VMD CORP

Employee Handbook

Version: 2.0
Last Updated: 07/19/2019

Confidential and Proprietary – All Rights Reserved

4114 Legato Road, 7th Floor

Fairfax, VA 22033
(571) 612-2424
vmdcorp.com
VMD Corp
Employee Handbook

Version: 2.0 Last Updated: 07/19/2019

Confidential and Proprietary – All Rights Reserved

4114 Legato Road, 7th Floor

Fairfax, VA 22033
(571) 612-2424
vmdcorp.com
 Employee Handbook
Version: 2.0
Approved By: HUMAN CAPITAL, 7/19/2019

Table of Contents
1 Preface................................................................................................................................................ 5

2 Introduction to VMD ........................................................................................................................... 6

2.1 Mission.............................................................................................................................................................. 6
2.2 Culture .............................................................................................................................................................. 6
2.3 Integrated Management System Policy .......................................................................................................... 6

3 General Employment Policies............................................................................................................ 7

3.1 Employment At-Will .......................................................................................................................................... 7
3.2 Equal Employment Opportunity (EEO) ............................................................................................................. 7
3.2.1 Complaint Procedure ...................................................................................................................... 8
3.2.2 No Retaliation ................................................................................................................................. 8
3.2.3 Violations of this Policy................................................................................................................... 9
3.2.4 Administration of this Policy ........................................................................................................... 9
3.3 Affirmative Action ............................................................................................................................................. 9
3.4 Harassment Free Workplace .........................................................................................................................10
3.5 Code of Business Ethics and Conduct ..........................................................................................................12
3.6 Protection of Intellectual Property, Trade Secret, and Confidential Information ........................................13
3.7 Insider Information .........................................................................................................................................13
3.8 Reporting Material Developments and Complying with Internal Controls...................................................14
3.9 Dealings with Suppliers, Venders, Business Partners, and Competitors ....................................................14
3.10 Fiduciary Duty of Employees ..........................................................................................................................14
3.11 Policies Related to U.S. Government Contracting ........................................................................................15
3.12 Reporting Obligations.....................................................................................................................................15
3.13 Reasonable Accommodation for Qualified Individuals with Disabilities .....................................................16
3.14 Religious Accommodations............................................................................................................................17
3.15 Drug and Alcohol-Free Workplace .................................................................................................................17
3.15.1 Drug testing for Government Services and Corporate Employees ............................................. 18
3.15.2 Drug and Alcohol-Free Workplace – Homeland Defense and other contracts subject to Federal
Acquisition Regulation (FAR) ........................................................................................................ 19
3.15.3 Tobacco Free Workplace .............................................................................................................. 19
3.16 Workplace Safety ...........................................................................................................................................19
3.17 Violence-Free ..................................................................................................................................................20
3.18 Bullying ...........................................................................................................................................................20
3.19 Weapons .........................................................................................................................................................20
3.20 Ban on Texting While Driving .........................................................................................................................21
3.21 Background Check and E-Verify ....................................................................................................................21
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3.22 Conflict of Interest ..........................................................................................................................................22

3.23 Nepotism and Fraternization .........................................................................................................................22
3.24 Hiring of Government and Former Government Employees ........................................................................23
3.25 Prohibited Contractual Relationships............................................................................................................24
3.26 Organizational Conflicts of Interest ...............................................................................................................24

4 Operational Procedures .................................................................................................................. 24

4.1 Employment Classifications and Categories.................................................................................................24
4.2 Company Job Classifications .........................................................................................................................24
4.3 Contract Specific Classifications ...................................................................................................................25
4.4 Fair Labor Standards Act (FLSA) Job Classifications ....................................................................................26
4.5 Service Date ...................................................................................................................................................26
4.6 SCA Seniority Date .........................................................................................................................................26
4.7 Business Hours and Work Schedules ...........................................................................................................27
4.8 Meal and Break Periods – Non-Exempt Employees .....................................................................................27
4.8.1 Mandatory Meal Period ................................................................................................................ 27
4.8.2 Rest Break .................................................................................................................................... 27
4.8.3 Impermissible Use of Meal Period and/or Rest Breaks ............................................................. 27
4.9 Payroll Procedures .........................................................................................................................................27
4.10 Overtime Pay Procedures...............................................................................................................................28
4.11 Timesheets .....................................................................................................................................................29
4.12 Recordkeeping ...............................................................................................................................................29
4.13 Performance Management ............................................................................................................................30
4.14 Personnel Files and Release of Employee Information................................................................................31
4.15 Change of Employee Information ..................................................................................................................31
4.15.1 Employment Verification and References ................................................................................... 31
4.15.2 Other Employment Verification Requests and Orders ................................................................ 32
4.16 Employee Referral Program ...........................................................................................................................32
4.17 Expense and Travel ........................................................................................................................................33

5 Professional Conduct ...................................................................................................................... 34

5.1 Professional Appearance ...............................................................................................................................34
5.2 Use and Protection of Company Assets ........................................................................................................34
5.3 Electronic Communications and Information Technology Use ....................................................................35
5.4 External Communications ..............................................................................................................................35
5.5 Social Media ...................................................................................................................................................36
5.5.1 Guidelines ..................................................................................................................................... 36
5.5.2 Know and Follow the Rules .......................................................................................................... 36
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5.5.3 Be Respectful................................................................................................................................ 37
5.5.4 Maintain Accuracy and Confidentiality ........................................................................................ 37
5.5.5 Using Social Media at Work ......................................................................................................... 37
5.6 Media Contacts ..............................................................................................................................................37
5.7 Retaliation and Employee Rights ..................................................................................................................38
5.8 Gifts, Gratuities and Entertainment ..............................................................................................................38
5.8.1 Acceptance of Gifts, Gratuities, and Entertainment ................................................................... 38
5.8.2 Provision of Gifts, Gratuities, and Entertainment ....................................................................... 38
5.8.3 Provision of Gifts and Gratuities to U.S. Government Officials .................................................. 38
5.9 Solicitation, Distribution and Posting of Materials .......................................................................................39
5.10 Disciplinary Process .......................................................................................................................................39

6 Employee Benefit and Leave Programs......................................................................................... 41

6.1 General ...........................................................................................................................................................41
6.2 Benefits Eligibility ...........................................................................................................................................42
6.3 Insurance Premiums ......................................................................................................................................42
6.4 Qualifying Life Event.......................................................................................................................................42
6.5 Short Term Disability ......................................................................................................................................43
6.6 Payment of STD Benefits ...............................................................................................................................43
6.6.1 Benefits ......................................................................................................................................... 43
6.6.2 Returning to Work......................................................................................................................... 44
6.7 Long Term Disability .......................................................................................................................................44
6.8 Payment of LTD Benefits ...............................................................................................................................44
6.8.1 Benefits ......................................................................................................................................... 44
6.8.2 Returning to Work......................................................................................................................... 45
6.9 Worker’s Compensation Insurance ...............................................................................................................45
6.10 Continuation of Benefits (COBRA) .................................................................................................................45
6.11 Education Assistance/Training Reimbursement ..........................................................................................46
6.11.1 Reimbursement Process and Amounts ....................................................................................... 47
6.11.2 Upon Termination ......................................................................................................................... 47
6.12 Computer Loan Program ................................................................................................................................48
6.13 Service Anniversary Awards ...........................................................................................................................48
6.14 Vacation/PTO/Sick Leave ..............................................................................................................................48
6.15 Holiday Schedule............................................................................................................................................49
6.16 Working a Holiday...........................................................................................................................................50
6.17 Bereavement Leave .......................................................................................................................................50
6.18 Jury Duty .........................................................................................................................................................50
6.19 Military Leave (USERRA) ................................................................................................................................51
6.19.1 Leave for Annual Training ............................................................................................................ 51
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6.19.2 Leave for Military Service ............................................................................................................. 52

6.20 Advanced Leave without Pay/Approved Absence ........................................................................................53
6.21 Family Medical Leave Act (FMLA) leaves ......................................................................................................53
6.21.1 Benefits while on FMLA ................................................................................................................ 54
6.22 State Leaves ...................................................................................................................................................55
6.23 Victims of Domestic Violence/Violent Crime Leave......................................................................................55
6.24 New Jersey Security and Financial Empowerment Act (SAFE) .....................................................................55
6.25 California.........................................................................................................................................................56
6.26 Washington, DC and the Accrued and Sick Safe Leave Act of 2008 ..........................................................56
6.27 New York State Human Rights Law (NYSHRL) ..............................................................................................56
6.28 Hawaii Statutes 378-72 & 378-73................................................................................................................56
6.29 Inclement Weather .........................................................................................................................................57
6.30 Telework .........................................................................................................................................................57
6.31 Employment Separation ................................................................................................................................58
6.32 Exit Interview ..................................................................................................................................................59
6.33 Benefits...........................................................................................................................................................59
6.34 Final Pay .........................................................................................................................................................60
6.35 Former Employees .........................................................................................................................................61
6.36 Forms and Information ..................................................................................................................................61

Definitions/Acronyms ............................................................................................................................... 62

Employee Handbook Acknowledgement ................................................................................................. 63

ADDENDUM A ............................................................................................................................................ 64
 Employee Handbook
Version: 2.0
Approved By: HUMAN CAPITAL, 7/19/2019

1 Preface

All VMD Corp a/k/a VMD Systems Integrators, Inc. (“VMD”) employees are responsible for ensuring that
their own conduct, both at work and away from the office, as well as the conduct of those who report to
them and who they observe, is honest and ethical under all circumstances and fully complies not only
with the applicable laws and regulations, but also with VMD policies.

It is the personal responsibility of each employee to read, understand and comply with this Handbook
and to diligently comply with all other VMD policies and procedures.

Policies contained in this Employee Handbook reflect the principles, philosophy, and guidelines
promulgated by Executive Management.

Nothing in the contents of this handbook implies a contract between employees and VMD. We enter
the employment relationship with all employees in good faith expecting that the duration of employment
will last as long as it is mutually beneficial. All employees of VMD are hired on an “at will” basis, for an
indefinite period, and are subject to termination at any time, for any reason, with or without cause or
notice. At the same time, employees may terminate their employment at any time and for any reason.As
the Company continues to evolve, the need may arise and the Company reserves the right to revise,
supplement, or rescind any policies or portion of the Employee Handbook at any time as it deems
appropriate, with or without notice, at its sole and absolute discretion. It will be the responsibility of the
Human Capital Director to prepare, recommend, and coordinate the approval of all policies included in
this manual with the Chief Executive Officer (CEO) & President. Any reasonable recommendation for
change in policy or procedures will be considered. If you have any such recommendations, please direct
them to the Human Capital Director.

Employees will be required to certify their understanding of this Employee Handbook after receipt of
it. The certification will require employees to affirmatively declare that they are aware of VMD’s policies
and procedures, that they understand that adherence to these policies is a condition of employment or
continued business with VMD, and that all violations or suspected violations may be reported and
investigated and could lead to disciplinary action up to and including termination.

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 Employee Handbook
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2 Introduction to VMD
2.1 Mission

At VMD, we are mission and vision driven. We’re motivated by the missions of our customers, and
we work together to envision smart, successful approaches to deliver on those missions – and then
some.

As a company and as a team, we believe:

• that customer relationships matter. Mission delivery is just the beginning. We go above and
beyond to build true relationships with customers. We listen, we counsel, we take on their
objectives as our own, and then we knock it out of the park.

• in operating with intention and purpose. We pride ourselves on being thoughtful and
deliberate – for our customers and for our business. We ask why. We ask how. And we ask
ourselves if there’s a better way, defining “better” as in the interest of our customers’
missions.

• that smart people doing the right things can do anything. We genuinely enjoy our work on
behalf of our customers, and we enjoy the individuals we work alongside each day. We have
high standards. We hold each other accountable. And we recognize we’re a better team for
it.

• that the growth and evolution underway at our company presents opportunity for us and for
our customers – those we have today and those we’ll win together. There’s never been a more
exciting time to be at VMD; and we all work hard to make sure that’s always the case.

2.2 Culture

VMD fosters a culture centered on three core components:

• Talent. VMD seeks and strives to retain talented, driven professionals who bring creativity and
innovation to the work we do. We offer challenging opportunities that are critical to VMD’s
and our customers’ missions. We invest in our employee’s development and are respectful of
their wellness and work-life balance.

• Commitment. We share a passion for quality, professionalism, and solving our customer’s
critical problems.

• Trust. We foster a diverse and inclusive environment where standards are high, doors are
open, autonomy and flexibility are valued, and different perspectives are sought and heard.

2.3 Integrated Management System Policy

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 Employee Handbook
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At VMD, we are inspired by our customers’ missions. In all we do, our policy is to deliver
innovative, value-driven, and mission-centered services to our clients that demonstrate superior
quality, provide outstanding customer service, and protect the confidentiality, integrity, and
availability of the information of all of our stakeholders.

To enable this policy, VMD established and maintains an Integrated Management System (IMS)
that ensures that the policies, processes, tools, and techniques are in place to instill quality,
service, and information security into all our activities. VMD senior leadership ensures that the
integrated quality policy and management system:

• Are effective, efficient, and appropriate to VMD’s purpose

• Provide a framework for establishing and reviewing quality, service and information security
objectives
• Are communicated and understood within VMD
• Comply with all relevant legislation, regulations and other legal and industry requirements
• Are certified compliant with ISO 9001:2015, ISO 20000-1, ISO 27001 standards, and
assessed at Maturity Level 3 of SEI’s CMMI for Services (CMMI-SVC) and Development
(CMMI-DEV)

This policy is reviewed annually by VMD Executive Management and is communicated to all
employees and may be made available by an authorized VMD representative to any other interested
parties.

3 General Employment Policies

3.1 Employment At-Will

Your employment with VMD is on an "at-will" basis. This means your employment may be
terminated at any time, with or without notice and with or without cause. Likewise, we respect
your right to leave VMD at any time, with or without notice and with or without cause. Although
you have the right to leave your employment with or without notice, we would prefer that you
provide us two weeks of notice before your departure so that we may begin taking steps to
ensure your position is staffed or your work otherwise distributed.

Nothing in the employee handbook or any other VMD document shall be understood as creating
guaranteed or continued employment, a right to termination only "for cause," or of any other
guarantee of continued benefits or employment. Only the CEO & President has the authority to
make promises or negotiate regarding guaranteed or continued employment, and any such
promises are only effective if placed in writing and signed by the CEO & President.

3.2 Equal Employment Opportunity (EEO)

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 Employee Handbook
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VMD is an equal opportunity employer and complies with all applicable federal, state, and local
fair employment practices laws. VMD strictly prohibits and does not tolerate discrimination
against employees, applicants for employment, interns, or any other covered individual because
of age, race, color, religion, creed, national origin including ancestry, ethnicity, sex including
pregnancy, gender identity, transgender status, physical or mental disability (including gender
dysphoria and similar gender-related conditions), medical condition, alienage or citizenship
status, military status, including past, current, or prospective service in the uniformed services,
genetic information, predisposing genetic characteristics, marital status, domestic violence
victim status, familial status, actual or perceived sexual orientation, unemployment status,
caregiver status, partnership status, credit history or any other characteristic or class protected
by applicable federal, state, or local law. All VMD employees, other workers, and representatives
are prohibited from engaging in unlawful discrimination. This policy applies to all terms and
conditions of employment, including, but not limited to, hiring, training, promotion, discipline,
compensation, benefits, and termination of employment.

VMD complies with the Americans with Disabilities Act (ADA), as amended by the ADA
Amendments Act, all corresponding or equivalent applicable state and local laws. Consistent
with those requirements, VMD will reasonably accommodate qualified individuals with a
disability if such accommodation would allow the individual to perform the essential functions
of the job, unless doing so would create an undue hardship. If you believe you need an
accommodation, refer any such request to VMD’s Human Capital Department. VMD will also,
where appropriate, provide reasonable accommodations for an employee's religious beliefs or
practices.

3.2.1 Complaint Procedure

Any VMD employee who feels that he or she has been harassed or discriminated
against, or has witnessed or become aware of discrimination or harassment in
violation of this Equal Employment Opportunity Policy, shall bring the matter to
the immediate attention of his/her VMD On-Site Supervisor, or any of the
following individuals: VMD’s Senior Compliance Officer; VMD’s Director of Human
Capital; or any member of VMD’s senior management team. VMD will promptly
investigate all allegations of discrimination and harassment and take action as
appropriate based on the outcome of the investigation. An investigation and its
results will be treated as confidential to the extent feasible. No individual will be
retaliated against for making a complaint or assisting with the investigation of a
complaint in good faith.

Additionally, any VMD manager or supervisor who observes discriminatory

conduct must report the conduct to the Director of Human Capital, so that an
investigation can be conducted, and corrective action taken, if appropriate.

3.2.2 No Retaliation

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No one will be subject to, and VMD prohibits, any form of discipline, reprisal,
intimidation, or retaliation for good faith reports or complaints of incidents of
discrimination of any kind, pursuing any discrimination claim, or cooperating in
related investigations. However, an employee or applicant who makes a false
report of harassment or discrimination may be subject to disciplinary action, up
to and including termination of employment.

VMD is committed to enforcing this policy against all forms of discrimination or

harassment. However, the effectiveness of our efforts depends largely on
employees reporting inappropriate workplace conduct. If employees feel that
they or someone else may have been subjected to conduct that violates this
policy, they should report it immediately. If employees do not report
discriminatory conduct, VMD may not become aware of a possible violation of
this policy and may not be able to take appropriate corrective action.

Your cooperation with all VMD investigations, including those involving a

complaint of illegal discrimination or harassment, is a condition of your
employment.

3.2.3 Violations of this Policy

Any employee, regardless of position or title, whom VMD determines has

subjected an individual to discrimination, harassment, or retaliation in violation
of this policy will be subject to discipline, up to and including termination of
employment.

3.2.4 Administration of this Policy

The VMD Human Capital Department is responsible for the administration of this
Equal Employment Opportunity Policy. If you have any questions regarding this
policy or questions about discrimination, harassment, accommodations, or
retaliation that are not addressed in this policy, please contact the VMD Human
Capital Department.

3.3 Affirmative Action

As noted in the EEO policy, it is the policy of VMD to provide equal employment opportunities without
regard to age, race, color, religion, creed, national origin including ancestry, ethnicity, sex including
pregnancy, gender identity, transgender status, physical or mental disability (including gender
dysphoria and similar gender-related conditions), medical condition, alienage or citizenship status,
military status, including past, current, or prospective service in the uniformed services, genetic
information, predisposing genetic characteristics, marital status, domestic violence victim status,
familial status, actual or perceived sexual orientation, unemployment status, caregiver status,
partnership status, credit history or any other characteristic or class protected by applicable
federal, state, or local law. This policy relates to all phases of employment, including, but not
limited to, recruiting, employment, placement, promotion, transfer, demotion, reduction of
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workforce and termination, rates of pay or other forms of compensation, selection for training, the
use of all facilities, and participation in all Company-sponsored employee activities. Provisions in
applicable laws providing for Bona Fide Occupational Qualifications (BFOQ), reasonably necessary
to specific business operations will be adhered to by VMD only where appropriate.

As part of VMD’s equal employment opportunity policy, VMD will also take affirmative action as
called for by applicable laws and Executive Orders to ensure that minority group individuals,
females, disabled veterans, recently separated veterans, other protected veterans, Armed Forces
service medal veterans, and qualified disabled persons are introduced into our workforce and
considered for promotional opportunities.

Employees and applicants will not be subjected to harassment, intimidation or any type of
retaliation because they have (1) filed a complaint; (2) assisted or participated in an investigation,
compliance review, hearing or any other activity related to the administration of any federal, state
or local law requiring equal employment opportunity; (3) opposed any act or practice made unlawful
by any federal, state or local law requiring equal opportunity; or (4) exercised any other legal right
protected by applicable federal, state or local law requiring equal opportunity.

It is the responsibility of each supervisor of VMD to ensure affirmative implementation of all policies
to avoid any discrimination or perceived discrimination in employment. All employees are expected
to recognize these policies and cooperate with their implementation.

The Human Capital Director of VMD has been assigned as the Affirmative Action Officer and will be
responsible to direct the establishment and monitor the implementation of personnel procedures
to guide our affirmative action program throughout VMD. A notice explaining VMD’s policy will
remain posted and available at VMD Headquarters.

3.4 Harassment Free Workplace

VMD has adopted this policy with respect to unlawful employee harassment and expressly prohibits
sexual or any other form of harassment. This includes unwelcome sexual advances, requests for
sexual favors, and all other verbal, visual or physical conduct of a sexual or otherwise offensive
nature that affects or in any way interferes with an individual's employment, disrupts or intimidates
or creates an intimidating, offensive or hostile work environment. This policy prohibits harassment
by co-workers, managers, vendors, customers, visitors or independent contractors.

