wireless
networks. In exceptional circumstance, data must be encrypted using approved encryption techniques (see the IT Service
Desk for further information).

16.5 DAILY USAGE


Employees should utilize good judgement to minimize costs and only incur expenses that are necessary to the business
objectives of the Company.
• The danger of using a mobile device while driving is well known, and it is an offense to use a device without a
‘hands free kit.’ Any calls made/received should be on hands free equipment only and be made/received when
the driver feels it is safe to do so.
• Please see the Company Travel policy for further information).
• It is forbidden to use a mobile device while driving internal vehicles, e.g. Forklift truck, Flatbed truck, Teletruck.

16.6 INTERNATIONAL TRAVEL / CALLS


Outgoing international phone calls may only be made by employees with roles specifically requiring communication with
people outside the US, and only in specific circumstances where there is no access to an appropriate fixed landline to
make the call.

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Employees are requested to minimize overseas data roaming by switching off the roaming feature prior to any
international travel and, where appropriate, using mobile wi-fi devices or Company wi-fi available at all JCB overseas sites,
to access any data-related mobile features.
Employees must be aware of local laws when travelling abroad and adhere to all regulations with reference to use of
mobile devices, e.g. when driving or on airplanes.

16.7 MOBILE DEVICE BILLS


IT will monitor mobile device usage and review the monthly bills. Financial Controllers will also have access to all bills
within their respective Business Units / Departments and review usage monthly. If an employee’s usage is deemed
excessive then the employee may be requested to provide a justification for any overspend, which could lead to the
employee being requested to repay costs deemed to have been unjustly incurred.

16.8 MONITORING MOBILE DEVICES


The Company monitors the use of company mobile devices and where it has good reason, may review the contents of
telephone calls, voicemail messages, internet use and emails.

The purpose of such monitoring is to investigate any unauthorized use of company mobile devices in breach of this policy,
such as excessive personal use or distribution of inappropriate material and to investigate any allegations of misconduct,
breach of contract, criminal offence or fraud.

The Company will always adhere to current legislative requirements.

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