This policy prohibiting harassment, whether sexual or of another nature, is not limited to
relationships between and among employees and prospective employees, but also extends to
interactions with customers, business guests, vendors and suppliers. No employee will ever subject
any customer or other business guest to sexual harassment or unlawful harassment of any
nature. Further, no employee will be required to suffer sexual or other unlawful harassment by a
customer, business guest, vendor or supplier.

Any employee who believes they have been a victim of harassment, or who has any knowledge of
such behavior, must immediately report such incidents to the attention of his/her management, a
member of Senior Management of VMD and/or Human Capital. Management shall immediately
report all claims of harassment to Human Capital. All such complaints will be promptly investigated,

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ensuring confidentiality to the maximum possible extent. Appropriate disciplinary action, up to and
including termination, will be taken against any employee found to be violating this policy.

Sexual harassment includes, but is not limited to, the following:

• Unwelcome sexual advances; requests for sexual favors; and all other verbal or physical
conduct of a sexual or otherwise offensive nature, especially where:
o Submission to such conduct is made either explicitly or implicitly a term or condition
of employment; ·
o Submission to or rejection of such conduct is used as the basis for decisions
affecting an individual's employment; or
o Such conduct has the purpose or effect of creating an intimidating, hostile, or
offensive working environment.
o Submission to such conduct is made either explicitly or implicitly in return for
employment requests or benefits or making threats if sexual favors are not provided.
• Offensive comments, jokes, innuendoes, and other sexually-oriented statements or
conduct, including written or oral references to sexual conduct, gossip regarding one’s
sex life, body, sexual activities, deficiencies, or prowess.
• Touching, such as rubbing or massaging someone’s neck or shoulders, stroking
someone’s hair, or brushing against another’s body.
• Grabbing, groping, kissing, fondling.
• Lewd, off-color, sexually-oriented comments or jokes.
• Using foul or obscene language.
• Leering, staring, stalking.
• Suggestive or sexually-explicit posters, calendars, photographs, graffiti, cartoons.
• Unwanted or offensive letters or poems.
• Sitting or gesturing sexually.
• Sending or forwarding offensive email or voice-mail messages.
• Questioning another about his or her sex life or experiences.
• Repeated requests for dates.
• Any other conduct or behavior deemed inappropriate by VMD.

Other forms of harassing behavior which VMD will not tolerate include, but are not limited to, the
following:

• Jokes that refer to race, color, religion, national origin, disability, marital or family status,
age, sex, sexual preference, veteran status, or any other protected status under federal,
state or local laws.
• Posting or distributing cartoons, drawings, or any other material which negatively
reflects a person’s race, color, religion, national origin, disability, marital or family
status, age, sex, sexual preference, veteran status, or any other protected status under
federal, state or local laws.
• The use of slurs or other offensive language.

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• Practical jokes, horseplay, or teasing that make fun of or insult a person’s race, color,
religion, national origin, disability, marital or family status, age, sex, sexual preference,
veteran status, or any other protected status under federal, state or local laws.

Each VMD employee is responsible for creating and maintaining an atmosphere free of
discrimination and harassment, sexual or otherwise. Further, employees are responsible for
respecting the rights of their coworkers.

If an employee experiences any job-related harassment based on race, color, creed, sex, age,
national origin or ancestry, physical or mental disability, pregnancy, veteran status, marital status,
lineage, citizenship, sexual orientation, gender identity, genetic information, as well as any other
category protected by federal, state, or local laws, or believe he/she has been treated in an unlawful,
discriminatory manner, the employee should promptly report the incident to his/her supervisor,
Human Capital or any member of the senior management of VMD. This policy applies to all incidents
of alleged harassment, including those which occur off-premises, or during off-hours, where the
alleged offender is a supervisor, coworker, or even a non-employee with whom the employee is
involved, directly or indirectly, in a business or potential business relationship.

Should the alleged harassment occur at a time of the day other than the employee’s normal business
hours, the complaint should be filed as early as practicable on the first business day following the
alleged incident. In addition to immediately registering the employee complaint with VMD’s
management, the employee should always feel free to tell the offending co-worker (or whomever the
offender may be) directly that he/she finds the behavior offensive and to demand that he/she
immediately stop the harassing conduct.

VMD takes complaints of discrimination and harassment very seriously. Thus, there is no need for
an employee to follow any formal chain of command when filing a complaint or when discussing or
expressing any issue of concern regarding alleged discrimination or harassment, and the employee
may bypass anyone in his/her direct chain of command and file a complaint or discuss or express
any issue of concern with any member of senior management. Human Capital in conjunction with
the Senior Compliance Officer will undertake a prompt investigation of any complaint.

If VMD determines that an employee is responsible for harassing another individual, appropriate
disciplinary action will be taken against the offending employee(s), up to and including termination.

VMD prohibits any form of retaliation against any employee for filing a bona fide complaint under this policy or
any other, or for assisting in a complaint investigation. However, if, after investigating any complaint of
harassment or unlawful discrimination, VMD determines that the complaint is not bona fide and was not made
in good faith or that an employee has intentionally provided false information regarding the complaint,
disciplinary action may be taken against the individual who filed the complaint or who gave the false information
up to and including termination.

3.5 Code of Business Ethics and Conduct

It is the policy of VMD to conduct business in strict compliance with applicable federal, state, and
local laws and with the highest standards of business ethics. As an employee, we expect you to
adhere to these personal, professional, and business ethics and compliance standards. You are
expected to use good judgment in the conduct of your work. Honesty, respect, and care in dealing
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with each other, our customers, and our suppliers will be the standard benchmark for
behavior. These commitments are summarized below:

• To each other: we will treat one another with respect and care, protecting each other's privacy
and conducting ourselves with dignity.

• To our customers: we are committed to continuing to provide outstanding performance, to

producing quality products and services that meet or exceed our customers' standards and
specifications, within time schedules and budgets.

• To our suppliers: we are committed to continuing to emphasize fair competition, long-lasting

relationships, and a sense of responsibility.

• To the many communities in which we reside and to society as a whole: we are committed to
responsible corporate citizenship and compliance with federal, state, and local laws.

The Company's success in business requires ethical behavior and actions, which includes following
and adhering to all policies within this Employee Handbook. A detailed code of business ethics and
conduct is set forth in our Ethics Policy Handbook (the “Ethics Policy”), which all our employees are
expected to review and follow. If you have any questions about VMD’s Ethics Policy, you should
reach out to your immediate supervisor or the Senior Compliance Officer, by phone at 571-459-
2498 or via email at jweiss@vmdcorp.com, or in person. You may also use the Hotline (844) 415-
9857, which allows for anonymous reporting as well, to report any misconduct or non-compliance,
or for any questions related to our Ethics Policy.

3.6 Protection of Intellectual Property, Trade Secret, and Confidential Information

It is essential for all employees to safe-guard VMD’s trade secrets and confidential information
and to refuse any improper access to trade secrets and confidential information of any other
company, individual, or entity, including competitors. VMD’s basic guidelines are:

1. Company proprietary or confidential information must not be discussed with others within
VMD, except on a strict need-to-know basis;

2. If there is a need to disclose VMD trade secrets or confidential information to any person
outside VMD, it must be done only in conjunction with a non-disclosure agreement provided
by the Senior Compliance Officer;

3. Always be alert to avoid inadvertent disclosures which may arise in social conversations or
in normal business relations; and

4. Do not receive any such proprietary or confidential information from other companies or
people except pursuant to written agreement.

3.7 Insider Information

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VMD has legal obligations to be especially vigilant in safeguarding material, non-public

information from disclosure both inside and outside the company. Our policy is that VMD
employees with knowledge of such information that has not been disclosed to the public must
refrain from disclosing such information to anyone else.

3.8 Reporting Material Developments and Complying with Internal Controls

It is the duty of every employee to fully, fairly, accurately, timely and understandably report
financial and non-financial information and developments that could possibly have a material
effect on the operations or financial condition of VMD to his/her immediate manager and to the
Senior Compliance Officer, the Controller, or the CEO as soon as it is discovered. Employees are
expected to report any failure to comply with such controls and procedures as described above,
to the Senior Compliance Officer or the VMD Hotline at (844) 415-9857, which has been
established for employees to report suspected improper conduct, including without limitation,
violations of corporate accounting policies, practices, or controls, or auditing policies and
practices.

3.9 Dealings with Suppliers, Venders, Business Partners, and Competitors

Integrity and fair dealing are core components of VMD’s business practices. All vendors,
suppliers, other business partners, and competitors shall be treated fairly and uniformly in
accordance with VMD's established purchasing policies and procedures. Employees must not
engage in any activity prohibited under anti-trust laws, including boycotting, price-fixing, refusal
to deal, price discrimination, or disparate treatment of suppliers. Paying bribes, accepting
kickbacks, and obtaining and using third party insider information in dealings with suppliers,
vendors and business partners are inappropriate and will not be tolerated.

3.10 Fiduciary Duty of Employees

VMD's greatest assets are the knowledge, ingenuity, and productivity of its employees. The
company benefits most from such assets when employees perform their work with the highest
degree of loyalty. In recognition of this fact, the law places upon each employee certain fiduciary
responsibilities to the company, including, for example, the duty to place the interest of the
company and its owners above the employee's personal interest in any situation where they
might conflict.

In light of the special trust and confidence that VMD places in its employees, this policy requires
that employees act with undivided loyalty to the company and fairness in dealings with the
company, its employees, its suppliers, its business partners, and its existing and potential
clients. The restrictions placed upon employees by policy are not intended to prevent employees
from competing lawfully and fairly with the company following termination of employment, or
from engaging in subsequent employment in any field of their choice. Instead, they are intended
solely to prohibit certain acts (including those listed below by way of example) that would be
inconsistent with employees' obligations arising out of their employment relationship with the
company, such as:

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1. Permitting the use of their names or resumes by another entity in any bid, any response to
a request for proposal, or any other similar application for a contract or task order that
competes against the company for new work; or is intended to replace, succeed,
supersede, reduce, or diminish VMD's work under a contract or task order;
2. Accepting kickbacks (soliciting or accepting, either directly or indirectly, any gift that is
offered because of the employee’s position. A gift includes any favor, gratuity, discount,
entertainment, hospitality, loan or any other thing of monetary value);
3. Conducting or planning to begin a new, non-VMD enterprise while an employee of the
company and carrying out the enterprise or preparations for a new enterprise on company
time;
4. Working on behalf of another entity while a VMD employee without receiving prior written
approval by VMD. Depending upon the circumstances, this approval may go to the level of
the VMD Senior Compliance officer or Executive Staff;
5. Using trade secrets or confidential or proprietary information in an unauthorized manner;
6. Soliciting the company's customers or employees; and
7. Taking opportunities that are discovered through the use of company property, information,
or position for personal gain.

Each employee is expected to fulfill his/her fiduciary responsibilities to the company as required
by law and these policies. Any failure to comply with the law or these policies constitutes grounds
for discipline up to and including termination of employment for cause.

3.11 Policies Related to U.S. Government Contracting

As a government contractor, VMD has a special obligation to the U.S. Government, and to the
general public, to ensure that VMD’s contracts are administered and VMD’s products and
services are delivered in a manner that fully satisfies both VMD’s legal obligations and VMD’s
high standards of integrity, honesty, and quality.

Contracting with the U.S. Government imposes requirements not traditionally associated with
purely commercial business transactions. VMD is committed to compliance with the letter and
spirit of the laws and regulations governing U.S. Government contracting. VMD’s Ethics Policy
summarizes a number of key requirements affecting U.S. Government contracts, however all
employees are responsible for understanding and abiding by all applicable contract
requirements. Any questions or concerns regarding the U.S. Government contracting policies
and procedures detailed in the Ethics Policy or in a specific contract should be directed to the
Senior Compliance Officer.

3.12 Reporting Obligations

Employee Reporting Requirements

It is the responsibility of any employee having knowledge of any activity that is or may be in
violation of the Ethics Policy, this Employee Handbook, any law, rule, or regulation applicable to
VMD's business, or any Affirmative Action Policy to promptly disclose such activity.

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For this purpose, VMD has established the following contacts for reporting violations:

1. Immediate Manager
2. Senior Compliance Officer
3. The Human Capital Department
4. VMD Hotline (844) 415-9857 (available 24 hours)

The VMD Hotline is intended for reports of any kind of inappropriate conduct, including reports
of concerns associated with accounting policies and practices, internal controls, and auditing
policies and practices. Employees may make reports via the Hotline on an anonymous basis as
well.

It is VMD's policy that there will be no retaliation against any person who reports what they
believe in good faith to be a violation of this policy or any law, rule, or regulation applicable to
VMD's business. Persons reporting potential violations should be aware that, while a VMD
representative receiving a report of a suspected violation will take steps to keep such report
confidential, the need to investigate and correct any impropriety may require disclosure of the
matter reported to a restricted group.

3.13 Reasonable Accommodation for Qualified Individuals with Disabilities

VMD is committed to complying fully with the Americans with Disabilities Act (ADA) and ensuring
equal opportunity for qualified persons with disabilities regarding the recruitment and hiring
process, rates of pay, promotion, training, termination, benefit plans, and all other forms of
compensation, conditions and privileges of employment for both employees and applicants. All
employment practices and activities are conducted on a non-discriminatory basis and in
accordance with all applicable federal, state and local laws concerning the employment of persons
with disabilities. For the purposes of this policy, “disability” refers to a physical or mental
impairment that substantially limits one or more of the major life activities of an individual.

A qualified individual who is regarded as having a disability or has an actual disability or record of
a disability who with reasonable accommodation and without undue hardship to VMD, can perform
the essential functions of the job, will be given the same consideration for that position as any
other applicant or employee. This also applies to employees who may have limited ability to
perform job duties due to pregnancy, childbirth, breastfeeding, or related medical conditions.

For the purposes of this policy, “reasonable accommodation” refers to any change or adjustment
to the job application process, work environment, or work processes that would make it possible
for the qualified individual with a disability to: (i) be considered for a position; (ii) perform the
essential functions of the job; or (iii) enjoy equal benefits and privileges of employment as are
enjoyed by other similarly situated employees without disabilities. A job function may be
considered essential for any of several reasons, such as: the job exists to perform that function,
the function requires specialized skills and the individual is hired for that expertise, or there are
only a limited number of employees to perform the function.

Furthermore, VMD will not discriminate against any qualified employees or applicants because they
are related to or associated with a person with a disability. VMD will follow any applicable state or
local law that provides individuals with disabilities greater protection than what the ADA offers.
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This policy is neither exhaustive nor exclusive. VMD is committed to taking all other actions within
reason that are necessary to ensure equal employment opportunity for persons with disabilities in
accordance with the ADA and all other applicable federal, state, and local laws.

Employees with questions, or who wish to request an accommodation should contact their Human
Capital Business Partner. It is the employee’s responsibility to participate in this interactive
process by seeking an accommodation, assisting VMD in reviewing accommodation alternatives
and providing medical certification of the need for an accommodation. Whether a requested
accommodation would create an undue hardship will be determined based on the facts of each
particular case. A copy of the form which an employee would need to complete to request an
accommodation may be found on the company SharePoint site under Employee
Documents/Company Forms.

3.14 Religious Accommodations

VMD will reasonably accommodate the religious practices of employees when this can be done
without undue hardship to VMD and/or fellow employees. Employees requiring an accommodation
must submit a Religious Accommodation Request form to his or her supervisor and Human
Capital. The employee’s supervisor and a representative from Human Capital will grant the request
so long as the accommodation does not result in an undue hardship to VMD and/or to fellow
employees.

Methods of accommodation include but are not limited to using Annual Leave - Paid Time Off,
flexible scheduling of work hours, leave without pay, or permitting a nonexempt employee to make
up time lost for the observance of religious practices. A copy of the form which an employee would
need to complete to request an accommodation may be found on the company SharePoint site
under Employee Documents/Company Forms.

3.15 Drug and Alcohol-Free Workplace

VMD is committed to maintaining a workplace free from the effects of alcohol, illegal drugs, or other
intoxicating substances which cause potential health, safety, and/or job performance
problems. Substance use and abuse in the workplace endangers fellow employees, safety,
Company morale, and productivity. VMD will act quickly to stop any drug-related or alcohol-related
activity which interferes with a safe, healthful and productive working environment or threatens
VMD’s reputation in the community. The following practices are strictly prohibited:

• Using, possessing, manufacturing, selling or distributing illegal drugs or illegal drug-related

paraphernalia.
• Possessing or using alcoholic beverages on VMD premises or client sites, except for beverages
served at a VMD-sponsored function or with CEO & President approval.
• Selling or distributing prescribed medications or abusing prescribed medications while on VMD
work time.
• Selling or distributing over the counter medications or abusing over the counter medications
while on VMD work time.

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Employees must report to work in an appropriate mental and physical condition, unimpaired by the
use of alcohol or other intoxicants. If an employee is impaired due to a prescription medication, that
employee may not be in the workplace. If an employee takes a prescribed medication that impairs
them beyond the time of their treating physician’s advice they should follow up with their treating
physician. Any employee found to be in violation of this policy will be removed from work and
subjected to disciplinary action, up to and including termination. Depending upon the
circumstances, other action, including notification of appropriate law enforcement agencies, may
be pursued. If employment is continued, the employee may be required to submit to follow-up drug
testing and participate in and successfully complete a substance abuse program.

This policy does not prohibit employees from the lawful use and possession of prescribed
medications. Employees must, however, consult with their doctors about the medications’ effect
on their fitness for duty and ability to work safely and promptly disclose any work restrictions to
their supervisor and Human Capital.

From time to time, VMD may sponsor functions where alcoholic beverages may be served to
employees, who are 21 years of age or older. While employees may consume alcohol at such
functions, all employees are expected to drink responsibly, exercise judgment and professional
decorum at all times, and comply with VMD’s standards of conduct.

3.15.1 Drug testing for Government Services and Corporate Employees

Participation, as requested, in the following screenings is a condition of employment with

VMD. Please note that Addendum A at the end of this handbook is incorporated by
reference and includes additional information that is specific to Homeland Defense:

1. Pre-Employment Testing – Similar to Addendum A, in positions and/or contracts

where applicable, applicants for employment may be tested for drugs at VMD’s
expense. If any prospective new hire refuses to provide a drug screen sample,
attempts to provide an invalid or fraudulent sample, or if results confirm the presence
of illegal drugs (or drug metabolites), then consideration for employment will
immediately cease.

2. Random Testing – Also like Addendum A and as may at times be used for any
employee, as permitted per state laws, VMD reserves the right to conduct random
drug and alcohol screenings determined exclusively by a third-party vendor engaged
by VMD using computer-generated, random-number generating programs to ensure
complete impartiality and objectivity. VMD will not conduct selection of employees
for random testing. If results confirm the presence of drugs (or drug metabolites),
the employee will be subject to disciplinary action up to and including termination.

3. “For-Cause” Testing – Finally, as also outlined in Addendum A, any employee will be

immediately tested for drugs and alcohol anytime at work for the following reasons:

a. A supervisor, or other member of Company management, has reasonable

suspicion an employee is under the influence of drugs or alcohol in the
workplace;
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b. There has been an accident in the workplace; or,

c. To maintain safety and security in the workplace.

“Reasonable suspicion” means the supervisor or member of management, based on

objective facts and the reasonable inferences drawn from those facts, whether observed
firsthand or based upon the reports of others, believes an employee may be under the
influence of a controlled substance or alcohol. Such facts and inferences may be based
on the employee’s erratic behavior while in the workplace, upon a significant deterioration
in the quality of the employee’s work performance, or upon other reasonable credible
evidence or observation.

Employees may be disciplined or terminated for refusing to be tested, and employees

may be disciplined or terminated for positive test results. Employees have the right to
request in writing all test results. VMD will maintain the confidentiality of the test results,
except as required by applicable law.

3.15.2 Drug and Alcohol-Free Workplace – Homeland Defense and other contracts
subject to Federal Acquisition Regulation (FAR)

Employees who work within the Homeland Defense Division of VMD and/or are on a
contract subject to the FAR, please refer to Addendum A for the Drug and Alcohol-Free
Workplace policy that is specific to these contracts.

3.15.3 Tobacco Free Workplace

In addition to the Drug and Alcohol-Free Workplace policy, VMD also prohibits the use of
any tobacco products on VMD property or offices except in designated areas outside of
the building where smoking is allowed.

Employees who smoke or use other tobacco products must limit the frequency and length
of break periods during the work day.

3.16 Workplace Safety

Safety is everyone’s responsibility. VMD wants to ensure that our employees always remain safe
and injury-free. Safety is often taken for granted in an office environment. Though VMD’s
employees may not be exposed to the same degree of risk as employees of a manufacturing firm
or health care facility, employees still need to recognize safety risks are present and take steps to
reduce the risk of injury or illness.

VMD intends to comply with all applicable safety laws. It is important to follow safety and security
measures while on the job. In order to guarantee accidents are avoided whenever possible, VMD
expects employees to refrain from horseplay, careless behavior and negligent actions.

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VMD employees are required to immediately notify their supervisor of any work-related injuries or
illnesses. The supervisor is then responsible to report the injury or illness to their Human Capital
Business Partner within 24 hours of being notified. This notification must take place regardless of
whether medical attention is deemed necessary. When injuries are reported immediately, they will
be quickly investigated, and corrective action will be taken to prevent more injuries.

Furthermore, to ensure the safety and security of employees and VMD offices, only authorized
visitors are allowed in the workplace (authorized visitors are associated with work activities,
including clients, off-site employees, prospective/current business partners, interviewees,
etc.). Restricting unauthorized visitors helps maintain safety standards, protects against theft,
ensures security of equipment, protects confidential information, safeguards employee welfare,
and avoids potential distractions and disturbances.

3.17 Violence-Free

VMD has a zero-tolerance policy regarding workplace violence and will not tolerate acts or
threats of violence, harassment, intimidation, and other disruptive behavior, either physical or
verbal, that occurs in the workplace or other areas. This applies to management, co-workers,
employees, and non-employees such as contractors, customers, and visitors.

Workplace violence can include oral or written statements, gestures, or expressions that
communicate a direct or indirect threat of physical harm, damage to property, or any intentional
behavior that may cause a person to feel threatened.

3.18 Bullying

Bullying is any repeated, unreasonable behavior directed toward an employee, customer, or

vendor which is intended to intimidate, creates a risk to health and safety, or results in
threatened or actual harm. The following list describes activities which are expressly prohibited
and is not exhaustive:

• Intimidating, threatening, or hostile statements, actions, or gestures.

• Excluding someone from workplace activities, social isolation.
• Verbal abuse, demeaning comments.
• Direct, conditional, or veiled threats.
• Being treated differently than the rest of the work group.
• Yelling, screaming, and other demeaning behavior.
• Being given the majority of unpleasant tasks.
• Public humiliation.

VMD expects employees to behave in a professional manner and to treat other employees,
customers, and vendors with dignity and respect when they are at work.

3.19 Weapons

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VMD understands it is every individual’s right to bear arms; however, VMD offices and client
sites are not the proper environment for any weapons, and they are therefore prohibited. This
policy applies to all employees, visitors and customers on Company premises, even those who
are licensed to carry weapons.

Some examples of prohibited weapons include:

• Firearms (pistols, revolvers, shotguns, rifles and bb guns)

• Knives (switchblades, gravity knives or any knife with a blade longer than three inches)
• Metal knuckles
• Bows and arrows
• Tasers

Any behavior that compromises the Company's ability to maintain a safe work environment
must be reported immediately to management or Human Capital, in accordance with this
policy. All reports will be investigated immediately and kept confidential, except where there is
a legitimate need to know. Any violations to this policy may subject the person in violation to
criminal charges as well as discipline up to and including immediate termination.

3.20 Ban on Texting While Driving

As an additional safety measure, employees may not send or read text messages while driving
either: (i) VMD-owned or rented vehicles or customer-owned or rented vehicles, or (ii) privately-
owned vehicles when on official company business or when performing any work for or on behalf
of VMD.

3.21 Background Check and E-Verify

VMD requires potential and current employees provide written authorization for background checks
as a condition of employment. In compliance with federal contract requirements, VMD also utilizes
the E-Verify system to help ensure compliance with federal immigration laws.

Every employee of VMD, regardless of his/her employment status, is subject to the following prior
to and during employment as business needs warrant:

• Verification of most recent education and employment information provided.

• Verification of authorization to work in the United States (e-Verify).
• Routine criminal background checks.
• Drug testing for certain positions.
• Credit history check for certain positions.
• Acquiring and maintaining the necessary government security clearance to perform an
employee’s work, if one is required, is a condition of employment. Failure to obtain and/or
maintain the necessary clearance may result in termination of employment.

Misrepresentation, fraudulent or negative information related to background and reference checks

will be reviewed with the respective employee and may result in termination of employment in
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accordance with federal, state and/or local laws. Background and reference checks, as well as
drug testing requirements may be subject to change at VMD’s discretion.

3.22 Conflict of Interest

All employees have a duty to further VMD’s mission and goals, and to work on behalf of its best
interest. Employees of VMD must not be under any prior obligation or agreement which would
prevent them from assuming their positions with VMD or would adversely impact their ability to
perform the expected services. Employees shall not place themselves in a position where their
actions or personal interests may conflict with those of VMD. Examples include: (a) soliciting or
profiting from VMD’s client or prospect base or other Company assets for personal gain; (b) acting
on behalf of VMD in servicing or obtaining a client and limiting the best solution for the prospective
or current client for personal financial gain; (c) or, acting as director, officer, employee or otherwise
for any business or institution with which VMD has a competitive or significant business relationship
without the written approval of the CEO & President.

If a current VMD employee plans to accept additional employment or embark on a personal

business venture, or serve as an advisor or board member, a request in writing must be submitted
to the employee’s supervisor, containing the following information:

1. Hours to be worked per week

2. Place of employment
3. Position Title
4. Nature of responsibilities
5. Duration of employment/engagement

Prior to beginning additional opportunities, a formal written approval from your supervisor must be
obtained and provided to Human Capital, to avoid any possible conflict of interest. In some cases,
the additional opportunity may also require review from the Senior Compliance Officer or Executive
Leadership. A copy of the Company’s conflict of interest form may be found on the company
SharePoint site under Employee Documents/Company Forms.

All VMD employees must report to Human Capital any situation or position (including outside
employment by an employee or any member of an employee’s immediate household) which may
create a conflict of interest with VMD. Additional information regarding VMD’s conflict of interest
policy may be found in the Ethics Policy.

3.23 Nepotism and Fraternization

VMD wants to ensure that corporate practices do not create situations such as conflict of interest
or favoritism. This extends to practices that involve employee hiring, promotion and transfer. Close
relatives, partners, those in a dating relationship or members of the same household are not

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permitted to be in positions that have a reporting responsibility to each other. Close relatives are
defined as:

1. Parent/step parent
2. Child/stepchild
3. Brother or sister/stepbrother or stepsister
4. Grandparents/spouse’s grandparents
5. Spouse/domestic partner
6. Direct in-law

VMD is committed to maintaining a positive work environment for its employees that encourages
all employees to perform to their best level in an environment that supports employee’s career
goals based on relevant factors such as ability and work performance. VMD strongly discourages
dating/romantic/intimate relationships occurring between employees. The Company recognizes
that there is a risk that romantic relationships within the workplace may arise and that this could
disrupt the employee work environment and negatively impact peers, coworkers and the Company.

If an employee begins a dating/romantic/intimate relationship or becomes relative, partner or a

member of the same household with another employee, particularly one who is in a supervisory
position, it is mandatory that both individuals inform management and Human Capital of the
relationship. Failure of a manager to self–report the existence of a romantic or intimate relationship
may result in disciplinary action up to and including termination of the manager. At no time will a
manager be in a relationship with an individual for whom they have supervisory responsibilities. If
reassignment, otherwise changing a reporting relationship, or finding one or both employees
another position within the Company prove not to be appropriate options for VMD, VMD may
terminate one of the employees as soon as practical.

VMD 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.

3.24 Hiring of Government and Former Government Employees

Special concerns apply to hiring or retaining a Government or former Government employee as an

employee or consultant of VMD. In addition, there are special constraints regarding any
communication concerning possible employment of Government employees who are designated as
"procurement officials" during the conduct of any procurement action and otherwise. VMD
employees shall not conduct any discussions regarding, or make any offer or promise of, future
employment or business opportunity to any procurement official during the conduct of any
procurement. Before discussing potential VMD employment with any Government employee,
contact the Senior Compliance Officer.

In addition, any plans to employ retired military officers of general or flag rank, or civilian officials
having the rank of Deputy Assistant Secretary or above, must be approved by the CEO/President
prior to an offer of VMD employment.

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3.25 Prohibited Contractual Relationships

VMD shall not knowingly employ an individual or contract with a company, by any means, if the
individual or company is on the Consolidated List of Debarred, Suspended and Ineligible
Contractors available on the System for Award Management (www.sam.gov), nor knowingly employ
an individual who has been convicted of an offense related to government contracting. Nor will
VMD knowingly contract with an individual or entity identified on the Office of Foreign Asset
Control's (“OFAC”) "Specifically Designated" list of nationals or persons who are subject to trade
restrictions.

VMD employees will immediately sever all business connection with any former employee or
consultant of VMD whose conduct violates applicable laws, regulations, or basic tenets of business
integrity and honesty, and such other individuals specifically identified by the company.

3.26 Organizational Conflicts of Interest

VMD’s ability to perform federal contracts, and its ability to qualify for new federal contracts, may
be limited in circumstances where VMD has a potential or actual organizational conflict of interest
(“OCI”). Generally, an OCI occurs where, because of other activities or relationships, VMD is unable
(or potentially unable) to render impartial assistance or advice to the Government; VMD’s objectivity
in performing the contract work is (or may be) impaired; or VMD has an unfair competitive
advantage. Employees should notify the Senior Compliance Officer of all potential or actual OCI
situations. Further details regarding VMD’s OCI policy and guidance can be found in the Ethics
Policy.

4 Operational Procedures
4.1 Employment Classifications and Categories

It is the intent of VMD to clarify the definitions of employment classifications so that employees
understand their employment status and eligibility for benefits. These classifications do not
guarantee employment for any specified period. The right to terminate the employment
relationship at-will at any time is retained by both the employee and VMD.

4.2 Company Job Classifications

Eligible for Holiday Eligible for H&W

Classification Reg Scheduled Max Hours Per Leave (PTO, PTO Leave Leave Benefits (health,
(Non-SCA) Hours Per Week Year Holiday) Prorated Prorated life disability, etc.)
Full Time 40 hours 2080 Yes N/A N/A Yes
Full Time
Reduced 30-39 hours 2028 Yes Yes Yes Yes
Part Time 13-29 hours 1508 No N/A N/A No*

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Variable 2-12 hours 624 No N/A N/A No*

Holiday only
Temporary/Intern 30-40 hours 520 *** N/A Yes No*

Eligible for Holiday Eligible for H&W

Classification – Reg Scheduled Max Hours Per Leave (Vac, Vac Leave Leave Benefits (health,
SCA Hours Per Week Year Sick, Holiday) Prorated Prorated life disability, etc.)
Full Time 40 hours 2080 Yes N/A N/A Yes
Full Time Program Program
Reduced 30-39 hours 2028 Yes specific specific Yes
Part Time 24-29 hours 1508 Yes Yes Yes Yes**
Part Time 13-23 hours 1196 Yes Yes Yes No*
Variable 2-12 hours 624 Yes Yes Yes No*
Temporary/Intern 30-40 hours 520 Yes Yes Yes No*
Notes:
*not eligible for benefits except 401k & My Commuter
**eligible for all benefits except for STD or LTD
***eligible for Holiday

Any changes to an employee’s classification must be approved by the manager and coordinated through Human
Capital.

4.3 Contract Specific Classifications

In addition to the above listed Company Job Classifications, employees may also be classified as:

Service Contract Act (SCA) employees are employees who are hired to perform work on a federal
government contract subject to the Service Contract Act. SCA employees are typically hired on
a full-time, part-time, or casual basis and are paid at least the wage prevailing minimum wage
rate and fringe benefits set forth in the applicable SCA Wage Determination (WD). Part-time
employees are only entitled to a proportionate amount of the fringe benefits specified in the
applicable WD. All SCA employees will be eligible to participate in a “bona fide” benefit plan
offered by VMD subject to terms, conditions, and limitations of each benefit program.

The McNamara-O’Hara Service Contract Act of 1985 requires employees who are covered
service workers on federal service contracts the right to receive at least the locally prevailing
wage rate, fringe benefits and safety and health protection, as determined by the Department
of Labor, for the type of work performed. The Act covers contracts and any bid specifications in
excess of $2,500, whether negotiated or advertised, entered into by federal and District of
Columbia agencies where the principal purpose of the contract is to furnish services in the U.S.
through the use of service employees. Non-exempt employees assigned to an SCA designated
contract are subject to these standards regardless if their status is full-time, part-time or
temporary. The SCA excludes individuals who are exempt under the Fair Labor Standards Act.
Each contract designated as SCA contains a Wage Determination (WD). Any employee who is
classified as performing SCA duties will be paid by the applicable Wage Determination as
incorporated into the contract.
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Employees designated under the Service Contract Act shall observe the compensation and
holiday schedule designated in the applicable Wage Determination fringe benefit listing. See
your manager or Human Capital for any clarification of holiday compensation under the Service
Contract Act.

Depending on the applicable area wage determination, most Service Contract Act employees
who are classified as SCA employees earn vacation in one lump sum on the anniversary date of
their “date of hire”. The SCA and WD benefits for non-exempt employees will supersede the
Company’s policies in the following areas:

• Vacation (vesting schedule by anniversary dates, including dates with predecessor

contractor if previous contract was SCA and no break in employment)

• Holiday (federal holidays)

• Fringe Benefits (a predetermined minimum value for health and welfare benefits per
hour)

Upon employment, if you are determined to be a SCA employee, you will be advised of your SCA
status, vacation benefits and health and welfare benefits. Contact your manager or Human
Capital for further explanation of your benefits under the SCA.

4.4 Fair Labor Standards Act (FLSA) Job Classifications

All employees are designated as either nonexempt or exempt under state and federal wage and
hour laws:

• Nonexempt employees are employees whose work is covered by the Fair Labor Standards
Act (FLSA). They are not exempt from the law’s requirements concerning minimum wage
and overtime. VMD will compensate all employees classified as nonexempt in accordance
with state and federal overtime regulations.

• Exempt employees are generally executives or managers or professional, administrative or

outside sales staff who are exempt from the minimum wage and overtime provisions of the
FLSA. Exempt employees hold jobs that meet the standards and criteria established under
the FLSA by the U.S. Department of Labor. Those employees whose positions are exempt
will receive a salary to be considered full compensation regardless of the number of hours
worked in one work week.

4.5 Service Date

An employee’s service date is the date the employee was hired for the current period of
uninterrupted employment. This date will be used to determine eligibility for enrollment in all VMD
benefit programs.

4.6 SCA Seniority Date

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An employee’s SCA seniority date is the start date an employee began supporting a project that
exists at the same location, providing the same services to the same client and that has had no
break in service.

4.7 Business Hours and Work Schedules

Hours for all full-time exempt and nonexempt employees of VMD consist of five (5) days (40 hours),
within a seven (7) day period. The workweek starts on Saturday at 12:00 a.m. and continues
through Friday at 11:59 p.m. Work schedules for full-time employees’ work will be determined by
management. With the approval of their supervisor in advance, a full-time employee may modify
their work hours within the same pay period. However, total hours worked must meet or exceed
the total number of hours regularly scheduled within that pay period. Work hours for part-time
employees will be set by their assigned supervisor.

Staffing needs and operational demands may necessitate variations in starting and ending times,
as well as variations in the total hours that may be scheduled each day and week.

4.8 Meal and Break Periods – Non-Exempt Employees

The scheduling of meal periods at VMD is set by the employee’s immediate manager with the goal
of providing the least possible disruption to company operations.

4.8.1 Mandatory Meal Period

A break during the day is important both to employee health and morale and employee
productivity. To that end, employees who work at least six (6) hours in a day will be provided a meal
break, not to exceed 30 minutes, unless otherwise indicated per state laws. The meal period will
not be included in the total hours of work per day and is not compensable. Nonexempt employees
are to be completely relieved of all job duties while on meal breaks.

4.8.2 Rest Break

Salaried employees, as they are paid a weekly salary regardless of the hours they work, may choose
to take breaks as needed. Nonexempt employees are permitted a 15-minute rest break for each
four hours of work. This is considered “time worked” and is compensable.

4.8.3 Impermissible Use of Meal Period and/or Rest Breaks

Neither the lunch period nor the rest break(s) may be used to account for an employee's late arrival
or early departure or to cover time off for other purposes—for example, rest breaks may not be
accumulated to extend a meal period.

4.9 Payroll Procedures

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All employees, regardless of employment category or classification, will be paid on a semi-monthly

basis. This schedule will consist of twenty-four (24) pay periods per year.

VMD’s workweek begins at 12:00 a.m. Saturday and ends at 11:59 p.m. the following Friday.

If a scheduled payday falls on a Company-observed holiday, or a Saturday, employees will be paid

the Friday before. If a scheduled payday falls on a Sunday, employees will be paid the Monday
after. Nonexempt employees will receive payment for overtime in the period in which such overtime
is worked, provided that time sheets have been properly prepared and approved.

Employees must submit a written request if a deviation in paycheck-distribution is

required. Employees who change banking accounts or require updates to their W-4 withholdings
should contact the Human Capital Department at HumanCapital@vmdcorp.com to update their
direct deposit or tax withholding forms.

Certain payroll deductions will be made in accordance with federal and state laws in addition to
voluntary employee deductions. Employees are responsible for reviewing their paycheck for
errors. If an employee finds a mistake, detail of the error must be immediately reported to the HR
Department at HumanCapital@vmdcorp.com and the Payroll Department at
Timesheet@vmdcorp.com who will take the steps necessary to correct the error.

Employees must notify the Payroll Department immediately if their paycheck is lost or stolen. If
VMD is able to put a stop-payment notice on an employee’s check, the employee will be issued
another check. Unfortunately, however, VMD is unable to take responsibility for lost or stolen
paychecks. If VMD is unable to stop payment on the employee’s check, the employee alone will be
responsible for the loss.

By law, VMD is required to comply with all court order or government mandate and applicable
laws. Upon receiving a court order or government mandate for garnishing wages, VMD will notify
the employee and begin withholding wages.

4.10 Overtime Pay Procedures

VMD compensates all nonexempt employees under the Fair Labor Standards Act (FLSA) one-and-
a-half (1 ½) times their regular pay for all hours worked in excess of forty (40) hours each work
week, or in accordance with applicable state and local laws. For the purposes of calculating
overtime, holidays, vacation, sick and other paid leave will not be considered as hours worked for
purposes of computing overtime pay. For employees located in California, overtime of one-and-a-
half (1 ½) times regular pay will be accrued for any hours in excess of eight (8) up to and including
twelve (12) hours in a day. California employees will also earn two (2) times their regular pay for
any hours in excess of twelve (12) worked in a day and for all hours worked in excess of eight (8)
on the seventh consecutive day of work in a workweek. A workday starts at 12:00 a.m. and goes
until 11:59 p.m.

At times, nonexempt employees will be asked to work overtime to complete necessary work
assignments. The employee’s supervisor will notify the employee as early as possible regarding
scheduling needs. To be eligible for overtime pay, if an employee has a need to work overtime
hours, the employee must receive advance authorization from his/her supervisor, before working
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any overtime hours. Non-Exempt employees are not to work overtime without the prior approval of
their supervisor. Employees who work unauthorized overtime will be paid; however, they may be
disciplined, up to and including termination for violations of this policy.

Furthermore, nonexempt employees are strictly prohibited from performing any work which is not
recorded. This ban includes any work performed for VMD outside normal working hours, such as
checking emails or responding to phone calls or text messages, unless preauthorized in writing by
the employee’s supervisor. Failure to accurately record time worked is grounds for disciplinary
action, up to and including possible termination.

Any supervisor, who encourages or suggests nonexempt employees work off the clock, is subject
to disciplinary action, up to and including possible termination.

Exempt employees are not eligible for overtime compensation.

4.11 Timesheets

VMD requires accurate and timely reporting of all labor charges. All employees must accurately
record and report to the appropriate charge number, all hours worked daily. Timesheets must be
completed at the end of each day and signed by the last day of the timesheet period. Employees
will be supplied with valid charge numbers by their immediate manager upon hire and/or change
in charge numbers. If an employee does not have a charge number for work completed, he or she
should request the number from management immediately.

If the electronic timesheet is not available, employees should record the date and hours worked
on a paper timesheet and transition those hours to the electronic timesheet when access is
restored. Employees should maintain a physical record of any time records and charge numbers.

In order to record and process all labor charges and leave usage, at the end of a payroll period,
each employee must complete, sign, and submit a timesheet to management. Management will
review and sign the timesheet by the close of business the next day. If corrections to the timesheet
are required, the timesheet will be rejected by management and the employee or appropriate
timesheet administrator will make the necessary changes.

In the event of a planned absence, the employee must complete the timesheet on the last day of
work before the absence begins. If an employee is unexpectedly absent on the day the timesheets
are due, the employee’s supervisor will record the best estimate of the employee’s charges and
confer with the employee upon their return.

It is a violation of VMD policy to willfully make a false or fraudulent representation through the
completion of an individual timesheet. Any employee who willfully and consciously misrepresents
labor charges through intentionally fraudulent coding of timesheets will be subject to disciplinary
action, up to and including immediate termination.

Questions about an employee’s timesheet should be sent to Timesheet@vmdcorp.com.

4.12 Recordkeeping

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VMD is frequently required to submit accounting and other records to the Government as a basis
for payment on existing contracts or as estimates on future work. All data must be accurate, and
all estimates must be made in good faith. VMD’s books and records must be maintained in
reasonable detail, appropriately reflect VMD’s transactions, and conform both to applicable legal
requirements and VMD’s system of internal controls.

Employees should never falsify or distort any information or documents related to their work for
VMD, including time records, expense reports, benefits claims, invoices, and entries in financial
books and records. Inaccurate records could result in VMD failing to satisfy legal, regulatory, or
other obligations, undermine the confidence of our customers, and cast doubt on VMD’s integrity
and honesty. Employees should make certain that all information and reports supplied to
Government authorities are accurate, timely, and supported by necessary documentation, and
respond truthfully to all inquiries from auditors.

Business records should be retained or destroyed only in accordance with VMD’s record retention
policies, and you should not discard, destroy, or improperly alter records that are required to be
preserved by law, policy, or a “hold” directive issued in the event of litigation or a Government
investigation. VMD’s business records, including information stored electronically on computers,
are the property of VMD.

4.13 Performance Management

VMD’s Performance Management Program is intended to give Regular Full-Time and Part-Time
employees timely feedback about their performance in order to enhance their professional
development and contribution to Company goals. Further, results can extend to: 1) identifying
individual training needs and career development goals, 2) evaluating the success of individual
selection and placement decisions, 3) improving employee understanding of Company functions,
4) enhancing open communication between the employee and the manager and 5) providing a
guide point in determining if an adjustment in salary is merited. The process is designed to ensure
that the employee and the manager are involved together in establishing realistic performance
objectives.

Performance discussions should occur between a manager and an employee on an on-going basis
throughout the year. Regular meetings to discuss expectations, progress and challenges should
be held between the manager and the employee. In addition to that, performance feedback
discussions with formal documentation will be conducted annually reviewing performance of the
prior year. Regular Full-Time and Part-Time Employees and supervisors or managers will complete
the individual’s Performance Feedback Form, followed by discussing past performance and
opportunities to develop individual objectives and goals for the future. All performance
documentation will be maintained in the employee’s personnel file with Human Capital. Generally,
performance appraisals are conducted during the first quarter of the year and cover the prior year.
If a person begins employment late in the fourth quarter, he/she may not be eligible for a
performance review until the following year. When this happens, any additional time due to the
start date late in the year will be added to the review time frame of the next year

VMD is not obligated to increase salary because of an employee’s performance feedback, but
recommendations for an increase may be made in conjunction with the performance feedback
process. Merit increases are reviewed and approved at the discretion of management. The
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company will pro-rate Merit Increases to eligible employees, based upon the employee's number
of active service days during the applicable calendar year. For example, if an employee begins
employment in May of 2018 their merit increase will be pro-rated because they did not start in
January 2018 at the beginning of the performance period. Merit Increases are effective on the
eligibility date for those employees who are actively at work on the day they become effective and
employees who are on a leave of absence on the effective date will have their increase delayed
until they return to active status.

4.14 Personnel Files and Release of Employee Information

VMD maintains a permanent personnel and security file on each employee at the VMD Corporate
Headquarters. The personnel file includes such information as the employee’s job application,
resume, training records, and documentation of performance appraisals, other employment
records, and all documents required by law. All benefit records and records containing employee
personal health information will be maintained in separate files and secured in accordance with
HIPAA privacy rules.

Personnel files are the property of VMD, are treated as confidential, and access to the information
they contain is restricted. An employee’s chain of command may request employment related
information from an employee’s file as an integral part of their responsibilities. Human Capital will
determine the appropriateness of any request for this information prior to release. Deliberate
unauthorized release or disclosure of personnel information to unauthorized personnel, including
other unauthorized employees or individuals outside of VMD, will be grounds for disciplinary action,
up to and including termination.

Employees who wish to review their own personnel file should contact Human Capital directly. With
reasonable advance notice, employees may review their own personnel file in the presence of an
individual appointed by VMD to maintain the files.

4.15 Change of Employee Information

It is the employee's responsibility to notify Human Capital of any changes in personal information,
such as: name, address, telephone number, marital status, tax withholdings, number of
dependents, military service status, beneficiaries or person to notify in case of an emergency.

4.15.1 Employment Verification and References

VMD maintains strict confidentiality of employee records. However, operating

requirements of VMD do necessitate disclosure of employee information.

Requests for employment verifications must be directed to Human

Capital. Human Capital will verify limited information to include name, job
title, and employment dates. VMD will not release additional information
without written authorization from the employee.

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It is not VMD’s practice to provide terminated or previous employees with a

letter of recommendation. Managers or co-workers who are contacted by a
former employee regarding a reference or confirmation of employment should
refer the former employee to Human Capital. Human Capital should be the
only entity within the company providing any employment details. The use of
VMD letterhead for letters of recommendation is strictly prohibited.

4.15.2 Other Employment Verification Requests and Orders

The following requests should be forwarded directly to Human Capital for action:

• Employment Verifications
• Wage Verifications
• References
• Salary Garnishments
• Support Orders
• Qualified Medical Child Support Order (QMCSO)

4.16 Employee Referral Program

Employees are a valuable resource in the recruitment process, and employee referrals account for
a significant amount of new hires within VMD.

VMD believes in the strength of networking to identify quality candidates for prospective
employment. As such, VMD is supportive of current employee’s referral of candidates for future
employment. All referrals are welcome for consideration, whether for an open position or a
potential future role at VMD. All referred candidates will be considered and evaluated based upon
experience and qualifications and will be subject to the same pre-employment standards as all
other candidates: qualification review, interview and selection.

If a VMD employee in our Corporate, Government Services, or Homeland Defense (except for
Transportation Security Officer Employees) Divisions wishes to refer a candidate, the VMD
employee must submit the referral’s resume or manually upload their information via JobVite
Dashboard (https://app.jobvite.com/login/login.html) for review and processing.

If a VMD employee in the Homeland Defense Division who is a Transportation Security Officer would
like to refer a candidate, the employee must provide either digital or paper copy of the individual’s
resume to a manager. That manager will enter the necessary information into JobVite for review
and action by a company recruiter.

When the referred candidate is hired for a position within VMD, the employee who generated the
referral is eligible for an award after the new hire has completed one hundred and twenty (120)
days of successful employment with VMD. Please note, the referring employee must be employed
by VMD at the end of the new hire’s employment period to be eligible for the referral reward. VMD

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will reward employees based on a three-tiered system and may be paid in a separate bonus check,
which is subject to tax withholding.

Bonus New Hire Position

$500 Part-Time

$1,000 Full-Time Non-Billable or Full-Time

Transportation Security Officers

$3,000 Full-Time Billable employees (except

Transportation Security Officers)

The following individuals are not eligible to participate in the reward portion of the Employee
Referral Program.
• Executives
• Hiring Manager / Director
• Human Capital
• Recruiters
4.17 Expense and Travel

VMD’s business needs from time to time require that employees travel and incur costs in the
performance of their job. VMD’s objective is that travel expenditures are made only when justified
by expected benefits that contribute to VMD's profitability.

All travel must have pre-approval from your supervisor. This will provide an opportunity for the
expected benefits of the expenditure to be weighed against the estimated cost. Travel that has not
been pre-approved will not be reimbursed.

When an employee travels on business, he or she is expected to exercise the same care in incurring
expenses that a prudent person would exercise traveling on personal business and expending
personal funds.

In some situations, employees may be granted a travel advance for their expenses.

The guidelines below are to be followed regarding travel and entertainment expenditures:

1. You must receive prior approval or authorization from your supervisor.

2. Meal expenses will only be reimbursed when you travel overnight or are engaged in authorized
business-related activities unless specifically dictated otherwise by contract requirements.
3. Business related activities may be authorized by a standing directive of the CEO. The
department head must approve the expense voucher turned in for the preauthorized specific
business-related expense reimbursement.
4. You will be reimbursed for approved travel and business-related expenditures when VMD’s
accounting office receives VMD's Expense Report which include the following:
a. Receipts of all items of expense.
b. Names of persons entertained and business relationship to VMD.
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c. Business purpose for the expenditure.

d. The employee's signature.
e. The supervisor’s signature

5. When you use your personal vehicle for approved VMD travel, you will be reimbursed at the
IRS-approved reimbursement level for the period during which you incurred the expenses.
6. Expense reports must be approved by the employee’s supervisor.
7. Expense reports and receipts must be submitted to Accounting within 30 days of the incurred
expense.

5 Professional Conduct
5.1 Professional Appearance

Your personal appearance reflects on the reputation, integrity, and public image of VMD. All
employees are required to report to work neatly groomed and dressed. You are expected to
maintain personal hygiene habits that are generally accepted in the community, including clean
clothing, good grooming and personal hygiene, and appropriate attire for the workplace and the
work being performed. This may include wearing uniforms or protective safety clothing and
equipment, depending upon the job. If you wear a uniform, all uniform guidelines must be
followed. Use common sense and good judgment in determining what to wear to work.

Fragrant products, including but not limited to perfumes, colognes, and scented body lotions or hair
products, should be used in moderation out of concern for others with sensitivities or allergies.

VMD will make every effort to reasonably accommodate employees with disabilities or with religious
beliefs that make it difficult for them to comply fully with the personal appearance policy. Contact
Human Capital to request a reasonable accommodation.

Failure to comply with the personal appearance standards may result in being sent home to groom
or change clothes. Frequent violations may result in disciplinary action, up to and including
termination.

5.2 Use and Protection of Company Assets

Depending on business needs, VMD may issue Company property to employees. It is the
responsibility of the employee to take all reasonable precautions in protecting and safeguarding
this equipment, including unattended equipment, while in their possession whether on or off
Company premises. This includes everything from an employee locking their computer screen
when stepping away from their desk to ensuring that company assigned equipment, such as
laptops, are kept in a safe place when taken outside of the office. VMD assets include physical
assets as well as intellectual property and confidential/classified information. All Company assets
are to be used for legitimate business purposes only.

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Theft, careless, inappropriate or negligent use, or loss, of VMD’s physical assets, as well as
unauthorized disclosure or transfer in the case of VMD’s intellectual property and/or
confidential/classified information, may subject the offending person to disciplinary action, up to
and including termination. Where appropriate, VMD may refer information regarding any such
action to law enforcement authorities.

Employees may not use Company equipment or property for illegal transactions, harassment or
obscene behavior, in violation of other existing VMD policies, or for personal reasons.

5.3 Electronic Communications and Information Technology Use

VMD provides access to information technology resources, including computers, networks, and
peripheral devices, as well as all communications equipment, systems, and services to support the
VMD mission. Employees are expected to conduct themselves with a high degree of
professionalism when using VMD resources and must review and abide by the VMD IT Acceptable
Use Policy (the “IT Policy”). This policy may be found on the company SharePoint site under
Employee Resources/Employee Documents/Policies and Procedures. In addition, employees who
use the government’s system agree to comply with the IT Policy and any applicable policies
provided by the government for its systems. VMD reserves the right to change its IT Policy at any
time at VMD’s sole discretion. If you have any questions regarding VMD’s IT Policy, contact VMD’s
IT Department and/or your immediate supervisor.

VMD’s systems and any information on those systems are VMD property and may be monitored by
VMD. Employees should have no expectation of privacy in any VMD system and should utilize
VMD’s system for company business only. The electronic mail system (“email”) is to be used for
VMD related communications and business. VMD employees are expected to use the internet
responsibly and productively. Internet access is for job-related activities and personal use should
be limited.

Employees may only use software on local area networks or on multiple machines according to the
applicable software license agreement. VMD prohibits the illegal duplication of software and its
related documentation. Employees are not permitted to install software or hardware on VMD’s
systems, including but not limited to personal programs, games, specialty screens or any
application of any nature. Software installation on any computer or network drive without the
consent of the IT Department is prohibited. Appropriate license documentation will be required for
any such approved installation. Use or distribution of all licensed copies of software outside the
scope of their licenses is not only against VMD policy, it is also illegal.

Employees should notify their manager or senior VMD leadership upon learning of violations of the
IT Policy. Employees who violate the IT Policy will be subject to disciplinary action, up to and
including termination.

5.4 External Communications

The reputation of VMD is essential to VMD’s success and external communications play a vital role
in marketing VMD capabilities. Therefore, it is critical that our communications are managed in a

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coordinated way to ensure a consistent message that is aligned with the policies and needs of
VMD.

All proposed press releases; external presentations at venues like conferences; white papers
relating to or referencing VMD, its projects, or products; or employee authored articles for
newspapers, magazines, journals, etc., must be reviewed by the CEO & President prior to being
released.

VMD employees must not communicate externally about VMD’s prospects, performance and
policies, or disclose sensitive or confidential information without appropriate authority. This may
include, but is not limited to, financial forecast and results, acquisitions, significant product news,
and litigation matters. Whether via media releases, press releases, external speaking
engagements or publications, only the VMD CEO & President is authorized to provide this
information and/or approve outgoing information regarding VMD.

5.5 Social Media

At VMD, we recognize the Internet provides unique opportunities to participate in interactive

discussions and share information using a wide variety of social media. However, use of social
media also presents certain risks and carries with it certain responsibilities. To minimize risks to
VMD, you are expected to follow our guidelines for appropriate use of social media.

This policy applies to all employees who work for VMD.

5.5.1 Guidelines

For purposes of this policy, social media includes all means of communicating or posting
information or content of any sort on the Internet, including to your own or someone else's
web log or blog, journal or diary, personal website, social networking or affinity website,
web bulletin board or a chat room, whether associated or affiliated with VMD, as well as
any other form of electronic communication.

VMD principles, guidelines, and policies apply to online activities just as they apply to
other areas of work. Ultimately, you are solely responsible for what you communicate in
social media. You may be personally responsible for any litigation that may arise should
you make unlawful defamatory, slanderous, or libelous statements against any customer,
manager, owner, or employee of VMD.

5.5.2 Know and Follow the Rules

Ensure your postings are consistent with these guidelines. Postings that include unlawful
discriminatory remarks, harassment, and threats of violence or other unlawful conduct
will not be tolerated and may subject you to disciplinary action up to and including
termination.

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5.5.3 Be Respectful

VMD cannot force or mandate respectful and courteous activity by employees on social
media during nonworking time. If you decide to post complaints or criticism, avoid using
statements, photographs, video, or audio that reasonably could be viewed as unlawful,
slanderous, threatening, or that might constitute unlawful harassment. Examples of such
conduct might include defamatory or slanderous posts meant to harm someone's
reputation or posts that could contribute to a hostile work environment based on race,
sex, disability, age, national origin, religion, veteran status, or any other status or class
protected by law or VMD policy. Your personal posts and social media activity should not
reflect upon or refer to VMD.

5.5.4 Maintain Accuracy and Confidentiality

When posting information:

• Maintain the confidentiality of VMD trade secrets, intellectual property, and

confidential VMD-related commercially-sensitive information (i.e. financial or sales
records/reports, marketing or business strategies/plans, product development,
customer lists, patents, trademarks, etc.).

• Do not create a link from your personal blog, website, or other social networking site
to a VMD website that identifies you as speaking on behalf of VMD.

• Never represent yourself as a spokesperson for VMD. If VMD is a subject of the

content you are creating, do not represent yourself as speaking on VMD's
behalf. Make it clear in your social media activity that you are speaking on your own
behalf.

• Respect copyright, trademark, third-party rights, and similar laws and use such
protected information in compliance with applicable legal standards.

• Refrain from posting pictures of yourself in any company or government assigned

uniforms or badges.

5.5.5 Using Social Media at Work

Do not use social media while on your work time, unless it is work related as authorized
by your manager or consistent with policies that cover VMD-owned equipment.

5.6 Media Contacts

As noted in the above External Communications policy, if you are not authorized to speak on behalf
of VMD, do not speak to the media on VMD's behalf. Direct all media inquiries for official VMD
responses to the CEO & President.

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5.7 Retaliation and Employee Rights

Retaliation or any other negative action is prohibited against an employee who reports a possible
deviation from this policy or cooperates in an investigation. Any employee who retaliates against
another employee for reporting a possible deviation from this policy or for cooperating in an
investigation will be subject to disciplinary action, up to and including termination.

Nothing in this policy is designed to interfere with, restrain, or prevent employee communications
regarding wages, hours, or other terms and conditions of employment, or to restrain employees in
exercising any other right protected by law. Employees have the right to engage in or refrain from
such activities.

5.8 Gifts, Gratuities and Entertainment

5.8.1 Acceptance of Gifts, Gratuities, and Entertainment

An employee’s acceptance of gifts and gratuities from actual or would-be clients,

suppliers, vendors, competitors or business partners can result in possible conflicts
between the employee's duty of loyalty to VMD and the personal interests of the
employee. To ensure that such situations are considered thoughtfully, any employee who
is offered a gift or gratuity with a value exceeding $25 must report such offer and seek
approval to accept it through the Senior Compliance Officer and transmit a copy of such
report to Human Capital.

In no event should an employee accept a gift where it would be prohibited by law or is

known by employee to be contrary to law or the corporate business practices of VMD.

5.8.2 Provision of Gifts, Gratuities, and Entertainment

Due to the nature of VMD's business, the giving of gifts, gratuities or entertainment
(considered "Business Courtesies") requires the use of good business judgment by
employees and careful monitoring by managers.

Federal government employees, as well as those of most state and local governments
and many private companies, are subject to strict rules regarding the acceptance of
gifts. VMD must respect these rules. In the government environment, the failure to
do so may result in severe legal and financial consequences for both VMD and the
offending employee. When in doubt regarding the appropriateness of a gift or extension
of business courtesy, consult your immediate manager or the Senior Compliance
Officer, and always err on the side of caution.

5.8.3 Provision of Gifts and Gratuities to U.S. Government Officials

As a general proposition, Government employees are not allowed to accept gifts that are
given to them because of their official position. Prohibited sources include Government
contractors, such as VMD, that sell goods and services to the Government. VMD
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employees must not offer, give, or promise to offer or give any gift to a Government
employee without the advance approval of the Senior Compliance Officer. A “gift” is any
money, gratuity, favor, discount, entertainment, hospitality, loan, forbearance or other
item having a monetary value such as transportation, meals at business meetings,
tickets to sporting or other events, or the like.

Even if applicable Government regulations permit their acceptance, VMD must refrain
from offering or giving or reimbursing expenses for any entertainment or offering any
gratuity to any Government employee who is personally and substantially involved in a
procurement or administrative function relating to any contract for the direct or indirect
purchase of products or services from VMD.

Further information regarding VMD’s gifts and gratuities policies can be found in the
Ethics Policy.

5.9 Solicitation, Distribution and Posting of Materials

To avoid disruption of business operations or disturbance of employees, visitors, and others, the
Company has implemented a Non-solicitation Policy. For purposes of the Non-solicitation Policy,
"solicitation" includes selling items or services, requesting contributions, and soliciting or seeking
to obtain membership in or support for any organization. Solicitation performed through verbal,
written, or electronic means is covered by the Non-solicitation Policy.

Employees are prohibited from soliciting other employees during their assigned working time. For
this purpose, working time means time during which either the soliciting employees or the
employees who are the object of the solicitation are expected to be actively engaged with assigned
work. Employees may conduct solicitations during their lunch period, coffee breaks, or other
authorized nonworking time, so long as they do so when the other employees are also on
nonworking time.

To avoid inappropriate litter, clutter, and safety risks, employees may not distribute literature or
other non-work-related items in working areas at any time. Working areas do not include
break/rest areas, lunch rooms, or parking lots.

Nothing in this policy is intended to limit employee rights under the National Labor Relations Act.

5.10 Disciplinary Process

Consistency and fairness in the treatment of employees is essential to the growth and prosperity
of VMD. These guidelines are provided to: 1) maintain high ethical standards and productivity, 2)
maintain a high level of morale, and 3) correlate disciplinary action to the seriousness of the
violation.

Every employee has the duty and the responsibility to be aware of and abide by existing rules and
policies. Employees also have the responsibility to perform their duties to the best of their ability
and to the standards as set forth in their job description or as otherwise established by their
manager.
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VMD supports the use of progressive discipline, when appropriate, to address issues such as poor
work performance or misconduct. Our progressive discipline policy is designed to provide a
corrective action process to improve and prevent a recurrence of undesirable behavior and/or
performance issues. Our progressive discipline policy has been designed consistent with our
organizational values, HR best practices and employment laws.

Examples of violations that could result in disciplinary actions up to and including termination
include, but are not limited to:

• Performance Issues and Insubordination

• Unprofessional Conduct
• Unauthorized or Excessive Tardiness and/or Absence
• Falsifying Timesheets / Expense Reports
• Dishonesty
• Misuse / Abuse of Funds, Company Assets, etc.
• Information Security Breach
• Conflict of Interest
• Discussion or Release of Personal or Confidential Information about Employees
• Illegal Substance Abuse
• Threatening the Safety or Well-Being of another Employee or Client
• Falsification or Omission of Information
• Harassment
• Gambling in the Workplace
• Workplace Violence

Outlined below are the steps of our progressive discipline policy and procedure. Employees should
not assume that any disciplinary action that they might be subjected to will follow the below outlined
steps. VMD reserves the right to combine or skip steps in this process depending on the facts of
each situation and the nature of the offense or issue. The level of disciplinary intervention may
also vary. Some of the factors that will be considered are whether the offense is repeated despite
coaching, counseling and/or training; the employee's work record; and the impact the conduct and
performance issues have on the Company.

Managers should coordinate counseling statements and any disciplinary measures through Human
Capital.

Occurrences Disciplinary Action Definition of Disciplinary Action

First Occurrence Verbal Warning Verbal Counseling about an issue of
concern. A written record of the
discussion may be placed in the
employee's file for future reference.
Second / Repeat Occurrences Written Warning / Performance Written - Used for behavior or
Improvement Plan (PIP) / violations that a supervisor
Suspension considers serious or in situations
when a verbal warning has not
helped change unacceptable
behavior.
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PIP – documented plan that will last

for a predetermined amount of time
not to exceed 90 days. Within this
time, the employee must
demonstrate a willingness and
ability to meet and maintain the
conduct and/or work requirements
as specified by the supervisor and
VMD. At the end of the PIP period,
the PIP may be closed or, if
established goals are not met,
termination may occur.

Written warnings and PIPs are

placed in an employee’s personnel
file.

Suspension – Depending on the

offense, suspension with or without
pay may be the best option while
investigating a situation, for
example.
Third / Final Occurrence Termination Termination of Employment for
“cause”
The following outlines VMD’s progressive discipline process:

Employees under a formal disciplinary action are not eligible for a transfer, promotion, or salary
increase. Employees subsequently dismissed for “cause” are not eligible for any further compensation
beyond pay for hours worked and unused PTO or vacation time (as applicable).

VMD reserves the right to determine the appropriate level of discipline for any inappropriate conduct,
including oral and written warnings, suspension with or without pay, demotion and termination with or
without cause and without notice.

6 Employee Benefit and Leave Programs

6.1 General

VMD offers a wide range of competitive benefits. VMD will periodically review the benefits program
and will make modifications as appropriate to the Company's condition. VMD reserves the right to
modify, add or delete the benefits it offers.

The following benefit programs are currently available to eligible employees:

• Insurance – Medical/Dental/Vision/Prescription
• 401(k) – 100% immediate vesting of employee contributions; VMD Company match
• Flexible Spending Accounts (FSA)
• Health Savings Account (HSA)
• Group Life/Short-Term Disability (STD)/Long-Term Disability (LTD)
• Voluntary Life/Accidental Death & Dismemberment (AD&D)
• Pre-Tax Commuter Benefit
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• Education/Training/Professional Development
• Computer Loan Program
• Employee Assistance Program (EAP)

Details regarding the specific benefit plans and coverage availability can be located on VMD’s
SharePoint site under: Employee Resources/Employee Documents/Open Enrollment or New
Employee Orientation. Benefit plans governed by the federal Employee Retirement Income Security
Act (ERISA) may be further described in formal Summary Plan Descriptions (SPDs) or other legal
documents available for your review via the Benefit Portal.

6.2 Benefits Eligibility

Both SCA and non-SCA, full-time and certain part time employees are eligible to participate in the
various insurance programs offered by VMD on the first day of the month following the date of
hire. If you decline to participate in these programs or fail to act to enroll in eligible insurance plans
on your initial eligibility date, you may request entry into the plan during annual open enrollment or
as a qualifying event enrollment.

6.3 Insurance Premiums

The employee’s portion of the premiums for medical, vision, and dental insurance are paid on a
before-tax, rather than after-tax basis {Premium Only Plan (POP)}. This provides employees with an
opportunity to receive the maximum tax advantage available by lowering of base pay by the amount
of the elective, before-tax deductions, thus reducing the base on which federal, state and FICA
taxes are applied. Premium information may be found on the VMD SharePoint site under Employee
Resources/Employee Documents/Open Enrollment or New Employee Orientation.

6.4 Qualifying Life Event

Qualifying life event (QLE) enrollment allows individuals who previously declined coverage or who
opted for a specific tier of coverage, to enroll or make a change in the plan upon a qualifying
event. Events include, but are not limited to:

• Loss of Health Care Coverage;

 Losing existing coverage, including job based, individual and student plans.
 Losing eligibility for Medicare, Medicaid, or CHIP.
 Turning 26 and losing coverage through a parent’s plan.
• Changes in Household;
 Getting Married or Divorced.
 Having a baby or adopting a child.
 Death in the family.
• Changes in Residence;
 Moving to a different zip code or county.
 A student moving to or from the place they attend school.
 Moving to or from a shelter or other transitional housing.

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• Other qualifying Events;

 Changes in your income that affect the coverage you qualify for.
 Gaining membership in a federally recognized tribe or status as an Alaska Native
Claims Settlement Act (ANCSA) Corporation shareholder.
 Becoming a U.S. citizen.
Employees must request enrollment within thirty (30) days of the loss of coverage or life event
triggering the qualifying event enrollment. Requests beyond thirty (30) days of the effective date
will not be approved.

6.5 Short Term Disability

An employee is eligible for benefits under the Short-Term Disability (“STD”) Plan if he/she is
completely unable to work, as certified by a physician, due to an injury or illness. STD benefits will
begin the day after the Plan’s fourteen (14) day elimination period is satisfied. VMD will pay an
employee for five (5) business days of leave during the elimination period. The rest of the
elimination period will be covered by the employee’s PTO or Vacation/Sick time. STD benefits will
continue for a maximum period as defined in the benefit documents, if the disability continues and
is certified by a physician. STD benefits will not increase because of a compensation increase
during a certified disability. Benefits will be based on an employee’s compensation as of the day
preceding the first day of certified disability. STD benefits will be integrated with any benefits that
may be payable under Worker’s Compensation or state disability insurance plans.

In the event of hospitalization, an accident or other unexpected absence that lasts more than five
(5) calendar days, related to illness or injury, Human Capital should be notified as soon as possible.

6.6 Payment of STD Benefits

Claims processing and payment of STD benefits will be handled by the insurance company. The
insurance company may also coordinate state disability benefits, where applicable. Following the
initial payment, the employee will receive weekly STD benefit payments.

The STD benefit payments are considered taxable income. If disability income is paid to an
employee, VMD is required by law to report such payments to the IRS and the state. FICA taxes will
be automatically withheld from disability payments. The employee’s W-2 will reflect the total
amount of STD payments and total tax withholding amounts.

6.6.1 Benefits

The employee will retain credited service or benefits that were accrued or vested prior to
the disability. PTO will not accrue during the STD leave. Vacation/PTO earned prior to the
disability may be retained.

While on STD, an employee will not be paid for standard VMD holidays. If the STD leave
runs concurrently with FMLA leave, VMD will contribute its portion to medical, vision, and
dental insurance premiums for a period not to exceed twelve (12) weeks within a twelve

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(12) month period. The employee is responsible for the employee portion of the
insurance premiums during the leave.

If STD runs concurrently with FMLA leave and extends beyond twelve (12) weeks, the
employee has the option to request Advanced Leave Without Pay (ALWOP) of up to 5 days.
During partial disability, an employee may make contributions to the 401(k) Plan based
on the salary or hourly rate attributed to actual work.

6.6.2 Returning to Work

Employees ready to return to work from a physician certified disability, must provide
Human Capital with an authorization from the physician stating they may return to work
and indicating any limitations.

Refer to the benefits documentation and/or contact Human Capital with any questions.

6.7 Long Term Disability

Long Term Disability (“LTD”) benefits are provided to eligible VMD employees to provide a degree
of financial security during an extended period in which the employee is totally (or partially) unable
to work due to an illness or injury.

An employee, who is unable to work beyond the STD benefit period, as certified by a physician, may
be eligible to receive LTD benefits. LTD benefits are combined with Social Security and Worker’s
Compensation, if any. These benefits can continue for a specified period, depending on the age at
disablement, as outlined in the benefit documentation.

6.8 Payment of LTD Benefits

An employee who qualifies for LTD will receive monthly LTD benefit payments after Human Capital
has processed the LTD claim, once it is determined the employee will exceed the limitations of the
STD maximum benefit period. LTD benefit payments are generally made at the end of each month.

6.8.1 Benefits

LTD coverage for the employee’s current disability will continue. The employee will be
given the option to continue medical, vision, and dental insurance through COBRA by
paying VMD 102% of the total monthly cost for the coverage. The employee will retain
credited service or benefits that were accrued or vested prior to the disability. PTO will
not accrue during the disability leave. Annual leave earned prior to the disability may be
retained. While on LTD, an employee will not be paid for standard VMD holidays. During
partial disability, or intermittent leave, an employee may make contributions to the 401(k)
Plan based on the salary or hourly rate attributed to actual work.

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6.8.2 Returning to Work

Employees ready to return to work from a physician certified disability, must provide
Human Capital with an authorization from the physician stating they may return to work
and indicating any limitations.

Refer to the benefits documentation and/or contact Human Capital with any questions.

6.9 Worker’s Compensation Insurance

Employees are eligible for Worker’s Compensation (“WC”) on the date of employment. WC provides
coverage for medical expenses incurred in connection with an injury or illness that arises out of, or
occurs in, the course of employment.

If an employee is injured “on the job”, there are specific procedures that must be adhered to in
reporting the incident. The compensability of the claim can be affected adversely by failure to
report an incident in a timely manner.

1. Immediately report any job-related injury to management and/or Human Capital.

a. Human Capital will obtain details from the injured employee and any witnesses to
the incident, so that a state-related report may be completed.
2. Do not delay seeking medical attention; however, to the extent possible, ensure, prior to
leaving the premises, that management is aware of the injury. If medical treatment is sought
for a work-related injury or illness, the employee must inform the doctor that the medical
claim is to be submitted to Worker’s Compensation.
a. Any expenses the employee incurs will be covered and paid by WC.
b. Payment for lost time may be made, if eligible, from WC Insurance or VMD’s Short
Term Disability Insurance Plan.
i. Claims will not be paid until a determination is made by the WC insurance
carrier as to whether the injury/illness is job-related.
The Benefits and Returning to Work process is the same as mentioned in the STD and LTD sections.

6.10 Continuation of Benefits (COBRA)

The Federal Consolidated Omnibus Budget Reconciliation Act (“COBRA”) gives employees and
their qualified dependents the opportunity to continue health insurance coverage under an
employer’s health plan when a “qualifying event” would normally result in the loss of eligibility.

Qualifying events that trigger COBRA include: termination of employment, death of an employee,
reduction in an employee’s hours or leave of absence, divorce or legal separation and a
dependent child no longer meeting eligibility requirements.

Under COBRA, the employee or beneficiary pays the full cost of coverage at VMD’s group rates
plus a 2% administration fee. Additional health insurance options are available through the

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individual Health Insurance Marketplace which may cost less than COBRA continuation coverage
through VMD.

6.11 Education Assistance/Training Reimbursement

VMD strives to provide employees with the opportunity for educational and training benefits to
enhance current skills and improve future potential, resulting in increased capabilities for VMD.

Regular Full-Time and Regular Part-Time employees of VMD that have completed 120 days of
successful employment with VMD are eligible. The use and availability of this program is subject
to VMD budgetary constraints. Degrees, certification courses, conferences or seminars pursued
must directly relate to the field in which the employee is now working or may reasonably be
expected to work

Employees interested in Education Assistance/Training Reimbursement are to complete the

Education, Training and Professional Development Request Form. All Education
Assistance/Training Reimbursement requests must be approved in advance by the employee’s
supervisor, Project Manager and Human Capital prior to registering for any courses, exams,
conferences or seminars. The employee’s supervisor and Project Manager will acknowledge the
job relatedness of the requested courses, certifications, degreed programs or seminars. Approvals
are only valid for the course and semester, certification test or seminar approved. Documentation
containing a description of the training program and anticipated costs must accompany each
request. Employees are responsible for obtaining their supervisor’s and Project Manager’s
approval on the request form and forwarding the completed form and supporting documentation
to Human Capital.

VMD will reimburse for:

• Tuition, lab and registration fees, and books for educational courses of study taken through
accredited business and technical schools, colleges or universities, or other qualified academic
institutions recognized by VMD.
• College level exam placement (CLEP) expenses which exempt an employee from taking a
specific course which otherwise would qualify for tuition reimbursement.
• Exam review courses, certification course, or certification exams which are affiliated with a
nationally recognized professional organization related to the employee’s field of
specialization.
• Training classes taken through approved vendors.
• Registration fees for conferences or seminars affiliated with a nationally recognized
professional organization related to the employee’s field of specialization.

Other costs:
• If a position related training class, conference or seminar occurs during business hours, full-
time employees may receive up to five (5) days regular pay while attending the training with
the approval of their supervisor and Project Manager. Part-time employees may also receive
up to five (5) days of pay pro-rated based upon their regular scheduled hours with the
approval of their supervisor and Project Manager.

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• Other costs including parking, tolls, gas, car rental, mileage, lodging and per diem are not
eligible for reimbursement under this policy.

For regular college courses, employees should schedule coursework and study periods around
normal working hours. In the event a course must be scheduled during working hours, prior
approval for time away from work is required by the employee’s supervisor. The employee is
required to use accrued unused PTO or Vacation hours.

6.11.1 Reimbursement Process and Amounts

For college courses, tuition will be reimbursed once proper approval is obtained, a grade
of C or better is received, and the proper documentation is submitted to Human Capital at
the end of the term in which the course(s) was taken. For courses not on the traditional
grading system, reimbursement will be made if a satisfactory or pass grade, as defined by
the educational institution, can be provided. Expenses associated with course
withdrawals, and unacceptable grades will not be reimbursed by VMD. Registration for
certification exams will be reimbursed after the certification is successfully achieved. The
proper documentation includes:

• Completed and approved Education, Training and Professional Development

Request Form for all courses taken;
• Original itemized receipt detailing costs incurred for the semester or the
training/certification;
• Proof of grade(s) if applicable;
• An Education, Training and Professional Development Reimbursement Form;
• Wage Withholding Agreement.
Reimbursement requests must be submitted within thirty (30) days following the
conclusion of the course(s), trainings or certification exams. For conferences or seminars,
Human Capital will pay the costs in advance on behalf of the employee.

The maximum reimbursement for Educational Assistance/Training Reimbursement is

$3,000 per calendar year for a Regular Full-Time employee and $500 per calendar year
for a Regular Part-Time employee. The total dollar amount is based upon the calendar
year in which the reimbursement is requested and approved.

Any financial aid an employee receives in the form of a grant, scholarship, or award must
be reported to VMD and will be integrated with the total amount reimbursable to the
employee.

All Education Assistance/Training Reimbursement related forms may be found on the

SharePoint site under Employee Resources/Employee Documents/Education Training &
Professional Development.

6.11.2 Upon Termination

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If an employee terminates employment while attending classes or training, VMD will not
provide reimbursement at the end of the semester or the class/training. In addition, if
an employee voluntarily terminates employment with VMD within one (1) year of
completing any courses or seminars or taking a certification examination and receiving
educational/training assistance, the employee agrees to repay VMD, at termination, for
100% of the educational/training expenses received through this benefit.

6.12 Computer Loan Program

Full-time employees are eligible for an interest-free loan of up to $2,000 for the purchase of
computer hardware or software. The loan is to be repaid to VMD through paycheck installments
within eighteen (18) months. Employees interested in this program are to complete a Computer
Loan Program Application. Approval must be obtained prior to the purchase of equipment and a
promissory note in a form acceptable to VMD completed and signed before the money is loaned to
the employee. The Computer Loan Application Form and the Computer Loan Promissory note may
be found on the SharePoint site under Employee Resources/Employee Documents/Company
Forms.

6.13 Service Anniversary Awards

VMD Service Awards are awarded to employees when they reach milestone anniversaries with the
company including 5 years, 10 years and 15 years. Included in the Service Anniversary Awards is
a certificate of appreciation and the chance to choose a gift from the Service Award providers
catalog. The monetary value of the gifts you may choose are $350 at 5 years, $500 at 10 years
and $1,000 at 15 years.

6.14 Vacation/PTO/Sick Leave

VMD offers vacation and Paid Time Off (“PTO”) (as applicable) to eligible employees. PTO
eligibility depends upon employment status and is earned on an accrued basis. A maximum of
80 hours of PTO may be carried over from one year to the next. This does not apply to SCA
employees or employees located in California. If you fall under the SCA category or work in
California reach out to your Human Capital Business Partner for further information. Vacation
time allotment is based upon an employee’s service time on a project/contract and the terms
of the contract on which the employee works (applies to contracts subject to the SCA). If an
SCA employee has not used any or all of his/her vacation allotment by the next anniversary
date when he/she is going to accrue another allotment, the remainder of the first allotment will
be paid out to him/her.

Part time SCA employees receive a pro-rated amount of the vacation benefits due to full time
employees. Irregular or Variable SCA Employees that work an irregular schedule may receive
a proportion of the vacation benefit due full-time employees based on the number of hours
which the employee worked in the year preceding the employee’s anniversary date of
employment.

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Employees who support contracts subject to the SCA are also eligible to earn paid sick
leave. This is accrued as one (1) hour of paid sick leave for every thirty (30) hours worked.
Employees will be eligible to accrue up to a maximum of 56 hours of sick leave in a calendar
year. Employees may roll over their accrued and unused sick balance into the next calendar
year. Balances will be capped at 56 hours. You will have been informed in writing at the time
of hire if you are eligible for sick leave.

Further specifics about what an employee is eligible for, as vacation, sick and PTO time, is
located on a separate summary of benefits. This summary of benefits is provided upon hire
and is also available via the VMD SharePoint site. In addition, employees can view their
PTO/Vacation/Sick hours by going to Costpoint/People/Self Service/Payroll and
Benefits/Leave Status. The hours that are reflected there will be accurate as of the preceding
pay period. For example, on the January 10, 2019 pay statement an employee’s
PTO/Vacation/Sick hours should be up to date through December 31, 2018. Allotments are
updated by close of business of each pay date. To see a current or real time vacation balance,
an employee should go to Costpoint/Browse Applications/Time &
Expense/Time/Timesheets/Manage Timesheets and click on the Leave button.

6.15 Holiday Schedule

VMD observes ten (10) standard holidays each calendar year and follows the Federal holiday
schedule.

New Year’s Day Independence Day

Martin Luther King’s Birthday Labor Day

President’s Day Columbus Day

Veteran’s Day Thanksgiving Day

Memorial Day Christmas Day

This schedule could change from year to year. Employees will be notified the preceding year of
the holiday schedule for the coming year.

• Full-Time Employees - are eligible to receive up to eight (8) hours of holiday pay per holiday
listed above. If a full-time employee in the Corporate or Government Services Division is
regularly scheduled to work between 30-39 hours per week, his or her holiday pay will be pro-
rated.
• An SCA’s Variable employee’s eligibility to holiday pay is determined by the work hours in the
workweek prior to that in which the named holiday occurs or is on paid sick leave or vacation
leave. In addition, the person must work during the week of the holiday as well in order to be
eligible for paid holiday time.
• Part-Time Employees (not covered by the SCA)– are not eligible to receive holiday pay.
• Part-Time SCA Employees – Employees governed by an SCA are eligible to receive pro-rated
holiday as dictated by the SCA wage determination. Unless there is a provision in the wage
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determination to the contrary, an employee will receive holiday pay if he/she worked part of
the week in which the holiday occurred. Holiday pay will not be provided to an employee who
does not perform any work in the workweek in which the holiday occurred.
• Irregular or Variable SCA Employees - Holiday pay obligations for employees who work an
irregular schedule may receive a proportion of the holiday benefit due full-time employees
based on the number of hours worked in the workweek prior to the work week in which the
holiday occurs.

6.16 Working a Holiday

Exempt Employees will be paid their regular rate of hours worked up to eight (8) hours. They may
bank the holiday hours for usage within 30 days of the original holiday. Banked holiday hours are
not to be used on consecutive days.

Nonexempt Employees with regularly scheduled hours will be paid their regular hourly rate for all
hours worked, in addition to being paid for the holiday hours.

Nonexempt Irregular or Variable SCA Employees who work an irregular schedule will be paid for hours
worked on a holiday and may receive a proration of the holiday benefit based upon the previous
week worked.

6.17 Bereavement Leave

An employee who needs to take time off due to the death of an immediate family member should
notify their supervisor immediately. Supervisors will notify corp-hr@vmdcorp.com who in turn
notifies payroll who will open the Bereavement code in their timesheet for the employee who needs
it. Bereavement leave will normally be granted unless there are unusual business needs or staffing
requirements. Immediate family member includes: Parent/Step-Parent, Child/Stepchild, Brother or
Sister/Stepbrother or Stepsister, Grandparent/Spouse’s Grandparent, Spouse/Domestic Partner, or
Direct In-laws.

Full-Time employees are eligible to receive up to sixteen (16) hours of bereavement leave per
incident, and Part-Time employees are eligible to receive a prorated amount, up to eight (8) hours.

Bereavement pay is calculated based on the base pay rate at the time of the absence and will not
include any special forms of compensation such as incentives, overtime, etc.

6.18 Jury Duty

An employee who is required to appear in court should submit a request in advance to their
supervisor, stipulating the circumstances and anticipated duration. During jury duty, the employee
will receive regular compensation and benefits during the period of the jury duty, not to exceed five
(5) days, forty (40) hours per calendar year (for full time employees) less monies received from the
court.

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Jury duty benefits for part-time employees will be calculated based on the average hours worked per
day for the prior two (2) pay periods less monies received from the court.

An employee subpoenaed to court because of legal action not initiated by the employee, and out of
the employee’s control, should submit a request to their supervisor, stipulating the circumstances.
The employee will receive up to eight (8) hours of regular compensation and benefits per calendar
year under these circumstances.

An employee, who initiates legal action resulting in a subpoena to appear in court, will be required
to charge accrued PTO or vacation leave or take leave without pay if the PTO/Vacation balance is
zero.

6.19 Military Leave (USERRA)

VMD provides military leave to eligible employees in compliance with federal and state laws,
including the federal Uniformed Services Employment and Reemployment Rights Act (“USERRA”).

Employees should notify their supervisor as soon as they become aware of a military service
obligation, by providing a copy of the summons or orders.

6.19.1 Leave for Annual Training

Employees who are members of the U.S. Army, Navy, Air Force, Marines, Coast Guard
Reserves or the National Guard may be granted leaves of absence for the purpose of
participating in Reserve or National Guard training programs.

Employees will be granted the minimum amount of leave needed to meet the minimum
training requirements of their units. No employee will be required to use accrued
Annual Leave for military duty, but employees who do elect to schedule their vacations
to coincide with military duty will receive their full regular vacation or PTO pay in
addition to any pay from the military.

VMD shall pay the employee the difference between their base military compensation
(excluding payments made for housing, travel, and food) and their normal VMD
compensation for a maximum of eighty (80) hours (ten (10) working days) per calendar
year. Per your employee classification, the number of hours that you are eligible to
receive will be pro-rated based upon your regularly scheduled hours.

At the employee’s request, vacation or PTO time can be used to compensate for the
time off. Once this option is elected, the employee ceases to be eligible for difference
pay.

VMD will pay difference pay when an employee produces their military pay stub and there
is a difference between what the employee would have earned as a civilian and what they
earned whilst on military leave.
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6.19.2 Leave for Military Service

Regular, Full- and Part-Time employees of VMD who perform service in the uniformed
services may be granted leaves of absence for the purpose of participating in military
service. Under USERRA, “uniformed services” consists of the U.S. Army, Navy, Marine
Corps, Air Force and Coast Guard and their Reserve components, U.S. National Guard
and Air National Guard, the Commissioned Corps of the Public Health Service and any
other category of persons designated by the President of the United States in time of
war or emergency.

Employees will be granted leave as required to complete the military service, for up to
five (5) years of cumulative uniformed service-related absences. Some special
categories of military service are exempt from this five-year limit.

Employees with leaves of less than thirty-one (31) days must report back to work by
the beginning of the first regularly scheduled work day after the end of the last calendar
day of service, plus the time required to return home safely and have an eight (8) hour
rest period.

Employees with leaves between 31 and 180 days must apply for re-employment no
later than fourteen (14) days after completion of uniformed service. Employees with
leave lasting longer than 180 days must apply for re-employment no later than ninety
(90) days after completion of uniformed service.

The reporting or application deadlines are extended for persons who are hospitalized
or convalescing because of an injury or illness incurred or aggravated during the
performance of military service.

Returning service members will be re-employed in the job that they would have
attained had they not been absent for military service, with the same seniority, status
and pay, as well as other rights and benefits determined by seniority (escalator
position). VMD will make reasonable efforts (such as training or retraining) to enable
returning service members to refresh or upgrade their skills to help them qualify for re-
employment. However, certain exceptions apply, and a service member may be placed
in an alternative re-employment position if he/she cannot qualify for the escalator
position.

Re-employed service members are entitled to the seniority and rights and benefits
based on seniority which they would have attained with reasonable certainty had they
remained continuously employed.

During a period of military service, the employees will be treated as if they are on a
furlough or leave of absence. Consequently, during their period of service they are
entitled to participate in any rights and benefits not based on seniority that are
available to employees on comparable non-military leaves of absence.

If an employee’s health plan coverage would terminate because of an absence due to

military service, the employee may elect to continue the health plan coverage for up to
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twenty-four (24) months after the absence begins or for the period of service (plus the
time allowed to apply for re-employment), whichever period is shorter. The employee
may be required to pay up to 102 percent of the full premium for the coverage as
required by COBRA. However, if the military service is for thirty (30) or fewer days, the
employee will not be required to pay more than the normal employee share of any
premium.

6.20 Advanced Leave without Pay/Approved Absence

In cases where employees have exhausted their paid time off, sick time, vacation allotment, or have
not yet received their service anniversary vacation allotment and have an unforeseen emergency
they may utilize Advanced Leave without Pay (“ALWOP”) for a period not to exceed 5 days. With
proper justification, VMD may authorize ALWOP. Requests for ALWOP may be initiated by the
employee or by VMD. Regardless of who initiates the request, or the reasons for it, the policy and
procedures associated with each leave will be handled similarly.

An employee’s request for ALWOP may only be approved if the accrued PTO or vacation time or sick
leave balance (as applicable) is exhausted. Exempt employees may only use ALWOP in eight (8) hour
increments. This leave should be used only in emergency circumstances that require a short term
time off where other leave is not available.

6.21 Family Medical Leave Act (FMLA) leaves

At the employee’s request, and with proper verification, VMD may approve a leave in accordance
with the Family Medical Leave Act (“FMLA”). To be eligible for FMLA, an employee must have worked
for the company for 12 months and have worked at least 1,250 hours. An FMLA leave may last for
up to 12 weeks or can be intermittent up to 480 hours for a full-time employee and is a time which
an employee is absent from work for a reason as identified below. Total number of hours available
are pro-rated for those who are scheduled to work less than a full-time schedule. Employees on
FMLA will be eligible for compensation only through the Short-Term Disability Insurance, Workers
Compensation Insurance, paid state leave program or accrued leave as applicable, as eligible.

FMLA may be used for:

• the birth of a child and to care for the newborn child within one year of birth;
• the placement with the employee of a child for adoption or foster care and to care for the newly
placed child within one year of placement;
• to care for the employee’s spouse, child, or parent who has a serious health condition;
• a serious health condition that makes the employee unable to perform the essential functions
of his or her job;
• any qualifying exigency arising out of the fact that the employee’s spouse, son, daughter, or
parent is a covered military member on “covered active duty;” or
• Twenty-six workweeks of leave during a single 12-month period to care for a covered
servicemember with a serious injury or illness if the eligible employee is the servicemember’s
spouse, son, daughter, parent, or next of kin (military caregiver leave).

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A request for FMLA should be made through the employee’s supervisor and Human Capital. The
employee should complete the Leave of Absence Request Form which may be found on the
SharePoint site at Employee Resources/Employee Documents/Company Forms. Human Capital will
provide the additional necessary paperwork to the employee. The paperwork will request the
medical factors resulting in the absence and must be verified by a physician, which should include
the following information:

• Explanation of medical diagnosis

• Expected duration of disability
• Prognosis – what is the expected degree of recovery from the disability
• Additional information as may be required for VMD to make a decision regarding the request

In the event an extension of leave is necessary, at least two (2) weeks prior to the expiration of the
approved FMLA leave, the employee should inform their supervisor and submit a written request to
Human Capital detailing updated anticipated return to work date. In cases where the approved FMLA
time will exhaust (due to maximum allowed FMLA time being reached), the employee may request
work with their HCBP to request Advanced Leave Without Pay (ALWOP). The written request must
be accompanied with a statement from the employee’s physician detailing information as specified
above.

If an employee lives in a state with more generous leave provisions than FMLA, VMD will apply those
leave provisions. For example, those who live in DC may be eligible for 16 weeks of FMLA if they
meet all the requirements for that leave. Those in New York may be eligible for a paid leave under
the New York Paid Family Leave Law if they meet all requirements. You will be informed of your
eligibility as you work with your HR Generalist to establish your leave. We have outlined the FMLA
terms in this section, but employees should reference the Family Medical Leave Act, 29 CFR Part
825, as published and amended, for the most up-to-date information regarding their rights and
responsibilities.

6.21.1 Benefits while on FMLA

All benefits which the employee was entitled prior to FMLA leave will continue. During
this time, the employee will continue to be responsible for the employee portion of all
benefit premium payments. In cases where an employee will receive a paycheck,
benefit premiums will be deducted from the paycheck. If the employee does not
receive a paycheck that will cover all benefit premiums, the employee will be
responsible for submitting a personal check to VMD totaling the employee portion of
the premium payment. This must be done on a monthly basis. The Human Capital
Business Partner will provide specific detail of your benefit premiums at the time of
leave determination.

PTO/Vacation leave does not accrue during the period of FMLA.

When an employee is ready to return to work at the end of the FMLA period he/she will
be returned to the same or equivalent job as the one he/she left at the start of the
leave. An equivalent job means one that is virtually identical to the one left in terms of
pay, benefits, and other employment terms and conditions such as shift and location.

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6.22 State Leaves

For employees located in New York, New Jersey and California, additional leave options exist. New
Jersey has a Family Leave Act and a New Jersey Temporary Disability plan. More details about New
Jersey’s plans may be found at https://myleavebenefits.nj.gov/worker/tdi/. New York has Paid
Family Leave. Details may be found at https://paidfamilyleave.ny.gov/. New York also has New York
State Disability. More details may be found at
https://ww3.nysif.com/Home/Claimant/DBClaimant/AboutYourClaim. California has Paid Family
Leave and more information may be found at https://www.edd.ca.gov/Disability/About_PFL.htm.
Each of these leave options require that an employee meet certain eligibility requirements to
participate. They may be used in conjunction with FMLA leave or in some cases, instead of FMLA
leave when the employee may not be eligible for FMLA. Employees should work with their HCBP to
determine which, if any, of these leaves could apply to their situation, whether they may qualify for
them and how to apply.

6.23 Victims of Domestic Violence/Violent Crime Leave

If you are the victim of a crime, or related to an immediate family member (spouse, child, stepchild,
brother, stepbrother, sister, stepsister, mother, stepmother, father, stepfather, registered domestic
partner, or child of registered domestic partner) who is a victim of certain types of crimes, you are
entitled to unpaid leave of absence to attend judicial proceedings related to this crime. You must,
prior to your absence, submit to Human Capital a written request and a copy of the notice of each
scheduled proceeding. If advance notice is not feasible or an unscheduled absence occurs, you
must provide the Company with documentation evidencing the judicial proceeding from:
1. The Court or government agency setting the hearing
2. The district attorney or prosecuting attorney’s office; or
3. The victim/witness office that is advocating on behalf of the victim.

The leave will be unpaid, however, you may elect to use your accrued but unused PTO/Vacation if
available for such absence. Victim means a person against whom one of the following crimes has been
committed:
1. Domestic Violence or Abuse
2. Sexual Offenses
3. Stalking
4. Other Violent Crime

6.24 New Jersey Security and Financial Empowerment Act (SAFE)

SAFE is a job protection statute that provides 20 days of protected unpaid leave to an employee
who is the victim of domestic violence or sexual assault, or, whose child, parent, spouse, civil union
partner, or domestic partner was the victim. The employee must have been employed at least 12
months for VMD and must have worked 1,000 hours in the preceding 12 months. Under the law,
each incident of domestic or sexual violence offense constitutes a separate offense for which an
employee is entitled to unpaid protected leave, provided that the employee has not exhausted the
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allotted 20 days for the year. Prior to taking the leave, an employee must, if the leave is
foreseeable, provide VMD with written notice as far in advance as is reasonable and practical
under the circumstances. Please contact your HCBP for further information.

6.25 California

You have the right to take time off from work to get help to protect you and your children’s health,
safety or welfare. You can take time off to get a restraining order or other court order. You can
take time off from work to get medical attention or services from a domestic violence shelter,
program or rape crisis center, psychological counseling or receive safety planning related to
domestic violence, sexual assault or stalking. You may use available vacation, PTO or accrued paid
sick leave for your leave. Even if you don’t have paid leave, you still have the right to time off. If
you can, you should tell VMD before you take time off. Even if you cannot tell VMD beforehand,
VMD cannot discipline you if you give proof explaining the reason for your absence within a
reasonable time. Proof can be a police report, court order or doctor’s or counselor’s note or similar
document.

6.26 Washington, DC and the Accrued and Sick Safe Leave Act of 2008

Under this act, employees are able to use their accrued PTO or vacation for absences related to the
employee’s or employee’s family member’s domestic or sexual violence, abuse or stalking in order
for the employee to: obtain social or legal services, if the employee or the employee’s family
member is a victim of stalking, domestic violence or sexual abuse; seek medical attention to
recover from physical or psychological injury or disability caused by stalking, domestic violence, or
sexual abuse; obtain services from a victim services organization; obtain psychological or other
counseling; temporarily or permanently relocate; take legal action, including preparing for or
participating in any civil or criminal legal proceeding; or take any other actions to enhance the
health or safety of the employee or the employee’s family member or to enhance the safety of
those who associate or work with the employee.

6.27 New York State Human Rights Law (NYSHRL)

The NYSHRL protects domestic violence victims from employment discrimination for taking time off
from work to go to court; consult with a district attorney, counselor and/or doctor; and recuperate
from injuries. It is a violation of the law to treat an employee who is a domestic violence victim
differently from any other employee because of that employee’s status as a domestic violence victim.
For example, if an employer provides personal time off or sick leave for its employees, it may not
deny a domestic violence victim use of those policies to attend to issues pertaining to domestic
violence, such as court appearances or going to doctors.

6.28 Hawaii Statutes 378-72 & 378-73

Under these statutes an employee may take up to 30 days unpaid leave per calendar year if the
employee or their minor child is the victim of domestic violence or sexual violence. Provided the
leave is to seek medical attention, obtain victim services, obtain counseling, temporarily or
permanently relocate, take legal action or implement other measures calculated to enhance the
health or safety of the employee or the employee’s minor child or the safety of those who associate
with or work with the employee. VMD may request a doctor’s certificate or a signed written
statement from a victim services organization, the employee’s attorney police or court record
related to the domestic or sexual violence. If a certificate is required, the right to leave under this

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section will not be protected until that certificate is provided to VMD. The employee must exhaust
all other paid and unpaid leave before these provisions apply.

6.29 Inclement Weather

The guiding principal in dangerous weather is to use common sense and be safe. Many VMD
employees work at government sites, and the customer's operating status is what they will follow
regarding reporting to customer sites. Most of the agencies in the Washington area follow OPM
operating guidance, which you can find at http://www.opm.gov/status. Occasionally, more localized
weather decisions are made. Follow the official guidance of your customer on whether to report to
work (or depart early) from a customer site. Here are specific scenarios that we usually encounter:

1. If your agency is open, you should report to work or take leave. If your agency allows telework
for you (some of ours do not) then consider that as an option. If you take leave or telework on
a day where the agency is operating, keep your customer and supervisor informed if you are
not reporting.
2. If your agency is closed, telework if you can, if not, then take leave or contact your supervisor
to see if there is work that you may perform at the VMD office or at home. Note, if you are
essential personnel on a government contract, you may have additional reporting obligations,
when in doubt contact your supervisor and the customer for direction.
3. If your agency opens with late reporting, report on time or as soon as reasonably and safely
possible, (this will vary depending on where you live relative to the customer). If you can't make
it to work on those days, then take leave. Keep the customer and your supervisor informed.

For exempt employees who take leave in one of these scenarios and want to make up some or all
that time within the pay period (within the constraints of the customer mission and operating hours),
then contact your supervisor with a planned schedule for doing so and for advanced approval.

Non-exempt employees who may have the option to make up some of the time within the same week
(within the constraints of the customer mission and operating hours) should contact their supervisor
with a planned schedule for doing so and seek advanced approval.

There may be extraordinary circumstances that do not fall into the three categories above. In that
case, we'll address those as they arise. When in doubt, contact your supervisor.

6.30 Telework

Teleworking, or telecommuting, is the concept of working from home or another location on a full- or
part-time basis. Employees must submit a Telework Request Form to their VMD supervisor to
request a teleworking arrangement. Director/Department Head level and above at VMD have the
authorization to approve or deny requests for teleworking. Approval will be granted based upon the
suitability of the job, job performance and an evaluation of the supervisor’s ability to effectively
manage teleworkers. The effectiveness of the arrangement will be evaluated periodically and may
be subject to change.

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Unless a specific situation dictates otherwise, telework is an option, not a required condition of
employment. Employees must always be in good standing. Please note that telework arrangements
are available in very limited circumstances in VMD’s Homeland Defense division due to the
requirements of the jobs and customers in that division. Any telework arrangements made in VMD’s
Homeland Defense division must be approved by the Director and the Executive Vice President of
VMD’s Homeland Defense division.

The amount of time the employee is expected to work per day or pay period will not change because
of participation in the teleworking program. VMD (or customer) may provide specific
tools/equipment for the employee to perform his/her current duties. This may include computer
hardware, computer software, and other applicable equipment as deemed necessary. The use of
equipment, software, data supplies and furniture when provided by VMD for use at the remote work
location is limited to authorized persons and for purposes specific to VMD or contract related
business.

The employee must abide by all VMD and client security guidelines and policies. Any materials
permitted to be taken to the employee’s remote workspace should be kept in the designated work
area and not be accessible to others, per client security requirements and policy. Employees are
required to be available by phone and email during core business hours. Employees engaged in
teleworking will be required to attend staff meetings, and other meetings deemed necessary by
management, just as they would be at a client or VMD worksite.

Telework arrangements may be requested as a reasonable accommodation, and if you are

requesting telecommuting as a reasonable accommodation you should consult with Human Capital
as soon as possible.

Alternate Worksite: Alternate work location applies to extenuating circumstances, such as natural
disaster or client site shutdown. During these events, and with proper VMD Management and
customer approval, an employee will be afforded the option to work from an alternate worksite,
specifically VMD headquarters as primary backup or home if VMD headquarters is not able to
accommodate a workspace.

6.31 Employment Separation

If at any time it is necessary for an employee to resign from VMD, VMD requests a minimum of two
(2) week’s written notice. This will give VMD the opportunity to plan for your transition and make the
necessary adjustments in Company operations. An employee’s last day of employment with VMD
must be on a regularly scheduled workday and the employee must be actively at work on their last
day. Furthermore, an employee’s last day of employment may not be extended using any form of
paid or unpaid leave. VMD retains the right, at its option, to accept an employee’s resignation
immediately.

Employees who fail to report to work for three consecutive business days without notifying VMD of
the absence will be considered as having voluntarily resigned. If the employee or a representative,
such as a family member or friend, is unable to contact VMD due to extreme circumstances, such
as a medical emergency or natural disaster, the employee or his/her representative must contact
VMD as soon as practical. In cases of extreme circumstances, VMD will consider the explanation
and its timing before determining if the voluntary resignation will be upheld.
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In the event VMD elects to terminate an employee’s employment due to a contract end or similar
circumstance, it is VMD’s goal when possible to provide employees with one (1) week of
notice. Other than as provided by applicable state or local laws, there is no obligation to provide any
severance or other compensation of any kind other than the wages accrued to the effective date of
separation.

While the decision to commence employment is consensual, the same is not always true when the
time comes to terminate the employment relationship. As an at-will employer, VMD reserves the
right to end the employment relationship at any time, with or without notice. In the event of
termination, employees must immediately return all Company-owned property and any customer or
related third party property (e.g. computers, keys, badges, work product, files, documents,
communications, confidential information, intellectual property, etc.) to their supervisor or Human
Capital, prior to departure. Failure to immediately return any VMD or customer or third-party property
(including without limitation to U.S. Government property) may result in civil and/or criminal liability
and enforcement actions against the employee.

To enable VMD to best manage relationships with its customers and other employees, and to remain
in good standing after an employee’s departure, VMD should be given the opportunity to notify its
clients about employee resignations and terminations, where appropriate, and therefore, all
employees should notify VMD management of their resignation first. VMD management will then
work with the employee to determine the best approach to notifying its customer and other
employees when necessary.

Upon termination of employment for any reason, it is important for former employees to provide VMD
with an accurate mailing address, phone number and email address for at least one year for tax and
benefit purposes.

6.32 Exit Interview

Employees may be asked to participate in an exit interview when they leave VMD. The purpose of
the exit interview is to provide management with greater insight into employee relations. Your
cooperation in the exit interview process is appreciated.

6.33 Benefits

Upon separation of employment from VMD, benefits will cease as stated below, unless otherwise
specified in writing by VMD or by insurance contract mandate.

Benefit Termination Process

Medical, Dental, Vision Insurance End of month in which employee terminates

Life Insurance, Disability Insurance,

Terminates on the last day of employment. Option to port life insurance;
Flexible Spending Account (FSA)
however, the individual is responsible for assuming total payment of the

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premium subject to the terms and conditions imposed by the insurance

company.

Contributions or plan loans cease last day of employment.

• If you have over $5,000 in your account, you can keep the money in
the 401(k) plan even after termination of your employment.
• If you have more than $1,000 but less than $5,000 in your account,
the plan will roll your money over into an Individual Retirement
Account (IRA) for your benefit unless you first request a rollover into
a new 401(k) plan or request a payout.
• If you have less than $1,000 in your account, the plan will distribute
it as a lump sum, or you can request that it be rolled over into
401(k) another 401(k) account or an IRA account.

If an employee has an unpaid 401(k) loan obligation, the remaining balance

becomes immediately due and payable.

When a person is eligible for a QNEC their QNEC account is left as active until
the QNEC account posts for the month that they last worked. Generally, it
becomes available approximately 45 days after the final paycheck. Once the
QNEC for the last month work has posted, an update is made in the Fidelity
system to terminate the employee and then the QNEC is available for removal
from the account by the former employee.

For employees enrolled in benefits, COBRA requires that terminated employees and all insured
family members be given an opportunity to continue their medical insurance for a period of
eighteen (18) months (in some cases 36 months, depending on the circumstances).

A third-party administrator will send you information regarding your options under COBRA and you
will receive this information within 2-3 weeks of your termination date. Employees electing this
option will be required to pay 102% of the premium for the coverage selected. The option to
continue coverage must be exercised within sixty (60) days from the date of insurance termination.

6.34 Final Pay

Upon separation of employment with VMD, employees will be paid all earned wages in their next
regularly scheduled paycheck, unless applicable state or local laws require otherwise.

Terminating employees will be paid for unused accrued PTO or vacation time (as applicable), unless
state or local laws require otherwise. Any sick time accrued as an employee will not be paid out
upon termination of employment. Any negative vacation or PTO time may be deducted from the
employee’s final paycheck where permitted by state law.

Final paychecks will be paid via the same method (i.e., direct deposit/online banking) in place during
the employee’s employment with VMD. Terminating employees will have access to review their final
paystub via Costpoint for 30 days after their final day with the company.

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Furthermore, consistent with all applicable federal and state laws, any outstanding financial
obligations owed to VMD will be deducted from the employee’s final paycheck(s). This should
include time that has not been satisfied per the appropriate written agreement, expenses that VMD
reimbursed (i.e. training, education assistance, etc.) per Company policies. If the final paycheck
does not sufficiently cover the money owed to VMD the employee will remain liable for that
amount. Alternative repayment arrangements can be discussed with Human Capital.

6.35 Former Employees

VMD will consider rehiring former employees who left VMD in good standing. Any former employee
terminated for cause will not be eligible for rehire. If a former employee is interested in returning to VMD
or has questions about their status, they should be directed to contact Human Capital.
For contracts not subject to SCA, if a former employee is rehired within 24 months of their separation
their hire date will be adjusted to reflect the number of months they were previously with the company.
If a former employee returns after having been gone more than 24 months, they will not be eligible for
any prior service recognition for seniority or benefit plan participation purposes.
For contracts subject to SCA, an employee’s break in service will result in a new employee status and the
employee will not be eligible for prior service recognition for seniority purposes.

6.36 Forms and Information

The forms referenced in this Employee Handbook are located on the VMD SharePoint site and may be
updated at VMD’s sole discretion from time to time. If you have any questions regarding this Employee
Handbook, the Ethics Policy, the IT Policy, or any other VMD policies or procedures, contact your
immediate supervisor or the Human Capital department.

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 Definitions/Acronyms
Americans with Disabilities Act (ADA): The nation's first comprehensive civil rights law addressing the needs of
people with disabilities, prohibiting discrimination in employment, public services, public accommodations, and
telecommunications.

Annual Leave: This may include Paid Time Off (“PTO”), or vacation leave, or sick leave (as applicable), depending
upon the employee’s individual classification status and specific contract work. A separate summary of applicable
Annual Leave will be provided to each employee in writing at the time of hire or upon request.

Consolidated Omnibus Budget Reconciliation Act (COBRA): Gives workers and their families who lose their health
benefits the right to choose to continue group health benefits provided by their group health plan for limited periods
of time under certain circumstances such as voluntary or involuntary job loss, reduction in the hours worked,
transition between jobs, death, divorce, and other life events. Qualified individuals are required to pay the entire
premium for coverage up to 102 percent of the cost to the plan.

Equal Employment Opportunity (EEO): EEO laws prohibit specific types of job discrimination including unfair
treatment or harassment because of race, color, religion, sex (including pregnancy, gender identity and sexual
orientation), national origin, age (40 or older), disability or genetic information. Harassment by managers, co-
workers or others in the workplace is also prohibited. EEO laws also protect against denial of a reasonable workplace
accommodation that the employee needs because of religious beliefs or disability. EEO laws also protect against
retaliation because the employee complained about job discrimination or assisted with a job discrimination
investigation or lawsuit.

Fair Labor Standards Act (FLSA): Unless exempt, employees covered by the Act must receive overtime pay for hours
worked over 40 in a workweek at a rate not less than time and one-half their regular rate of pay. There is no limit in
the Act on the number of hours employees aged 16 and older may work in any workweek. The Act does not require
overtime pay for work on Saturdays, Sundays, holidays, or regular days of rest, unless overtime is worked on such
days.

Family and Medical Leave Act (FMLA): Entitles eligible employees of covered employers to take unpaid, job-protected
leave for specified family and medical reasons with continuation of group health insurance coverage under the same
terms and conditions as if the employee had not taken leave.

Paid Time Off (PTO): A bank of hours in which the employer pools sick days, vacation days, and personal days that
allows employees to use as the need or desire arises in accordance with Company policies.

Service Contract Act (SCA): Every service employee performing any of the Government contract work under a service
contract in excess of $2,500 must be paid not less than the monetary wages, and must be furnished fringe benefits,
which the Secretary of Labor has determined to be prevailing in the locality for the classification in which the
employee is working or the wage rates and fringe benefits (including any accrued or prospective wage rates and
fringe benefits) contained in a predecessor contractor's collective bargaining agreement. The wage rates and fringe
benefits required are specified in the SCA wage determination included in the contract. If no wage determination
has been made applicable to the contract, employees performing work under the contract must be paid not less
than the federal minimum wage provided in section 6(a)(1) of the Fair Labor Standards Act.

Uniformed Services Employment and Reemployment Rights Act (USERRA): Protects civilian job rights and benefits
for veterans and members of the Reserves. establishes the cumulative length of time that an individual may be
absent from work for military duty and retain reemployment rights, provides protection for disabled veterans and
provides that returning service-members are reemployed in the job that they would have attained had they not been
absent for military service.

62
 Employee Handbook Acknowledgement

I acknowledge that I have received a copy of the VMD Corp. (“VMD”) Employee Handbook and that I have read
and understand the entire document.

I understand that information, policies, and benefits described in the Employee Handbook are subject to change
at any time. All such changes will generally be communicated through official notices, and I understand that
revised information may supersede, modify, or eliminate existing policies. I also understand that additional HR
related policies may also be available to me.

I understand that the working conditions, policies, procedures, appeal processes, and benefits described in this
handbook are confidential and may not be distributed in any way, nor discussed with anyone who is not an
employee of VMD.

I have read and understand the contents of this Employee Handbook and will act in accordance with these
policies and procedures as a condition of my employment with VMD.

I understand that if I have questions or concerns at any time about the Employee Handbook, I will consult my
immediate supervisor, my supervisor’s manager, or Human Capital for clarification.

I also acknowledge that the Employee Handbook contains an employment-at-will provision that states either
VMD or I can terminate my employment relationship at any time, with or without notice. I understand that while
personnel policies, procedures, and employees may change at VMD’s discretion, this at-will employment
relationship can only be changed by an express written employment contract signed by the CEO & President.

___________________________________________________ ____________________________
Employee Printed Name Date

___________________________________________________
Employee Signature

E-mail signed acknowledgement to Human Capital (HumanCapital@vmdcorp.com)

63
 ADDENDUM A
VMD HOMELAND DEFENSE
DRUG & ALCHOL-FREE WORKPLACE POLICY TABLE OF CONTENTS

I - GENERAL PROGRAM PROVISIONS 1

PURPOSE 1
DEFINITIONS 3

II - DRUG AND ALCOHOL TRAINING/AWARENESS 3

CORPORATE LEVEL TRAINING 3
SUPERVISOR (STSO) TRAINING 3
EMPLOYEE EDUCATION 4

III - DRUG AND ALCOHOL PROHIBITIONS 4

PROHIBITED DRUG- AND ALCOHOL-RELATED CONDUCT 4
DETERMINING 4
DISPOSITION FOLLOWING A DRUG OR ALCOHOL VIOLATION 5

IV - GENERAL TESTING OVERVIEW 5

TESTING OF COVERED EMPLOYEES 5
DESCRIPTION OF TESTS 5
NOTIFICATION OF TESTING TO EMPLOYEES 7
NOTIFICATION OF TESTING TO APPLICANTS 7

V - SPECIMEN COLLECTION AND DRUG TESTING 8

POLICY 8
RANGE OF DRUGS 8
COLLECTION SITE 8
CHAIN OF CUSTODY 8
LABORATORY PROCEDURES 8

VI - ALCOHOL TESTING 9
ALCOHOL TESTS 9
ALCOHOL TESTING EQUIPMENT 9
ALCOHOL TESTING SITE 9
ALCOHOL TESTS CONDUCTED BY LAW ENFORCEMENT 9

VII – CONFIDENTIALITY 9
POLICY 9
PROVISIONS TO PROTECT CONFIDENTIALITY 10

VIII - DISCIPLINARY ACTION 10

VIOLATION OF PROHIBITED CONDUCT 10
OTHER ALCOHOL-RELATED CONDUCT 11
DISCIPLINARY PROCEDURES 11

4114 Legato Road, 7th Floor

Fairfax, VA 22033
(571) 612-2424
vmdcorp.com
I. GENERAL PROGRAM PROVISIONS

PURPOSE/POLICY OVERVIEW. The general purpose of this company policy is to ensure VMD is in compliance with
the requirements outlined in 49 CFR Part 40 Procedures for Transportation Workplace Drug and Alcohol Testing
and Programs. Compliance to this requirement is indicated in our contracts with the Transportation Security
Administration (TSA) referenced to as Covered Employees in this Policy and is further defined in the following
portions of the CFR and the contract with the minimal requirements:

a. The Contractor shall establish a program to conduct pre-employment, reasonable suspicion, random, and
post-accident testing for the use of a controlled substance consistent with the requirements and
procedures set forth in 14 CFR Part 120 Subpart E (excluding 14 CFR §§ 120.17 and 120.125) and 49 CFR
Part 40, for all employees who perform security screening under this contract. Similarly, the Contractor
also shall establish a program to conduct reasonable suspicion, random, and post-accident testing for the
use of alcohol consistent with the requirements and procedures set forth in 14 CFR Part 120 Subpart F
(excluding 14 CFR § 120.225) and 49 CFR Part 40. However, no reporting to the Federal Aviation
Administration (FAA) shall be required.

1. DEFINITIONS. For the purposes of understanding this policy the following definitions apply:

a. Air blank. A reading by an evidential breath testing device of ambient air containing no alcohol.

b. Alcohol. The intoxicating agent in beverage alcohol, ethyl alcohol, or other low molecular weight alcohols
including methyl or isopropyl alcohol.

c. Alcohol concentration (or content). The alcohol in a volume of breath expressed in terms of grams of alcohol
per 210 liters of breath as indicated by an evidential breath test under this Order.

d. Alcohol testing (or Urine Collection) site. The place designated by DOT where individuals are required to
present themselves for the purpose of providing breath for alcohol testing, or urine for drug testing.

e. Alcohol use. The consumption of any beverage, mixture, or preparation, including any medication,
containing alcohol.

f. Breath Alcohol Technician (BAT). A person who instructs and assists individuals in the alcohol testing
process and operates the evidential breath testing device.

g. Canceled or invalid test. In drug testing, a drug test that has been declared invalid by the Medical Review
Officer (MRO). A canceled test is neither a positive nor a negative test. A sample that has been rejected
for testing by the laboratory is treated the same as a canceled test. In alcohol testing, a test which
has been declared invalid under this Order. It is neither a positive nor a negative test.

h. Collector. A person who instructs and assists individuals in the urine collection process and who
receives and makes a screening examination of the urine specimen provided by those individuals. The
collector shall also initiate the chain of custody documentation and ship the urine specimen to the
laboratory.

i. Confirmation (or Confirmatory) test. In drug testing, a second analytical procedure to identify the
presence of a specific drug or metabolite that is independent of the screening test and that uses a
different technique and chemical principle from that of the screening test in order to assure reliability
and accuracy. (Gas chromatography/mass spectrometry (GC/MS) is the only authorized confirmation
method for cocaine, marijuana, opiates, amphetamines, and phencyclidine.) In alcohol testing, a
second test, following a screening test with a result of 0.02 or greater, that provides quantitative data
of alcohol concentration, on an evidential breath testing device.

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j. Covered employee. All current and New Hire employees who occupies a safety- or security-sensitive
position as a Supervisory Transportation Security Screener (STSO), Lead Transportation Security
Screener (LTSO) or Transportation Security Screener (TSO) and are therefore subject to the Drug and
Alcohol test requirements mandated by 49 CFR Part 40.

k. Evidential breath testing device (EBT). A breath testing device approved by the National Highway Traffic
Safety Administration (NHTSA) for the evidential testing of breath and placed on NHTSA's "Conforming
Products List of Evidential Breath Measurement Devices" (CPL).

l. Not ready for duty. The status of an employee reports for duty with an alcohol concentration equal to
or greater than 0.02.

m. Performing a safety-sensitive function. An employee is performing a safety-sensitive function during any

period in which he or she is performing, ready to perform, or immediately available to perform such
functions.

n. Refusal to submit to testing. An employee is considered to refuse to submit to testing if he or she:

i. fails to provide adequate urine for drug testing without a valid medical explanation after
he or she has received notice of the requirement for drug testing in accordance with this
Order;

ii. fails to provide adequate breath for testing without a valid medical explanation after he
or she has received notice of the requirement for breath testing in accordance with this
Order; or

iii. engages in conduct that clearly obstructs the testing process, including but not limited
to, failure to report to the testing or collection site, or attempts to alter, adulterate, or
substitute a urine specimen.

o. Screening test (also called Initial test). In drug testing, an immunoassay screen to eliminate
"negative" urine specimens from further analysis. In alcohol testing, an analytic procedure to determine
whether an employee may have a prohibited concentration of alcohol in a breath specimen.

p. Designated Employee Representative (DER). An Employer or designated representative

of the donor who will be identified prior to the actual collection process when positive identification
of the donor is required to:

i. maintain appropriate statistical records, including numbers of employees and

applicants tested and test results, and assure that such records are free from personal
identifying information; and

ii. maintain and initiated the random drug testing process utilizing approved DOT
randomizer software; and

iii. maintain a dedicated fax in a secured area to receive positive test result. Maintain all
records containing Personal Identifiable Information (PII) and all test results in a secure
dedicated cabinet.

q. Medical Review Officer. The contractor provided Medical Review Officer (MRO), in accordance with
Department of Health and Human Services (HHS) criteria, is a licensed physician (Medical Doctor or
Doctor of Osteopathy), responsible for receiving laboratory results generated by the Department of

2
 Transportation drug testing program. The MRO has knowledge of substance abuse disorders and has
appropriate medical training to interpret and evaluate an individual’s confirmed positive result together
with his or her medical history and any other relevant biomedical information. The MRO shall:

a. receive, review, and interpret all confirmed positive drug test results submitted from the
drug testing laboratory contracted by VMD, prior to release of verified positive test results
to management officials;

b. examine alternative medical explanations for a confirmed positive drug test result,
including conducting employee medical interviews, reviewing the employee's medical
history, or reviewing other relevant biomedical factors and medical records made
available by the tested individual when a confirmed positive test could have resulted
from legally prescribed medication;

c. determine if there is a legitimate medical explanation for the confirmed positive drug test
result, and if so, declare that the result is consistent with legal drug use and take no
further action other than reporting the test result as negative;

d. determine, based on review of inspection reports, quality control data, multiple samples,
and other pertinent information, if the result is scientifically insufficient for further action
and, if so, declare the test result as negative.

r. Split Specimen Testing. As an employee, when the MRO has notified you that you have a verified positive
drug test or refusal to test because of adulteration or substitution, you have

72 hours from the time of notification to request a test of the split specimen. The request may be
verbal or in writing. If you make this request to the MRO within 72 hours, you trigger the requirements
of this section for a test of the split specimen.

i. If, as an employee, you have not requested a test of the split specimen within 72 hours,
you may present to the MRO information documenting that serious injury, illness, lack of
actual notice of the verified test result, inability to contact the MRO (e.g., there was no
one in the MRO's office and the answering machine was not working), or other
circumstances unavoidably prevented you from making a timely request.

ii. If the MRO conclude from the employee's information that there was a legitimate reason
for the employee's failure to contact you within 72 hours, you must direct that the test of
the split specimen take place, just as you would when there is a timely request.

iii. When the employee makes a timely request for a test of the split specimen under
paragraphs (a) and (b) of this section, you must, as the MRO, immediately provide written
notice to the laboratory that tested the primary specimen, directing the laboratory to
forward the split specimen to a second HHS-certified laboratory. You must also document
the date and time of the employee's request.

iv. As the employee requesting the split specimen test you will be responsible for the payment
of the split test. If the employee cannot afford to pay for the split at the time of requesting
the test the employee can sign a release to deduct it from their upcoming pay check.

II - DRUG AND ALCOHOL TRAINING/AWARENESS

1. CORPORATE LEVEL TRAINING. (To include but not limited to: Designated Employee Representative (DER),
Program Managers, Deputy Program Managers, Site Managers): All Corporate level managers with oversight
of employees covered in 49 CFR Part 40 will be required to complete a Department of Transportation (DOT) course

3
 that meets or exceeds the “Urine Specimen Collection Guidelines” for DOT Workplace Testing Program as defined
in 49 CFR Part 40.

2. SUPERVISOR (STSO) TRAINING. All Supervisors shall receive drug and alcohol awareness training. At least 60
minutes of this training shall be on the physical, behavioral, speech, and performance indicators of probable
illegal drug use and alcohol misuse. Training shall cover DOT and VMD policies and procedures on substance
abuse, including reasonable suspicion testing procedures and notification procedures. VMD shall maintain
records of the names of the supervisors trained, the date of the training, and the training program content.

3. EMPLOYEE EDUCATION. This Policy will be provided and briefed to all current VMD employees currently
covered under the requirements of 49 CFR Part 40 considered Covered Employees and all New Hires will be
brief during New Hire Orientation. VMD includes verbiage in all Offer Letters to our employees that indicates
they are subject to Drug/Alcohol test as determined by VMD Policy.

III - DRUG AND ALCOHOL PROHIBITIONS

1. PROHIBITED DRUG- AND ALCOHOL-RELATED CONDUCT. The following specific drug- and alcohol-related
conduct by VMD employees in Covered Employees Positions is prohibited under this Policy.

a. Illegal drugs. A Covered Employee is prohibited from use, whether on or off duty, possession,
distribution, or trafficking of controlled substances. Employees in non-TDPs are prohibited from on duty
use, on-duty impairment, possession, distribution, or trafficking of controlled substances.

b. Alcohol misuse concentration. A Covered Employee is prohibited from reporting for duty or remaining
on duty while having an alcohol concentration of 0.02 or greater on a confirmation test.

c. On duty alcohol use. A Covered Employee is prohibited from use of alcohol while on duty.

d. Pre-duty alcohol use. No Covered Employee shall use alcohol within four hours preceding performance
of safety-sensitive functions. This includes paid or non-paid breaks during the workday.

e. Use of alcohol following an accident. No Covered Employee required to take a post-accident test for
alcohol shall use alcohol within eight hours following an accident of which the employee has actual
knowledge and in which management either has not completely discounted his or her involvement
as a contributing factor to the cause of the accident or has not completed a post-accident test.

f. Refusal to submit to a required drug or alcohol test. No employee or applicant shall refuse to
submit to a drug or alcohol test required by this Policy.

2. DETERMINING DRUG AND ALCOHOL VIOLATIONS. The determination by management that an employee
has engaged in conduct which constitutes a drug or alcohol violation of this Policy may be made based on:

a. direct observation of drug or alcohol use;

b. a criminal conviction for use, possession, distribution, or trafficking of a controlled substance;

c. a positive drug screening obtained from a DOT certified Urine Specimen Collector/processed at a
certified DOT laboratory and reported to the DER from a certified DOT MRO;

d. a Medical Review Officer (MRO) verified adulterated, substituted and/or positive drug test result conducted
under the DOT program;

e. a confirmed test result having an alcohol concentration of 0.02 or greater on an alcohol test conducted
under the DOT program;

4
 f. the employee’s own admission of violating a drug or alcohol prohibition by this Policy; other
appropriate administrative inquiry that produces evidence of drug or alcohol-related misconduct; or

g. the results of a breath test for the use of alcohol, conducted by Federal, State, local or tribal government
officials, having independent authority for the test, shall be considered the equivalent of a breath
alcohol test conducted under this Policy, provided such test conforms to applicable Federal, State, local
or tribal government alcohol testing requirements, and the results of the test are obtained by the
employer.

3. DISPOSITION FOLLOWING A DRUG OR ALCOHOL VIOLATION. VMD, having actual knowledge that a Covered
Employee has engaged in conduct prohibited by this Policy, shall not permit that employee to perform or
continue to perform a safety- or security-sensitive function. Specific disciplinary action, for Covered Employees,
resulting from a drug or alcohol violation, shall be handled in accordance with the provisions in Chapter IX,
Disciplinary Action. If an employee is found to have a verified adulterated, substituted and/or drug positive
test result or a confirmed alcohol violation, the Supervisor of the applicable contract will be notified by
an authorized representative of VMD.

IV - GENERAL TESTING OVERVIEW

1. TESTING OF COVERED EMPLOYEES. All current and New Hire employees who occupy a safety- or security sensitive
position as a Supervisory Transportation Security Officer (STSO), Lead Transportation Security Officer (LTSO),
or Transportation Security Officer (TSO) are consider Covered Employees and are therefore subject to the
following drug/alcohol testing:

a. Reasons for testing Covered Employees. Any Covered Employee employed by VMD is subject to the
following four types of reasons-for tests. The reasons for testing a Covered Employee are: (1)
random, (2) pre-employment/pre-appointment, (3) reasonable suspicion, and (4) post-accident.
Likewise, all New Hire Covered Employee applicants are subject to pre-employment/ pre-appointment
testing, as deemed appropriate for the position.

2. DESCRIPTION OF TESTS. The following provides a description of each reason for test, along with any procedural
differences that are required by statute for a Covered Employee.

a. Random Testing. Under this type of testing, all Covered Employees shall have an equal statistical
chance of being selected for testing within a specified time frame. Random testing is unannounced
and could occur on any workday; random testing shall occur during the period the employee is
performing his or her safety-sensitive functions. At the time of selection, the employee shall be
subject to testing for drugs, or drugs and alcohol, as appropriate.

b. Pre-employment/Pre-appointment Testing. All applicants for Covered Positions are subject to pre-
employment/ pre-appointment testing for drugs and alcohol, as denoted in the recruitment
announcement. Any applicant having an alcohol concentration measuring 0.02 or greater on a
confirmation test, shall be refused employment or appointment. All applicants with verified positive
drug test results shall be refused employment.

c. Reasonable Suspicion Testing. This type of testing, for drugs, or drugs and alcohol, as appropriate,
may be required of any employee when management has reasonable suspicion to believe that the
employee has violated the prohibitions of this Policy.

i. General. This type of testing shall be conducted as soon as possible following the belief that
an employee, subject to this Policy, has used illegal drugs or misused alcohol. This belief
must be based on specific objective facts and reasonable inferences drawn by an
appropriate management official or trained first line supervisor (STSO) from these facts in

5
 the light of experience. Reasonable suspicion does not require certainty; however, mere
"hunches" are not enough to meet this standard.

ii. Reasonable suspicion testing shall only be ordered by a management official after receiving
the concurrence of the Site Manager/Deputy Program Manager/Program Manager or DER.

i. Drugs. The determination that reasonable suspicion exists to require a Covered Employee to
undergo a drug test shall be based upon:
• observable phenomena, such as direct observation of drug use and/or the
physical symptoms of being under the influence of a drug; or
• information provided either by reliable and credible sources or
independently corroborated

iv. Alcohol. The determination that reasonable suspicion exists to require a Covered
Employee to undergo an alcohol test shall be based on specific, contemporaneous,
articulable observations concerning the appearance, behavior, speech, or body odors of the
employee.

v. Time limitation. If an alcohol test required under this Policy is not conducted within
two hours following a determination of reasonable suspicion, the Site Manager/Deputy
Program Manager/Program Manager shall prepare, and maintain on file, a record stating
the reasons the test was not promptly conducted. If the same alcohol test required is not
conducted within eight hours following the determination of reasonable suspicion, the Site
Manager/Deputy Program Manager/Program Manager shall cease attempts to conduct the
alcohol test and shall state in the record the reasons for not conducting the test.

vi. When a test is not possible. Notwithstanding the absence of a reasonable suspicion test
required under this Policy, no Covered Employee shall report for duty or remain on duty
requiring the performance of safety-sensitive functions while the employee is under the
influence of, or impaired by, alcohol, as shown by behavioral, speech, and performance
indicators. The Covered Employee shall not be permitted to perform safety-sensitive duties
again until notified by his/her supervisor and pending an investigation that the employee
has violated the prohibitions of this Policy.

vii. No discipline without a test. The Site Manager/Deputy Program Manager/Program Manager
shall not take disciplinary action against a covered employee, under this Policy, based solely
on the employee’s behavior and appearance, with respect to alcohol use, in the absence of
an alcohol test. This does not prohibit a Site Manager/Deputy Program Manager/Program
Manager with authority independent of this Policy (Refusal to Comply) from taking any other
appropriate action.

viii. Documentation. Documentation shall be developed describing the circumstances which

formed the basis that reasonable suspicion exists to authorize such testing. This
documentation shall be maintained in accordance with Privacy Act requirements and
applicable company procedures.

d. Post-Accident Testing. This type of testing may be required of any employee when management
determines an accident has occurred that qualifies according to the provisions set forth in the
subparagraphs below.

i. General. This type of testing shall be conducted as soon as practicable following an accident
or incident that involves one or more of the following covered events: a fatality; a serious
injury; substantial damage and/or, substantial damage to other property. Only employees
whose job performance at or about the time of an accident or incident provides reason to
believe that such performance may have contributed to the accident or incident or cannot

6
 be completely discounted as a contributing factor to the accident or incident, shall be
determined to be subject to post-accident testing.

ii. Mandatory steps. The determination to initiate post-accident testing shall be made in the
following manner:

• The appropriate Site Manager/Deputy Program Manager/Program

Manager/Project Manager shall determine whether the accident meets the
criteria listed above based on a review of all facts reasonably available.
• Following a determination that the accident qualifies for post-accident
testing, the Site Manager/Deputy Program Manager/Program Manager/Project
Manager shall take all practical steps to identify employees that shall undergo
post-accident testing.
• The process of determination, specified above, shall be completed, the
proper notification shall be given to the employee and testing must be
accomplished as soon as practicable after the accident or incident.

iii. Availability. An employee who is subject to post-accident testing shall remain readily available
for testing or may be deemed by the Site Manager/Deputy Program Manager/Program
Manager/Project Manager to have refused to submit to testing. Nothing in this chapter shall
be construed to require the delay of necessary medical attention for injured people following
an accident or to prohibit an employee from leaving the scene of an accident for the period
necessary to obtain assistance in responding to the accident or to obtain necessary
emergency medical care.

iv. Drugs. Whenever feasible, a drug test must be completed within four hours after the accident
or incident. If a required post-accident test for illegal drug use is not conducted within four
hours following the accident, the Site Manager/Deputy Program Manager/Program
Manager/Project Manager shall submit a report to the DER stating the reasons the test was
not promptly conducted.

v. Alcohol time limitation. If a required post-accident test for alcohol is not conducted within two
hours following the accident, the Site Manager/Deputy Program Manager/Program
Manager/Project Manager shall submit a report to the DER stating the reasons the test was
not promptly conducted. If a required post-accident alcohol test is not conducted within
eight hours following the accident, the Site Manager/Deputy Program Manager/Program
Manager/Project Manager shall cease attempts to conduct an alcohol test and shall submit
the same report.

3. NOTIFICATION O F T E S T I N G T O E M P L O Y E E S . Employees subject to reasonable suspicion testing, and

post-accident testing shall receive written notice prior to testing that includes all of the following:

a. the specific basis for the drug or alcohol test;

b. assurance that the quality of testing procedures is tightly controlled, that the test used to confirm
use of illegal drugs or alcohol misuse is highly reliable, and that test results shall be handled with
maximum respect for individual privacy, consistent with safety, security, and confidentiality;

c. notice of the opportunity and procedures for submitting supplemental medical documentation that may
support a legitimate use for a specific drug;

d. the consequences, including disciplinary action of a verified positive drug test result, a confirmed
alcohol concentration measuring 0.02 or greater, or a refusal to be tested.

7
 4. NOTIFICATION OF TESTING TO APPLICANTS. Employees or applicants subject to pre-employment or pre-
appointment testing shall receive notice prior to testing. Vacancy announcements for Covered Employees
shall contain the following:

a. that the applicant shall be tested for illegal drug use or alcohol misuse prior to appointment;

b. that the applicant shall be subject to random testing for drugs or alcohol, if appointed;

c. that applicants shall be provided an opportunity to submit medical documentation to the

MRO that may support a legitimate use for a specific drug; and

d. that such information shall be reviewed only by the MRO to determine whether the individual
is using illegal drugs.

V - SPECIMEN COLLECTION AND DRUG TESTING

1. POLICY. All urine collections for drug testing conducted under this Policy shall be done in accordance with
the policies and procedures contained in 49 CFR Part 40 “Mandatory Guidelines for Federal Workplace Drug Testing
Programs" by VMD, DOT certified contractors and or VMD employees certified as DOT Urine Specimen Collectors
(drug testing)/Screening Test Technicians (Alcohol Testing)".

2. RANGE OF DRUGS. Tests shall be conducted for the illegal use of the following drugs considered to be a
controlled substance.

3. DRUGS COVERED. VMD is required to test for marijuana, cocaine, opiates, amphetamines, MDMA, and
phencyclidine (PCP) when conducting any drug test covered by this Policy.

4. COLLECTION SITE. Management shall designate the place where employees and applicants provide urine
specimens to be analyzed for illegal drug use. The site shall possess all necessary personnel, materials, equipment,
facilities, and supervision to provide for the collection, security, temporary storage. Employees shall be escorted
to the Collection Site by the appropriate management official.

5. SITE SECURITY. VMD Management will assure that the collection site is secure during the
time of each urine collection. No unauthorized personnel shall be permitted in any part of the collection
site where urine specimens are collected or stored.

6. CHAIN OF CUSTODY. In order to assure that the urine samples taken from an individual are properly identified
and not accidentally confused with any other samples, strict procedures shall be used when collecting and
transferring the samples. The total of the procedures (i.e., the official transfers from the individual providing the
urine to the drug testing laboratory personnel, including storage of confirmed positive samples at the laboratory)
and notification to VMD’s DER is known as the chain of custody.

7. COLLECTOR CONTROL. While performing the collection part of the procedures, it is essential that the urine
specimens and accompanying custody and control document be under the control of the collector. VMD
management has gone to great lengths to assure that all contractors performing the testing are DOT Certified and
Compliant.

8. STANDARD FORM. The Federal Drug Testing Custody and Control Form shall be utilized for maintaining control
and accountability from point of collection to final disposition of specimens. These forms contain a pre-printed
specimen identification number and unitary seals to ensure the security and integrity of the specimen, all VMD
contractor collection sites are in compliance and utilize the Federal Drug Testing Custody and Control Form.

8
 9. BALANCING INDIVIDUAL PRIVACY AND SPECIMEN CONTROL. Collection of urine specimens shall allow individual
privacy unless there is reason to believe that a particular individual may alter or substitute the specimen to
be provided. Precautions shall be taken to assure that the urine specimens have not been adulterated or diluted
during the collection procedure and that the information linking the urine bottles and the control forms can be
identified as belonging to a given individual.

10. LABORATORY PROCEDURES. All laboratory testing and laboratory chain of custody procedures shall be done in
strict accordance with the DOT “Mandatory Guidelines for Federal Workplace Drug Testing Programs.”

VI - ALCOHOL TESTING

1. ALCOHOL TESTS. Alcohol tests are conducted to detect the consumption of any substance that contains alcohol (i.e.,
any beverage mixture, preparation, or medication containing alcohol).

2. ALCOHOL TESTING EQUIPMENT. VMD shall make exclusive use of an Alcohol Screening Device (ASD) which is
a saliva-based test to fulfill the requirements in 49 CFR Part 40 to determine an alcohol rate of no greater than
.02 for random and reasonable suspicion testing. Testing will be conducted by VMD, DOT Certified, Screening
Test Technicians (STT).

a. An Alcohol Test using an ASD with an alcohol rate of less than .02 will be considered a negative test.
The STT will document the test on the U.S Department of Transportation Alcohol Testing Form and
forwarded to the DER.

b. An Alcohol Test using an ASD with an alcohol rate greater than .02 will be considered a positive test.
The STT will document the test on the Alcohol Test Form and begin the Site-Specific Blood Alcohol (BA)
test procedure. The BA will be administered by a Blood Alcohol Technician (BAT) using an Evidential
Breath Testing Device (EBT).

3. ALCOHOL TESTING SITE. Management designates the place where employees and applicants present
themselves for the purpose of breath alcohol testing. The site must possess all necessary personnel,
materials, equipment, facilities, and supervision to provide for testing. Employees are directed by an
appropriate management official to report to the testing site.

a. The alcohol testing site must provide visual and aural privacy to the employee or applicant being tested,
sufficient to prevent unauthorized persons from seeing or hearing test results.

b. The BAT/SAT must ensure that the alcohol testing site has all needed personnel, materials, equipment,
and facilities to provide for the collection and analysis of breath and a suitable clean surface for
writing.

c. The Site Manager/Deputy Program Manager/Program Manager’s/Project Managers will ensure that
all persons are always under the supervision of a STT/BAT when permitted into the site.

d. The only individuals authorized to be present at the alcohol testing site are: employees or applicants
being tested; STT/BATs; employee representatives (whose presence is consistent with law and
collective bargaining agreements); and

e. The Site Manager/Deputy Program Manager/Program Managers/Project Managers or STT/ BAT will
remove, or cause to be removed, from the testing site any person who obstructs, interferes with, or
causes unnecessary delay in the testing process.

f. The STT/BAT must not allow any person other than the employee or applicant, designated VMD
representatives, or an employee union representative at the employee’s request, to witness the
testing process.

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 4. ALCOHOL TESTS CONDUCTED BY LAW ENFORCEMENT. The results of a breath test for the use of alcohol,
conducted by Federal, State, local or tribal government officials having independent authority for the test, shall
be considered the equivalent of a breath alcohol test conducted under this Order, provided such test conforms
to applicable Federal, State, local or tribal government alcohol testing requirements, and the results of the test
are obtained by the employer.

VII – CONFIDENTIALITY

1. POLICY. VMD will comply with requirements outlined in the DOT Drug and Alcohol Drug/Alcohol Testing
Requirements. VMD will utilize DOT certified drug testing laboratories, split-specimen testing procedures, urine
collection contractor, alcohol testing contractor, and VMD trained and certified employees. Anyone involved in
any aspect of the company drug and alcohol testing program are required to maintain strict standards of
confidentiality in carrying out responsibilities. This includes:

a. maintaining maximum respect for individual privacy consistent with safety and security issues;

b. handling of test results; and

c. controlling all contacts with medical and health personnel and customer representatives (COTR’s,
FSD’s, etc.).

2. PROVISIONS TO PROTECT CONFIDENTIALITY. Test results shall be disclosed to the employee and VMD’s DER.
The DER will through the designated management personnel notify the appropriate COTR. The following
provisions are designed to protect the confidentiality of negative, confirmed and verified positive drug test
results, measured alcohol concentrations, and not-ready-for-duty determinations, pre-duty or on-duty use
records:

a. Notification to Employees. Employees shall receive written notification of drug and alcohol test results.

b. Authorized Disclosure. The results of drug and alcohol tests of a Covered Employee shall not be
disclosed without the prior written consent of the employee, unless the disclosure would be:

i. to the employee's MRO (applies only to drug test results);

ii. to the supervisory or management official having authority to take adverse personnel action
against such employee.

VIII - DISCIPLINARY ACTION

1. VIOLATION OF PROHIBITED CONDUCT. VMD is committed to its policy of maintaining a drug-and alcohol-free
workplace. Disciplinary action for prohibited drug- and alcohol-related misconduct shall be taken under each
of the circumstances described below.

a. On-duty use or possession of illegal drugs. VMD shall initiate action to remove a Covered Employee
from employment, up to and including termination of the individual, in the case of on-duty use or
possession of illegal drugs.

b. Drug trafficking. VMD shall initiate action to remove a Covered Employee or initiate appropriate
disciplinary action against an employee, up to and including removal, where it has been determined
that the employee has engaged in illegal drug trafficking; e.g., sale, manufacture, growth, distribution,
or transportation.

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 c. On-duty use of alcohol. VMD shall initiate action to remove a Covered Employee or may initiate
appropriate disciplinary action against an employee up to and including removal, in the case of any on-
duty use of alcohol.

d. Off-duty use of illegal drugs. VMD shall initiate action to remove a Covered Employee or initiate
appropriate disciplinary action against an employee up to and including removal, in the case of off-duty
use of illegal drugs as determined by a verified positive drug-test conducted under this Policy.

e. Alcohol misuse concentration. The agency shall initiate action to remove a covered employee
from Federal service in the case of off-duty misuse of alcohol as measured by an alcohol concentration
of 0.04 or greater on a confirmation test.

f. Refusal to comply with procedures during collection or testing. VMD shall initiate action to remove a
Covered Employee or initiate appropriate disciplinary action up to and including removal, who fails to
report to the designated testing site, refuses to provide a urine specimen or an adequate amount of
breath for testing, attempts to alter, adulterate, or substitute the specimen provided, or engages in
conduct that clearly obstructs the collection or testing process.

2. ALCOHOL-RELATED CONDUCT. VMD must depend on its workforce to be able and available when scheduled
for duty. Testing not ready-for-duty is consistent with this requirement. Disciplinary action for other
alcohol-related conduct (i.e., testing not-ready-for-duty) is set forth below and shall be taken under the
described circumstances.

a. Not ready for duty. A covered employee subject to alcohol testing must be removed from safety-
sensitive functions if the result of any agency alcohol test produces an alcohol concentration equal
to or greater than 0.02 on a confirmation test. Any employee testing in a not-ready-for-duty status shall
not perform his or her safety-sensitive functions for the remainder of the shift. This employee shall
not return to his or her safety-sensitive functions until notified by his/her immediate supervisor.

3. DISCIPLINARY PROCEDURES. Any disciplinary action under this chapter shall be taken in accordance with law
and VMD policy.

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